Gary Margadant | Jan 14, 2015

Neighbors:

The WAA (water availability analysis) required for all discretionary projects, is currently being revised by Steve Lederer and the NC Dept of Public Works. On Jan 7, they appeared before the NC Plan Comm with a Draft, and with additional comments, a final draft presentation for the Feb 4 Plan Comm . The link below has Item 10A, containing the Draft WAA and a list of FAQ. The FAQ has several determinations that are not discussed in the Draft WAA, so both are important.

Planning Commission Agenda

Sadly, there is only a one sentence mention of WATER QUALITY in the DRAFT. Contrast this with the attached document from GRAC and LSCE (Napa County Hydrologist), which has a healthy discussion of water quality and the needs for such in Napa County.

Here is an excerpt:
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FEBRUARY 2011 NAPA COUNTY GROUNDWATER CONDITIONS
AND GROUNDWATER MONITORING RECOMMENDATIONS

FEBRUARY 2011 GRAC LUHDORFF & SCALMANINI, CONSULTING ENGINEERS

ES.4.2 Groundwater Quality
Historical groundwater quality records are typically lacking in Napa County. From records that do exist, groundwater is generally of good quality throughout most subareas. Poor groundwater quality exists in the south and the north central parts of the county. The poor groundwater quality includes concentrations of metals such as arsenic, iron, and manganese that exceed drinking water standards throughout the county. Elevated levels of boron are also prevalent in most subareas. Subareas south of the Napa Valley Floor, such as Carneros, Napa River Marshes, and the Jameson/American Canyons, have poor quality water due to high levels of electrical conductivity (EC), total dissolved solids (TDS), and chloride. The Calistoga Subarea of the NapaValley Floor also has poor quality water in many wells due to hydrothermal conditions resulting in higher concentrations of metals. Nitrate concentrations are not generally a concern throughout the county, but nitrate levels tend to be higher in agricultural areas in the Napa Valley Floor. Available groundwater quality data in the county are incomplete in regards to spatial distribution, number, and record. Many subareas do not have sufficient spatial coverage to gain a full understanding of groundwater quality. Six subareas have ten or less wells with available groundwater quality data, which limits the ability to determine representative quality and some subareas have no historical data. As a result, without sufficient groundwater quality records, it is impossible to determine trends in many subareas.

ES.5.2 Groundwater Quality Monitoring
The primary objectives of the countywide groundwater quality monitoring program include:

 Evaluate groundwater quality conditions in the various county subareas and identify
differences in water quality spatially between areas and vertically in the aquifer system
within a subarea;
 Identify where data gaps occur and provide infill, replacement, and/or project-specific monitoring (e.g., such as may occur for planned projects or expansion of existing projects) as needed;
 Detect the occurrence of, and factors attributable to, natural or other constituents that are a concern;
 Assess the changes and trends in groundwater quality; and
 Identify the natural and human factors that affect changes in water quality.

A preliminary ranking and priorities for improving or expanding groundwater quality monitoring was prepared for each of the county subareas. Four subareas (including NVF-MST, Carneros, Jameson/American Canyon, and Pope Valley Subareas) are given a higher priority for improving the groundwater quality monitoring network based on factors of current and /or projected land uses and also the lack of spatially distributed groundwater quality monitoring. Three subareas, including Livermore Ranch, Southern Interior Valleys, and Western Mountains, are preliminarily assigned lower priorities for groundwater quality monitoring due to the likely lower levels of projected land and groundwater use. The ten remaining subareas are designated as medium priorities for groundwater quality monitoring. Many of these areas have current monitoring programs, so the emphasis in these areas is to further examine land use with respect to monitoring locations and the units(s) of the aquifer system represented by this monitoring.

Many subareas outside the Napa Valley Floor have limited spatial distribution of the current groundwater quality monitoring wells/sites. Basic data are described as a key monitoring need to accomplish groundwater quality objectives. Importantly, expansion and/or refinement of groundwater quality monitoring conducted in all subareas should be coordinated with efforts to expand or refine groundwater level monitoring.

ES.6 Findings and Recommendations
This project led to a broader awareness of available groundwater data and an assessment of current groundwater conditions and trends, and also identified factors related to future assessment of groundwater availability. Spatial data coverage was good for some County subareas; however, for other subareas, monitoring network enhancements are needed. Recommendations are presented to enhance and expand countywide monitoring to facilitate understanding of groundwater availability and integrated regional water management and planning efforts. Section 6 of this report includes a table that summarizes the recommended implementation steps, including the implementation time frame, a relative estimated budget, and the relative priority for implementation.
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Why is the county reluctant to include water quality??? Industry objections on divulging sensitive data? The industry is not protecting and restoring surface water and groundwater quality to safeguard public and environmental health and secure water supplies for beneficial uses.

Water Quality is very important and we must push these requirements into the WAA!! Otherwise the county is sticking its head in the sand and hoping it will go away. But this affects everyone in the same watershed: What is the original quality, how has it changed over time as affected by the pumping and irrigation?

As the State is beginning to mandate these requirements in the new water laws, and water quality is the third rail of understanding the common resources under the ground, Napa County will be way behind as these regulations come into effect.

Push now. Push Public Works, Plan Com and BOS. Otherwise we are going to be surprised by the cumulative impacts hidden below the ground.

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