January 15, , 2021
Sonoma County Board of Supervisors
575 Administration, Room 100A
Santa Rosa, CA 95403
cc: Tennis Wick, County Counsel
RE: Conversion of farmland to visitor-serving commercial zoning
Honorable Chair Hopkins and Board Members,
The County is initiating an EIR for a project proposed by Jackson LLC, composed of a hotel
and a winery on River Road and a residential subdivision in Wikiup. The hotel portion of the
project proposes a zoning change, which would convert farmland to a much more intense
land use and zoning, and requires a General Plan Amendment.
The concerns in this letter relate only to the hotel component of the overall project. We
strongly believe approval of the hotel component would set a harmful precedent for converting more farmland to visitor-serving commercial zoning. We endorse Permit Sonoma’s position that the proposed rezoning of agricultural land to commercial
zoning allowing hotels is inconsistent with the General Plan’s goals to preserve ag land. Permit Sonoma staff have gone on record that they cannot support the proposed rezoning.
For example, on October 7, 2020, Permit Sonoma stated: The General Plan underscores the value of agricultural enterprises in Sonoma County as expressed through its various goals, objectives, and policies prescribing protection of agricultural lands and support for agricultural production. The applicant’s proposal to redesignate LIA land to Recreation and Visitor Serving Commercial (RVSC) to allow for the development of a 50-guest room inn and related facilities is in conflict with a number of policies and inconsistent with the
Plan’s principal goals to preserve agricultural land.
The applicant must seek rezoning because the hotel component is not allowed under the land’s current Land Intensive Agriculture (LIA) zoning. While the General Plan allows certain visitor-serving uses to promote agricultural products on ag-zoned lands, Policy AR -6d specifically prohibits hotels.
In addition, the General Plan states that amendments to designate land as visitor -serving
commercial zoning must meet eight criteria. Importantly, criteria (8) specifically prohibits rezoning ag land with USDA Class I, II, III, and IV soils for recreational and visitor- serving uses iii. A technical study shows the hotel site contains both Class III and IV soils; thus, it is ineligible for consideration of rezoning from ag to commercial iv. Even if such a conversion were not specifically prohibited by the General Plan, spot zoning any isolated parcel, whether ag or not, requires a clear public benefit. Spot rezoning prime ag land to hotel
commercial use requires an even greater “overriding public benefit,” according to
Policy LU-9d. v Adding a luxury hotel with restaurant, events, spa, fitness center and swimming pools in the middle of an agricultural area does not meet the test for an “
overriding public benefit.”
For public benefit, the applicant proposes, as an inducement for the housing development
project , a donation of land in Wikiup for a public park, if a third party can be found to own, develop and maintain the park and complete stream restoration. It has been difficult to find agencies or entities willing to assume such financial responsibility. But in any event, park land for ag land is not an “overriding public benefit.” It violates the General Plan, turns the
overall goal of city-centered development on its head, and encourages sprawl and more density on protected ag land. Approval would encourage more such conversions, eroding our agriculture future and rural character.
Other “benefits” (stream protection and designs to minimize water use at the winery and hotel sites) are necessary mitigations to offset impacts to Mark West Creek from the overall project.
They are not an “overriding public benefit” sufficient to justify such a questionable and precedent-setting rezoning request.
Sonoma County has overwhelmingly voted for multiple initiatives to protect our precious open space and ag lands – urban growth boundaries, community separators, and tax increases to purchase land and development rights . Yet Sonoma County continues to
lose incrementally more farmland every year through conversions to urban development.
Rezoning this parcel of prime farmland to commercial zoning flies in the face of the will of the people and the carefully-designed protections in our zoning code and General Plan
to prevent such conversions. It is important to promote Sonoma County’s agriculture and sustainable practices.
To that end, LIA land can accommodate wineries, wine tasting, organic gardens, educational events, farm retail and more, to support ag tourism. . But hotels belong elsewhere. There are over 300 parcels in the unincorporated areas of the County, and many more within the cities, with zoning that allow s hotels or resorts. And with nearly 500 wineries, most located in agricultural areas, there are more than ample existing venues
to showcase Sonoma County’s agricultural bounty and heritage.
Given the significant inconsistencies with and outright prohibitions in the General Plan relating to the hotel proposal, even consideration of such a proposal undermines the spirit and intent of the protections Sonoma County voters have put in place to prevent sprawl and protect open space, and it crosses a red line for Sonoma County residents and environmental groups.
We respectfully request that before any further effort and resources are expended, the Board send a clear message that the hotel portion of the project is not likely to result in approval.
Thank you for considering our comments.
Please see endnotes for further details.