Bill Hocker | Nov 17, 2016

[My third Walt Ranch letter - not so different from the second.]

Members of the Board of Supervisors,

I would like to repeat here my letter of opposition to the approval of the Walt Ranch FEIR. While I too feel there are significant impacts on water resources, on wildlife habitat and on our county's carbon footprint, my concern is also about the suburbanizing trend that this project represents for the remote and natural woodland areas of the county. Supervisor Pedroza has repeatedly said that "once our open space is gone, it's gone". He is right, and I would seriously encourage you to heed his words.

This project is not a vineyard erosion control plan. No real estate developer (as the owners are) would spend 10 years and milions of dollars seeking approval for 21 miles of roadway and a substantial water storage and distribution system on 2300 acres of land only to serve a 209 acre vineyard. The project is, in fact, the preliminary infrastructure development for a 36 unit residential subdivision. The FEIR failed entirely to discuss the reasonably foreseeable future development and growth inducing impacts that the project represents. From the FEIR:

"As stated above in General Response 4, the purpose of the Proposed Project is to develop vineyards on the Walt Ranch; the EIR does not analyze the development of homes on the parcels because that is not proposed by the project applicant. No other reasonably foreseeable future development would occur on the project site beyond what is described in the EIR. Therefore, it is not appropriate to include the development of single-family homes on the Walt Ranch property in the cumulative analysis for the Proposed Project". (FEIR v1 pg4-39)

This FEIR has completely ignored the discussion required under CEQA guidelines of the reasonably foreseen "growth inducing impacts" that the project represents. The FEIR mistakenly concludes that because a particular use has not been proposed as part of the project that such use is not forseeable. Until such use has been legally prohibited on these properties, that use is eminently forseeable. From the CEQA guidelines:

CEQA Sec 15126.2(d) (pg155): "Growth-Inducing Impact of the Proposed Project. Discuss the ways in which the proposed project could foster economic or population growth, or the construction of additional housing, either directly or indirectly, in the surrounding environment. Included in this are projects which would remove obstacles to population growth (a major expansion of a waste water treatment plant might, for example, allow for more construction in service areas). Increases in the population may tax existing community service facilities, requiring construction of new facilities that could cause significant environmental effects. Also discuss the characteristic of some projects which may encourage and facilitate other activities that could significantly affect the environment, either individually or cumulatively. It must not be assumed that growth in any area is necessarily beneficial, detrimental, or of little significance to the environment."

It is irresponsible for the FEIR to foresee no other development on the properties as a result of the creation of an all-weather road system and the provision a water system and water lines to each property, by a developer that has a track record of developing vineyard-ready residential subdivisions. [ http://www.hall-ranch.com ]. The FEIR states in General Response 4 (FEIR v1 pg4-5) that "There is no evidence that, elsewhere in the region, vineyard projects are being proposed as a catalyst for future residential development." They weren't looking very hard.

From the Hall Ranch website:



The reason that everyone in the county is now stuck with traffic congestion, unaffordable housing, an agrarian landscape now littered with building projects and more and more in taxes to cover the infrastructure costs of an expanding population is because each project approved never considers the reasonably foreseen future development that the completed projects will necessitate, encourage and make possible.

If the developer is serious about denying the growth inducing impacts of their project they should place non-development conservation easements on the properties or a no-future-development clause into the property deeds. If they are serious about only using the vineyards to supply grapes for Hall wines then let them recombine the properties into one parcel as a show of commitment. These steps need be taken as a condition for the granting of the ECP.

The parcel and vineyard map of Walt Ranch is here. Just look at the vineyard block plan. Would any vintner sensibly create such a convoluted, inaccessible and expensive vineyard just to supply grapes to their winery? Would anyone buy 2300 acres of land for 288 (now 209) acres of grapes? The convoluted vineyard configuration does insure that 34 of the 35 parcels each have some vineyard acreage necessitating road access and water availability required for the sale of vineyard-ready residential property.

The perfunctory discussion regarding growth inducing impacts by claiming this project is only about vineyards in the FEIR can only be seen as an attempt to fudge over real intent of the project and a sidestepping of the intent of CEQA. The CEQA "growth inducing impact" discussion is at the heart of this project.

It is, as well, a discussion that is at the heart of all the projects that that have generated so much opposition in the last three years as the obvious impacts of growth are beginning to destroy everything special about Napa County. Beyond this review, and the infrasturcture that his project will create, there are no land use restraints on the further development of these properties for housing. Walt Ranch, at 2300 acres, is a significant piece of open space and undeveloped natural woodland in the county. It deserves a better fate than just 35 more luxury homes (actually 105 residences when including allowed secondary units and guest cottages). If approved, the urbanization of Napa County, with each project's urbanizing impacts mitigated to a level of insignificance on paper, will go on unabated and, eventually, the open space will be gone.

Thank you for this opportunity to re-emphasize my concerns.

Bill Hocker
3460 Soda Canyon Rd
Napa

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