December 2002
Napa County Board of Supervisors
1195 Third Street
Napa, CA 94559
Dear Sirs,
I am opposed to the proposed Stream Setback Ordinance in its present form because it is premature and will be ineffective:
- The relationship between the health of the Napa River watershed and human land use activities is not yet sufficiently well understood to warrant the development of new setback regulations.
- The ordinance now exempts so many parcels and activities that it is likely to have very little effect on the health of the watershed while adding to the regulatory workload of the county and increasing the cost to taxpayers.
I have read the Stream Setback Technical Memo prepared by Jones & Stokes and was unimpressed with its reasoning. (I am a scientist and have considerable experience with both reading and writing technical documents.) The Technical Memo defends stream setbacks in general as a means to improve riparian and aquatic habitat but it does not address the specific situation in the Napa River watershed. Most notably, it ignores the other important factors that may have contributed to the decline of certain fish species, such as dams, dredging, removal of woody debris and levee building. All the stream setback regulations in the world will not bring the fish back unless these other factors are also considered.
I have also read the report of the Napa River Basin Limiting Factors Analysis (NRBLFA) prepared in June 2002 by Stillwater Sciences and Professor William Dietrich of UC Berkeley for the San Francisco Bay Water Quality Control Board and the California State Coastal Conservancy. (This report is not even mentioned in the Jones & Stokes Technical Memo.) The NRBLFA report presents the results of a two-year evaluation of factors limiting populations of Chinook salmon, steelhead and freshwater shrimp and a study of stream and riparian habitat conditions in the Napa River watershed. The report also analyzes historical and current land use activities in the Napa River basin. The report covers only Phase I of a two-phase project, however. It is explicitly stated in the report that the cause-and-effect relationships between human land use and these species have not yet been established. That is one of the objectives of Phase II of the study. I hope you will all read at least the Executive Summary of this report (available at http://www.coastalconservancy.ca.gov/Programs/napa.htm and also at http://www.swrcb.ca.gov/rwqcb2/Download.htm).
The exemptions granted for vineyard replanting and proposed for residential parcels will certainly make this ordinance more palatable to most Napa County residents and thus remove much of the political opposition. The burden of the ordinance will thus be unfairly placed on the shoulders of relatively few property owners. But these exemptions weaken the ordinance to such an extent that it is highly unlikely that it will have any impact on the biological health of the Napa River and its tributaries because it will affect such a tiny percentage of the stream and river banks.
If it is determined (in Phase II of the NRBLFA) that human land use is the cause of fish decline, then all contributing factors, not just sedimentation and water temperature, should be considered for regulation. Perhaps gravel beds should be restored, multiple river channels allowed to re-form, levees removed, fish ladders installed alongside dams. And all parcels along the river and its tributaries should be regulated to the same degree, whether they are in the cities or in the county, whether they are used for vineyards or housing developments or shopping centers. What is the scientific basis for exempting residential parcels? What is the scientific basis for allowing current vineyards close to the riverbank to remain but prohibiting new ones?
As with all environmental regulation, the benefits to the watershed that might result from these measures must be balanced with the social and economic costs. I hope you will not allow yourselves to be pressured into prematurely adopting this ill-conceived ordinance. Please take the time to become informed and to consider both the costs and benefits to Napa County, its people and its economic base.
Yours truly,
Carole Meredith
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