Draft Regional Climate Action and Adaptation Plan

I head the Solid Waste/Recycling (SWR) division for the City of Napa. The basic draft RCAAP plan for SW measures are fine at a high level but I think it might be a good idea to documents policies and programs already in place for jurisdictions in Napa County. For the City of Napa, three specific policies and/or programs may be of particular note. First, the Disposal Reduction Policy (Council Resolution R2012-100) was adopted in 2012 and set a City target goal of 75% (or higher) for reduction of landfill disposal. Second, the City adopted a very ambitious Construction & Demolition Debris Recycling Ordinance in 2010 (O2010-18) that requires a minimum level of 50% recycling (without any credit for Alternative Daily Cover - or ADC - at landfills) that is more stringent that the current Statewide CalRecycle requirement of 65% (that provides full "diversion" credit for ADC application at landfills). Third, the City is fully committed to full compliance with SB 1383 program requirements and is ahead of most jurisdictions throughout California in this regard (having accepted food scraps and soiled paper for composting collection systems since 2015). I will send an email to City/County staff with more information and relevant attachments for consideration in the RCAAP. - KM

Add in "Napa County Flood Control and Water Conservation District"

"US"

Delete stray "e"

Recommend replacing NCFCWCD with Napa RCD

"grant"

WW-4-C and WW-7-E should be merged together so that the 2027, 2028, and 2029 deadlines are all included.

Delete

"(including grants)"

Retain individual Short-Term Actions here or relocate them to WW-4 as listed in earlier comments.

Delete NCFCWCD from Partners list.

Delete "offer rebates and incentives to the community for water-efficient solutions, establish water-efficient landscaping requirements, and".

In conjunction with my recommendations for WW-4, I strongly recommend making this measure WW-7 analogous to SW-3 and BE-6 by changing it to "Empower Community to be Water-Efficient".
This measure should retain only the following Actions:
WW-7-D, WW-7-J, WW-7-L, WW-7-M, WW-7-N, WW-7-O, WW-7-P, WW-7-Q and add one new long-term action as indicated below in that section.
As mentioned earlier in WW-4, the following Actions should be relocated to that measure instead:
Short-Term WW-7-A, WW-7-B, WW-7-E, WW-7-F, WW-7-G, WW-7-H, WW-7-I, WW-7-K
Long-Term WW-7-R, WW-7-S, WW-7-T, WW-7-U, WW-7-V, WW-7-W, WW-7-X, WW-7-Y, WW-7-Z

Change Strategy name to "Water Education, Awareness, and Behavior Change". Water Loss was covered in previous strategy/measure.

Change "Water Loss" to "Water Education, Awareness, and Behavior Change". Water Loss was covered in previous measure/strategy.

Delete NCFCWCD. Add CA-NV Section of American Water Works Association.

"and"

Delete NCFCWCD. There are no external partners as enforcement is handled by staff of each jurisdiction.

"and"

Remove this last sentence, as it is not applicable to this measure.

Change "public works" to "municipal"

"(e.g., Qualified Water Efficient Landscaper (QWEL) or ReScape certification).

Delete. Moving WW-7-U to WW-4 covers this issue.

Remove last sentence, as WW-7-E will be deleted from WW-7.

Delete "public works"

Recommend eliminating "native". Water-wise landscapes do not have to be exclusively natives to be appropriate for our climate.

Edit Targets to reflect broadened Measure as recommended above.
Again, AB 1572 does not mandate the elimination of non-functional turf. It addresses irrigation, but certainly does incentivize replacing turf with water-wise plants.

Based on broadening this measure as recommended above, Partners list should include:
Napa RCD
UCCE Master Gardeners
Napa County Green Business
Napa Green Certified Winery
California Water Efficiency Partnership

NCFCWCD is not a relevant partner and can be deleted form this list.

Recommend changing WW-4 to "Reduce Non-Residential Water Use and Ensure Efficiency in New Development" (as detailed in relevant section below).

This is way too narrow a measure. I strongly recommend making it analogous to WW-3 by changing WW-4 to "Reduce Non-Residential Water Use and Ensure Efficiency in New Development".
Rewrite opening paragraph to encompass this change, avoiding narrow focus on municipal landscaping, which is covered in the actions.
Relocate numerous WW-7 Actions to this measure instead:
Short-Term WW-7-A, WW-7-B, WW-7-E, WW-7-F, WW-7-G, WW-7-H, WW-7-I, WW-7-K
Long-Term WW-7-R, WW-7-S, WW-7-T, WW-7-U, WW-7-V, WW-7-W, WW-7-X, WW-7-Y, WW-7-Z

"and"

NCFCWCD is not the relevant partner. I recommend listing:
- Napa County Resource Conservation District
- California Water Efficiency Partnership

"grant"

"(AMI)"

Delete this bullet item. Issue of grant funding incorporated in suggested edit in WW-3-B lead sentence above.

"(including grants)"

", while achieving efficient outdoor residential water use."

"for 2030 and beyond"

"through" not "by"

"indoor"

"and"

Recommended Applicable Jurisdictions change to "All" as there are several current and potential future recycled users within city limits (e.g., Napa Pipe Project, Napa Valley Commons, Napa Valley College, South Napa Marketplace).

The Napa River watershed is a narrow watershed highly incised due to land uses such as deforestation for vineyards high in the watershed. There are approximately 55,000 acres of sloped vineyards in Napa County all of which have caused deforestation or other vegetation removal and erosion control plans have been installed as piping under the sloped vineyards (anything over 5% slope) to capture storm runoff and divert it to the nearest stream to help prevent erosion at the vineyard site. When you remove the natural vegetation and install underground pipes to capture stormwater, you are removing rainfall that would have naturally percolated through the natural vegetation at a slow rate recharging the aquifers and providing soil. moisture throughout the year. Removing this percolating groundwater and discharging this water through underground pipes to a discharge point in the watershed off site of the developing vineyard causes increased rate of flow or discharge of stormwater to the receiving stream, creek or river. Throughout the Napa River watershed this 'erosion control' infrastructure is discharging increased rate of storm water eventually discharging from all over the watershed to the Napa River. There are an estimated 35K vineyards on the valley floor and approximately 55K in the mountains or any sloped vineyard in the watershed over 5% slope has erosion control pipe infrastructure discharging to the Napa River. This cumulative increased rate of flows of stormwater to the Napa River is causing the river to carry more storm water than it can hold there-by causing all this increased stormwater flows have erosional forces which collapse the stream and river's banks and cuts down into the bed of the stream and river driving millions of tons of sediment into the River and eventually the San Francisco Bay. All of this eroded soil will deposit this sediment throughout the watershed covering up spawning gravels for salmonids, making the river more shallow in places where the sediment plugs or drops of the flowing water which causes a more shallow and warming river. Many reaches of the Napa River are seriously incised which is steep banks from the erosion of increased rate of flows and then other parts of the river are really shallow because sediment has dropped in the river from all the eroded banks and bed areas of the river. This sets up a disaster of huge magnitude given climate change. If we have deluge the shallow parts of the River will not carry the deluge and this stormwater will jump out of the banks and cause massive flash flooding that can cause death and property damage because people and property will not be able to get out of the way in enough time to do so. The deforestation and vegetation removal so common in vineyard development, prevents groundwater recharge. Not looking at nature based solutions to climate adaptation, is a huge oversight. We must prevent vegetation loss in our watershed so we can help prevent catastrophic flooding, flash flooding, torrents of water and debris damaging property and killing people. We have aging dams like Milliken Dam that are not capable of holding back torrents of water and flash flooding events due to their age and instability determined by the Ca. Division of Dams and Safety. Reservoirs are collapsing all over the world during catastrophic flooding events caused by deluge which is a climate event problem. We must repair and restore our watershed, by planting trees and preventing further tree losses and remove dangerous dams and restore the watersheds thereof.

Add "and" so Strategy is "Water Use Efficiency and conservatin"

See comment on ALL-5.3 re: Emergency Traffic Operations Center, and consider adding NVTA as partner to this Measure.

Support consistency with NVTA comments provided in AG-5-B re: locations for prioritizing urban tree canopy.

Modify TEMP-3.3 to read "Identify opportunities to expand tree canopy or other shade and provide water refill stations at major transit stops."

Revise TEMP-2.5 to include reference to transit riders.

Add to ALL-5.3 or add a new Action to support development of emergency traffic operations center by NVTA, ensuring all-electric fleet can serve needs of community in evacuation or other emergency scenarios.