|Chris Malan - Mar 9, 2017 10:55AM |
We know now that the County planning staff are hearing us (italicized and copied from the BOS agenda letter here):
There have been two recent items of note regarding the ECPA review process.
On January 20, 2017, staff sent a notice to stakeholders and interested parties indicating that PBES would no longer accept hydrologic analyses and vineyard ECPAs designed in reliance on modified hydrologic soil group (HSG) assumptions. The HSG methodology is no longer recommended by either the Resource Conservation District or the Regional Water Quality Control Board, and is not supported by Department engineering staff. We are working with those applicants who have not yet transitioned to the preferred approach.
(LRC debunked the Walt project soil analysis claims that after grading the soils are more permeable therefore, groundwater has a high recharge value with vineyard development-an utter false assumption. I wonder what this will do for our litigation)
Recently, CalFire held a training exercise on private property in the Soda Canyon area. It generated complaints from nearby residents who were concerned that illegal brush clearing and/or grading was occurring. Section 18.108.050.(H) of the County Code exempts the creation and/or maintenance of firebreaks required by, and completed under the direction of the California Department of Forestry. However, the exemption does not specifically address fire training exercises. Similarly, work to create fuel breaks (not fire breaks) is being proposed by Napa Firewise. Staff is working closely with both Firewise and CalFire to ensure that necessary fire prevention work is allowed to move forward, in a way that does not impact the environment or create violations of County Code.
(so we know now that the grading on Soda Springs road was actually NOT Allowed and NOT specifically exempt!)
|Chris Malan - Mar 9, 2017 10:12AM |
At the Napa County BOS [see list of acronyms at end] yesterday they voted to approve two changes in regards to the approval of erosion control plans for the conversion of lands to vines.
1. ECPA CEQA process for THP/TCP is now going to be done through Napa County. This is good for us for several reasons:
2. The PBES is now taking over the ECPA process from the RCD who was NOT qualified to oversee these engineering plans . This is good news on several fronts because:
Living Rivers Council has worked on this for over 17 years and finally there are changes coming through the SFRWQCB telling the Counties that their erosion control plans must have robust engineering/modelling that shows scientific evidence of deep ripping and deforestation impacts on soil types. This is a much higher CEQA bar now for these projects. The SFRWQCB is collaborating this with the NCRWQCB for the implementation of their WDR in Sonoma County and beyond!
FYI-with this the WDR will be rolled out soon and the BMPs for vineyards will be such that the ECPA must demonstrate no increased rate of runoff-this will limit the amount of deforestation in certain soil types.
Cal Fire told the BOS that Napa County has the most TCP�s in the STATE! We need to really use this in our Initiative language, PR and fundraising. This means that Napa really needs initiative protection.
Hydrologic Soil Groups (HSG)
Timber Harvest Plan (THP)
Timber Conversion (TCP)
Wastewater Discharge Requirement permit (WDR)
San Francisco Regional Water Quality Control Board (SFRWQCB)
North Coast Regional Water Quality Control Board (NCRWQCB)
Resource Conservation District (RCD)
National Resource Conservation District (NRCD)
Living Rivers Council (LRC)
Best Management Practices (BMP)
Erosion Control Plan Application (ECPA)
California Environmental Quality Act (CEQA)
Board of Supervisors (BOS)
Planning Building and Environmental Services (PBES): Napa County department where ECPAs are processed
Total Maximum Daily Load (TMDL)
California Department of Forestry and Fire Protection (Cal Fire)