To: The Sonoma County Board of Supervisors
From: The Western Sonoma County Rural Alliance

Western Sonoma County Rural Alliance (WSCRA) appreciates the opportunity to comment on the current Draft of the Vineyard Development Ordinance for Sonoma County and are concerned that the public comment period was less than 30 days.

WSCRA recommends the Board of Supervisors instruct staff to incorporate almost all of the ten recommendations provided by the Office of the Sonoma County Council(SCC) dated April 8, 1999 into the final version of the Vineyard Develoment Ordinance. The SCC letter incorporated information provided by the California Department of Fish and Game, the National Marine Fisheries Service, the Natural Resources Conservation Service and the Southern Sonomy County Resource Conservation Distirct. WSCRA has used this letter to organize our analysis and recommendations for several of the key issues including;

1. Elimination of the distinction between previous land use as a means for establishing conservation guidlines. WSCRA is concerned that an Ordinance that excludes existing vineyards from improved managment guidlines would provide unfair advantage to established vineyards and allow some existing problems to continue unchecked. At the very least, existing vineyards should be visited to identify existing problems and all vineyards should be required to protect soils from erosion during the winter.

2. Replace four tier regulatory approach. WSCRA agrees that all projects should be subjected to on site review and that the response period should be at least 45 days due to the many issues that need to be addressed. Furthermore, the entire concept of slope averaging is seriously flawed. The method for averaging slopes should be much more conservative and limited to averaging within sub-drainages. To allow vineyard development on less than 50% slopes is to promote "resculpting" of the natural topography of the land. This process destroys existing drainage areas at the headwaters of blue line streams. The elimination of these "ephemeral" or Class Three streams will eliminate wildlife habitat,contribute greater sediment loads and increase the magnitude and frequency of flooding downstream.

3. Expand the definition of designated streams: The definition of protected streams should be based upon analysis of aerial photographs by NRCS and DFG. In addition, the recontouring of hills should not be allowed unless thorough hydrologic analysis can verify that the work will not destroy the sub-surface drainage patterns that allow perched aquifers to drain slowly into the stream channels after the winter storms have passed. This will be particularly important in Western Sonoma County where ground-water supplies are extremly limited and intact riparian ecosystems still support native salmonids, California Freshwater Shrimp, Western Pond Turtles and a wide variety of mammals and birds that depend upon healthy riparian corridors.

4. Replace two tier riparian setback requirements: WSCRA recommends a 50 foot setback for all streams. A riparian buffer strip on all streams throughout Sonoma County would greatly reduce sedimentation in streams, maintain cooler water temperatures essential for fish and other aquatic organisms and provide wildlife corridors to maintain the rich variety of animals that have managed to survive in Rural Sonoma County. A simple ruling of this type would provide enormous protection and eliminate the need to develope separate strategies to address each of these issues in a piecmeal fashion.

5. Establishing and appeal board is an excellent idea. The policy for selection and replacement of these experts needs to be carefully developed. There is always some bias in a process such as this and we encourage the selection of qualified individuals who will place long-term sustainability of nature above the immediate financial gain of the industry.

WSCRA concurs with County Council on all aspects of Recommendations 6 through 8.
With regard to 9 Revise erosion plan requirements, we would like to point out that we have seen no reference to the Gold Ridge Resource Conservation District which administers the the region west of the Laguna de Santa Rosa and south of the Russian River. As you know, this area includes coastal woodlands and grasslands on highly erodible soils in a water poor area. Despite these conditions, a relativly pristine and unique coastal ecosystem survives. Naturally, we are very concerned that this area be protected from rampent vineyard development that would destroy the habitat of a wide variety of plants and animals and threaten the water supply of existing residents. Therefore, we question the validity of the County council's tenth recommendation to provide a Categorical Exemption to CEQA? CEQA provides one of the few mechanisms for scientific evaluation of conditions at specific sites. Through this process, we have the opportunity to exchange current information about conditions at a specific site. This process can then be reviewed so that we can learn from the past and improve managment of our dwindling natural resources.

In closing, we would like to acknowledge the hard work and cooperation that is evident in this draft Ordinance and encourage all concerned, to continue to work on improving vineyard management guidlines in the years to come.

Thank you for your consideration.

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