The name of our group is Stop Syar Expansion (SSE), not Close Down Syar. We acknowledge the need for aggregate, even while we know aggregate mining to be one of the the most destructive and polluting of land uses. However, quarries do close. They extract a material that is non-renewable in human time scale. They grow as far as they can based on surrounding uses, or they run out of rock. The Syar Napa Quarry will not be operating forever.

It is precisely because the rock is a non-renewable resource that it must be properly managed for Napa’s needs. Like groundwater. Although the aggregate is under land that is privately owned, because of its critical nature to many kinds of construction processes, the county is obligated by its exercise on our behalf of management of the public trust. It cannot allow a company to plunder this resource.

Look at the environmental impact report, the document of record for the project, the document that, according to California Environmental Quality Act (CEQA), is supposed to contain the information necessary for reasoned analysis by the public and county officials, and rational planning decisions by the county officials.The environmental report states: “Currently, the majority of truck trips travel south on SR 221 to SR (Highway) 29 south to SR 12 (Jameson Canyon Road) and access to I-80 or further south to American Canyon and deliver aggregate materials throughout the Bay Area. In discussion with Syar Industries, this pattern is expected to continue in the future.” Taking that scenario to its logical conclusion, we can see that we would soon arrive at the scenario the expansion’s supporters tell us we should fear - that we will run out of rock for Napa.

The quarry, properly managed and right-sized, could continue to serve Napa for many years. But not if it is producing more than what is needed to satisfy local need and exporting that to other counties. This is just one of the many areas of the environmental report is lacking in objective analysis.

Another area of deficiency is with regard to mitigation, which in several key areas is inadequate, impermissibly deferred or lacking proper enforcement mechanisms. As just one example, the formulation of a mitigation plan for greenhouse gas emissions is deferred to at least three years beyond the point where allowable levels are exceeded.

Regarding mitigations and environmental protections more generally, Syar has promised mitigations to such an extent that the expansion is being sold as a net environmental gain. This is, in fact, proof that all that could be done to protect the environment is not being done - despite Syar’s claims in the environmental report that all “best practices” are already being implemented. If the best is already being done, what could be improved? The county acknowledges that the past permits were lacking in environmental and community protections. The question is what is stopping Syar industries from improving the operating conditions now? Why must they wait for a new permit to, for example, upgrade their fleet of mostly tier 0 and tier 1 vehicles - the most polluting?

Our citizen group, Stop Syar Expansion, has submitted expert comments in the areas of traffic, hydrology, noise and air quality, detailing the numerous flaws and inadequacies of the environmental report, and demonstrating why it cannot be certified. We spent a great deal of time and money to gather this information to assist the county and its citizens in making a good decision for the future of Napa.

We have shown that environmental impacts have been systematically and grossly underestimated through basing analysis on faulty data and methodology.

The decision for a 35-year project must be made with a long view, on the basis of sound reasoning and with comprehensive understanding of fundamental facts. Not on the basis of politics, personalities or scare tactics. The planning commission is mandated to evaluate projects for the benefit of local residents - including the environment- as a whole, not to serve business interests. To fully evaluate a project, we all have to know the true price tag. The true price tag of this project, now in its seventh year, is still unknown.

The need for the project is also unknown. When we are about to undertake any project, we have to know: “Why are we doing this?” We have to ask, “What is the need?” Let’s say you are at the grocery store, and someone in your household says, “Let’s get more apples,” don’t you ask, ‘how many do we have at home? How many have we been eating? What are we doing in the next week, and how many will we need?’

For a project that undeniably impacts the environment and our community, how can we not ask the same questions: What are the reserves of the quarry? How much aggregate has Napa actually used? How much will we actually need, based on factual analysis, not hypotheticals, assumptions, or mere assertions.These fundamental questions are missing from the environmental report.

In the interest of space, I won’t repeat here all the analyses provided in the expert comments we have submitted, which are or will shortly be on the county’s website. However, to touch on just one point: The environmental report uses the number of 8.9 tons per year per person for the analysis of county need for aggregate. Where does this number come from? It is an average for the North Bay region from studies carried out from 1960 to 2011. Napa is a slow-growth, agriculturally-based county with an Agricultural Preserve. Even for the larger region, can we possibly believe that the same amount of growth will occur from now forward for 35 years that occurred in the rough half century between 1960 and today? What agricultural ground in Napa are we planning to pave over?

Stop Syar Expansion has looked at the information from weight tags for Syar Napa quarry aggregate use by all county entities for the last 10 years. We do not have access to contractor purchases, but we have seen Public Works purchase orders from all the cities, the township of Yountville and from the county’s Public Works department.

Although it can readily do so, Syar Industries has chosen not to provide the weight tags for the years used to establish the baseline for the environmental report. By not making public the records that actually establish the true need for the quarry’s need to expand, Syar Industries disserves the community and its governing bodies. The amount of Syar Napa Quarry aggregate known publicly to be used in Napa is far lower than the regional average calculated over a time-frame of rapid growth. Furthermore, there are other companies (Cemex, Shamrock, Mark West BoDean, for example) that supply aggregate to Napa County. It is simply not believable that only Syar Industries will be providing all of Napa County’s aggregate needs for the next 35 years instead of sharing the market with other companies as it currently does.

That the county proposes to make a decision affecting the future of Napa for 35 years (a very long time for a permit, given how fast technology, environmental understanding, and community needs can change) without this fundamental information is, frankly, frightening.

What forces are directing our local governments? What influences are guiding their decisions? I fear that the same influences are behind recent thinking and decisions and on large building projects, winery event centers, massive vineyard developments in our watersheds, and a permitting permissiveness that bends over backwards for applicants and rewards violators. If the county continues to serve the few at the expense of the many, we have to get involved and make changes.

Napa is the beautiful place it is because of people who had the wisdom to see the need to protect this agricultural treasure. We need a new wave of champions coming forth to protect the land, air of and water of this valley and to fundamentally reshape the way the county does business. Our new and evolving understanding of the health risks involved, as well as social responsibility, true sustainability, climate change, and social justice demand no less.

Napa Valley Register version: Flaws of Syar process related to other County issues
.