29 Mar 2021
Donald Barrella, Planner III
Napa County Planning, Building, and Environmental Services Department
1195 Third Street Suite 210
Napa, CA 94559
Re: Stagecoach North Vineyard Conversion
Erosion Control Plan Application #P18-00446-ECPA
Draft Environmental Impact Report
Many thanks of the opportunity to respond to the Stagecoach North DEIR.
The No Project Alternative
I would like to express opposition to the project and ask you to consider accepting the No Project Alternative to the proposal. It is, at least in my mind, the superior environmental alternative.
The DEIR states more clearly than I could why this alternative should be considered. I will take the liberty of repeating some of the conclusions here:
"Unlike the proposed project, the No Project Alternative would not require construction equipment and materials, vehicles, and crews; ground-disturbing construction activities; or operation and maintenance activities. For this reason, the No Project Alternative would result in less severe impacts than the proposed project related to air quality and greenhouse gas (GHG) emissions, biological resources, cultural and tribal cultural resources, geology and soils, hazards and hazardous materials, hydrology and water quality, land use and planning, noise, and transportation. Mitigation measures identified for the proposed project also would not apply to the No Project Alternative.
Vegetation removal, implementation of the Erosion Control Plan, and vineyard conversion would not occur under the No Project Alternative. The environmental setting would remain identical to conditions that existed at the time of the Notice of Preparation.
Unlike the proposed project, the No Project Alternative would not generate project construction emissions or result in a cumulatively considerable net increase in criteria pollutants, and this alternative would be consistent with the 2017 Clean Air Plan. Therefore, the No Project Alternative would not require implementation of Mitigation Measures 3.2-1a through 3.2-1c or the open burning condition of approval, as identified for the proposed project, to reduce impacts on air quality to less-than-significant levels. The No Project Alternative would not include activities that would expose sensitive receptors to substantial pollutant concentrations or result in other emissions (such as those leading to odors), adversely affecting a substantial number of people.
In addition, because this alternative would not involve any construction work or operation and maintenance activities, the No Project Alternative would not generate GHG emissions that would have a significant impact on the environment or conflict with an applicable plan, policy, or regulation adopted for reducing GHGs. No impacts would occur in these areas under the No Project Alternative, compared to the less-than-significant impacts that would result from the proposed project.
Because ground-disturbing activities would not occur under the No Project Alternative, impacts on biological resources, potential impacts on previously unrecorded cultural and tribal cultural resources, and conflicts with applicable sections of the Napa County Code and Napa County General Plan would not occur. The approximately 75.17 acres that provide habitat for approximately 1,912 holly?leaved ceanothus individuals, consisting of chamise alliance (48.85 acres), mixed manzanita (3.77 acres), and scrub interior live oak (22.55 acres), would remain on the project site. Populations of Franciscan onion, narrow-flowered California brodiaea, small-flowered calycadenia, two-carpellate western flax, nodding harmonia, Napa lomatium, and green monardella on the project site would not be removed and/or replanted. The 31.63 acres of California bay forest and 0.75 acre of black oak forest would remain on the project site. The approximately 2,790 total trees on the project site with a stem diameter at breast height of 5 inches or more would remain undisturbed. Therefore, the No Project Alternative would not require implementation of Mitigation Measures 3.3-1a through 3.3-k, 3.3-2a, 3.3-2b, 3.3-3, 3.3-4, 3.3-5, 3.4-1a, 3.4-1b, 3.4-2, and 3.4-3 as identified for the proposed project to reduce impacts on biological resources, cultural and tribal cultural resources, and land use and planning to less-than-significant levels.
With the No Project Alternative, proposed erosion and runoff control measures would not be implemented. Therefore, unlike the proposed project, this alternative would not cause a reduction in soil loss of approximately 29.78 percent (160.01 tons) or a net decrease in peak- flow rates relative to existing conditions. The No Project Alternative would not affect water quality and groundwater supplies.
Because construction and maintenance activities for the vineyard would not occur, the No Project Alternative would avoid potential impacts of the proposed project related to hazards and the use of hazardous materials on the project site and temporary, less-than-significant impacts associated with noise and transportation-related construction activities."
A better case to protect an environment would be hard to make. Additionally, there are a few other impacts the No Project Alternative would avoid:
No cars would be added to the 50 or so that caravan up and down the road each day, increasing the danger of its blind curves and backing up the junction at the Trail. Traffic on the road, which has more than doubled since 2014, would not be increased further.
No more service vehicles, large dump trucks, grape trucks, or other large equipment would add to the danger and the maintenance of an already dangerous road and grade. Nor would the No Project Alternative add to the number of large vehicles that tend to get stuck trying to make it up the grade.
In the No Project Alternative, wildfire danger in this high wildfire severity zone would not be increased by the addition of more people and vehicles, (and possibly power lines if other wells are developed). Nor would it add to the number of people needing to evacuated by helicopter in the event of another fire, like that in 2017, blocking the exit down the road.
At the macro scale, the No Project Alternative would not add to the need for more affordable housing and infrastructure to accommodate a larger work force. Nor would it add to the glut of grapes that the industry seems to be experiencing.
For all the positive benefits to the environment that the No Project Alternative would sustain, the one negative that it posits is the larger amount of siltation that would occur by not doing anything. Perhaps. But the DEIR seems to assume normal rain events and a retention system that must be maintained in perpetuity. In 1997-8 an exceptionally rainy season caused massive amounts of sediment from the newly begun Stagecoach vineyard to wash down canyon walls into Rector reservoir causing filtration failure and substantial repairs. Despite the DEIR’s many pages of elaborate calculations, the notion that churning up 42-60 inches of topsoil and rock over 100 acres of land, and the ongoing use of farming equipment on miles of new block perimeters, will result in an ultimate decrease of soil erosion seems very hopeful engineering. Forgive me for being skeptical.
Perhaps an alternative could be proposed that would stem the most egregious current erosion, replanting unused roads for example, while retaining the other environmental benefits of the No Project Alternative.
Rector Watershed Development
It is late now to get worked up over another vineyard diminishing the remaining natural landscape in the Rector watershed. The fire that ravished the project site last year even reduces some concern about the potential loss of the natural landscape. And certainly new vineyards are far superior to housing tracts, vineyard estate development or winery tourist attractions. But a look at the amount of acreage developed on the Rector plateau shows that the entire watershed is coming closer to being completely developed. It is already the most heavily developed watershed in the county by far. The Stagecoach North project is the first to push up to the ridge that surrounds the watershed, and a harbinger for further development along the ridge lines.
In that regard the county should again address the potential cumulative impacts of further development of the watershed. It is a shame that developers are forced to spend over $300,000 on a report that is predetermined to conclude that what the developer’s proposal will have less-than-significant impacts.
The money would be better spent on a study of the impacts as a watershed area is maxed out in vines. The Rector watershed, and the Stagecoach vineyard occupying a very hefty portion of it, would be the perfect subject for a case study in changes in water availability, siltation, animal habitat and traffic generation from its inception in 1995 though the present. It would give everyone a data-based view of the continuing efforts throughout the county to convert raw land to more profitable uses.
Suggested project inclusions
Whichever alternative is finally decided upon, I would like to see two issues considered in the final EIR for the project:
First that a vanpool arrangement be included not just for the proposed project but for Stagecoach as a whole, so that it might set a precedent in reducing GHG’s and dangers on the road through a more environmentally-friendly worker transport system.
Second, that an additional northern access road to Stagecoach Vineyards be established connecting it to Hwy. 128, both as a fire security measure and to reduce the traffic load on Soda Canyon Road.
It should be mentioned, with or without this project, that Gallo will remain by far the largest producer of wine in the world. Its revenues, with the acquisition of Constellation, are now over 60 times greater than its next closest competitor. There is a point at which the growth mentality of capitalism begins to defy the logic of maintaining a livable world, indeed of maintaining our species. Oil companies will always want 100 more acres of tundra, cattle companies 100 more acres of rainforest, and in Napa, warehouse builders 100 more acres of wetlands or gravel companies 100 more acres of wooded knolls.
For all of the “less severe impacts” listed in the No Project Alternative, it is beyond time to recognize that the natural world is not just an infinite resource to be consumed for financial growth. And for those same reasons, it is beyond time that governments begin to accept the No Project Alternatives in front of them, and I ask you to do so here.
Again thank you for the opportunity to comment.
3460 Soda Canyon Rd