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Protecting our Environmental Resources
Updated: 21 hours 59 min ago

Rush to Judgement on Knight’s Bridge Winery

Tue, 09/12/2017 - 10:57

Rush to judgment

EDITOR: Congratulations to the Sonoma County supervisors for rushing to approve the Knights Bridge Winery project (“Supervisors back Knights Valley winery,” Aug. 23).

Just as our harvest begins, in a year of good rains, our last well is barely recharging. This is the first time it has ever happened so dramatically. We own the property adjacent to the project, and where county policy legally requires surrounding properties’ groundwater be protected when permitting discretionary land use. The developers’ deal in the public hearing for “no net water increase,” when they already pump more than any nearby neighbor, doesn’t hold water.

The supervisors had no qualms approving a project based on consultants working for the developer rather than granting the public the environmental impact report we requested. We met with board members to discuss the multiple new wells for the 10-bedroom, 10-bath estate, swimming pool and guest home, but granting a permit for the proposed winery took precedence.

Our 40 years of experience in the ag preserve growing grapes had no merit or influence, and now our wells have drained. Shame on the county for not representing the people who are the backbone of agriculture in favor of outside money. Is this the way democracy works?


Knights Valley

Categories: Food and Farming

Vineyard Workers

Tue, 09/12/2017 - 10:53

Opinion Press Democrat


Clearly the health of grapes takes precedence over the well being of vineyard workers. On Saturday September 2nd, I read the online article in the Press Democrat, “Harvest in Heat Wave.” A few of the photos show workers wearing bandannas that cover their mouth and nose for protection against dust and smoke. Some also wear caps and hoodies for further protection. These people were picking grapes at night under hot, bright lights, under skies shrouded with smoke during last weekend’s excessive heat wave when temperatures rose to over 100 degrees. Workers toil at a feverish pace from early evening until dawn picking grapes and then running with bins full of grapes when even the nights were much warmer than usual.

I was stunned by the paragraph that read, “Smoke from Trinity and other northern California fires should not pose a problem for the local crop as grapes are more susceptible to smoke taint in the early summer than at this point in the growing season.” In this entire article there is no empathy shown or compassion stated for the workers who pick in extreme weather conditions and no mention of the workers’ health when exposed to “smoke taint.”

This situation reminds me of how the Trump administration treats people and the environment.


Pamela Singer



Categories: Food and Farming

Challenge to Napa’s winery environmental reviews: Napa News

Fri, 09/08/2017 - 17:38
What part of cumulative impacts, flawed traffic studies, making significant environmental damage a Mitigated Negative Declaration to by pass environmental issues and back dating permits to get wineries in compliance are Napa and Sonoma County officials not getting?

Challenge to Napa’s winery environmental reviews: Napa News

A mystery group calling itself Alliance for Responsible Governance claims Napa County regularly fails to fully follow California environmental laws when approving new wineries and winery expansions.

Since 2013, Napa County has approved more than 90 winery projects. It has generally conducted environmental reviews for traffic and other issues that fell short of California Environmental Quality Act (CEQA) requirements, the group wrote.

The Alliance’s letter to the county Board of Supervisors and Planning Commission has potential legal ramifications. It comes from the San Francisco-based law firm Shute, Mihaly & Weinberger on behalf of the group.

“Alliance for Responsible Governance urges the county to remedy its failed procedures promptly,” attorneys Ellison Folk and Robert Perlmutter wrote.

Interim County Executive Officer Minh Tran said Friday the county will soon respond publicly to the Alliance for Responsive Government letter. He added the county disagrees with the premise that it does inadequate environmental reviews.

The Alliance letter comes at a time when some residents worry that tourism threatens to overshadow the area’s agricultural roots. Others embrace what they see as a wine country success story.

So who is behind the Alliance for Responsible Governance?

“At this point, the Alliance doesn’t really want this to be about individuals in the group,” Folk said in a phone interview.

Rather, members want the focus to be on the future of Napa Valley. They are concerned about the way the county has consistently failed to adequately analyze new wineries, she said.

Folk said she doesn’t know how many members are in the Alliance.

Napa Vision 2050, a coalition of environmental and community groups, has been amid the thick of the county’s growth battles. Vision 2050 President Dan Mufson said he doesn’t know identities of the Alliance’s members, though he’s seen the letter and recognizes kindred spirits.

“We certainly support what’s in there,” Mufson said. “These are issues we’ve been dealing with one-by-one, piecemeal.”

Alliance members might be wine industry figures sympathetic to these causes who don’t want their names known, Mufson said.

Rex Stults of Napa Valley Vintners could only speculate on who might be behind the Alliance. He said that, if not for a few egregious violations of use permits, the focus in the community would be on the bigger problems of traffic and affordable housing.

Jennifer Putnam of Napa Valley Grapegrowers said the group’s board has yet to discuss the Alliance letter. But, she said, the Alliance approach of hiding behind a secret identify might not be the most productive way to plan the county’s future as an agricultural community.

“We look forward to being part of any of those productive conversations,” Putnam added.

The Napa County Farm Bureau said in a statement it largely supports the positions in the Alliance letter. The group noted it has long been engaged in the county code compliance issue.


Shute, Mihaly & Weinberger for various clients has raised objections related to several proposed winery projects in recent years: Yountville Hill Winery, Girard Winery, Caymus Vineyards, Frog’s Leap Winery and Raymond Vineyards.

The law firm also worked with proponents of the oak woodland and watershed protection ballot measure that the county in 2016 disqualified on a technicality. It drafted both Measure J in 1990 and its 2008 successor Measure P, which puts most Napa County agricultural land use designation changes in the hands of voters.

Folk and Perlmutter wrote that the county since 2013 approved 93 winery projects that combined allow a million visitors and covered more than a million square feet. They noted the county required full environmental impact reports for only the Hall Winery distillery building demolition and proposed Yountville Hill Winery.

Instead, Napa County has used exemptions and smaller studies called negative declarations to satisfy California environmental laws. Folk and Perlmutter claimed that this has resulted in inadequate environmental review.

The Alliance criticized the county for allowing illegal activities to be part of the baseline when it evaluates a winery seeking after-the-fact approvals. That allows the unpermitted uses to evade environmental review, Folk and Permutter wrote.

For example, the letter said, Frog’s Leap Winery in 2016 had a permit for 350 visitors weekly. It was actually hosting 800 visitors weekly. It voluntarily stepped forward and successfully asked the Planning Commission to modify its use permit to allow 1,100 visitors weekly.

Yet, when the county analyzed traffic and other impacts at Frog’s Leap, it compared the requested increase to the unpermitted visitation already taking place, not what was permitted, Folk and Perlmutter wrote.

“This improper baseline obscured the true environmental impacts of the approvals and produced a misleading environmental review,” they wrote.

Then-Planning Commissioner Heather Phillips asked about this practice at the Aug. 17, 2016 Frog’s Leap hearing. She added she understood it was part of a Board of Supervisors directive to encourage voluntary compliance.

Deputy County Counsel Laura Anderson confirmed that this approach is the Board’s directive. The practice is perfectly acceptable under state law and, in fact, the typical baseline for environmental analysis is the existing setting, she said.

“The agency does have some discretion to deviate from that. But generally speaking, existing conditions are what you want to follow,” Anderson told Planning Commissioners. “And that’s what we’ve been following.”

Folk and Perlmutter wrote that the county’s traffic studies are flawed. For example, the county considers a traffic increase of less than 1 percent resulting from a winery projects as insignificant. But many smaller projects taken together do have significant effects, they said.

The county repeatedly defers cumulative traffic impacts to the environmental impact report done for its 2008 general plan. Yet that 2008 study failed to adequately address winery-related traffic, Folk and Perlmutter wrote.

Folk and Perlmutter made several other claims, among them that the county requires mitigation such as winery event visitors using shuttles, but .

“Alliance for Responsible Governance hopes to resolve these issues with the county in a timely and amicable fashion,” Folk and Perlmutter wrote.

But if the county doesn’t take appropriate steps, the Alliance reserves its right to ensure that environmental impacts for winery projects are analyzed and mitigated as required by state law, they wrote.

Categories: Food and Farming

Commercialism Prevails in Knights Valley

Wed, 09/06/2017 - 11:21

Commercialism prevails


EDITOR: In the aftermath of the denial of the Knights Bridge Winery appeal, Sonoma County must already deal with this applicant’s trail of carelessness (“Supervisors back Knights Valley winery,” Aug. 23).

The Knights Valley hillside is scarred with an oversized building labeled as a house — right before our eyes in our scenic corridor — and more building to come. Neighboring properties report their wells have been reduced since the applicant built the 10-bedroom, 10-bath lodge and planted additional vineyards on a property with too many vineyards to begin with. Bidwell Creek restoration efforts taking place nearby are offset by Knights Bridge taking too much water from this already challenged creek.

Recognizing the area’s special nature, the intent of the specific plan governing Knights Valley was preservation and to protect this rural area in the 4th District from this type of commercialism. Responsibility for allowing this tragedy to occur lies in the 5-0 vote.

All should ask why this project wouldn’t require an environmental impact report under the California Environmental Quality Act.


Knights Valley

Categories: Food and Farming

Watershed & Woodland Protection in Napa County: Environmental Leader Collaborate to Protect Woodlands & Watershed

Wed, 09/06/2017 - 10:51

Dear friends and supporters of our watershed and oak woodland protection initiative,

Last year, our grass roots organization gathered 6,300 signatures for an initiative to enhance protections for streams and oak woodlands. It was a phenomenal accomplishment and speaks volumes to the support we received from the community. Voters are increasingly aware that the health of the natural environment and human ecology are integrated. They’re concerned, as they should be, and want to have a voice in the matter. 

As it turned out, we weren’t able to bring our initiative to the ballot. But earlier this year, when leaders in the NVV suggested we partner in the process, it gave us hope we could strike out on a new path that would ultimately succeed. And now we have a revised initiative that we’re confident will meet the needs of the present but also protect the needs of generations to come. It is titled, Napa County Watershed and Oak Woodland Protection Initiative of 2018.  

We’re grateful for the Vintners’ bold leadership and their solidarity with neighbors seeking solutions to pressing needs of the natural environment. Please take a look at their bulletin, below, for more information. We’ll be gathering signatures soon for the June ballot. You’re welcome to join us if you can.

Sincerely grateful, on behalf of all of those pulling together for the common good,


Subject: NVV and Environmental Leaders Collaborate to Protect Woodlands and Watershed

Date: September 5, 2017 NVV is collaborating with local environmental leaders in support of a ballot initiative that will protect oak woodlands and the local watershed.

The Napa County Watershed and Oak Woodland Protection Initiative of 2018 establishes enhanced water quality buffer zones and oak woodland protections in the Ag Watershed, without overburdening responsible property owners.

The initiative has been filed with the County Clerk’s office for the June 2018 ballot. It comes following several months of thoughtful discussions and compromise between our leadership and Mike Hackett and Jim Wilson, co-authors of last year’s similar initiative effort that did not qualify for the ballot due to a legal technicality. NVV actively opposed the 2016 proposal, which lacked industry input.

What Will the Initiative Accomplish?
Together, we identified common ground to enhance environmental protections in the Ag Watershed (AW):

  • Water Quality Buffer Zones: Compromise on buffer zones around creeks and streams in the AW was achieved by looking back at 2004’s Measure P, a stream setback ordinance championed by NVV and other industry partners. The new initiative will expand the definition of watercourses subject to stream setbacks by utilizing common stream classification definitions, compared to the county’s current unique definition. Class 2 streams will have a 75’ setback and Class 3 streams will have a 25’ setback. Presently, setbacks are 35’ to 150’ based on slope.
  • Oak Woodland Protection: Compromise on oak woodland preservation includes a new mitigation ratio for removal of oaks of 3:1, rather than the existing 2:1. A qualified professional must prepare the mitigation plan and at least 80 percent of the replanted trees must survive at least five years. The initiative does not include a new permit process for removal of oaks.
  • General Plan Projections Used to Limit Future Oak Woodland Removal: The joint initiative proposes a limit on oak woodland acreage that can be removed within the AW. The limit is based on the amount of oak woodland removal associated with vineyard development envisioned through the lifetime of the current Napa County General Plan in 2030. With limited exceptions, further removal of oak trees above this limit would be precluded after that date, unless voters decided to increase it. Future vineyards could be developed in the same manner as now, provided this development didn’t involve further removal of oak woodlands.

It’s important to note that the initiative is forward-looking and will not affect vineyard replants.

Why Did We Do This?
Goal 2 of the NVV’s Strategic Plan calls for us to “Protect and enhance the Napa Valley, its wines, environment and community” and to “Improve our environment” by “developing and advocating for strong conservation-based positions to protect and enhance natural resources.” The joint initiative helps accomplish this goal and strategy.

Though the 2016 initiative, which we and other industry groups actively opposed, failed to qualify for the ballot, we never considered that a “win” for the wine industry. Rather, it inspired us to explore common ground and the chance to collaborate with the original petitioners, given they had publicly declared their intent to come back with a new ballot measure. Together, we found an approach that we believe will receive widespread support and eliminate the need for a potentially costly and divisive community campaign with an uncertain outcome.

When presented with the concept over the summer, initial feedback from County leaders has been extremely enthusiastic. They, too, recognize the value of industry and environmental leaders working together for common community benefit, as we have done in the past.

What’s Next?
The Napa County Watershed and Oak Woodland Protection Initiative of 2018 will receive a Title and Summary from the County. This month, we’ll begin a signature gathering campaign. Approximately 5,000 registered voters must sign on for the initiative to qualify for the June 2018 ballot. Concurrently, we will be reaching out to build a broad coalition of stakeholder and community support.

How Can You Help?

  • If you are registered to vote in Napa County, be one of the 5,000 signatories to help this initiative qualify for the ballot.
  • Spread the word to your friends, neighbors and colleagues on the win/win aspects of the initiative: enhanced environmental protection without undue burden on responsible property owners.

Leaders in our community have a long and successful history of collaboration and compromise for the greater good, going back to the establishment of the Ag Preserve a half century ago. There are numerous examples since. This is the next step in that proud local tradition.

We thank NVV Board Chair Michael Honig and NVV Community and Industry Issues Chair Russ Weis for the countless hours they have invested in this effort, as well as neighbors Mike Hackett and Jim Wilson for the spirit of collaboration demonstrated in this process.


Categories: Food and Farming

Critical hearing Sept. 21st for large winery/hospitality complex on already highly impacted Westside Road, Healdsburg.

Sun, 09/03/2017 - 10:43
Your neighbors need help with this project. Please consider emailing your response or attending the meeting to this terrible project that will add traffic, safety issues, over concentration, loss of groundwater resources, additional pesticide use and more. If you don’t live in the immediate area, projects like this set precedent and your area could be next.


Note the march towards “food pairings” at wineries which are competing with local restaurants and changing the definition of “agriculture”. This project also furthers the creep of office buildings, lodging and event centers as normal for agriculture….no it is NOT. This is exactly how Napa went down the slippery slope to “Napafication”… “little” change at a time to the definition of “agriculture” allowing the wine industry to gain more control over the community and economy. Our corporate wine industry model is not sustainable! From our friends at West Side Road (Dry Creek Valley) group ….  

This is a critical hearing regarding the potential  of a large winery/hospitality complex on Westside Road. 

There are three existing tasting rooms within a 1000 foot radius of this project.

Please get the work out to your members to attend hearing and write letters to County officials.


Mark Your Calendars – September 21 Hearing @ 1 pm – 2550 Ventura Ave, Santa Rosa Plan to Attend Hearing – Project at 7097 Westside Road, UPE14-0008

A large winery/ tasting room/ hospitality complex is proposed for 7097 Westside Road; consisting of a 60,000 case winery (32,000 sq. ft. winery and a 20,000 sq. ft. cave), about 6,000 sq. ft. of commercial office space, 4 tasting rooms, 3 commercial kitchens, a VIP lounge,  2 overnight lodgings, daily food pairing, 24 Ag promotional events with up to 300 people, and parking for 84 cars. Project will import 720 tons of grapes, and employ 24 employees.

Too Large in Scale —This proposed project is simply too large in scale compared to other wineries along Westside Road and for the rural neighborhood in general.

Road Safety Issues — Westside Road bisects the proposed project; thus, two (2) driveways provide access on both sides of the road, and the project is within a ¼ mile of three (3) existing tasting rooms. This stretch of road has very limited sight distance requiring the removal of trees and cutting back a hillside, which, along with the scale, is detrimental to rural character. The proposed public and truck traffic creates significant road safety and joint road use conflicts. 

Specific Issues with Proposed Project:

  1. Disproportionate focus on hospitality and promotional uses is inconsistent with the Williamson Act contract and the intent of the General Plan to preserve agriculture and rural character;
  2. Minimum setbacks to adjacent properties may create significant unmitigated noise impacts;
  3. Generates significant employee, public and truck traffic in an area with inadequate sight lines and several access roads to existing tasting rooms – traffic safety and joint road use conflicts;
  4. The operation of a 60,000 case winery/distribution center, office building and hospitality complex is incompatible with the rural neighborhood, and better located in a town center;
  5. Location of large buildings and parking lots within the designated scenic corridor is inconsistent with the General Plan Open Space Element; and
  6. Large-scale project, with tasting rooms on both sides of the road, situated within an approx. 1000 ft. radius of three existing tasting rooms is detrimental to the rural character of the area.

Let County officials know your concerns with such a large-scale project on a scenic, rural road that will create serious noise and traffic safety issues. _______________________________________________________________________

It is important for neighbors and concerned citizens to attend the hearing; you do NOT need to speak. Please write your concerns to our Planning Commissioners for this hearing:


1st District Greg Carr                 

2nd District Larry Reed            

3rd District Paula Cook            

4th district Cameron Mauritson

5th district Pam Davis                          


Note: cc: County Planning Director, and Permit Sonoma staff Traci Tesconi,


Thank you – and see you at the hearing!

Categories: Food and Farming

NapaVision 2050 Town Hall meeting, neighbors working on issues together

Fri, 09/01/2017 - 12:33
Let’s Keep The Conversation Going!

We the People of our Napa County came together Thursday, August 10th, standing room only, at the Horsemen’s Association in Napa.
For over two hours many residents spoke of concerns as we brainstormed together how to make our community more cohesive and resident-friendly. Thank you who joined us.

It is incredibly important that we keep together  – that we let our elected and appointed officials know of our concerns and remind them of the mandate in our County Organizational chart:
the Citizens are the boss!

Let’s keep the conversation going!

September 7, 2017 at 7:00 pm

Native Sons Hall 1141 Oak Ave, St Helena, CA 94574

Categories: Food and Farming

When Governing Powers go Rogue

Wed, 08/30/2017 - 09:16

NapaVision 2050

When Governing Powers go Rogue.

A Challenge to the County’s Compliance with the Law by The Alliance for Responsible Governance

In a letter dated August 11, 2017, the environmental law firm Shute, Mihaly & Weinberger, representing The Alliance for Responsible Governance, a group “whose members are strong supporters of the sustainable economic growth in Napa County within the context of the agricultural protections embraced by the citizens of Napa County and codified within the County’s General Plan,” put Napa County Board of Supervisors and Napa County Planning Commission on notice:


“You have a pattern and practice of failing to comply with California Environmental Quality Act (CEQA). Correct this, or we will make sure you do!”


The law firm studied every permit granted since 2013 and determined that only two of the 93 winery permits had adequate environmental review. They believe projects were approved with improper use of categorical exemptions (which allows avoidance of CEQA review) and negative declarations (no significant impact, since there is no CEQA review). Furthermore they believe traffic and noise were not properly evaluated. Citing a 2015 grand jury finding, “Napa County’s oversight of wineries is almost non-existent, and therefore insufficient to insure compliance with CEQA.”


The letter cites particularly egregious examples: In 2016 Caymus Vineyards was granted major modifications under a categorical exemption which allowed substantial road modifications, changes in production levels, and building demolition. However, a threefold increase in visitation to 450 visitors a day was also granted without CEQA review. These substantial increases in visitation and production, which will have cumulative impacts on the environment, traffic and noise, were not considered.

In the period referenced in the letter (2013-2016), the County approved  an increase of over a million visitors and permitted over a million square feet of winery surface area expansion– almost all without consideration of cumulative impact on our County.


The letter further states that the County routinely miscalculates Project Baseline by including unpermitted (illegal) uses and activities in the baseline analysis when assessing a potential project’s impacts. Baseline activities avoid environmental review because they are already happening. “At least 10 of the 68 permit applications that the county received were fromwineries who were operating illegally.” Illegal activities include unpermitted marketing events, visitation in excess of permitted levels, unauthorized facility development, and exceeding production levels.


The example of Reverie Winery was given.   Although the existing use permit allowed only 20 visitors per week and six small events a year, the Planning Commission granted a use permit modification which increased visitation ten times, despite the obvious impacts on the environment, traffic and noise—a prime example of granting forgiveness for the winery having operated illegally for a number of years.

The letter directs the County to correct its implementation of CEQA guidelines on all new and/or expanded projects and informs the County that The Alliance will “reserve(s) its right to ensure (that) the environmental impacts of new or expanded wineries are analyzed and mitigated as required by CEQA”.


We believe that these practices of our County Planning Department, Planning Commission, and Board of Supervisors circumvent and mislead the public. CEQA review is a protection for the public, telling us what these expansions are going to do to traffic, noise, congestion, water supply, and health of our environment. Furthermore, the integrity of our Ag lands, protected by the landmark zoning decision made by our forward thinking predecessors in 1968, are threatened by commercialization.

We at Napa Vision 2050 are delighted The Alliance for Responsible Governance  has joined this battle to get the County to do the right thing. With our letters, appeals of Planning Commission approvals and public statements, we have been trying for several years to highlight and change these behaviors to no avail. We are pleased that someone with more money than we have has stepped up to legally force compliance and hope they will follow through to the proper conclusion.  Thank you, Alliance!  We don’t yet know who these folks are but they are our new best friends!

Categories: Food and Farming

Neighbors clean up watershed, Sept. 3rd next clean up

Wed, 08/30/2017 - 09:09
Atascadero Watershed is conducting their annual clean up of local watersheds. If you can help, show up Sept. 3rd for a few hours at 10am Graton and Ross Rd intersection. This is what community is all about!

From our friend John Roberts.


This coming Sunday, Sept. 3,  we will be working on Graton Rd., Ross Rd., and the downtown areas and environs of Graton.  I’ll be parked in a conspicuous location around Graton Rd. and Ross Rd. intersection.  The AGVWC has bought 60 grapplers over the years and we have shared them with many folks.  I  only have  seven left so if folks participating have trash pickers, please bring them along.  We do have a fair amount of safety vests and lots of bags etc.


Gloves, sun hats, water bottles, long pants,  are very useful.  I will have a 5 gal. water jug available.


Generally, we do not include children in this process as we are working along well traveled roads and safety is of upmost importance.  However, in the town of Graton kids accompanying their parents can work the sidewalks and the Joe Rodota Trail.  All our other pickups along Green Valley Rd. and Mill Station Rd. and Sullivan will be along roads with traffic and children are welcome to stay home.


I will be setting up around 8am this coming Sunday and we will hopefully finish well before noon.


Tentatively,  we will be on Green Valley Rd. on Sunday, Sept. 10  and on Mill Station Rd.  on Sunday, Sept. 17.  To be confirmed later.


One note – Occidental Rd. has always taken two Sundays to complete.  The crew was excellent last Sunday and there seemed to be a small  reduction in quantity along the road.

To finish in one day was great.  The plastic bag ban has made a huge difference.


Now for the awards – In the  Lite Beer competition, once again the Coors Lite guy wins but not by much over Bud Light.  The gentleman who tosses out his little plastic bottles (one shot size) generally with E & J Gallo Brandy is still around, still continues to toss them in the same place and has slowed down his drinking.  That’s progress for him.


There may be room/time for one or two more trash pickups to fill out Sept., hopefully before the rains.  Suggestions welcomed.



Thanks to all,     John


Categories: Food and Farming

Proposed Russian River Watershed Pathogen TMDL Workshop

Fri, 08/25/2017 - 10:29
This is an important workshop to attend and give feedback on the growing problem of toxins in the Russian River. TMDL is the amount of toxins to be allowed on a daily basis. With low flow during the summer months, Monte Rio beach has been closed down from the algae threat. If you live or visit the Russian River, the health of this wonderful river resource is vital to our community. NOTICE OF PUBLIC WORKSHOP SEPTEMBER 20, 2017 Proposed Russian River Watershed Pathogen TMDL

The California Regional Water Quality Control Board, North Coast Region (Regional Water Board) is proposing to amend the Water Quality Control Plan for the North Coast Region (Basin Plan) to establish a Pathogen Total Maximum Daily Load (TMDL) and Program of Implementation (TMDL Action Plan) for the Russian River Watershed. Regional Water Board staff invites you to attend a public workshop to learn about the Draft Pathogen TMDL and TMDL Action Plan.


Regional Water Board staff has drafted the Pathogen Total Maximum Daily Load and Program of Implementation for the Russian River Watershed (TMDL Action Plan) and the Staff Report for the TMDL Action Plan (Staff Report). The draft Staff Report describes the watershed setting, the applicable regulatory framework, and desired watershed conditions. It further documents pathogen pollution and impairments in the Russian River and its tributaries, identifies potential sources of pathogens, and estimates the pathogen loading capacity of the system based on the draft statewide bacteria objectives for E. coli now out for public review. The draft Staff Report provides the scientific basis and technical evidence of the Pathogen TMDL and proposes a concentration-based Waste Load Allocation and Load Allocation for the fecal indicator bacteria, E. coli for pathogen sources. The draft TMDL Action Plan contains the technical components of the Pathogen TMDL and the draft Program of Implementation. The Program of Implementation includes a proposed Advanced Protection Management Program (APMP) boundary, within which Onsite Waste Treatment System (OWTS) owners will have certain responsibilities to confirm the proper functioning of OWTS. The draft Action Plan also includes a prohibition of the discharge of fecal waste materials that cause or contribute to an exceedance of bacteria water quality objectives except as authorized by waste discharge requirements or action of the Regional Water Board or State Water Board.

Public Workshop:

Regional Water Board staff will present the draft Staff Report and draft TMDL Action Plan for the Russian River Watershed. Written and verbal public comments will be received at the workshop.

Date: Wednesday, September 20, 2017 Time: 5:30 p.m. – 8:00 p.m.

Location: Guerneville Veterans Memorial Hall16225 1st Street, Guerneville

Public Comment Period:

Written public comments regarding the Draft Pathogen TMDL and TMDL Action Plan will be received from August 7, 2017 – September 29, 2017. Public comments can be sent to the attention of Alydda Mangelsdorf at the Regional Water Board at Comments can also be faxed to 707‐523‐0135 or mailed to the California Regional Water Quality Control Board – North Coast Region, ATTN: Alydda Mangelsdorf, 5550 Skylane Blvd., Suite A, Santa Rosa, California 95403

DOCUMENT AVAILABILITY The draft Action Plan, draft Staff Report, including the draft Substitute Environmental Document, are available for public review and comment and can be downloaded from the Regional Water Board’s website at: These documents can also be viewed by contacting or visiting the Regional Water Board’s office at 5550 Skylane Blvd., Suite A, Santa Rosa, California 95403 weekdays between 8:00 a.m. and 5:00 p.m. or calling 707‐576‐2220.

CONTACT INFORMATION For information, contact: Alydda Mangelsdorf, Senior Environmental Scientist, (707) 576-6735
Categories: Food and Farming

Insult to injury by Craig Enyart on Sonoma County Supervisors decision to accept “paper water” for Knights Bridge Winery

Fri, 08/25/2017 - 10:19

Insult to injury

EDITOR: Regarding the Knights Bridge Winery project, Sonoma County has failed to look at the whole project, and in doing so has ignored the cumulative impacts, including negative effects to neighbor’s wells. Instead the developer’s fake water use numbers keep ever spiraling downward in an attempt to justify this winery project.

When the developer’s anticipated water usage data was first presented to the county in 2013, it reflected one set of numbers, and now four years later the water usage data reflects something quite different, now magically reduced. In the meantime the only thing that has changed is even more intensive water usage as the developer has replanted significant acres of new vineyard, added a 10-bed/10-bath guest lodge complete with a large recreational pool and all new landscaping.

To add insult to injury, the county is accepting the developer’s overall project water use calculations, in part by accepting the claim that the lodge’s water usage will be equivalent to “an average household of four.”

As the water uses have intensified, the development’s overall water usage calculations have gone down. How is that possible? As with fake news, so goes fake water to justify this winery project.

Craig M. Enyart, Knights Valley

Categories: Food and Farming

Pesticides Threat to Champagne Water Quality

Fri, 08/25/2017 - 10:10
France leading way to ban pesticides. What’s in your water?  Pesticides Threat to Champagne Water Quality

Intensive agricultural practices are causing concern as chemicals reach the water table. By Caroline Henry

A hot, dry summer has left pesticide levels in Champagne’s groundwater at dangerous levels, according to a local study, raising fears about the region’s water quality.

The extensive use of pesticides – including insecticides, herbicides and fungicides – in the region is causing serious concerns to the water quality of the region. According to a study conducted by the local water agency, Eau Seine et Normandie, the chemical residues found both in the surface and ground water in the Champagne area regularly exceed European authorized levels, both for individual chemical molecules and chemical compounds.

Related stories: Organic Boost for Champagne

According to Daniel Beddelem, regional director for the Marne area of Eau Seine et Normandy, part of the reason is that the Seine has one of the smallest water flows of all French rivers, yet the water requirements of the region are extremely high at around 3 billion cubic meters per year. That combination means that the dilution capacity is limited in comparison with other regions.

Pollution levels have reached such toxic levels that a study earlier this year estimated that some 2.8 million people in France – mostly in areas where there is intensive agriculture, such as Champagne and the southwest of France – were drinking polluted tap water as a result of pesticides and nitrates leaching into the water table.

A study conducted in 2013, and updated in 2016, shows that pesticides remain the most important threat (with 54 percent of the total) to the degradation of the groundwater quality. Herbicides, particularly glyphosate, remain the largest culprit among the pesticides. The problem is further exacerbated by the fact that it takes several years for the chemical traces to completely disappear from the groundwater, as they tend to cling to the chalk omnipresent in the Marne region. This historical build-up has created a certain urgency to restrict the current use of pesticides and more specifically herbicides to prevent further pollution and possible mass degradation of the region’s water sources.

The desire to reduce the amount of pesticides used in France is not new. In 2008, the French government put in place a first EcoPhyto plan, piloted by 1900 agricultural business who aimed to reduce and measure their pesticide usage over the following years. In the light of the relative success, the French government launched a second plan in 2015; Ecophyto II, aimed to reduce the use of pesticides by 50 percent by 2025, and has been adopted by 30,000 agricultural and viticultural players across the country.

The Comité Interprofesionnel du Vin de Champagne (CIVC) has committed to the objectives of the EcoPhyto II plan, and after having almost completely eradicated the use of insecticides in the region, has now moved its focus to the reduction of herbicides, which are still widely used in Champagne. Last year, Arnaud Descotes, technical director of the CIVC, told Wine-Searcher that two-thirds of the region’s vineyards were still blanket-sprayed with herbicides, and almost 90 percent of the vineyards used herbicides to weed under the rows.

However, it looks like change is imminent, as later this week the Technical Committee of the CIVC will vote to accept a ban on the blanket spraying of pre-emergent herbicides (including glyphosates) from 2018 on. This move was lauded by Beddelem as an important step in the right direction.

Besides working with the CIVC, the Eau Seine et Normandie agency also works closely together with several grower cooperatives and Champagne houses to further promote the reduction and even the elimination of herbicide usage.

Veuve Clicquot is one of the Champagne houses that has changed to a zero-herbicide regime. According to cellarmaster Dominique Demarville, the choice was an obvious one, especially considering the continuing deterioration of the ground water and erosion of the hillside soils.

“We are very fortunate to have such a wonderful terroir in Champagne; it is part of our heritage and we owe it to the future generations to preserve it. This means we have to reign in our pesticide usage,” he said.

However, Romain Leguillou, Clicquot’s vineyard manager, added that this change of policy has not always been easy to implement and that it had significant social and economic drawbacks. “We have come to realize that the move to eliminate the use of herbicides has significantly changed the working conditions of our 120 vineyard workers, often complicating their labor,” he said.

“Furthermore, we have also noticed that our yields have been reduced significantly, which means we have to review and tweak our current practices if we want to continue to meet our market demand.”

Clicquot is also trying to get as many grower suppliers on board as possible, by assisting interested growers with free technical advice and know how, as well as an extra premium on the grape price. “We want to set an example and show that it is possible to work without herbicides,” concludes Demarville.

Categories: Food and Farming

Update: Knight’s Bridge Winery appeal denied….county to move forward with permit

Wed, 08/23/2017 - 10:35
Alot of public concerns here on geology, wildlife, and more with the county accepting a 2012 water study by contractor and ignored neighbors self monitoring of their wells. No mention of what month this water study was done in 2012 with many conditions changing in those 5 years. Was the old water study done in April or May to justify the net zero water the project is proclaiming? Sonoma County Press Democrat reports: Supervisors back Knight’s Valley winery by J.D. Morris The Sonoma County Board of Supervisors signaled Tuesday that it would approve a new winery in Knights Valley, advancing a long-planned 10,000-case facility despite concerns from residents worried about how the project would impact the rural area, particularly its limited groundwater supplies.

After a nearly three-hour hearing, supervisors unanimously agreed to move the Knights Bridge Winery proposal forward, indicating the board intends to deny a request from residents who wanted the county to require another layer of environmental review.

The board directed county staff to bring the winery’s use permit back for a formal vote Sept. 19, incorporating several conditions proposed by Supervisor James Gore, who represents Knights Valley.

“There’s one thing everybody has in common, which is this beautiful place,” Gore said at the hearing’s outset. “It’s absolutely gorgeous and pristine, and it’s a place that deserves protection and deserves the highest level of review for projects, too.”

The most significant of Gore’s conditions would solidify a pledge made by the winery’s proponents that the project would offset any additional groundwater use, a key concern of residents opposed to the winery, slated for a roughly 86-acre site on Spencer Lane about a mile west of Highway 128. The property’s net demand on its well — half the acreage is planted in vineyards — was previously estimated at about 162,900 gallons per year.

Donna Oldford, a consultant for the Knights Bridge Winery team, said after the hearing that the condition could be met through techniques such as drought-friendly farming or removal of vines.

A 10-bedroom, 10-bathroom mansion and another residence are also located on the site. The winery has an existing tasting room in Calistoga.

In the works for more than four years already, the new plan would add a 5,500-square foot winery building and about 17,730 square feet of wine caves, among other additions. The winery would produce no more than 10,400 cases per year and on-site tasting would occur by appointment only, with no more than 13 people allowed to visit the winery each day. The county would not permit any special events on the site, staff said.

“We’re anxious to get started,” said Jim Bailey, the site owner and project applicant, after Tuesday’s hearing. “But we want to make sure we address everything in terms of the conditions. We’re happy, but we’ve got lots of work to do.”

The county’s Board of Zoning Adjustments approved a permit for the winery in September 2015 on a 4-0 vote. Two groups of local residents, the Maacama Watershed Alliance and the Friends of Spencer Lane, appealed the permit approval shortly thereafter, insisting the project warranted a full-blown environmental impact report largely due to its potential affect on groundwater supply and the possible strain from groundwater pumping on nearby Bidwell Creek. Residents have also raised concerns about traffic impacts, among other issues.

“Knights Valley is the most special place in the world, and I’m worried about water, traffic, noise — and they’re of great concern for those of us who live there full time,” said Lauren Thollander, a longtime Knights Valley resident, during the hearing Tuesday. “We do not want our valley to become Sonoma Valley, an Alexander Valley (or) a Mark West … which just turned into traffic jams every weekend.”

The watershed alliance previously derailed two other winery proposals in Knights Valley, including a smaller 5,000-case project put forward about a decade ago by billionaire vintner Jess Jackson.

Craig Enyart, a spokesperson for the watershed alliance, previously said residents were prepared for possible legal action if supervisors did not require an environmental impact report for the Knights Bridge Winery.

After the hearing, he called the idea of zero-net increase in water usage a “good salvo” and a “compelling piece of information for the board,” though he indicated that court challenge remains a possibility.

“We haven’t had a chance to talk, obviously,” Enyart said. “We’re going to huddle up between now and Sept. 19.”

You can reach Staff Writer J.D. Morris at 707-521-5337.

Categories: Food and Farming

Pattern of CEQA Violations Alleged in Napa

Tue, 08/22/2017 - 13:36

A prominent environmental law firm has told Napa County:

You have a pattern and practice of failing to comply with California Environmental Quality Act (CEQA). Correct this, or we will make sure you do!

In a letter dated August 11, 2017, the environmental law firm Shute, Mihaly & Weinberger, representing The Alliance for Responsible Governance, a group “whose members are strong supporters of the sustainable economic growth in Napa County within the context of the agricultural protections embraced by the citizens of Napa County and codified within the County’s General Plan,” put Napa County Board of Supervisors and Napa County Planning Commission on notice:

“You have a pattern and practice of failing to comply with California Environmental Quality Act (CEQA). Correct this, or we will make sure you do!”

The law firm studied every permit granted since 2013 and determined that only two of the 93 winery permits had adequate environmental review. They believe projects were approved with improper use of categorical exemptions (which allows avoidance of CEQA review) and negative declarations (no significant impact, since there is no CEQA review). Furthermore they believe traffic and noise were not properly evaluated. Citing a 2015 grand jury finding, “Napa County’s oversight of wineries is almost non-existent, and therefore insufficient to insure compliance with CEQA.”

The letter cites particularly egregious examples: In 2016 Caymus Vineyards was granted major modifications under a categorical exemption which allowed substantial road modifications, changes in production levels, and building demolition. However, a threefold increase in visitation to 450 visitors a day was also granted without CEQA review. These substantial increases in visitation and production, which will have cumulative impacts on the environment, traffic and noise, were not considered.

In the period referenced in the letter (2013-2016), the County approved  an increase of over a million visitors and permitted over a million square feet of winery surface area expansion– almost all without consideration of cumulative impact on our County.

The letter further states that the County routinely miscalculates Project Baseline by including unpermitted (illegal) uses and activities in the baseline analysis when assessing a potential project’s impacts. Baseline activities avoid environmental review because they are already happening. “At least 10 of the 68 permit applications that the county received were from wineries who were operating illegally.” Illegal activities include unpermitted marketing events, visitation in excess of permitted levels, unauthorized facility development, and exceeding production levels.

The example of Reverie Winery was given.   Although the existing use permit allowed only 20 visitors per week and six small events a year, the Planning Commission granted a use permit modification which increased visitation ten times, despite the obvious impacts on the environment, traffic and noise—a prime example of granting forgiveness for the winery having operated illegally for a number of years.

The letter directs the County to correct its implementation of CEQA guidelines on all new and/or expanded projects and informs the County that The Alliance will “reserve(s) its right to ensure (that) the environmental impacts of new or expanded wineries are analyzed and mitigated as required by CEQA”.

We believe that these practices of our County Planning Department, Planning Commission, and Board of Supervisors circumvent and mislead the public. CEQA review is a protection for the public, telling us what these expansions are going to do to traffic, noise, congestion, water supply, and health of our environment. Furthermore, the integrity of our Ag lands, protected by the landmark zoning decision made by our forward thinking predecessors in 1968, are threatened by commercialization.

Read NapaVision 2050’s Reaction: When Governing Powers Go Rogue >>

Read the Background to this Case: The Billionaires are Driving the Millionaires Out >>

Learn more about this law firm: Shute, Mihaly & Weinberger LLP >>

Original Source: NapaVision 2050

Categories: Food and Farming

Neighbors Shut Down Illegal Cannabis Grow

Mon, 08/21/2017 - 10:38
Neighbors Shut Down Illegal Cannabis Grow by Dr. Shepherd Bliss

Disclosure: I’m a Peace in Medicine patient. CBD-rich cannabis improves my health. I support cannabis growing that follows the rules and does not endanger creeks, wildlife, or neighbors


 My farmer neighbor here in Blucher Creek Watershed, Lari,emailed me Aug. 7 that a new neighbor had just bulldozed a huge area and was constructing large cannabis grow buildings. We immediately visited him to view the site—a disaster to many life forms dependent on that water, including listed endangered California freshwater shrimp, much wildlife, vegetation, and humans.


“What we saw was jaw dropping.  Land cleared, all the topsoil pushed into the creek bed,” wrote Lari.  The environmental consequences will be long-lasting and hard to remedy soon, certainly not before the coming rains that farmers and others depend upon. Then plastic, silt, and sedimentation will flow freely down the creek, polluting it.


“They filled the tributary, so needed for flood protection, with the land scraping. A 100-foot long building appeared, which three days prior was a virgin field.  Three more large building sites were cleared, and the topsoil pushed into the riparian zone.  Miles of plastic, barrels of chemicals, fertilizer piles, and marijuana plants arrived. We actually stood there mouths agape! How can this happen?” added Lari.


No permits existed for this devastation. We reported this violation to various government officials and agencies, including Supervisors David Rabbitt and Lynda Hopkins. They responded promptly and effectively.            


“Illegal grows are a huge concern, environmentally and socially,” wrote Supervisor Hopkins. “Unfortunately they give the folks doing the right thing (going through County permitting processes and growing in appropriate locations) a bad name,” she added.


On the next day, representatives from the North Coast Regional Water Quality Board, the county’s Permit and Resources Management (PRMD), Supervisor Rabbitt’s office, and our Bloomfield/Lone Pine/Cunningham Neighborhood Association met at Lari’s farm. The government officials visited the grow, confirmed that it did not have the required permits, red tagged it, and shut it down.


The new owner then put it up for sale. We reminded his agent that a full disclosure was necessary; he took the “For Sale” sign down.


Another neighbor showed us an un-permitted grow nearby on Schaeffer Road. We also managed to get that operation red tagged and shut down. “Weeks ago, huge earth-moving equipment came onto the property that adjoins us, graded a large area and began to construct a massive greenhouse for commercial cannabis,” said Patrick Ball, “without a permit.”


“Families with children live on both sides and just across the street. We are on wells and worry about the massive amount of water that a commercial cannabis operation consumes. If this is allowed to be completed on the large commercial scale that it was intended, we will have lost the safety, peace and well-being our neighborhood has provided,” Ball added.


A meeting for the public to comment on cannabis growing will occur Sept. 27, Wed., 3 p.m., hosted by the Cannabis Program of the Sonoma County Economic Development Board. Environmental and community protection should be part of that discussion, at 2550 Ventura, Santa Rosa, at PRMD. We plan to go and hope that others will join us there and speak up. Since the room is relatively small, getting there early would be best.


Hundreds of such un-permitted cannabis operations are popping up around the county. This endangers food farming, as well as the environment.


These illegal growers often pump water from creeks. It can take up to 10-20 gallons a day per cannabis plant. These growers tend to select hidden rural areas and set up cameras.


To cannabis growers out there, please do it the right way. This not only benefits you financially, but also the environment, its many critters, and neighbors. We’re watching you carefully.


As Margaret Meade said, “Never doubt that a small group of thoughtful, committed citizens can change the world; indeed, it’s the only thing that ever has.”  and  “We won’t have a society if we destroy the environment.”


We can provide assistance to others, including the names and contact information of the appropriate officials.


(Shepherd Bliss {} has farmed in Sebastopol for 24 years, and recently retired from college teaching.)

Categories: Food and Farming

PUBLIC HEARING APPEAL OF KNIGHTS BRIDGE WINERY Sonoma Co. UPE13-0046 and Intent to Adopt a new Mitigated Negative Declaration

Mon, 08/21/2017 - 10:08

August 17, 2017

To our Board of Supervisors,

We thank you for considering the Maacama Watershed Alliance (MWA) appeal of the Knights Bridge Winery Use Permit, filed with Friends of Spencer Lane on September 23, 2015, by letter to Tennis Wick.
For almost 4 years our watershed protection group including residents, grape growers, and ranchers in Knights Valley, has submitted public and expert testimony on significant and cumulative impacts from the construction, operation and ground water demand from this project proposed in the Resource Conservation Area and Class 3 Marginal Groundwater Availability Area under the county’s Franz Valley Area Plan.

As the public’s representatives, the entity responsible for implementing the mitigating policies of the General Plan GP2020 EIR to protect the environment, and now the decision-making body on this discretionary permit, we trust that you will carefully review whether the consultant assessments for the developer provide adequate evidence that can support the determinations of the Mitigated Negative Declaration. None of the feasibility assessments, subsequent peer reviews for the County, or the voluminous supplemental memoranda in the public record have provided location-specific data to prove there is or will be no significant or cumulative impacts on the environment with this project.

MWA and professional experts have reviewed and provided comment on other discretionary projects in our watershed. Two of the applicant’s consultants, reporting for Knights Bridge Winery and this MND, previously did assessments for wineries in Knights Valley that did not attain Use-Permits: 1) Biological Assessment by Kjeldsen Biological Consulting for “Delectus Winery”, and 2) RC Slade & Associates, Hydrological Assessment for “Pelton House Winery” (Use-Permit rescinded by court order.) Testimony on these consultants’ previous findings of no impact on water supply, water quality, and biological resources without actual study of impacts are included in the public record.

The following issues on the Knights Bridge Winery July 21, 2017 MND remain unresolved:

“Applicant” has changed from “James Bailey” in the May 28, 2013 Use-Permit Application and August

21, 2015 Public Notice and September 2016 MND to “Knights Bridge LLC” in the July 21, 2017 MND.


The project description has been unstable and the size and scope of development has expanded since the application was filed on 5/28/2013. The calculation of the amount of acreage to be disturbed has increased from under 1 acre to over 8 acres. The building sq. footage has expanded to a size appropriate for a 20,000 case winery, almost double the capacity of what is requested in the Use-Permit. The project’s water and transportation infrastructure developed prior to CEQA review are part of the project’s cumulative impacts on the local environment and natural resources but are not included in the project description.

The MND, as filed with State Clearinghouse, records the project as 2 parcels. The MND considers potential impacts only from APN120-090-038 and excludes all impacts occurring from APN 120-090-005.
As access to and from the winery, partner parcel 120-090-005 is an essential part of the Project. The winery access road will be a continuing source of sediment and pollutants where storm water drains to Bidwell Creek on both parcels. Parcel 120-090-005 includes grapes to be processed at the proposed winery. Both parcels have been the site of advertised, unpermitted industry and marketing events for the same wine producing entity, which were recorded in complaints to the Permit and Resource Management Department. Both parcels are areas of high archeological sensitivity as identified in the 1979 Franz Valley Area Plan and construction of the winery access road from 120-090-005 to 120-090-038 already damaged cultural resources within the road corridor.

The parcels share groundwater supply. Of the 6 new wells added to the two parcels since purchase from previous owners, 2 new riparian wells (Serendip Wells #5 and #6)120-090-005 were permitted with water conduit for irrigation at 120-090-038. Bauer (March 2013) provides Well Completion Reports for 8 wells of the 2 parcels. None of 120-090-005’s groundwater use is considered for estimating the existing Total Water Use for irrigation of parcel 120-090-038 to be able to accurately consider the impacts of new water demand for the Project. The Hydrological Assessment (Slade 2013) considers only one parcel in disclosing Total Water Use and appears not to consider water supplemented by the partner parcel.

Hydrogeological Assessment and MND consider APN 120-090-005 as merely an “adjacent parcel” when considering a cumulative impact area for the project rather than part of the project and its existing water use. The Cumulative Impact Area therefore does not meet the County minimum requirement “to include at least the project parcel and all surrounding parcels” to consider impacts on local ground and surface water supply.

Surface Water Quality, Ground and Surface Water Supply and new Cultural Resource Impacts to land- uses occurring on 120-090-005 are not assessed or mitigated in the MND. Project description does not accurately define 120-090-005 as part of the project.


Based on the description by applicant’s consultant Plans4Wine, the MND states that the project “will not be visible from public view sheds.” There appears to have been no Visual Resource Assessment of the project. Tree removal is part of the project and there is no prohibition to future tree removal. The visibility of the future winery from Scenic Vistas and Scenic Corridor of the Franz Valley Area Plan was not studied or evaluated. No sight line data or any visual impact evaluation is in the public file. Knights Bridge Estates’ 10 bedroom compound and buildings occupied are now exposed in the Scenic Corridor.

Water Quality and Water Supply Impacts from the project may negatively affect Species and Habitat. 2103

Biological Assessment is inadequate, with survey and observation limited to a confined and already-disturbed “building footprint”, and did not assess where negative impacts of the construction and operation of the project could occur.

a) Would the project have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species?

Habitat modification or substantial adverse effect may occur with the project to the following species: -State Endangered California freshwater shrimp
-State and federally Endangered Central California Coast (CCC) coho salmon
-Federally Threatened steelhead

-Plant and animal species not surveyed or disclosed in Kjeldsen’s 2013 Biological Assessment

Sonoma County recognizes a ground and surface water connection and the state of native species on the brink of extinction in the Russian River system. Peer Review of a 2013 Hydrology Assessment on behalf of the County (O’Connor May 15, 2017) acknowledges that expanded groundwater pumping for the project may impact water supply of Bidwell Creek.

New and on-going groundwater pumping in the Bidwell Creek subbasin has reduced the stream’s ability to retain dry season pools which are essential summer rearing habitat, necessary for species survival. The project parcels pump groundwater from multiple wells and share groundwater from wells pumping from riparian zone of Bidwell Creek. The use of groundwater currently on the 2 parcels is at the level considered “buildout” for domestic and agricultural water demand that the Hydrogeological Assessment (Slade 2013) applied for the “cumulative impact area.” 6 new wells were approved as ministerial permits since 2011 and 2012 in an area of limited groundwater availability to supply the parcels that previously irrigated the same acreage on existing wells. Only for discretionary projects are the biological and local water supply impacts of additional groundwater extraction considered. Further reduction in dry season pools would more than modify summer habitat for aquatic species, it could eliminate them.

The magnitude of project-generated soils at this sloped project location and potential for sediment release into surface waters and critical habitat may not be contained in the flood zone of Bidwell Creek under major storm events. A sediment spill of up to 23, 000 cubic yards of cave spoil possibly containing undetermined pollutants would catastrophically modify or eliminate habitat and destroy nursery sites at Bidwell Creek. Multiple agencies and public organizations have contributed to restoration efforts for the protection of aquatic species upstream and downstream from the project site.

Biological Assessment or MND does not address the environmental impact and potential for project-generated sediment to pollute and modify habitat in Bidwell Creek due to the illegal removal of riparian vegetation on the 2 project parcels.

Water Quality impacts to Bidwell Creek from project generated soils could destroy critical habitat and nursery sites if BMPs proposed as mitigation in the Fill Disposition Plan prove to be inadequate or infeasible

under major storm events or with the release of soils from upslope of the cave excavation site. The disposition of up to 23,000 cubic yards of cave spoils over 6.2 acres at 2’ depth at the Riparian Corridor and flooding zone of Bidwell Creek, downslope from a cave exaction site and landslide zone, may be a water quality and habitat-destroying accident waiting to happen. Standard BMPs and the Fill Disposition Plan may not be adequate protection for water quality for downstream water users, species and their habitat with the intense winter storm events that occur with the project’s proximity to Mt. St. Helena. Natural drainage patterns of the sloped site have already been substantially modified. The Biological Assessment and MND do not address the added risk for project-generated sediment and pollutants to enter and modify habitat in Bidwell Creek due to the loss of protective riparian vegetation.

b) Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified local or regional plans, policies, regulations by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service?

The Kjeldsen Biological Assessment is inadequate in determining impacts from the project.
There is no survey, no base-line data or evaluation of Riparian Habitat on the project parcels by Kjeldsen to determine the project’s direct or cumulative impact on biological species. The 2013 Biological Assessment and survey was restricted to a “building footprint.” Kjeldsen’s Subsequent August 19, 2014 letter briefly considers distribution of treated winery waste water to .8 acres of oak woodland. The Biological Assessment is incomplete and excludes where impacts of the project may occur, including Bidwell Creek and Riparian Habitat, downslope of winery construction site. Kjeldsen repeatedly states “this report is not an impact study” yet makes findings in supplemental memoranda that the project will have no impact. Only through information provided by the public did Kjeldsen acknowledge in later memoranda the existence of endangered species and critical habitat at the project site. Kjeldsen never commented on riparian habitat of the site.

The project zoning includes Valley Oak Habitat and the project plans a continuous distribution of treated winery wastewater onto oak woodland bordering Sonoma Land Trust’s Laufenburg Ranch. Kjeldsen provides no studies or data on the biological impact of long-term distribution of treated winery wastewater on native oaks.

c) Have a substantial adverse effect on federally protected wetlands as defined by Section 404 of the Clean Water Act?

The 2013 Kjeldsen Biological Assessment did not acknowledge the existence of springs, seeps or waters of the state on the winery parcel because it was confined to a strict “building footprint” at an already cleared and graded building site. “The “biological” footprint of the project consists of the following elements: Winery/Cave Portal site, temporary cave spoils area future septic field and location of storage tanks.” (Kjeldsen 2013) The Biological Assessment was inadequate to determine the project’s impacts on surface waters at the site.

The Biological Assessment or the MND do not address the potential for project-generated sediment from the sloped site to pollute and modify Bidwell Creek or federally-protected waters of the state due to the illegal removal of protective riparian vegetation on the 2 project parcels.

d) Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites?

Kjeldsen’s (June 21, 2016) finding “The proposed project will not interfere with the movement of any native or migratory fish or wildlife species or with the established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites.” cannot be supported without:

-A Biological Assessment of Bidwell Creek and Riparian Habitat on the project site.
-A Restoration of native vegetation before the up to 23,000 cubic yards of cave spoils are deposited at riparian corridor.
-An Analysis of feasibility and adequacy of standard BMPs to prevent devastating spill of project-generated soils from the sloped project site under major storm events.
-An Impact study to determine effect of groundwater pumping on Bidwell Creek’s summer pools.

The Project’s expanded groundwater pumping may interfere with Bidwell Creek’s retention of summer pools which are native nursery sites for aquatic species. All aquatic species of Bidwell Creek depend on the stream’s summer pools for survival. Salmonids spawn in intermittent streams following increased flow from winter rains. Juveniles survive the summer in dry season pools and later swim to the Russian River and beyond if pools are not drained by wells and stream diversions. Expanded ground water pumping in the Bidwell Creek watershed has already reduced the function of the Russian River tributary to retain adequate summer pools essential for species survival.

Fish biologist Dr. Stacy Li, visited Bidwell Creek at project location where the stream flows onto the neighboring property and submitted a report on the potential impacts to native salmonids from the project. He commented on Bidwell Creek’s aquatic habitat, salmonid species dependence on dry season pools, and the function of riparian vegetation in the health of the stream. His observations of Bidwell Creek at the project site describe the applicant’s evident removal of riparian vegetation on both project parcels, reported in previous public testimony.


b) Would the project cause a substantial adverse change in the significance of an archeological resource?

Construction of the winery access road through both parcels has already damaged a recorded cultural site of the Wappo Tribe, as discovered by Origer (March, 2013). The Northwest Information Center submitted testimony that the damage to resources was avoidable if Sonoma County had complied with policies for the protection of cultural resources in the grading permitting process that were established in the EIR for the Franz Valley Specific Plan

The Franz Valley Area Plan identifies the project site as an Area of High Archeological Sensitivity, emphasizing the frequency of cultural resources near surface water which occurs on both parcels of the Project. New mitigations have been added since the previous revised MND following delayed notification of the tribe for compliance with requirements under Assembly Bill 52.

Mitigation Measure 5.b.1. “Any ground disturbing activities on the project site (including outside of the three known archeological sites and development area) will require monitoring by a qualified archeologist with a representative of the Mishewal-Wappo Tribe of Alexander Valley. This includes any activity that willdisturb soils below the ground surface (including installation of landscaping and gardens), as well as subsurface work such as deep ripping and trenching for irrigation.”

The mitigation is inconsistent with MND (pg 18) comment as to what area will require monitoring: “Since the presence of the existing identified resources, together with the acknowledged density of cultural resources in the Knights Valley area generally, indicate there is potential to uncover additional currently unknown resources, any ground disturbing activities on the entire property (including outside of the three known archeological sites) will require monitoring by a qualified archaeologist with a representative of the Mishewal-Wappo Tribe of Alexander Valley.” Professional assessments used for assessing biological impacts and water quality impacts of the project considered the “project site” to include only the “winery building footprint.”

Project conditions that require a monitor of the Wappo Tribe with “any further land disturbing activities” to mitigate further damage to archeological sites, as occurred with construction of the winery access road, do not appear to apply to protect cultural resources on 120-090-005. This parcel, containing Bidwell Creek, is also a location of high archeological sensitivity in the 1979 Franz Valley Area Plan, where construction of the winery access road from this parcel damaged a recorded archeological site. The MND’s new mitigations and condition to require a monitor of the Wappo Tribe with all further land disturbance do not protect cultural resource impacts to this second parcel from road use, public tours, or land disturbance during or following winery construction.

Summit Engineering recalculations of the “amount of ground disturbance” for the project do not describe the linear trenching projects required for the “Residential Well” water line from the property border across the parcel to the winery site, and possibly the separate trench for the LYVE system treated waste water line across the parcel again to oak woodland at the border of Laufenburg Ranch. These ground disturbance areas were not calculated in the Summit Engineering (2017) newly expanded description of ground disturbance required for the project.

The applicant and consultants have underreported the degree of “development area” from “under 1 acre” as submitted by James Bailey with Use-Permit Application and now the 2.4 acres considered in the MND. 6.2 additional acres, downslope from the winery and cave excavation site, will receive up to 23,000 cubic yards of cave spoils along Bidwell Creek, where other archeological sites are noted to be most likely to occur. The scope and location of ground disturbance required for the project have been underreported or incorrectly established since the submittal of the project application, previously avoiding the requirement of State water quality permits. The applicant proceeded recently with deep ripping and summer replanting of vineyard blocks near Bidwell Creek at the Fill Disposition Area before the Cultural Resource mitigations of this MND were adopted. For this project, compliance with mitigations and project conditions will rely on self-reporting by the applicant, which has been inconsistent with this project.

For mitigation to be effective in protecting further damage to Cultural Resources on these 2 parcels, accurate self-reporting by the applicant, inspection and enforcement by the Lead Agency is necessary. The mitigation and monitoring required for avoiding impacts to Cultural Resources with this project is substantial. The MND does not address the fees for cost recovery by the County for mitigation, monitoring and reporting authorized under CEQA Guidelines Section 21089. Sonoma County’s Mitigation and Monitoring or Reporting Program under AB3180 appears to be unavailable for public review.


The MND acknowledges the inconsistency of geological interpretations of the project site by Bauer, March 29, 2013, Cotton, Shires April 12, 2013 and internal peer review by Michael Dwyer as to the underlying geology of the winery wine cave construction site. Independent expert testimony by geologists Ray Walbaum and Jane Nielson submitted on behalf of the public find that the feasibility and safety of excavation and construction of approximately 17,500 sq. ft. of wine caves at the sloped landslide location has not been established.

a)ii Would the project expose people or structures to potential adverse effects from strong seismic ground shaking?

The MND comments that all of Sonoma Co. is subject to seismic shaking and that seismic events cannot be predicted, but does not address the great frequency of seismic ground shaking that occurs specifically in the project area due to proximity to the Geyers Geothermal Plant. MND does not address the adequacy of the standard California Building Code load and strength standards applied to construction of a subsurface 17,000 sq. ft. winery cave on sloped land of a former landslide where ground shaking is common. The MND does not consider whether the standard seismic and soil test/compaction requirements applied to above ground structures is adequate protection for the risk of injury from seismic shaking for public visitors and full-time employees working in the 17,500 sq. ft. wine cave at this location.

a)iv Would the project expose people or structures to adverse effects from Landslides?

The Project proposes excavation of up to 23,000 cubic yards of soil and rock from a sloped site at an ancient landslide. The MND acknowledges that project consultants and County geologists do not concur on the underlying rock and soil of the building or cave excavation site or the location from which landslide debris originates. All of these should be established in order to demonstrate the project’s safety and feasibility for any structure (or wine cave) where humans would work or visit and where downslope surface waters would receive landslide-released soils and debris. The project location and upslope parcels have had many smaller landslides, evidenced by the landslide debris observed upslope from the cave excavation area by project consultants. Bauer 2013 recommends “diversion/catchment walls” 600-700 sq. ft. area 6 ft. deep to accommodate future debris flows originating from above the construction site. Dynamite blasting and tunneling for the excavation of 17,500 sq.ft. of wine caves into the sloped site present a risk factor for additional landsliding at the site. This risk factor is not addressed in the MND or consultant studies.

h) Would the project expose people or structures to a significant risk of loss, injury, or death involving wildland fires?

The MND considers fire response capability within the winery project, but does not consider the considerable risk of wildland fires of the project area. The State Very High Fire Hazard Severity Zone is also an area of limited groundwater availability.

The project includes fire protection features and on-site water storage to respond to fires occurring at the winery, but local residents and structures outside the winery are at significant risk of property fires and spread of wildland fires in the dry season due to reduced water supply in the high fire risk zone. The project will increase groundwater demand in a drainage basin already experiencing significantly lower well yields. Local wells, directly downstream in groundwater flow from the project, have shown lowered yield and have reduced water supply following the addition of multiple new wells pumping from the project parcels. The project parcels pump more local groundwater than any other water users in the consultant-designated Cumulative Impact Area.

The project parcels’ Total Water Use and contribution to lowered ground water levels in the vicinity may affect local residents’ ability to respond to fire when all are pumping groundwater at the same time. New groundwater demands on a local area already grappling with reduced groundwater supply may increase the risk of loss, injury or death from wildland fire. The sufficiency of local water supply for residents for and the Knights Valley Volunteer Fire Department, downstream neighbor to the project, must be established to assess this risk exposure with the project.


a) Would the project violate any water quality standards or waste discharge requirements?

Substantial storm water management is required for the sloped site where landsliding is possible and up to 23,000 cubic yards of cave spoils will be excavated. An incremental or accidental spill of project generated soils would far exceed water quality standards. All of the Russian River Watershed, included tributary Bidwell Creek, is listed by the Regional Water Quality Control Board as 303(d) impaired due to excess sedimentation/siltation and temperature. The 2004 Maacama Watershed Assessment and 2015 Maacama and Upper Mark West Creek Integrated Watershed Management Plan cite the density of rural roads and stormwater runoff of disturbed soils from agricultural cultivation as the greatest contributors to reduced surface water quality specifically in the Bidwell Creek Subbasin. Water quality impacts would occur from increased vehicular use of the Winery Access Road on BOTH PROJECT PARCELS where vineyard silt, eroded soils, and pollutants are washed into Bidwell Creek. Study of the impact, site specific mitigation and monitoring are not in the environmental document.

 winewaterwatch.orgb) Would the substantially deplete groundwater supplies or interfere substantially with local groundwater recharge such that there would be a net deficit in aquifer volume or lowering of groundwater table level?

Residents directly downstream in the watershed have reported lowered groundwater levels after the applicant’s expansion of groundwater pumping in 2012. The winery project’s “Residential Well” was tested for adequacy to serve its multiple uses in addition to the future winery one time in 2012. Yield testing in the dry season was NOT done. The well was tested before 2 residences (one of at least 10,000 sq. ft.) on the parcel began drawing from the same well. Slade has performed no new well performance data or tests for interference with other wells since the original single test in 2012, prior to the Use-Permit application. DWR Well Completion Report states “Initial yield is not representative of long-term yield.” Calculations for individual well performance and anticipated yield are not provided. ADD SUMMIT LETTER AND REFERENCE

All consultant determinations for adequate ground water for the project and adequate ground water recharge at the site have been based on assumptions and non-comparative data (Napa River locations) that have not been established for the project or the project wells.

Riparian wells #5 (owner Knights Bridge LLC) and #6 (owner Serendip LLC) on partner parcel 120-090- 005 convey well water to vineyard blocks on the winery parcel. Slade 2013’s Total Water Use figures of project site omit consideration of parcel 120-090-005, underestimating Total Existing Groundwater Demand. The need for 2 wells from the partner parcel to irrigate vineyard on the winery parcel put into question that parcel’s ability to meet existing groundwater demand. (The Geotechnical Investigation March 29, 2013 by Bauer includes the Well Completion Reports of 9 wells on the 2 parcels. Only 3 wells of Knights Bridge Estates are considered for estimating the pre-project Existing Groundwater Demand.

National Marine Fisheries Service and Hydologist Greg Kammon find that the project’s water use and additional GW pumping for the project may impact local ground water levels and Bidwell Creek’s water supply in the critical dry season. Hydrology Peer Review (OEI May, 2017) finds that pumping from the Project Well is expected to perturb local hydraulic gradients in the aquifer and will have some effect on groundwater down- gradient from the well nearer to Bidwell Creek.

RE: Groundwater Recharge Interference FRANZ VALLEY AREA PLAN 5.35 Groundwater Recharge Areas
In addition to the valley recharge in the alluvial soils and the stream gravel of Franz and Knights Valley,

the more permeable and fractured areas in the Sonoma Volcanics are of major importance for groundwater recharge. Construction activities, changes in drainage, and impervious surfaces should be avoided or minimized with these areas.

2013 Hydrolgeologic Assessment makes assumptions on the adequacy of future water available for ground and surface water recharge without consideration of changing climate and the demonstrated trend of longer and more frequent drought.

c) Would the project substantially alter the existing drainage pattern of the site or area in a manner which would result in substantial erosion or siltation on or off site?

Franz Valley Area Plan states that changes to natural drainage patterns and construction in Sonoma Volcanic should be avoided where they may be important for ground water recharge. There have been substantial changes to the natural drainage of the sloped parcel made in advance of the winery project. The water quality impacts from those changes and from new alterations required to manage storm water with the project have not been evaluated for their cumulative impacts on surface waters.

f) Would the project otherwise substantially degrade water quality?

Hydrologist Greg Kamman reported on the potential for mercury contamination to surface waters from up to 23,000 cubic yards of soil that will be excavated and distributed over 6.2 acres along the Riparian Corridor of Bidwell Creek downslope from the cave construction site. The peer review (OEI 2017) discounted this human health and water quality concern stating that spread of mercury contamination from the project would not occur due to the distance of the closest mine and its location in “a different watershed.”

Bidwell Creek Subbasin is bordered by YellowJacket Creek (Kellogg Creek Subbasin) whose waters are diverted to reservoirs in the Bidwell Creek Basin upstream from the project site. Yellowjacket Creek was used for processing with ore taken from the historic YellowJacket Mine upstream in the watershed. NCRWQCB commented previously on the project area as “a historically mined, mercury laded area which when disturbed could pose a hazard for human and aquatic life. The Regional Water Board implements monitoring programs which continuously reveal unknown sources of mercury in the watershed.” (John Short letter re: Pelton House Winery, Oct. 14, 2008) Soil composition must be established before distributing up to 23,000 cubic yards of excavated cave spoils with unknown mineral content along a Russian River tributary. The Sonoma Water Agency provides drinking water to the largest cities of Sonoma County, 90% of it coming from the Russian River.


Franz Valley Area Plan
The local Area Plan, an enforceable planning document for the review of discretionary projects and

part of the County’s General Plan, has been applied to the review of this project in name only. The project is within the Resource Conservation Area and Class 3 Marginal Ground Water Availability Area designated in the Franz Valley Area Specific Plan (EIR certified April 17, 1979, Resolution #63601). The Visual, Cultural and Resource Conservation protections of the Franz Area Plan are not considered in the MND.

Franz Valley Specific Plan: 5.36 Resource Conservation Areas
“Despite the remoteness and appearance of wildness of the majority of the Franz Valley study area, no portion remains unaffected by recent human utilization. However, relative to other areas of Sonoma County, the area remains of major importance an area of resource conservation.

Large blocks of lands of limited access and marginal economic productivity are extremely important for maintaining and building soil, recharging groundwater, producing oxygen and consuming carbon dioxide, moderating climate, and sustaining biological diversity and genetic adaptability to future change. An additional human benefit resulting from resource conservation areas is the preservation of some of the County for tranquility, the freedom from urban noise and congestion necessary for spiritual growth and artistic exploration. Scientific and educational uses of these areas depend on the protection and enhancement of these often overlooked resource conservation values in rural areas.”

General Plan Inconsistency
Water Resource Element of the General Plan and the Mandatory GP Policy WR-2e. Section 15-17q, Section 25- 56c, and Section 7-12 of the County Code: “Deny discretionary applications in Class 3 and 4 water areas unless a hydrogeologic report establishes that groundwater quality and quantity are adequate and will not be adversely impacted by the cumulative amount of development and uses allowed in the area, so that the proposed use will not cause or exacerbate an overdraft condition in a groundwater basin or subbasin.”

Applicant consultant Slade did not complete the General Plan WR-2e requirements for “Procedures for Groundwater Analysis and Hydrogeologic Reports (No. 8-1-14)” or obtain the local data for WR-2e Compliance Checklist # 9, 10, 11, 12, 13, and 21 as requested by Jon Tracy, R.E.H.S January 22, 2014 to Project Review planner Sigrid Swedenborg. (Slade ADDENDUM March 6, 2014 to Plans4Wine does not comply with required procedures.)

The 2013 Hydrogeologic Assessment (Slade2013) did not consider or provide any local data on impacts to interconnected surface waters and aquatic habitat. Biological Assessment (Kjeldsen2013) did not survey the project parcels to determine the presence of aquatic habitat, springs or seeps that may be impacted by the project.

Approval of commercial land use in the land extensive agricultural zone would conflict with the goals and policies of the Franz Valley Area Plan for preserving land and resources for productive agriculture and conservation and restricting commercial development in the agricultural zone.

Approval of a Use Permit for a 17,500 sq. ft. commercial winery building, 5,500 sq. ft. wine cave and public tasting destination in the Land-Extensive Agricultural Zone would be a growth-inducing and cumulative impact for the planning area. GP2020 Policy LU-1a “In any case where there appears to be a conflict between the General Plan any Specific or Area Plan, the more restrictive shall apply.”


b) Would the project expose persons to the generation of ground borne vibration or ground borne noise levels?
d) A substantial temporary or periodic increase in ambient noise levels in the project vicinity above levels existing without the project?

The MND states “Sonoma County has no noise standards for construction in its General Plan or County Code.” This does not exclude the need to consider noise impacts and provision of mitigation for excessive noise for humans and nesting species in the project vicinity. Tunneling methods and noise produced are not addressed. All noise, including construction noise, is amplified and echoed in the narrow southern area of the Knights Valley.


The Focused Traffic Study for Knights Bridge Winery 2013 is flawed and incomplete because it does not consider the roadways over which most visitors and employees would access the project. The study considered traffic only originating from Napa Valley and State Hwy. 128. The study does not consider the most traveled and common access for reaching the project location (from Hwy. 101 and Santa Rosa via Franz Valley) where the greater number of visitors or employees would be assumed to travel.

d) Would the project increase hazards due to sharp curves or dangerous intersections or incompatible uses?

The County should consider the project’s traffic safety impacts from increasing travel to and from wine tasting and the sightline deficiencies, inherent hazards, and unmaintained condition of the winding Franz Valley Rd.

e) Conflict with adopted policies, plans, or programs regarding public transit, bicycle, or pedestrian facilities, or otherwise decrease the performance of safety of such faculties?

The County should consider the conflicts occurring with the Traffic Study’s estimated 30% increase in vehicular traffic on Spencer Lane on the designated Bicycle Routes of the Franz Valley Area Plan.


On-site Wastewater Treatment System

Kjeldsen and the MND describe the LYVE Winery Waste Water System but do did not provide any data on the biological safety of the system or appropriateness of the distribution area. The biological effect of permanently releasing treated wastewater on .8 acres of oak woodland has not been studied. To determine the environmental impact of this on-site treated wastewater distribution system, the reasons as to why the chemical composition or quality of this water is non-damaging to native oaks but cannot be used to irrigate grapevines should be explained.

Native oaks have adapted to low or no rainfall in the dry season and are subject to fungal diseases, death or decline with summer irrigation. Kjeldsen gives one example of the LYVE system being used in Napa County and provides no studies or data on the safety of long-term distribution of treated winery wastewater on native oaks. No consideration has been done on animal-caused destruction of above groundwater lines and potential leaks or release of larger quantities of treated waste water at the sloped site draining to Bidwell Creek. In the dry season, thirsty animals commonly chew apart irrigation water lines in the vineyards of Knights Valley. Mitigation for system failures and resultant soil erosion should be considered for the wastewater dispersal area draining to Bidwell Creek.


a) Does the project have the potential to degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant of animal community, reduce the number or restrict the range of rare or endangered plant of animal or eliminate examples of major periods of California history or prehistory?

The project has the potential to further reduce Bidwell Creek’s dry season water supply, degrade and reduce the habitat for endangered coho salmon, steelhead trout, Ca. fresh water shrimp and native riparian species, and eliminate examples of a major period of California prehistory and Wappo Culture.

b) Does the project have impacts that are individually limited, but cumulatively considerable?

The project’s impacts from groundwater pumping on Bidwell Creek, its water supply for summer pools which are critical habitat for the survival and reproduction of species, may be individually limited, but cumulatively considerable in the Maacama Creek Watershed.

The project’s expanded groundwater extraction may be a cumulatively considerable impact on local ground water supply in the Class 3 Marginal Groundwater Availability Zone of the Bidwell Creek Subbasin and for the Russian River system with the longer and more frequent droughts projected due to climate change.

Based on the public and expert testimony submitted before you, the Maacama Watershed Alliance asks that Sonoma County require an Environmental Impact Report for Knights Bridge Winery to Include impacts on Aesthetics, Biological Resources, Cultural Resources, Geology and Soils, Wildfire Hazard, Hydrology, Land-Use, Noise, and Traffic Safety.

Respectfully submitted,

Craig Enyart
Maacama Watershed Alliance

-SUMMIT ENGINEERING “Knights Bridge Winery Well Demand Reduction Through Re–use” May 23, 2016 (Proposes winery water demand could potentially be reduced to approximately 0.5 acre-feet/year (afy.) – General Plan Policy WR-2e Compliance Checklist and Procedures for Hydrogeologic Reports (Missing data) -Letter from Jon Tracy, REHS Project Review Section asking for missing data. Jan. 22, 2014
-Response from consultant RCS to Donna Olford Plans4Wine, March 6, 2014 (public file)

Maacama Watershed Alliance


Categories: Food and Farming

Sonoma County supervisors to weigh disputed Knights Valley winery proposal, Tuesday Aug. 22nd 2:10pm BoS chambers

Sun, 08/20/2017 - 12:20
Last year in openly advertised and reported in the Press Democrat, an unpermitted event was held at Knight’s Bridge Winery with  local government dignitaries attending the function at the winery. Some of the same attendees (supervisors) will be voting on approval or rejection of this intensive water sucking project. They should be recusing themselves to show they are fair and unbiased. For so long in our county and Napa, the wine industry has called the shots. The Supervisors knowingly allow water intensive projects like this into water scarce areas and the residents pay for it in low water quality (from the millions of tons of pesticides used) which in turn pollutes our air and soil. With that sucking noise, water deliveries to areas once with no problems by the end of summer are now required.   In this case, the residents have been faithfully monitoring their wells, some for up to 8 years and showing the impacts of the smaller version of this big wine project, have greatly diminished their water, some critically, not to mention the habitat destruction for coho and native wildlife. The county refuses to acknowledge the monitoring because it doesn’t fit with their “one size fits all’ stamp of approval for large winery owners.   Remember the Bella Winery in Healdsburg permit for added production/events where PRMD told the winery owners to go back and redo the traffic study during low traffic periods so they could approve the permit? Where is the difference here when water studies by paid contractors (was peer reviewed but where is the total figures for all seasons of monitoring?) are used to permit huge water withdrawals in a water scarce area that the county even recognizes is WATER SCARCE? In 1970, before water irrigation began Sonoma County had 12,597 acres planted with an average of 2.37 tons per acre and cost about $250 a ton. By 2014,  62,650 acres with an average of 4.39 tons per acre and some types of grapes getting close to $4,500 a ton (Sonoma County Ag Commission Crop Reports). That’s your water, their profit.  Oh and thanks wine industry for making us tied for #3 in childhood cancers, low wage industry that causes families to move away from each other due to the high cost your wine/tourism industry has brought on us, loss of so much that we hold dear…! It’s time for the supervisors to show backbone and either recuse themselves from this vote or vote to NOT approve this effrontery to the community.   To be fair to the residents and business owners, all reports for permits that require resource extraction, MUST be done high and low seasons so the truth is known and can make wise, science based judgement for the decision making process. Many organizations have been calling for a county wide EIR on cumulative impacts so we all know the costs to our community. We need this NOW before anything else is approved, period.  PLEASE email your supervisor now and let them know how yo feel. planner supporting approval:

Supervisors email: ; ; ; ;

Sonoma County supervisors to weigh disputed Knights Valley winery proposal J.D. MORRIS | Updated 12 hours ago.

A 10,000-case winery long planned in Knights Valley faces a crucial and possibly controversial vote this week from Sonoma County supervisors, reviving a yearslong public debate about the role of winemaking in the picturesque area northwest of Calistoga.

Slated for a more than 86-acre site about 1 mile west of Highway 128, the proposed Knights Bridge Winery has been several years in the making already, but it has been met with fierce opposition from an organized group of local residents whose objections previously thwarted two other winery projects.

Those residents, joined by another neighborhood group, appealed planning officials’ 2015 approval of the Knights Bridge project, and the matter is now up for consideration Tuesday by the Board of Supervisors.

At stake is whether Knights Valley, a pristine grape- growing region dividing a corner of northern Sonoma County from Napa Valley, will get its second winery, or whether local concerns about the potential strain on precious groundwater supplies and other issues will prevail.

Neighbors say the county has failed to appropriately study the possible impacts of the winery, and they want to see an exhaustive environmental analysis completed before the project moves forward.

Knights Bridge Vineyards co-founder Jim Bailey has sought to assuage neighbors’ concerns, telling them in a letter earlier this summer that the winery he plans won’t be visible from “any public road.”

“I purchased our Knights Valley property for the same reason as most of you, for the quiet, agricultural nature, and this winery does not intend to change that,” Bailey wrote. “I think we all share the same concerns, whether it’s water, traffic, or whatever, and we honestly feel that we have done our best to address them and put the best and most careful plan in place.”

Bailey could not be reached for comment last week. The Knights Bridge brand is currently based in Calistoga.

The site off Spencer Lane includes about 43 acres of vineyards, mostly cabernet sauvignon, chardonnay and sauvignon blanc grapes, according to county planner Georgia McDaniel. The property also includes two residences: a 10-bedroom, 10-bath mansion as well as a smaller residence, McDaniel said.

Bailey and his team want to develop a 5,500-square-foot winery building and about 17,730 square feet of wine caves, among other additions. The winery would produce a maximum 10,400 cases per year, and tasting would occur by appointment only, with visitors capped at no more than 13 people per day. The winery would not be allowed to host any events. The Maacama Watershed Alliance, a Knights Valley environmental group, says the project demands a deeper study of its potential effects on groundwater, already a scarce resource in the area.

While the applicant did commission a groundwater analysis — which was subsequently peer reviewed — critics are seeking a full-blown environmental impact report that would entail a much more thorough and expensive review of the project.

That review is required for such a project under the California Environmental Quality Act, or CEQQ, opponents claim.

“We don’t oppose wineries or winery projects or the winery industry, but you can’t circumvent CEQA and approve these without proper review,” said Craig Enyart, a spokesperson for the watershed alliance.

McDaniel said county officials have so far decided an environmental impact report was not necessary because the project’s potential impacts can be offset to “less than significant” levels.

The county zoning board in September 2015 approved a use permit for the Knights Bridge project on a 4-0 vote, prompting the Maacama Watershed Alliance and a group called the Friends of Spencer Lane to file an appeal.

Supervisors were supposed to consider the appeal last year, but the hearing was delayed so staff could consult with the Mishewal Wappo Tribe of Alexander Valley about cultural resources on the site. County staff also had the project’s groundwater study peer reviewed at the time.

Neighbors remain skeptical about how the winery would affect groundwater levels in the area.

“The view is, it’s an extra demand on water that isn’t necessary,” said John Campbell, a spokesperson for Friends of Spencer Lane. “Locating the winery in Knights Valley imposes a burden of risk on other neighbors. It risks their water supply.”

The Maacama Watershed Alliance has opposed two other Knights Valley winery proposals before, including a 5,000-case plan put forward about a decade ago by billionaire vintner Jess Jackson. The Board of Supervisors in 2009 approved Jackson’s proposal on a 4-1 vote, but the watershed alliance sued and a Sonoma County judge ruled in 2010 that the development would need an environmental impact report to proceed. Jackson shelved the project.

In the second proposal, Gerhard Reisacher wanted to build a 12,000-case winery in the valley and also encountered stiff resistance from the watershed alliance, which called for an environmental impact report. Reisacher put the proposal on hold indefinitely before supervisors made a decision.

Supervisor Shirlee Zane, then in her first year on the board, was the lone dissenting vote in 2009 against Jackson’s proposal. Zane, the board chairwoman, said that vote would have no bearing on her decision-making for the latest Knights Valley proposal, which she said she was reviewing in “hundreds of pages” of documents and through meetings with stakeholders on both sides.

Still, she indicated groundwater impacts would be a focus of her attention.

“The water issues are always paramount,” Zane said. “That’s one of the biggest things that we have to look at in any type of winery application.”

If supervisors approve the proposal without requiring an environmental impact report, Enyart indicated critics may again take legal action.

“We’re willing to go to the mat on this one and take it all the way back to Superior Court if we have to,” he said.

You can reach Staff Writer J.D. Morris at 707-521-5337 or On Twitter @thejdmorris.

Categories: Food and Farming

County to decide winery’s fate

Wed, 08/16/2017 - 09:27

Neighbors have been monitoring their wells before the new wells went in and have documented the major decrease of groundwater resources which the county has not acknowledged. Once again the wine industry trumps the residents. Was the water monitoring in the reports produced for Knights Bridge owners done during low flow? Our county is notorious for allowing these studies on water and traffic flows to be done at low peak times. Maybe it’s time to require low and high flow studies on all such “reports” by paid consultants?

Wine & Water Watch has been advocating for a cumulative impact study to be done for the entire industry in this county for years. Should such a study be done, we are sure it will show such massive impacts to water, air, soil, our health and our quality of life that the big wine juggernaut would get a black eye. The tide has turned and we are all waking up to the price our families and communities bear for big wine’s profits.

County to decide winery’s fate

By Amie Windsor, Staff Writer,

Environmental groups oppose Knights Valley project

A controversial project for a winery in Knights Valley will return to the Board of Supervisors on Tuesday for a public hearing on an appeal submitted by community and environmental groups concerned with the project’s potential to drain precious and limited water resources in the area.

The project is for Knights Bridge Vineyards, which proposes a 5,500 square-foot winery and 17,500 square-foot wine cave to be located near Calistoga in the drainage basin of Bidwell Creek, a tributary to the Russian River. The winery would produce a little more than 10,000 cases of wine annually. Tastings would be allowed for up to 13 people per day by appointment. Events would not be permitted.

The project received initial support and approval by the county’s board of zoning adjustments in September 2015. Just days after the approval, the Maacama Watershed Alliance (MWA) and Friends of Spencer Lane submitted an appeal to the county board of supervisors, stating the project could potentially harm the local water supply and environment.

The Board of Supervisors was set to hear the appeal last November but had to reschedule the public hearing. On Nov. 16, the county invited the Mishewal-Wappo Tribe of the Alexander Valley to consult and participate in the environmental review for the project.

With the help of Kamman Hydrology and Engineering, the MWA and Friends groups have submitted independent studies and analyses on the potential impacts of natural resources from the winery.

“We all question the assumptions of the developer’s consultants,” said Craig Enyart, spokesperson for the watershed protection group.

The consultants include Summit Engineering, Kjeldsen Biological Consulting and Richard C. Slade and Associates; all consultants responded to issues raised by the environmental protection groups.

One of the major issues brought up in the appeal include the impact the winery could have on neighboring wells. MWA stated that neighbors who live adjacent to the Calistoga-area winery already report lower yields and water table to the county’s permit resource management department (PRMD) after the winery added six new wells in 2011. They were concerned the new winery would further erode water availability.

The National Marine Fisheries Service chimed in, stating that groundwater pumping may affect Bidwell Creek. The tributary, according to NMFS, is home to freshwater shrimp, Coho salmon and steelhead, all which are endangered or threatened at the state or federal level. 

“Groundwater pumping has reduced the stream’s dry-season pools necessary for survival of the species,” Enyart said in a press release.

According to the July 2017 environmental review, the area’s groundwater basin is not designated by the county’s department of water of resources as high or medium priority; it is a low priority and not subject to the provisions of the new sustainable groundwater management act, which requires tightened management of groundwater basins at the local level. Nevertheless, after the appeal and ensuing new studies, the environmental review required revised mitigation measures to reduce the project’s estimated net water demand. The revisions were not considered substantial but merely clarified the points made in the original environmental review.

Other issues brought up by both the environmental groups and within the mitigated negative declaration include impacts to biological resources, cultural resources, geology and soils and air quality. As such, mitigation efforts that must be followed are outlined to prevent such issues as soil erosion, landslides, air pollution, archaeological disturbance or habitat destruction.

Vineyards aren’t new to the Knights Valley area. More than 100 years ago, wine grapes were the area’s most planted crop, paving way for some of the area’s most famous wineries, including Chateau Montelena, Beaulieu Vineyards and Beringer. Today, there are more than 2,000 vineyard acres in Knights Valley, which produce multiple varietals, including cabernet sauvignon, Bordeaux, chardonnay, syrah and sauvignon blanc.

Categories: Food and Farming

Environmentalists say proposed cannabis grow rules fail to protect wildlife

Sun, 08/13/2017 - 09:13
Last week neighbors banded together to red tag 2 illegal grows in Sonoma county after it was discovered out of state buyers had graded land and moved the soil into a local creek. The creek had been going through years of restoration work by the locals, destroyed in one fell swoop.

Environmentalists say proposed cannabis grow rules fail to protect wildlife GUY KOVNER

Four environmental groups have faulted proposed state rules for commercial cannabis cultivation for failing to protect imperiled species, including the reclusive Pacific fisher, from rodent poison frequently used at unregulated grow sites.

The Center for Biological Diversity, a national conservation nonprofit, and three allies filed a 36-page comment alleging numerous shortcomings in the California Department of Food and Agriculture’s draft report on the proposed standards for growing legal marijuana.

In particular, the groups said, the standards fail to protect wildlife — fishers, foxes, eagles, owls, bobcats, raccoons and others — from harm that comes from eating poisons or rodents killed by toxins.

Federal and state regulators, as well as University of California researchers, have documented the impact on wildlife from the rodent poisons dispersed at illegal pot gardens to prevent damage to plants and irrigation lines.

“We can’t allow the expanding pot industry to snuff out imperiled wildlife like Pacific fishers,” said Jonathan Evans, environmental health legal director for the center.

The proposed standards represent “a real lost opportunity” for California to be a national leader in setting appropriate rules for cannabis cultivation, he said.

The state department’s 484-page report asserted that “adverse effects on wildlife due to rodenticide use” are “less than significant” and therefore require no mitigation measures under state environmental law.

 The report cited guidance from the state Department of Pesticide Regulation in suggesting that capsicum oleoresin, the active ingredient that makes chili peppers hot, and other nontoxic repellents be used around marijuana plants instead of rodent poison.

But that stops short of a prohibition on the use of poisons that Evans said are readily available at farm, feed and hardware stores.

“The best thing to do is to be explicit about what you are prohibiting,” he said.

A Pesticide Regulation memo in 2013 noted the U.S. Forest Service had cleaned up 335 illegal marijuana grow sites in California’s national forests, removing 300 pounds of pesticides, including rodent killers. It also said more than 200,000 pounds of rodent poison containing blood thinners were sold or used in California each year from 2006 to 2010. The memo concluded that rodent killers “present a hazard” to wildlife. The fisher, a relative of weasels and otters, is about the size of a large house cat with short legs and a long bushy tail.

Despite its name, the fisher neither eats fish nor lives by the ocean. Its California population, estimated between 630 to 1,200, ranges from Mendocino County to the Oregon border on the North Coast and in the Sierra Nevada.

Hezekiah Allen, executive director of the California Growers Association, said in an email there is no reason to use rodent poison in cannabis cultivation, noting that growers in his group have been operating without if “for generations.”

The fatal impact on wildlife, he said, is primarily associated with “criminal grows” on public lands or trespassing on private property.

“Unfortunately these growers are not likely to respond to regulations as they have no intention of complying with requirements or moving into the regulated system,” Allen said.

Law enforcement should crack down on pot crops on public lands, and groups like the center should educate cannabis consumers about “the cost of buying unregulated product,” including “significant harm to natural resources,” he said.

The environmental groups’ comment challenged other portions of the state report, including the assertion that legalization will move cultivation within the law without expanding the size of the crop.

Disputing the claim of an essentially stagnant industry, the comment noted that marijuana acreage in the Emerald Triangle doubled following the move in 2010 to reduce possession of an ounce of pot from a misdemeanor to an infraction, similar to a traffic ticket.

The public comment period on the Food and Agriculture Department’s proposed cannabis cultivation rules ended July 31.

Steve Lyle, a department spokesman, declined to comment on the center’s criticism regarding rodent poison. The agency is now reviewing all comments, as required by state environmental law, and each one will “receive a response” in the final report, he said in an email.

Joining the Center for Biological Diversity in its comment were three other nonprofits: the Environmental Protection Information Center in Arcata, Sequoia Forestkeeper, a defender of Sequoia National Forest in Kern County, and Preserve Wild Santee, a San Diego County conservation group.

Categories: Food and Farming


Thu, 08/10/2017 - 10:43
Wine & Water Watch supports the efforts of the Maacama Watershed Alliance and Friends of Spencer Lane in their efforts to save their watershed and quality of life of their neighborhoods. Big wine continues the unsustainable march into groundwater depletion, habitat destruction and damage to precious archaeological treasures. Unpermitted events, working on the land before permits are approved shows distain to their neighbors and leaves a black eye on the industry. We urge your support at the hearing and/or writing letters to stop this ill conceived project that will impact the area and leave property owners high and dry. This needs a thorough review (unbiased, peer reviewed)of impacts conducted at times of lowest water levels to determine the truth of the situation. APPEAL OF CONTROVERSIAL KNIGHTS VALLEY WINERY BACK TO SONOMA COUNTY SUPERVISORS

Knights Valley, Sonoma County, CA – August 9, 2017


Over 9 months ago, an Appeal Public Hearing for the Knights Bridge Winery Use-Permit was canceled at the 11th hour by Sonoma County Counsel and did not take place.  A continuance was ordered after the Maacama Watershed Alliance and Knights Valley residents submitted letters to the Board of Supervisors on the impacts from the project’s groundwater pumping on downstream wells, Bidwell Creek, endangered salmonid habitat, and further damage to archeological resources at the site.


The Board of Supervisors, now the decision-makers on this project, will hear the appeal by Maacama Watershed Alliance and Friends of Spencer Lane in a Public Hearing, Tuesday August 22, 2017 at 2:10 PM


The Knights Bridge Winery project is proposed in the drainage basin of Bidwell Creek, tributary to the Russian River, in the county’s Marginal Groundwater Availability Zone.  This area of N.E. Sonoma County is a Very High Fire Hazard Severity Zone.  Adjacent to Knights Bridge Estates, neighbors repeatedly reported lower yields and water table to the County’s Permit and Resource Management Department.  The Board of Zoning Adjustments approved the project exceeding a water use threshold for water scarce areas despite Project consultants’ failure to contact neighboring well owners and well drillers or comply with General Plan Policy Guidelines.


Maacama Watershed Alliance (MWA), residents, farmers and ranchers of Knights Valley, and other public interest groups and government agencies have submitted studies and independent analysis on the potential impacts to natural resources from Knights Bridge Winery. “All question the assumptions of the developer’s consultants,” reported Craig Enyart, spokesperson for the watershed protection group.


The National Marine Fisheries Service and a county-ordered Peer Review of the project’s 2013 Hydrogeological Assessment found that groundwater pumping for the project may affect Bidwell Creek.  The Russian River tributary is home to State Endangered California freshwater shrimp, State and federally Endangered Central California Coast (CCC) coho salmon and federally Threatened steelhead.  Groundwater pumping has reduced the streams’ dry-season pools necessary for survival of species.


Land-use violations have occurred on the project’s properties before approval of the Use Permit.  Among these are riparian habitat removal, holding unpermitted industry events and wine tasting at the Knights Bridge Estates’ partner parcel which includes the 20’ public access road.  This parcel, excluded from the County’s environmental review, also provides water from 2 riparian wells to meet demands of winery parcel.  Whereas previous owners had farmed the same acreage on 3 existing wells, Knights Bridge Estates added 6 new wells since 2011.


Sonoma County’s ability to manage its limited groundwater supply and all vulnerable natural resources is determined by its decisions in land-use permitting.  It is only discretionary permits, like this winery Use-Permit, that legally require environmental review.  The Maacama Watershed Alliance thanks all the citizen groups and individuals, including growers in the wine industry, and agencies responsible for resource protection, who have submitted comments on the need for greater review of winery development impacts. The public continues to focus its efforts on demonstrating to their representatives that an Environmental Impact Report to study impacts is essential for this discretionary project. 


Public Comment is needed until the Aug. 22nd Public Hearing.  Written comment can be directed to the Sonoma County Board of Supervisors, the decision-makers on the Project at , and to Project Planner   Re: Knights Bridge Winery UPE13-0046

For information contact MWA P.O. Box 1226 Calistoga, CA 415-385-2385-direct

Categories: Food and Farming