Lisa Hirayama | Nov 23, 2014

November 19, 2014

Kelli Cahill, Planner III
Napa County Planning, Building and Environmental Services Dept
1195 Third Street, 2nd Floor
Napa, CA 94558
RE: Draft Environmental Impact Report Walt Ranch Expansion Project #P11-002005-ECPA

Dear Ms. Cahill,

I have concerns regarding the above named Walt Ranch project that aren't referred to in the DEIR, but I believe are relevant to this proposal. I believe these issues need to be considered in the decision process of whether or not to approve this development.

It has come to my attention that Hall Financial of Frisco, TX is selling a 421-acre property in Geyserville on which they are awaiting approval to subdivide into 10 parcels. Once approved, they will be selling the parcels as estates, each with vineyard acreage. Interestingly enough, those vineyard blocks appear similar to how Hall Brambletree will be planting their 356 acres of vineyards on 35 parcels for Walt Ranch. Will the County specifically prevent the splitting of Walt Ranch into estates, if in fact, that is the end goal of Hall Brambletree? I have attached to this letter the informational flyers on this property. I would like to understand if a corporation can receive a development permit under the Napa Ag Preserve and then years later, possibly subdivide the property and sell it as estate parcels? How would this be the "highest and best use" of agricultural land? Once the County allows Walt Ranch to move forward, will Hall Brambletree be required to file an EIR again if they want to sell off each parcel as an estate? Or does it mean that once they are allowed to develop Walt Ranch as vineyards, later on they can do as they wish to the property without any restrictions? Will the impact on the neighbors and the environment have no validity?

A neighbor in passing commented to me that Circle Oaks is similar to Foss Valley which is due west of us up Soda Canyon Road. She said it has suffered no ill effects from vineyard development. I would beg to differ for many reasons. Our soil is of a completely different quality because we are more prone to slides and subsidence. For example, on January 1, 2006, there was a massive mudslide between Circle Oaks and Napa that closed Hwy 121 for a week. There are also always pockets of mudslides in our neighborhood that occur when heavy rains fall. Foss Valley's "hillsides are steep and well drained with volcanic soils of red dirt, loads of rock and tuffa." The soils there are not deep and it has a high water table. There is a surprisingly broad valley floor "with all of the area's water flowing into it from sources such as Rector and Milliken Creeks." Foss Valley is relatively close to the Walt Ranch project, but no comparison can be made between the two since the areas are dissimilar in soil quality, stability, water sources and current residential population. There is no moderately dense housing in that area. Circle Oaks operates a closed water system for its residents with no access to any other public water sources. Circle Oaks is truly unique and believed to be the only such type of this community in the State of California.

I have learned that the Hall's own the property at 3438 Atlas Peak Road under a different company name. One would think this should have been disclosed in the DEIR if there exists another access point to Walt Ranch other than Circle Oaks Drive, their dirt road 1/4 mile east past the CO entrance and Circle S, but I don't recall seeing anything about it. Shouldn't Napa County know all information if it pertains to Walt Ranch? Why would Hall Brambletree not mention it even if it is under a different named company owned by the Hall's? This goes to the transparency of this project--what else is possibly being concealed?

On November 16, 2014, "60 Minutes" aired a segment about the depletion of groundwater in California, especially in the Central Valley, to sustain agricultural crops. Wells are now being dug 1200' down to reach water and the ground has dropped 6' in some areas of the Valley because so much groundwater has been pumped out. One test well dropped 5' in one month and that same well has dropped 200' in the last few years. Water levels are at historic lows in the Central Valley. Is this what it will take for Napa County to realize that projects like Walt Ranch are devastating and unsustainable? By that time, the damage will be irreversible. Napa County should be considering the future cumulative impacts of allowing so much groundwater to be removed if Walt Ranch is allowed to proceed.
http://www.cbs.com/shows/60_minutes/video/

This past August, the Groundwater Resources Advisory Committee, formed in 2008 to study, monitor and make recommendations about Napa County's groundwater supplies, delivered its final report to the Board of Supervisors. "It focused on the valley floor because it contains the greatest amount of groundwater and the hillsides' complex geology would take too long to tackle. Gauging groundwater health in the hillsides would have to be done on a property-by-property basis." The committee declined to comment on how one property owner's water usage would impact another neighbor's well. "It's all very site-specific", so developing rules for usage can't be applied universally. If that is the case, then how can Hall Brambletree conclude that just by testing Walt Ranch wells, the Gale Well and the Circle-S wells, there is more than enough water in the aquifer to support Walt Ranch, Circle Oaks and all neighboring properties. They did not even know where the COCWD wells and possible spring were located, much less test them. I learned from a neighbor who relies on well water that testing for water volume should be done in the month of September. Walt Ranch testing was done in June 2009 before peak summer usage and before the drought. I would conclude that the Walt Ranch aquifer testing appears to be woefully inadequate and, at a minimum, needs to be retested for the current year.

Climate change is a reality. One just has to watch the news everyday to see the incredible rainfall and flooding that occurred this past summer back east, in the midwest, the south and the southwest, but California got nothing. Now all those areas are in a deep freeze with record snowfalls for this time of year, and California is still below average in rainfall for this time of year. Water monitoring needs to be mandatory for any new vineyard development or expansion. We can't extrapolate future water availability based on past water availability because climate change has made those records obsolete. The water issue is one of the most important aspects of any expansion or development in Napa Valley and the hills surrounding the valley. Water is life and it needs to be protected. I believe that Napa County needs to be the steward of the land and protect the well being of its residents. It needs to stop issuing use permits for new vineyards without considering the cumulative impact on the environment, watersheds, and residents. Now is the time for Napa County to make the difficult decisions that can one day be looked upon as the turning point that preserved Napa Valley for future generations. The residents are the heart and soul of Napa Valley, not the corporate vineyards.

Thank you for your consideration.

Sincerely,

Lisa Hirayama

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November 21, 2014

Kelli Cahill, Planner III
Napa County Planning, Building and Environmental Services Dept
1195 Third Street, 2nd Floor
Napa, CA 94558
RE: Draft Environmental Impact Report Walt Ranch Expansion Project #P11-002005-ECPA

Dear Ms. Cahill,

I have lived in Circle Oaks for 14 years and am deeply concerned about the above named project. As a lay person, I have done my best to understand this immense document. As such, I believe there are innumerable troubling issues in the DEIR, some of which I list below, and therefore, it should be rejected in its current form.

Section 3.4.3, pg 3.28
Walt Ranch proposes to use 213.5 acre feet of water annually or approximately 69.6 million gallons of water. The proposed project would rely solely on groundwater (Appendix--Vol I, pg 3-41). Circle Oaks used 19.5 million gallons of water in 2013, down from 23 million gallons in 2012. As of 11/19/14, Circle Oaks water usage for this year is down nearly 10% from last year at this time. Circle Oaks is doing their part to conserve water, so why would Napa County allow a vineyard to use 3.5 times the amount of water for grapes that a residential community uses to sustain lives? The state is in its third year of drought, now categorized as an exceptional drought, so how does Napa County justify allowing a project to massively dewater the aquifer? There is no way of knowing when or if this drought will end. California residents have done their share of conserving water: overall state usage is down 11.5%, but the Bay Area has decreased usage by 15%. Why then would Napa County give all that water savings to a vineyard for their grapes? Will Napa County guarantee that Circle Oaks, Atlas Peak, Monticello Road or any Walt Ranch neighbors not run out of water? If this project is approved, it is very possible that it could take a few years for water issues to arise. Will Napa County guarantee to pay for the water that will have to be trucked in to sustain households? Property owners on Mt. Veeder are experiencing dry springs/wells after the 32-acre Woolls Ranch vineyard was planted. How can I NOT be concerned about a 356-acre vineyard and the effect it will have on the water table. The California Water Code section 106 states, "It is hereby declared to be the established policy of this State that the use of water for domestic purposes is the highest use of water and that the next highest use is for irrigation." Given this statement, how can Napa County justify allowing agriculture to take priority over human consumption of water?

Section 4.6.1-3, pg 4.6-15
When groundwater is depleted, the concentration of minerals and solids increases. The DEIR states that "the primary constituents of concern are high total dissolved solids (TDS), nitrate, boron and organic compounds." A table on the following page lists arsenic, iron, manganese, and silica from groundwater samples taken at wells in June 2009 and May 2007. Why weren't samples taken recently to see if concentrations have increased after three years of drought? It appears that all the information we have encountered in the DEIR was taken in 2009 which is pre-drought. If the mineral concentrations increase years down the road and the water is unsafe to drink, will Napa County pay for water to be trucked in for all affected residents? Who will guarantee that our water will remain safe to drink when the ground water is depleted? Mt. Veeder is now experiencing high concentrations of boron and arsenic in a pond well since the Woolls Ranch vineyard was planted in 2010. Those levels are too high for grape irrigation and human consumption. In July 2013, Woolls Ranch began hauling water to irrigate their vines. Between 7/10/13 and 9/30/13, a time period of 82 days, Woolls Ranch hauled 1,748,000 gallons of water for their vineyard. In a time period of just 3 years, boron and arsenic levels have increased to unsafe levels and nearly 2 million gallons of water is being trucked in. Is this the fate Walt Ranch neighbors will have to endure in a few years if this project is approved? What will it take for Napa County to protect domestic water usage which is deemed by the California Water Code section 1254 to be "the highest use of water"?

Section 4.6.1-4, pgs 4.6-18 and 19
The DEIR states, "The COCWD may also have two wells and a spring water source located along the southern Walt Ranch property boundary; numerous attempts to contact the COCWD to participate in the groundwater study went unanswered." It would seem logical that if the hydrologist is trying to determine how Walt Ranch water usage will affect existing the water supply, he should know exactly where all wells and springs are located, not state "COCWD may also have.....property boundary". How can he determine how much water is available in the aquifer if he doesn't even know how many locations are tapping into that aquifer? He refers to five wells that are representative of the local groundwater conditions, but he doesn't verify that there could be more in the area? That analysis sounds extremely incomplete. It is also difficult to believe that Hall Brambletree (HB)was unable to make contact with anyone from COCWD. The ranch entrance is 150 feet from the COCWD office where someone staffs it Monday through Friday from 9am to noon. COCWD has an answering machine for off-hours, and there is an emergency number HB could have used if they were truly unable to make contact any other way. COCWD has no record that they were ever contacted by HB. This statement makes me wonder how much other information contained in the DEIR is suspect and dubious.

The DEIR states, "Due to the highly fractured nature of the Sonoma Volcanics and subsequent folding of the geology, it can be difficult to predict the influences of groundwater pumping over long distances in these rocks. Groundwater is found within the fractures, fissures and joints of the rocks." It states that the recharging of the Sonoma Volcanic rocks would be expected to occur due to direct rainfall on various types of surfaces that would filter down to the Volcanics. As I stated previously, California is currently in an exceptional drought, and no one knows when, or even if, it will end. With climate change, this region might never again have the normal rainfall we once experienced. How is the aquifer suppose to recharge if there is no rainfall? In January 2014, Governor Brown asked CA citizens to conserve water and they did. Again, how can Napa County justify allowing a vineyard development that will use 69.6 million gallons of water when there is an ongoing statewide conservation of water? California residents are not conserving water just so that it can be given to a corporation to grow grapes.

Also, because the Sonoma Volcanics are highly fractured, it can be more susceptible to earthquakes. A tributary creek that runs through Circle Oaks is normally dry during the summer. After the 8/24 earthquake, it started flowing and is still flowing strong. Creeks in Vallejo, Green Valley and Sonoma, normally dry at this time of year, have been flowing again due to the earthquake. Some people believe that this proves there is extra water in the aquifer, while I believe that the groundwater has been pushed to the surface which means there will be less water in the aquifer. Unfortunately, all that water flowing in the creek is not being saved for any use. How can anyone really know how much groundwater there is? After the September 2000 earthquake, one of the springs used by COCWD increased its flow. And just as easily as an earthquake can increase water flow, it can also cause creeks to dry up. I understand that acts of nature cannot be predicted. However, when one is willing to allow vineyard water usage priority over human lives, then something is seriously wrong. The aquifer has been productive in sustaining Circle Oaks and it's neighbors, but increasing its water demand 3.5 times over current human consumption just for grapes seems to defy common sense. Is Napa County going to monitor the water usage if Walt Ranch is allowed to be developed? Highly doubtful, so will Walt Ranch be monitoring their own wells for the sake of Circle Oaks? That's like asking the fox to guard the henhouse.

The groundwater analysis looked at the proposed pumping with annual precipitation and the average drought year. The flaw in that statement is that there is no average drought year anymore due to climate change. The DEIR makes the following partial statements, "A typical and conservative estimate of specific yield; based on available data; based on these calculations; volume that can potentially be extracted." Does this mean that there was no actual testing done to determine the true volume of groundwater? It sounds like it's all calculations based on information that might no longer be relevant or accurate. What happens if Walt Ranch is permitted and then it's proven that their numbers were inaccurate? There will be no reversing the damage that will have been done. Will Napa County just say "too bad"? Will Napa County take responsibility for their error in allowing this project to be developed? The analysis found that there is sufficient groundwater available in the Sonoma Volcanics to support the proposed project for a long period of time, even during drought years and even when demand might exceed recharge. Again, who is guaranteeing that statement to be true? Hall Brambletree? Napa County? As I stated before, who knows when and if the current drought will end. Global warming is throwing a monkey wrench into all previous climate records. These tests were done in June 2009 before the drought began. Why were measurements not taken more recently? And I've been told that to get an accurate reading of well water volumes, it should be measured in September, not in June before the peak summer usage.

Walt Ranch is proposing to build four new open reservoirs for the groundwater storage. Based on typical evaporation rates in the region, the DEIR estimates that 207 acre feet, or 6,745,116 gallons will be lost to evaporation. That translates to a third of the water consumed by Circle Oaks in one year, and this will happen every year. Why would Napa County allow that type of water waste? The DEIR states that average annual rainfall is 35" and will directly add 27.4 acre feet (or 8,928,317 gallons) into the reservoirs annually, so that amount will offset any evaporative losses from the storage reservoirs. In this time of drought, why would anyone think 6.7 million gallons evaporating annually is acceptable? If covered water storage tanks were used, then it would be an 8.9 million gallon water gain every year for the aquifer. However, the problem with the whole situation is that it is working off the assumption that every year will have 35" of rainfall. What happens when there isn't that much rainfall for extended years? What if there is never that much rainfall ever again?

Appendix--Volume I: Section 3, pg 3-8, d,e)
Hall Brambletree (HB) intends to manage the vineyards with sustainable agricultural practices. Does that mean poisonous pesticides? They state that it's not expected "to expose sensitive receptors to substantial pollutant concentrations or create objectionable odors affecting a substantial number of people." Since "this impact is considered less than significant , the EIR will not discuss or analyze these issues." Shouldn't ONE person be considered significant? If I'm that ONE person, why am I not important enough to consider? If my health or my children's health are affected by HB's poisons, why am I not considered signficant enough? We currently breathe unpolluted air. Is Napa County going to guarantee that the air I breathe will not become poisonous from pesticide usage on Walt Ranch? The prevailing winds blow directly onto my house from where the proposed vineyards will be developed. Will I no longer be able to enjoy the breeze in the late afternoon and evenings because I will have to worry about the poisons that might be carried by the wind? Will I no longer be able to open my windows because it will be dangerous to have any dust settle into my house possibly contaminated with pesticides? Why should my right to breathe clean air be considered less important than vineyard development?

Appendices Vol. I, Appendix D, pg 11
When a well is drilled, it is sealed to prevent contaminants from entering into the groundwater from the surface. For agricultural purposes, wells are sealed down 25 feet. For domestic usage, wells are sealed down 50 feet. The wells that have been drilled on Walt Ranch are sealed 50 feet down. If the property is to be developed under the Ag Preserve, why would Hall Brambletree need to seal 50 feet down? After learning of the Geyserville property for sale that I reference in my November 19, 2014 letter, this just reinforces suspicions that Walt Ranch will be subdivided in the future and sold as estate parcels. It would appear that Hall Brambletree is trying to develop the area under the guise of agriculture, but that is not what the end result will be. Why would the County not take possible future developments into consideration when granting approval under the Ag Preserve? If this permit is allowed because of the Ag Preserve, then how can houses be considered agricultural?

The Napa County Planning Department, the Planning Commission and the County Board of Supervisors need to listen to their citizens. Our county government has the responsibility to the hundreds, if not thousands, of residents who will be impacted by the Walt Ranch project. It is a massive and aggressive proposal that threatens to cause chronic dewatering problems and put entire communities and the environment at risk. Approval of this project would send the wrong message to the wine industry and to the people who live in rural Napa County. One of Napa County's roles in government is to be the steward of the land and protect it for current and future generations. Please remember that when making your decision on Walt Ranch.

Thank you for your consideration.

Sincerely,

Lisa Hirayama

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