April 1, 2004 - General concerns from NVLSA Board of Directors to Napa County Board of Supervisors
NAPA VALLEY LAND STEWARDS ALLIANCE
P.O. Box 3238, Napa, CA 94558
www.landstewards.org
April 1, 2004
Napa County Board of Supervisors
1195 Third Street, Room 310
Napa, CA 94559
Re: Special Forestry rules
Dear Supervisors Dillon, Dodd, Luce, Rippey, and Wagenknecht:
Napa Valley Land Stewards Alliance Board of Directors discussed the latest proposed special forestry rules at its March 31 Board meeting, and, based on information currently available, voted unanimous opposition to these rules. The Board respectfully requests that you either withdraw the rules request or delay the Board of Forestry’s consideration of it.
Supervisor Dodd recently told me that your original intent was to regulate only conversions, not selective harvests, and that he thinks the original package was much more inclusive than you intended because Jones and Stokes understood how difficult it is to get special County rules approved by the Board of Forestry, so they "threw everything they could at the Board in the hope that something would stick".
Unfortunately, "throwing everything they could at the Board" also confused and clouded the issues that should have been analyzed at the previous public hearing. The rules package considered at that hearing dealt primarily with selective harvests and made no mention of conversions. However, all but four of the twenty-eight rules we are now seeing have been substantially reworded to apply to conversions only.
The rules request is now completely different from the original request, and its new focus brings with it a completely different set of issues and concerns. Therefore, if the Board chooses not to withdraw the request, then we ask that you at least delay the request and reopen the public hearing so these issues and concerns can be properly and publicly aired. The previous public hearing cannot be considered a proper and adequate public hearing on the new issues raised by this new and quite different rules package.
While the previous package proposing to regulate selective harvests raised concerns about our ability to properly manage our permanent forests, the new package addressing only conversions raises concerns about conflicts with our General Plan and with our identity as an agricultural county. Erecting new obstacles to vineyard conversions seems to discourage putting agricultural-zoned land to productive agricultural use. This apparently conflicts with the Napa County General plan and with existing zoning standards. It also seems to conflict with the County's stance as an agricultural county, including the notice of official County policy that we receive with our tax bills each year informing us that to preserve our agricultural identity we all must tolerate some necessary and worthwhile inconveniences that go along with being agricultural. Doesn’t this policy also mean that we should tolerate some marginal forest land being converted to more productive agricultural use?
This revised rules request makes us think that Napa County might be experiencing an identity crisis which should be resolved before embarking on a course seemingly in conflict with long standing policy. Are we a premier wine grape region, or are we a public park? Is agriculture the highest and best use for our Agriculture-zoned land, or should that land be rezoned to "Wildlands"? Do tourists come here to see the vineyards, or will they stop coming if we add another vine? Should vineyards be encouraged as part of a network of firebreaks and fuelbreaks in order to protect our forests from wildfire, or should additional vineyards be forbidden and some other way found to limit the spread of fire?
Is what we are trying to accomplish here compatible with our current General Plan? If not, does it merit changing the General Plan to accommodate these rules, or should we simply abandon them? Are the 250+ pages of existing State Forestry rules, virtually all of which address environmental protections and which fully comply with CEQA, really inadequate? If so, exactly how and why are they inadequate, and how do these rules cure those inadequacies?
The majority of the new special rules raise the question, "Why just Napa County?" If these rules really have merit, why shouldn't they apply to all counties? And if they have no such merit, why apply them in any county? What is different about Napa County that would justify applying each of these special rules here, but not elsewhere? We find no answers to these questions in the County's request to the Board of Forestry.
If there is something unique about Napa County that might justify different rules, we think it must be Napa County's ability to produce premium grapes that make the finest wines in the world. If so, then why is this unique character of ours not construed to justify more lenient rules on converting land to the production of those premium grapes, rather than the erection of more obstacles to conversion?
We hope you will agree that these important questions must be answered before allowing this special rules request to go any further. Until we have clear and satisfactory answers, Napa Valley Land Stewards Alliance is opposed to these new rules. I look forward to discussing our viewpoint with each of you.
Sincerely,
George Bachich, president
Napa Valley Land Stewards Alliance