TO: Technical Advisory Group for the Napa County Groundwater Sustainability Agency
FROM: Brian D. Bordona, Director of Planning, Building and Environmental Services
REPORT BY: Jamison Crosby, Natural Resources Conservation Manager
SUBJECT: Napa Valley Subbasin GPR Implementation: TAG Review of Vineyard and Winery Certification Program Framework
RECOMMENDATION
title
Technical Advisory Group (TAG) members will receive a presentation of the current proposed framework for the NCGSA Water Conservation Certification Program minimum requirements and preview the vineyard benchmarking program. This will spur discussion, questions, and provide feedback to staff and participants.
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Procedure
Staff introduces.
Questions and answers with the TAG.
Public comments.
BACKGROUND AND DISCUSSION
The Napa County Groundwater Sustainability Agency (NCGSA) has developed and is implementing the Water Conservation (WC) and Groundwater Pumping Reduction (GPR) Workplans. The WC Workplan identified a suite of water conservation practices and the GPR Workplan includes an implementation plan and anticipated timeline for a broad program to achieve measurable reductions in groundwater pumping in the Napa Valley Subbasin (Subbasin). GPR implementation anticipates a voluntary program that incentivizes growers and other water users/industries in the Subbasin to adopt and expand water conservation practices. Water conservation actions include those that reduce total groundwater pumping and those that may additionally reduce net depletion of groundwater (total groundwater pumping less usable groundwater that returns to the aquifer).
One opportunity identified in the GPR implementation plan for encouraging voluntary adoption of water conservation practices is certification programs. Certification programs require producers to meet specified standards to become certified. In exchange, certified businesses can demonstrate to peers and others good stewardship of resources, meet regulatory standards, satisfy buyer specifications, label their product in a certain way, and potentially have access to new markets. This can also create additional value (higher price or cost savings) for some producers.
In addition, benchmarking was also identified in the GPR implementation plan. To encourage voluntary water conservation, an agricultural benchmarking program can provide anonymous data on crop evapotranspiration (or other measures of water use) to show how an individual vineyard operation compares to a group of its peers. This program establishes a structured framework for tracking and assessing water use, defines comparable anonymous water user types, and provides this information to water users. Then, each water user can make informed changes to reduce water use. It can also be applied to other contexts beyond agriculture, such as municipal and industrial water use. Benchmarking has the potential to create behavioral changes among participants, reduce water use, and potentially inform system-wide improvements over time.
For certification, the GPR implementation plan specifies that NCGSA staff and its consultants will work with existing certification programs, or potentially a new program, to develop specific water conservation practices, standards, and a method for reporting and sharing data. In short, the goal is to develop or expand one or more certification programs to achieve and verify additional water conservation in the Subbasin, above and beyond the levels of conservation which have already been achieved by growers over many years. Over the last few months, NCGSA staff and consultants have been working to develop the potential framework (including minimum requirements) for a water conservation certification program. The draft framework presented in this meeting outlines program structure, monitored water conservation practices, data reporting and verification, water use measurement, impact evaluation, costs and funding, and outreach and education. At the same time, NCGSA staff and consultants have also been developing the framework and methodology for a vineyard benchmarking program in the Subbasin.
The TAG has received information and presentations regarding certification and benchmarking programs from NCGSA staff and consultants at multiple TAG meetings in 2022, 2023, and 2024. During today’s meeting, the TAG will have an opportunity to review the draft proposed Water Conservation Certification Program guidelines and preview the vineyard benchmarking program framework. To guide the discussion, topics/questions on certification are identified that would benefit from input from TAG members for effective program implementation.
Question/Prompts for TAG Discussion
For a voluntary certification program to be a successful part of GPR implementation, it must result in the adoption of new water conservation practices (and expansion of existing practices that are already widely adopted), verification of water conservation, and result in demonstrable, collective progress towards reducing groundwater pumping (for the entire Subbasin in aggregate).
At this time, the complete draft “NCGSA Water Certification Program: Structure and Minimum Requirements” document is ready for review and feedback.
One (1) overarching question with four (4) specific certification program sections were identified for this TAG meeting. In addition, one (1) question was identified regarding the benchmarking program. Questions are presented below.
1. What feedback and questions are there for the current framework of the NCGSA Water Conservation Certification Program?
• Additional context: This program has benefited from continual feedback from the TAG and stakeholders throughout its development. Currently, four program sections describe the key minimum requirements for the NCGSA Water Conservation Certification Program and how those differ from other, existing certification program practices: practices, verification, data calculation and reporting, and incentives and outreach. Potential areas of discussion are included below.
o Minimum water conservation practices. Six vineyard practices and three winery practices have been developed into the program framework as minimum requirements for recognized certification. This includes installing meters within a period of 3 years. In addition, this includes irrigation system efficiency, distribution uniformity, recycled water, agronomic practices, planting design practices, water wise winery processes, and processing water treatment and reuse.
o Verifying water conservation. To be certified, participants must provide proof of practices. Third-party audits are required. There are a variety of verification methods under third-party auditing and program auditing, including records/documentation, photos, and in-person inspection/review.
o Program water conservation. Water conservation is measured relative to a baseline that should represent what water use would have been in the absence of adopting water conservation practices. Data from participants/partner programs will be necessary to measure changes in water use and program impacts overtime. A program baseline is defined for average annual and water year-specific water use. The program requires annual reporting for aggregate regions (specifically American Viticultural Areas or AVAs) to protect individual water user data.
o Program incentives. There are several different potential types of incentives the NCGSA can develop to encourage participation in the certification program. To ensure these incentives and the program will be effective, ongoing outreach efforts have solicited feedback from a range of stakeholders, with additional activities planned as the program is refined and finalized. A separate document describing incentives will be developed and presented at a future TAG meeting.
2. What other factors should be considered in the release of the benchmarking program?
• Additional context: The benchmarking program offers opportunities to empower stakeholders to improve water use though comparison to an anonymous peer group. The framework and methodology currently utilize parcel and APN data to develop peer-to-peer comparison. Peer groups are based on several factors, including field characteristics, grape characteristics, and location. As the program is rolled out, several factors will impact the success of the program’s release.
• Potential discussion topics:
o How should the results be presented to parcel owners and growers?
o What factors should be considered when enrolling pilot sites?
ENVIRONMENTAL IMPACT
ENVIRONMENTAL DETERMINATION: The proposed action is not a project as defined by 14 California Code of Regulations 15378 (State CEQA Guidelines) and therefore CEQA is not applicable.
SUPPORTING DOCUMENTS
A. ERA Economics PowerPoint Presentation: Certification Program for GPR Implementation, November 2024
B. NCGSA Water Conservation Certification Program: Structure and Minimum Requirements (Draft), November 2024