Bill Hocker | Jun 20, 2015

[my own modest suggestions for APAC consideration.]

Chairman Hall and Members of the Agricultural Protection Advisory Committee

At the June 8th meeting Chairman Hall asked for members of the committee to prepare proposals describing what accessory uses should be allowed on agricultural land in Napa County.

I hope that you will allow non-committee members to offer their thoughts as well. As someone facing the prospect of a winery event center in my back yard I have some interest in the recommendations put forward by this committee.

I frankly think that the task before you is quite straightforward, and I would suggest the following outline for your ultimate recommendations:

Preamble:

1: Recognize that protecting agriculture is not a winery problem but a tourism problem. There are now development impacts being felt by communities throughout the county as more event center wineries are proposed and approved. Those impacts are not just to the quiet enjoyment of the communities in which they are located, but are part of a county-wide cascade of urban development necessary for the accommodation and maintenance of an ever increasing tourist population. That development puts urbanization pressure up against the maintenance of an agricultural economy. Residents, growers and concerned vintners have begun to realize that, as former Supervisor Mel Varrelman said, "tourism is a very destructive thing" when it comes to protecting agriculture in the county. Rising concern in the last couple of years about development impacts is why this committee has been formed.

2: Recognize that without tourism as a component of winery projects that the decision to build or not devolves to the economic need and feasibility for that winery as a processing facility. Given the declining need for processing, winery proposals should be encouraged to diminish rather than increase over time.

3: Recognize that this tourism trend has been exacerbated by modifications to the WDO in 2010. The 1990 WDO managed to survive 20 years because it embodied a balance between those interested in protecting the vineyards and those wishing to commercialize them. The 2010 modifications have changed and codified the balance heavily toward visitation and created ambiguity in what uses are appropriate. The changes were made against the backdrop of a wine industry slump during the recession, a slump that abated even before the changes to the WDO had an impact. They were changes heavily promoted by the tourism industry.

4: Recognize that food service is an inappropriate use for an agricultural processing facility. While there may be a justification for tours of factories and for the sampling of their products as a means of education and marketing, the serving of food crosses a boundry between education and entertainment. Food service for tours and tastings was a significant of aspect of the 2010 WDO modifications and is at the heart of the transition of wineries from processing facilities to event centers.

5: Recognize that the at-winery direct-to-consumer model of wine marketing, cited also as a justification for 2010 changes to the WDO, is a tourism industry solution to a problem of its own devising. Of course dozens of small, inefficient wineries, costing more in construction and operations costs than they can reasonably recoup from wine sales, will need some other form of help to remain in business. The tourism industry solution? - tourists. The problem is not that wine is now harder to market, the problem is that there are too many small wineries to market wine efficiently.

6: Recognize that the 1990 WDO was not completely up to the task of preventing the intrusion of tourism events into the vineyards. Even before the recession, un-permitted tourism uses proliferated because of ambiguity in the wording of marketing events and because the county has had few resources to enforce permit compliance at wineries, especially given that ambiguity. Only now, as wineries are being sold or expanded or their event activities rise to a public nuisance level, are requests for "recognize and allow" permits coming forward, necessitated by a lack of appropriate enforcement early on.

Recommendations:

1: Recommend that the 2010 WDO modifications be rescinded in their entirety.

2: Recommend that the language of the "Marketing of Wine" definition in the 1990 WDO be changed to eliminate the ambiguous and all-encompassing phrase, "or members of a particular group for which the activity is being conducted on a pre-arranged basis."

3: Recommend that county staff be empowered with the means too adequately detect and enforce non-compliance of use-permits at wineries.

Thank you for this opportunity to comment

Bill Hocker
3460 Soda Canyon Road

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