If you’re involved in the Napa winery industry you’ll likely be interested in attending the next Napa County supervisors meeting on Tuesday, December 8th at 9 am. The topic of great interest: discussion of the recommendations of the APAC committee. This is a list of their 11 final recommendations after their session of meetings began upon the committee’s formation in March of this year. The supervisors review and potential eventual approval of items on this list will mark the next chapter in Napa County’s evolution of how it defines and regulates a winery. The list of the committee’s recommendations cover a wide scope; from specifics related to winery compliance reporting to developing new use permit application processes to completing the county’s climate action plan. 

Here are their recommendations which would impact your compliance reporting as a Napa county use permit holder.

  1. Annual compliance reporting requirement
  2. Signature (by principal officer) certification of compliance with all use permit conditions
  3. Submission of copies of your TTB 5120.17 & California Grape crush reports 
  4. Based on the results of these annual report filings, civil penalties would be assessed on any non-compliant wineries

My key suggestion to all current Napa County winery use permit holders is this: Are you currently keeping watch on your use permit conditions as they are connected to your ongoing TTB & CDFA report numbers?

Those two specific use permit conditions being your production gallons and 75% grape source requirement. If you aren’t familiar with how the county determines compliance for these see my earlier blog post here.

What I often find interacting with wineries is that the individuals who are responsible for tracking the above two sets of numbers are simply not aware of their site’s county use permit conditions. So though they are the ideal source to be keeping an eye on their county use permit compliance, the connection has not been made for them to take ownership of it. They simply have never seen the use permit and it’s list of conditions. 

The solution to this is simple. Track down your site’s county use permit. The original, plus any modification updates needs to live at your winery site. If for some reason you cannot locate it you can contact the Napa county planning commission offices for a copy of your site’s complete file. If your site has not been random audited by the Napa county planning office in recent years then run a self assessment of your numbers (from your TTB 5120.17 & CA grape crush reports) to determine whether or not you’re currently in compliance with your use permit.

Questions on any of this my office can provide guidance and/or assistance. Please contact me at:   ann@winecompliancealliance.com   or (707) 266-1946

Here is a link to the APAC committee’s list of recommendations:

APAC recommendations

 

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