SCCA Response to Wineries: PRMD Working Group on Wineries and Events– Policy Development

Thank you Sonoma County Conservation Action and Dennis Rosatti for writing such a well thought letter on dealing with winery event policies in this county.

wine-shop-725x544RE: PRMD Working Group on Wineries and Events– Policy Development

Dear Sonoma County Planning Staff:

Past and current PRMD policies and standards, as implemented, have allowed overconcentrations

of wineries on agricultural lands in Sonoma Valley,in the Russian River Valley,

along Westside Road and in Dry Creek Valley. Increasingly, the wineries have moved beyond

the long-accustomed wine-tasting tours and industry events, to ever more numerous and elaborate

events and commercially oriented activities, such as food service, weddings, concerts, and

parties. On most weekends and many holidays, these uses have imposed the parking overflows

and road congestion more characteristic of urban areas, on narrow, winding, country roads.

These conditions amount to life-threatening road hazards for rural residents, and especially

when combined with party-level alcohol consumption and inebriation.

Rural residents have legitimate concerns regarding the expansion of urban activities and associated

congestion to other agricultural zones, including the already-impacted Laguna de Santa

Rosa. Conservation Action supports agriculture and wants the County to implement General

Plan objectives through standards that will prevent advanced urbanization of agricultural-zoned

lands, as well as enforce existing ordinances and use permit conditions for existing facilities.

Since the 1989 General Plan, Sonoma County has protected agricultural lands from urban subdivision

with parcel-specific zoning. On these grounds, we reject the false claims that limiting

winery-centered events on agricultural lands will turn Sonoma County into Santa Clara County

suburban sprawl, and the County should ignore them.

As in France, we want grapes to be grown in agriculture-zoned Sonoma County countryside.

Some wineries and food processing also may be located on ag lands. But the County should

strongly encourage locating most wine/food processing and retailing functions in previously

urbanized areas. By “strongly encourage,” we mean permit fewer events and commercial-related

activities in rural areas and greater numbers in more urbanized areas, with better highway access

and support services, and that the County must enforce its permit standards and restrictions.

By emulating France’s land use distinctions, Sonoma County also can preserve that balance between

agriculture, natural areas and rural ambience, and town-centered marketing of local products,

which attracts tourists with many different interests from all over the world.

In its report to the Winery Events Working Group, PRMD has listed the policy options for addressing

the present impacts of winery-based or winery co-located events. This report is focused

on the current General Plan’s Goal AR-6, but does not cite to “Regulate the Location and Intensity

of Visitor Serving Uses within Agricultural Areas” for mitigating “Conflicts between Agricultural

and Nonagricultural Uses in Designated Agricultural Production Areas.”

On page AR-11), the initial paragraph of this Goal states: “the economic benefits of agricultural

tourism must be balanced against associated impacts such as increased traffic, particularly

in areas such as the Sonoma Valley or along routes where multiple visitor serving uses may

be hosting events at the same time. In addition, visitor serving uses must supplement agricultural

production, not replace it.”

Rural residents who spoke at the first public hearing on the Winery Event Working Group process expressed the need

for PRMD to set standards for establishing that balance, and the desire to see such standards enforced. In contrast, most

(although not all) wine grower-vintner statements at the public hearing indicated a lack of interest in establishing standards,

or addressing the growing imbalance of urban traffic and industrial land uses in the County’s agricultural zoned


Some representatives of each group expressed a sense that PRMD, County Planning Commission, and County Supervisors

enforcement will be the key to preserving that balance.

We are deeply concerned that neither the County’s October 14, 2015, “Development Criteria and Performance Standards”

paper for WEWG, nor its Key Issues and Policy Options stress:

a) the issue of limits to scale and location in GP Goal AR-6;

b) the qualification in Objective AR-6.1 that “Visitor serving uses … shall be secondary and incidental to agricultural

production,” or

c) the stated aim in Objective AR-6.3 “…to minimize the adverse cumulative impacts of such uses, particularly

in areas where agriculture related support uses and/or visitor serving uses are concentrated.

Some of the policy options were so weak as to offer no tools for planners to achieve the above objectives.

Policy AR6-f “specifically states that local concentrations of visitor serving uses, even if related to surrounding agricultural

activities, are detrimental to the primary use of the land (agriculture) and may constitute grounds for denial

of such uses.” The denial of such uses will be critical to limiting concentration of these uses in ag zones.

Preserving agriculture in Sonoma County depends on paving over very little of its agricultural lands, and that is the objective

of rural residents, as it should be the objective of farmers of all types. Based on the Key Issues and Policy Options

document, dated November 4, 2015, we therefore support the following policies and standards for preserving Sonoma

County’s agricultural heritage into many future generations:

Minimum site area:

In areas of overconcentration, establish a minimum parcel size of 20 acres with a vineyard covering at least 15 acres

that will support a winery with a capacity of no more than twice the volume produced from grapes of that vineyard,

with a maximum of .75 square foot of total facility (winery and tasting room) per case of production.

To avoid creating more areas of overconcentration, establish a countywide minimum parcel size of 10 acres, with a

vineyard covering at least 7.5 acres that will support a winery with a capacity of no more than twice times the volume

produced from grapes of that vineyard, with a maximum of .50 square foot of total facility (winery and tasting room)

per case of production.

Driveways along the same County road, which provide access to wineries that sell to the public on site, should be at

least a half-mile from each other.

Setbacks for Noise (All Agricultural Zones):

Noise transmissions vary with on air flows, air temperature, and topography, so vary with season and climate conditions,

building positions and materials, and topographic variations. All these factors need to be assessed to prevent

sound transmissions reaching the boundaries of a property where non-agricultural noises may be generated.

include the winery and event areas, and parking areas.

No amplified sounds should be permitted for outdoor events. Indoor amplified sounds may be allowed as long as they

are not audible at the property line.

Tasting Rooms:

Allow tasting rooms only when they are accessory to both grape production and processing on a parcel, as defined


Do not allow stand-alone tasting rooms in ag zones.

Limit on-site wineries and tasting rooms to one per parcel, with visitor serving spaces related to on-site grape processing:

and all labels poured must be related to the winery owner or to the use permit holder.

Limit custom crush operations to industrial/urbanized areas.

Visitor Hours:

Establish uniform tasting room hours (11 AM to 5 PM or earlier) to avoid traffic congestion.

Limit all events, including outdoor events, to tasting room hours (11 AM to 5 PM)

Limit the number of seats or size of the area where food is tasted along with wines.

Through special permits, allow outdoor events to extend to 9 PM.

Only one such special permit per week should be allowed in areas of high concentration, and restrict food service for

those events.

Allow more events, with extended time frames, at wineries in County towns and industrial zones.

Food Service:

Limit food and wine pairings to events, within the permitted visitor hours.

Allow only Promotional Events and Industry-Wide Events in the Use Permit.

Allow Special and Cultural Events with a special permit.

Require tasting rooms serving meals in County towns and industrial zones to apply for licensing as restaurants.


All parking for events are to be contained on-site, in addition to other proposed standards..

Many events may need an on-site coordinator and parking attendants.


The County shall prohibit allowing overnight guest accommodations on Ag lands that are not directly associated with

the production of agriculture and its activities.

The County shall require 2 units of farmworker housing for every 1 unit of guest accommodation that are allowed.

Temporary overnight guests must pay a TOT tax to the County.

Monitoring and Enforcement:

The foregoing suggestions are meant to severely reduce, if not completely eliminate, trespass, and noises at late


To support the proposed standards, PRMD must investigate alleged permit violations, and impose sanctions whenever

evidence supports the allegations.

Meaningful fines should be assessed for violations and permit restrictions should be imposed on repeat violators.

We believe that the above standards will provide the proper balance between the needs of the wine industry to continue

to promote its products, with the needs of local residents for the quiet enjoyment of their property, while preserving

Sonoma County’s agricultural areas as tourist-attracting rural landscapes for all County residents to enjoy.

Thank you for the opportunity to provide our input into your policy making endeavor, and please keep us informed as

this process continues forward.


Dennis Rosatti

Executive Director


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