|May 1, 2019|Update 4/9/19: Water Quality and Tree Protection Ordinance
On Apr 9, 2019, after several public meetings at the BOS and the Planning Commission
, the Supervisors approved the Water Quality and Tree Protection Ordinance
, the Supervisors attempt to respond to the issues raised by Measure C. The changes were not greeted with enthusiasm by any of the county's' stakeholders.
Update 10/20/18: Measure C
In 2017 the growing concern over climate change and the pace of vineyard development in the watersheds led community environmental activists to once again propose an initiative, in conjunction with some members of the wine industry, to be placed on the 2018 ballot. The vintners seemed to recognize that vineyard development of Napa's watersheds and woodlands can't go on forever and they wanted to be a part of the effort to draft a long term plan. In the June 2018 primary election Measure C, the Watershed and Oak Woodland Protection Initiative
, failed by 650 votes out of 37,500 votes cast. The contentiousness of the campaign was seen by many as not just a vote on the protection of watersheds but a referendum on the pace of development in the county as a whole. The Supervisors, mindful of the community split that the vote represented, have renewed a Strategic Plan process
to seek out a consensus on County priorities over the next three years. Part of that process is an attempt by the Supervisors
to get agreement on changes to the conservation regulations, if any and move on.
9/15/16: The Conservation Regulations
In the 1980's, with the Napa Valley floor almost fully developed in vineyards and a continuing flow of wannabes wishing to fulfill their Napa dreams, vineyard development in the hilly watershed areas surrounding the valley began to take off. Following several vineyard clearing projects in the late 1980's that resulted in land erosion and river sedimentation, Napa county passed Conservation Regulations
in 1991 that established stream setbacks and maximum deforestation limits.
By 2002 it was apparent to some that the effectiveness of the 1991 measures were in doubt, given the magnitude of development in the watersheds, unless more protective measures were put in place. A stringent ordinance was proposed by environmentalists in 2002. In 2003 the Board of Supervisors passed a short term stream setback ordinance, banning commercial development within 25-150' from streams. Two measures were placed on the 2004 ballot in response: Measure O, an outgrowth of the 2002 effort, was created with 350-1000' setbacks and limits on deforestation. A counter Measure P, was created by the wine industry in line with the BOS 2003 ordinance. Both measures
were defeated after a campaign by "land steward" property rights advocates (who proposed their own law
In 2001 the State of California had established an oak woodlands conservation fund to provide funding for the protection of oak woodlands. In 2010 a Voluntary Oak Woodland Management Plan
was produced by Napa stakeholders and adopted by the county as a voluntary plan to be used by entities that wanted to tap into the conservation fund. This document serves as the current basis for woodland protection in the county.
Since 1991, vast areas of the watersheds have been deforested and the landscape in the hills, seen on Google Maps, now resembles Vietnam after the war rather than the forests that once defined the hills around the valley. In some areas like the Rector watershed , pictured here, the conversion of natural lands to vineyards is substantial.
In 2016, as an era of global warming begins to impact water sources throughout the state, concern has again heightened over the loss of forest and woodlands that retain and filter surface water for municipal reservoirs, over the depletion of groundwater and toxic runoff from ever more agriculture, and over the urban development of the watersheds for tourism facilities and vineyard estates. The relationship between the deforestation process and GHG emmisions has also become a concern in the county's climate action plan. The threat to the water resources and the rural environment of the county has never been greater. As with the impact of expanding tourism and industrial development on traffic and affordable, small-town community life on the valley floor, the question of the long term viability of the watersheds and the commitment to the sustainable rural community envisioned in the county general plan is now back on the agenda.
County comprehensive Timeline of Water Availability Analysis efforts from 1963 to present
2019 Water Quality and Tree Protection Ordinance
Comparison of Water Quality and Tree Protection Ordinance and existing code
2019 Staff letter with history of Conservation Regulations and Initiatives
2017-18 SCR Measure C page
2010 County Voluntary Oak Woodland Management Plan
1991, 2007 Napa County Conservation Regulations
Igor Sills LTE 5/8/20: Napa's woodlands are thriving and vital
Chris Marlin LTE 7/19/19: Trees can help save us from climate catastrophe
NVR 4/9/19: Napa County passes controversial tree and water ordinance, so what's next?
Wine-searcher 4/6/19: Napa's Problem is Cars, Not Drought
NVR 4/8/19: After marathon hearing, Napa County ready to finalize tree and water quality protection ordinance
Norm Manzer 4/2/19: Your Turn: Is this an extreme lack of integrity?
NVR 3/26/19: After marathon debate, Napa County supervisors pass watershed, tree protections
Laurie Claudine 3/11/19: Your Turn: Join together to protect our resources
NVR 2/24/19: Need a scorecard of key players in Napa's land use battles? Here it is
NVR 1/29/19: Napa's Board of Supervisors swamped with public comments over vineyard development rules
NVR 5/24/05: Property rights law proposed by Land Stewards
NVR 2/29/04: The homestretch for Measures O and P
James Conaway: The Far Side of Eden: New Money, Old Land, and the Battle for Napa Valley The watershed conservation battle at the turn of the millennium.
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|Mike Hackett - Jun 14, 2019 9:05AM Share
[One in a series of articles in the Register presented by the Growers/Vintners for Responsible Agriculture
For all of us fortunate enough to call the Napa Valley home, its apparent that the beauty of our surrounding hillsides is very important to us. It's also a very important reason visitors return to our famous wine-growing region.
We all realize that open space, forests and the natural environment we cherish moves us emotionally and provides that much needed rhythm of life. Did you know that Napa County has the highest density of oak woodlands in all of California? Not the most oaks, because we are small geographically, but the highest concentration.
The oak woodlands provide that much needed connectivity with our eco-system and natural beauty, and free of charge, they provide two-thirds of the water running down into the valley floor, they aid in cooling our climate and provide homes for thousands of species important for biodiversity. Most importantly, is that the oak woodlands combat climate change right here at home.
Although written specifically about blue oaks, Professor David Stahle, University of Arkansas writes: "In a state famous for remarkable forests, the blue oak woodlands must be included among the most exceptional. Blue oak woodlands are a mosaic of forest and savanna on the foothills of the Coast Ranges and Sierra Nevada, encircling the Central Valley of California.
"These beautiful woodlands are one of the largest ecosystems in California, but they are imperiled by agricultural development, suburbanization and by the apparent decline in natural regeneration.
"Many of the remaining blue oak woodlands were never systematically logged and still contain canopy-dominant individuals that are 150 to over 600 years old. In fact, that remaining blue oak woodlands may be one of the most extensive old-growth forest types left in California. These ancient woodlands contribute to watershed protection and preserve an important component of the eroding biodiversity of California."
The California Wildlife Foundation/California Oaks proudly state that the window that blue oaks provide into California's hydrological history offers a roadmap for stewardship as the climate warms.
The annual growth rings of blue oaks record the history of California's rainfall, because the trees are an integral part of the watershed.
Oak litter, duff, downed logs, understory and root systems stabilize and enrich soil, regulate run-off, prevent erosion, cool riparian corridors and access groundwater and soil moisture. It is estimated that California's oak woodlands protect the quality of greater than two-thirds of California's drinking water supply. Keeping our old-growth oak forests standing is essential to achieving a secure water future.
The persistence of California's old-growth oak ecosystems through prior climate shifts offers a degree of certainty during uncertain times. In addition to their importance to watersheds, oak ecosystem services include the maintenance of biodiversity and carbon sequestration.
Blue oak ecosystems sequester an estimated 18,783,312 metric tons of above and below ground carbon in live and dead trees. In total, California oak ecosystems are estimated to sequester 675 million metric tons of carbon stored. Soil organic carbon is positively correlated with woody plant cover, and can be quickly degraded and lost upon the removal of oaks.
Enhanced and continued protection of all our oak woodlands is paramount here in Napa. We have the opportunity here in Napa County, to set an example for the world to follow. Preservation of our oaks is not mutually exclusive of the need to manage our forests. Let's do both and help sustain the movement needed to combat our climate crisis.
NVR LTE version 6/9/19: Growers/Vintners for Responsible Agriculture: Why oak woodlands matter
|Mike Hackett - May 6, 2019 2:03AM Share
As part of Growers/Vintners for Responsible Agriculture
's discussions related to Napa County's recently passed Water Quality and Tree Protection Ordinance, this Op-Ed provides perspectives and specifics related to new rules. Amendments recently adopted by the Board of Supervisors will go into effect on May 9.
A study by Amber Manfree
, PhD in geography and GIS mapping, determined that newly adopted rules will reduce total developable area by a mere 3 percent, leaving over 28,000 acres of trees on developable land open to deforestation in Napa County.
During the ordinance adoption process, Napa County Board of Supervisors and Planning Commissioners received comments from stakeholders, property rights advocates, subject area experts, and the general public. Numerous calls were made for science-based decision-making. Commenters including Ross Middlemiss on behalf of The Center for Biological Diversity, the California Wildlife Foundation and California Oaks, biologist Jake Ruygt, and others pointed to scientific research that shows conserving Napa's wildlands has tremendous benefits for biodiversity, climate change buffering and adaptation, and water security. Essentially we need to preserve a minimum of 90 percent of our wildlands to maintain a healthy eco-system.
In the late 1900s, Napa Valley saw a shift from prunes, walnuts, and other crops to wine grapes. With the Napa Valley floor effectively planted out, large-scale vineyard developments now typically require removal of forested wildlands. In a time of increasing awareness of the related threats of climate change and biodiversity loss, bulldozing of wildlands is far less socially acceptable than it once was. At the same time, wildland conversion is often the only realistic way for new wine grapegrowers to enter the Napa market. But how much land are we really talking about, and what may the effects of newly adopted rules be?
Most remaining undeveloped land is in the 442,200-acre Agricultural Watershed Zoning District, which encompasses mountainous areas surrounding Napa Valley. There are a total of about 199,300 forested acres in the Agricultural Watershed. About 50 percent of the Agricultural Watershed has slopes over 30 percent, which are rarely permitted for development due to Napa County's Hillside Ordinance and concerns about erosion. Prior to recent amendments, there were about 69,000 acres available for development in the Agricultural Watershed. About half of this developable area, or 34,400 acres, is forested. Over 70 percent of those trees are oaks. The remainder of the non-forested area is covered in grasslands, chaparral, and other land cover types. Changes to existing protections may reduce at-risk forest to 28,700 acres in the Agricultural Watershed. These rules may yield an overall increase of 5,700 acres, or three percent, in protection of Agricultural Watershed forests beyond existing rules. Will a two to three percent reduction in development potential meaningfully slow or prevent wildland conversion in Napa County? It will not.
NVR version 5/6/19: Your Turn: A good first step, but not enough
|Mike Hackett - Mar 6, 2019 4:17AM Share
I would like the opportunity to set the record straight about oppositional distortions from those interested in further development on our hillsides. They say:
1. It's a solution looking for a problem. Measure C was anti-ag.
2. Measure C and the current proposal for a water and tree protection ordinance proposed by the county will be the demise of agriculture here in Napa County.
3. There's no science behind the environmentalist's claims.
4. Enhanced watershed protections take away property rights.
5. This idea for more water protections will kill the small farmer.
6. These ideas come from a small minority who have theirs and have deep pockets with selfish motivations.
7. It's too much to protect 70 percent of our forests.
8. Measure C would have allowed removing 795 acres of forest.
9. The Napa River is much cleaner than it was in the '60s.
Response: I call BS on all of that.
1. There's a much greater threat to agriculture in Napa Valley than sparing our hillsides from deforestation, and that's running out of water. It's a finite resource we all share as a community. Two-thirds of the water used for ag on the valley floor comes from our hills.
2. There is a misconception that growth is mandatory if we want a strong wine economy. Absolutely untrue. Most longtime successful wineries are interested in quality (the brand ) not in growth. Growth is necessary only for those needing share prices to rise.
3. If only these people would open a book. It's ludicrous to think we don't have a climate crisis. All science points to the need for changing the way we take care of our home.
4. Property rights are limited by the effect on our neighbors. This is a community problem. Our community shares our water. It's not just for ag, but for the fish in the river, the water in our reservoirs, the habitat in our woodlands and ag.
5. The idea of a small farmer is not real. It's $200,000 per acre at a minimum to go from bare ground to a producing vineyard; that's if you already own the land. Actually the vast majority of successful wineries today have no interest in supporting the fantasy of small farmers.
6. The Yes on C constituency is made up of nearly 18,000 voters; that is no small minority. The Growers/Vintners for Responsible Agriculture are selfless individuals from the wine grape growing industry who feel their mission in this is to protect this treasured Napa Valley. They and all the others promoting enhanced protections only care about our future here. They speak from their hearts, not from their wallets.
7. We can take no pride in allowing 30 percent of our forests to be clearcut. The services the trees provide are far reaching: soil retention, certainty for water quality, carbon sequestration, species protections, and water, water, water for all. Let's take back our water from the self-interested, greedy segment who hide behind distortions of reality.
8. The 795 acres agreed upon after collaboration with the Napa Valley Vintners, was designed to be a "soft landing" for those with projects in the pipeline. It was a compromise that was used against us. If the current proposed ordinance were to pass, there would be nearly 30,000 acres open to deforest in Napa County. The voters didn't like 795. We cannot take any pride in allowing that level of clearcutting here at home.
9. It's true, we are not dumping pollutants from the likes of tanneries any more. But our Napa River is listed as impaired by federal standards that are regulated by the state. The river is in a critical stage where way too much sediment and nutrients are pouring in from increasing development. The fish that used to be abundant have left. That is indisputable. Coho salmon and steelhead are tiny in numbers. They are prevented from spawning because the river bottom that should be lined with gravel is covered with sediment. The river is too warm and negatively affected by negative nutrients.
Please write and call your local county representative
and tell them we need the very strongest protections available that will help keep our Napa Valley, our community, our forests and streams, and our shared water supply plentiful and for all.
NVR Version 3/6/18: Open letter to voters regarding post-Measure C: clarifications
|George Caloyannidis - Feb 26, 2019 9:30AM Share
How interesting that all commentators -- whether in the press or during the public hearings -- who blame the lack of science for the proposed watershed regulations come from the wine and farming industry.
By all standards, this is a self interested, conflicted group that has submitted no science itself to support its arguments that existing regulations are sufficient to prevent the downward spiral of all aspects of our environment. It is the all familiar model of financial interests denying the degradation they are inflicting upon it.
But those who have no financial interests to protect, see clearly what actual science tells us about current conditions and on what lies ahead for us all, including them and the very industry's survival. The scientific record submitted in the county file is comprehensive and voluminous on all aspects of the environment. This writing concentrates only on water quality.
Only deniers would argue that the findings of the 2009 San Francisco Bay Are Water Quality Control Board on the alarming degradation of the Napa River water quality are not based on science. Enough so, that the river has been listed as impaired under Section 303(d) of the U.S. Clean Water Act due to pathogens (RWQCB 2008), nutrients (RWCB 2003) and excessive sedimentation (RWCB 2007). This water in the river is our drinking water from stream runoff primarily from the watershed and spilling into and from our reservoirs in the winter.
Any doubters can look at Lake Hennessey's brown water that supplies the city of Napa. Our other reservoirs are in the same sad condition. The steadily declining fish population -- the pitiful few hundred Coho -- knows what the conflicted refuse to acknowledge.
Of the 170,000 tons per year of all man-made river sedimentation, 67,000 tons are directly attributed to vineyards and grazing land, even though they comply with the county's current erosion control measures. According to the 2012 San Francisco Estuary Institute's Napa River Watershed Profile report, these erosion control practices have the "unintended effect of increased runoff without a compensating increase in course sediment supply." The steady increase in fine river (and reservoir) slimy sediment is choking its oxygen regeneration, vital to a healthy fish population and our water quality.
In 2009, the Water Quality Board recognized that we are past the tipping point and set a goal of a 50 percent – yes, a full one half - reduction in fine river sedimentation and 51 percent for one generated by vineyards. The report, was revised in 2018 and found that nine years later we had made no progress. Reasonable people would agree that based on our available science something drastic needs to be done.
The conflicted deniers are guided by an additional motivation to resist change: The Water Board estimated that the goals it has set for Napa County will cost the wine industry $800,000-1.7 million per year for the next 20 years for a total of $16 million-$34 million. And as usual, the bulk of the cost, a staggering $34 million-$68 million to correct the development sins of the past will be borne by the public in the form of grants, meaning taxes.
Sadly, the proposed ordinance, while it will slow the rate of increases, will not even begin to reverse the trajectory towards what is an impending crisis.
LTE version 2/26/19: Some science behind the watershed ordinance
|Patricia Damery - Feb 26, 2019 9:26AM Share
On March 6, the Napa County Planning Commission will meet again to take more public comment and make a recommendation to the Board of Supervisors on a watershed and tree protection ordinance. This is the result of Measure C's (Watershed and Oak Woodland Protection Initiative) almost passing.
The wine industry showed up in force at the Feb. 20 Planning Commission meeting, asserting that protecting our hillsides and watersheds any further would result in the demise of the wine industry.
Talk about Chicken Little. The truth is, if further protective measures are not put in place, our environment and water supply will suffer, and with it, the wine industry as well.
The wine industry is robust. Limiting its ability of develop our hillsides and watersheds is not going to be the death of it. However, there is a conflict of interest when any industry insists that a governmental body protect its financial interests at the cost of the environment and water supply.
This is why the Environmental Protection Agency was formed in 1970: to separate out the interests of agriculture's use of pesticides from the needs of the environment. Until then, pesticide usage was governed by the United States Department of Agriculture (USDA), described by Rachel Carson of Silent Spring as a financial "conflict of interest."
We need the planning commissioners and the Board of Supervisors to act on behalf of the citizens of Napa County in protecting our water supply and our environment.
The assertion from some in the wine industry that only a few individuals are pushing watershed protections similar to those of Measure C is absolutely false. A growing number of citizens, vintners and growers are leading the push to protect our natural resource;. 49.1 percent voted for Measure C in a dirty campaign too often based on the opposition's false assertions and efforts to confuse the voters.
This current effort for the Board of Supervisors to pass an ordinance to protect our hillsides, oak woodlands, forests and watersheds was spearheaded by U.S. Rep. Mike Thompson. Hopefully another initiative will not be needed, but when a governing body does not govern, in California, we the people have that right.
Please contact your supervisor and planning commissioner to encourage them to act on behalf of the environment, not special interest groups.
LTE version 2/26/19: Talk about Chicken Little
|George Caloyannidis - Jan 25, 2019 2:49AM Share
Stuart Smith's letter ("Accusations without evidence
," Jan. 18) is a perfect example on how "science" is tossed around to make points that have nothing to do with science.
Mr. Smith disputes Mr. Smithers' assertions ("Climate and environmental downside of vineyards
," Jan. 10) that assigned blame to the proliferation of hillside vineyards for the degradation of our environment.
Mr. Smith cites the improved water quality in the Napa River as scientific proof that the concurrent proliferation of hillside vineyards is the cause of this improvement. Quite a leap in scientific reasoning, let alone proof.
Second, while Mr. Smith's advantageous comparison of vineyards to Napa Valley forests in terms of propensity to fire is correct, it is unfair because it is one to ill managed - not well managed - forests as Napa's are. Given all the other scientifically proven environmental advantages forests have over hillside vineyards (superior erosion control and carbon sequestration, slower runoff and water table replenishment), the logical course of action is not to replace them with vineyards but rather manage them properly.
In comparison, forest fires in Western Europe, where forests are properly managed are extremely rare.
Third, properly designed firebreaks do not even remotely resemble a patch work of vineyards as Mr. Smith suggests. Their standards include firefighting equipment access roads at prescribed intervals along with accesses to them. The USDA Natural Resources Conservation Service Practice Code 394 and the Fuel Break Guidelines of the Tasmania Fire Service Bushfire Policy are good information starting points. And let's not ignore the visual blight of such deforested patchwork.
The scientific community established that 84 percent of all wildfires are caused by human activity. Vineyards and wineries with their tasting rooms and events in the hillsides invite such activity. The cigarette butts along Soda Canyon Road are enough to convince any doubter how inappropriately dangerous such development is. Mr. Smith failed to include this parameter in his science.
Fourth, Mr. Smith argues that the absence of pesticides in the Napa River (if true) is scientific proof that pesticide use at hillside vineyards is harmless. Yet, scientific inquiry would ask the question that if they are being used, how do they simply disappear? The truth is that they end up in the water table, and from there, in all of us.
Mr. Smithers is being castigated by Mr. Smith as irresponsible -- even demanding that he issue an apology to the wine industry -- for suggesting that the use of pesticides such as Roundup (containing Glyphosate) is responsible for Napa Valley's highest cancer incidents for children and second in adults in California.
I hope Mr. Smith did not hold Bayer AG (Monsanto's parent company) stock. Its price plummeted more that 10 percent in August 2018 following the California Superior Court in San Francisco County $289 million award to a former school groundskeeper for developing non-Hodgkin's lymphoma due to his exposure to Roundup.
If Mr. Smith is waiting for chemical cause and effect proof to the link of Glyphosates to cancer, he ought to consider that such chemical link of the use of tobacco to cancer has yet to be established. The link is a statistical one, enough for an eventual call to action -- but only after millions died.
Sadly, proving a chemical link between the use of Roundup and cancer enough to satisfy Mr. Smith will be just as imAccusations without evidence
possible. While we are waiting for the eventual statistical evidence, hundreds of Napa Valley children - millions around the globe - will have their lives shortened. This is what is irresponsible.
But the noose is closing ever tighter around Bayer AG's neck since 2005. The European Union has rescinded its usual 15-year extension to the use of Glyphosates and limited it to three. France has pledged its outright ban in three years, Germany and Italy are considering similar action.
But the Napa Valley remains hostage to the wine industry in spite of all the evidence. Shockingly, Napa is one of the few counties in the state that has no mandated pesticide-free zones around our schools. Shame on it.
Stuart Smith LTE 2/12/19: Please partner with us, instead of attacking us
Richard Cannon LTE 2/2/19: Objective truth or blind spot?
George Caloyannidis LTE 1/25/19: More on science and vineyards
Stuart Smith LTE 1/19/19 : Accusations without evidence
Smithers LTE 1/10/19: Climate and environmental downside of vineyards
Garrett Buckland LTE 12/12/18: Facts about the Environmental Benefits of Ag Land
|Mike Hackett - Jul 2, 2018 12:55PM Share
We know now that Measure C did not pass. However we feel tremendous appreciation for the hundreds of volunteers that helped raise awareness about this defining environmental issue.
We garnered nearly 50 percent of the votes and those approximately 18,000 citizens believe that our water resources are in jeopardy and that we need to curb vineyard development on our hillsides here in the Napa Valley.
We lost a precious opportunity to show the world that growers and vintners here were willing to show leadership with a sustainable vision for the community's future. This was lost early on when the Napa Valley Vintners, betrayed the trust we had built up during the collaboration of Measure C, and joined forces with the other wine trade groups, and together spent roughly three quarters of a million dollars to oppose the collaborated agreement we had reached together.
The wine industry has done an incredible amount of harm to its own reputation here. Over the years, the Napa Valley Vintners has given millions of dollars for worthy causes here. During the campaign for Measure C, they allowed a Trump-like campaign that used false and misleading information to be spread to our voters. We are deeply disturbed and saddened that this type of nasty campaign would be utilized here.
One has to wonder: at what cost to their reputation and was it worth it? There are no winners here, only losers. The oak woodlands will continue to be clear cut for vineyards and the wine industry has lost the respect not only of Napa's citizens, but wine lovers from around the world.
Once again, big money got the most votes, but our citizen's awareness of the negative campaign will leave a bad taste for a very long time.
We look back to the amazing collaboration we had with the NVV, which culminated in a jointly crafted Initiative which we submitted to the County on Sept. 1, 2017. Their Board of Directors voted unanimously on four occasions to support the Watershed and Oak Woodland Protection Measure.
However, almost immediately some short-sighted, powerful and greedy winery owners, joined by the corporate wine interests decided to use fear and intimidation to scare the NVV board into reversing their position. The tactics were simple from big boys: pull your support for this environmental issue or we'll pull out as members and not participate in the Napa Valley Wine Auction.
Evidently, it worked and these same forces allowed the disinformation campaign to distort the facts and confuse the voters. While campaigning, it became evident that many people thought a "no vote" meant no more cutting of trees. One of their campaign flyers called us "crazy."
We citizens feel like our moral compasses were broken by organizations utilizing campaign tactics designed to get folks to vote against their own best interests.
Looking ahead is difficult at this time. There's clearly too much power in too few hands here; and it's all within the wine industry. This one-industry town can celebrate this initial win at the polls, but the awareness that the majority of elected officials are answering to the industry and ignoring the pleas of the majority of citizens here, will mandate we move forward with another measure as soon as possible.
We all remain committed to protecting Napa County's water, forests, watersheds and quality of life and will remain active until our lands are protected from over development.
NVR LTE version 9/1/18: What next after Measure C?
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