Response to Donna Oldford letter to Planning Dept.
Bill Hocker | Jun 10, 2014
[Letter sent to Napa County Planner Shaveta Sharma in response to the re-submission letter by Donna Oldford with copies sent to the PBES Director Morrison and Deputy Planning Director McDowell]
Ms. Shaveta Sharma
Dept of Planning Building & Environmental Services
1195 Third St, Suite 210
Napa CA, 94559
I have received a copy of a letter dated May 27th 2014 addressed to you by Ms. Donna Oldford relating to their resubmission of documents for the Mount Peak Vineyards Project. I have taken the liberty of uploading it here: http://sodacanyonroad.org/docs/oldford5-27-14.pdf . It gave a summary description of the project and included a timeline of meetings held between myself and the Argers and various representatives of the applicant and the county and a list of mitigations proposed by the developer.
While I will be raising questions concerning the specifics of the project proposal once the final submission has passed to public review, I would like to comment on the issues mentioned in the letter here.
Regarding the reduction in grape truck transport
The letter mentions that 88 grape truck trips are saved per year up Soda Canyon Road. Rather than looking at that number in a vacuum, I would ask that you compare it with the numbers for materials, supplies and case goods that must be transported to and from the remote site. If I interpret the county’s trip generation formulas properly, they would amount to 500 trips per year. More importantly, you might compare the number to the 46700 trips made up and down the road by the visitors, employees and part-time employees each year. All of these trips would be unnecessary if the winery were located in a more accessible place. While 88 trips may be saved in grape transport, they are dwarfed by other deliveries necessitated, and they are statistically miniscule compared to the trips necessitated by locating a tourism facility in such a remote location.
Regarding LEED Certification
LEED certification is a score of potential building energy conservation that will no doubt emphasize the reduced refrigeration and air conditioning costs in this project created by the caves [although it seems that mechanical refrigeration of the caves will be necessary as well]. But many energy expenditures are not reflected in the LEED score. Not considered are the fuel energy costs of mining the caves and relocating the spoils. Not considered also is the cost in fuel energy and road maintenance necessary to accommodate years of construction equipment and contractors making the trip up and down the road. Nor does it consider the fuel for 47000 trips/year made by visitors and employees to such a remote location. Nor is the wasted energy involved in new construction to replace a perfectly good structure factored into the score. (It is worth noting here that the former owner of this property, Jan Krupp, plans to reuse the house on his new winery property on the Silverado Trail as his tasting room). And most important what is not considered is that the grapes currently on the site and on the owners other property are already being processed by another winery, and that the huge amount of energy consumed for the project’s construction, maintenance and access is completely unnecessary in the first place. In fact, 4-5 acres of existing grapes are being removed to make way for the project resulting in less Napa wine being produced as a result of the massive amounts of energy being expended.
Finally, LEED is at best an unreliable metric of energy conservation. You might take a look at this article . (Sorry for the advert) As with J.D. Powers ratings, a company or developer pays money to a rating company to give a favorable review based mostly on nonessential minutia. The rating can, of course, translate into tax breaks, a marketing or public opinion advantage, or a planning commission approval that justifies the high price paid for the rating. The actual benefit in energy conservation based on LEED criteria is often arguable or non-existent.
Regarding the LYVE wastewater treatment system.
It is commendable that a system is being put in place to reduce water consumption on the site. But the employment of such an initially expensive and energy consumptive system is in fact recognition that there may not be enough water on the site to maintain the groundwater necessary to supply the needs of a winery-tourism project. I would again ask the county if permitting a project that actually reduces the acreage of Napa grapes in the county, while potentially exacerbating water availability in a time of global warming, is a wise decision. It is an argument that I will return to at the appropriate time.
Regarding minimal visual impact
I would ask that the county weigh the minimal visual impact of the buried winery to other aspects of the project that are not so minimal. There is nothing minimal about the outdoor 15000 sf. crush pad where the actual noise and light and unsightly visual impacts of a winery are generated. There is nothing minimal about the 1,200,000 cf. being extracted to make way for the largest wine caves ever proposed in the county. (At 65,000 sf. this is also probably the largest 100,000 gal/year winery in the county.) There is nothing minimal in moving 2,000,000 cf. of dirt around the site, or of the backup beeps and grumbling of heavy machines during years of construction and re-grading. There is nothing minimal about the 2-100000 gal tanks (each 35’ dia. x 25’ high) on my property line or the container cargo sized wastewater treatment plant next to them with its 2 -10000 gal tanks and pumps and motors always churning. There is nothing minimal about the 4’ platform of spoils adjacent to my property or of the 10’ of spoils adjacent to the blue line creek that crosses their property. There is nothing minimal about the 20’ high berm next to my property line for the crush pad entry road. There is nothing minimal about the lights and noises of the cars in the parking lots accommodating 25000 visitors and employees per year or of the 10000 sf. of lighted glass pavilions and their terraces filled with happy and noisy wine consumers until 10:00pm. Minimal is not a word easily applied to this project.
Regarding the marketing plan of similarly sized facilities in the area
There are no marketing plans in the area to compare to. The only winery on the watershed, Antica Napa Valley, has no marketing plan. They are permitted 100 tasting/tours per week that they seldom use. They seem to have survived quite well (and have been a good neighbor) without the necessity of a marketing plan. I would suggest that their formula be applied to this project as well.
The nearest similar winery is the newly permitted and not yet built Corona winery 6 miles down that winding road on the Silverado Trail. The capacity is the same. The marketing plan IS comparable. Corona, of course, creates none of the impacts of trying to accommodate its hundreds of deliveries and thousands of visitors each year up a 6 mile winding road.
But while making the comparison, you should also note that the Corona winery is only about 2/5ths the size of this project in enclosed area. In fact, looking at the 4 – 100,000 gal/year wineries that have come before the planning commission in the last 2 years, the range of enclosed space is from 13000 to 49000 sf., nowhere near the nearly 80,000 sf. proposed for this project. The enclosed space of the Antica winery is 47000 sf. and it is permitted 450,000 gals/yr. This raises the question of why this proposal is so large in area (and hence in potential capacity). It is a question I will return to at a later time.
Regarding our meetings with the developer
All of the meetings, save the first and the last, were undertaken to discuss the proposed project entry access point to be used by 18500 tourists/year off of a one-lane gravel road that currently serves perhaps 30 residences and all of the daily operations of over 1000 acres of vineyards. A variance would be necessary to avoid cutting down trees that line the road. Considering the County’s normal fastidiousness about the traffic impacts and mitigations relating to new projects, it was a little discouraging that such a proposal had survived so long. The county should have nixed it long before and it should not have been an issue for neighbors and the developer to spend time and money on.
Regarding my own conversations with the developer, at my first meeting with Mr. Rea I asked if he would be willing to omit the tourism component of his project. That mitigation was not acceptable. At our last meeting I asked the same question. The answer was still no. As I mentioned, the one winery on the Rector watershed, Antica Napa Valley, has managed to be a profitable business, and a good neighbor, since 1987 with no marketing plan and only a few infrequently used tasting/tour slots. Antica shows that a marketing plan on this remote watershed is unnecessary to justify profitably (often cited as a reason for its inclusion). Absent the willingness to eliminate or very drastically reduce the tourism component, which represents by far the most egregious of the impacts presented by this project to the Soda Canyon Road community, I have seen no purpose yet in discussing more specific issues or mitigations.
Regarding the mitigations proposed
-The 100000 water tank at the entry was to my understanding already proposed to be underground to the benefit of the appearance of the approach to the project and was not discussed in any of the meetings.
-The temporary tunnel speeds up the project completion to the benefit of the developer as well as residents. This was also not talked about in meetings.
-Dust mitigation in the form of shade cloth on the fence, while an appreciated suggestion, is unlikely to be effective. Given the amount of earth being moved around it is unlikely that even watering will have much effect.
-The proposed mitigation on visitations is a pretty convoluted calculation, but I assume that the 320 per week limit would still be allowed, and that any appointments reduced on an event day could just be added to a non-event day resulting in the same 18500 number at the end of the year.
-The removal of the tractor barn was, I believe, related to the acquisition of greater additional acreage some distance from the project site, and the barn’s more logical location there. Frankly I would much prefer to have the barn remain and the LYVE system and its gargantuan tanks removed.
-The landscaped berm is the only real mitigation proposed. When we get to the point of discussing specific mitigations on our property it is one that I would also welcome between my property and the crush pad, wastewater treatment plant, worker parking lot, and Stagecoach Vineyards picnic area.
In Conclusion (and probably outside the realm of your review)
As Ms. Oldford highlights, this process represents the investment of a significant amount of money, as does the project as a whole. But the amount of money invested should not be the basis for the County's decisions. I feel, quite frankly, that given the inappropriateness of tourism in this remote location, given the unnecessary size of the facility and given the lack of any functional necessity for a winery to be located here, that the project mostly represents the vanity of an owner interested in investing in an ostentatious display of wealth in a county so conducive to such preening. The impacts of that vanity will change the lives of all the residents of Soda Canyon Road. The project will create a precedent for future tourism developments on the road that will continue to debase the remoteness and privacy that are the reasons we, grape growers and mere residents alike, have chosen to live here. I am dismayed (and as you can tell from the tone of this letter, a little angry) that the county seems to consider the imposition of this individual extravagance to be more worthy of governmental support and protection than the maintenance of a rural community of hundreds of people that have called this road their home, some like me for only 20 years, many for most of their lives and some for generations.
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