September 30, 2015

Re: Local Coastal Plan Update

The most alarming thing about this new preliminary draft of our Local Coastal Plan is that it
seeks in many areas to bring the Sonoma Coast, an especially vulnerable and precious part of
California, in line with General Plan provisions elsewhere in the county. So many times
throughout this document the citation (General Plan 2020) is used to validate the appropriateness
of an addition or revision. The intention of a separate Local Coastal Plan in the first place was to
recognize the unique vulnerability of this area. Some of the new additions in fact increase the
potential for commercial and industrial incursions on the coast. All of these General Plan 2020
inclusions should be reviewed carefully along with other revisions and additions.
As a specific example, it came to light late in the period for public comment for the preliminary
draft of this plan that extensive changes to the Agricultural Element had not been pointed out by
PRMD staff at various public workshops.
I call your attention to the simplicity and brevity of the most relevant agricultural passage in the
former plan:
Excerpt from: California Coastal Commission on December 12, 2001.
Coastal Agriculture
Approximately three-fourths of the Sonoma County coastal zone is used as timberland, sheep and cattle
grazing land, or dairy land. The coastal zone is equally divided between land suitable for timber
production and land suitable for grazing or pasture. Grassland suitable for sheep and cattle grazing is
found along the coastal terrace and lower slopes on the north coast, and throughout the coastal zone
south of Jenner. Dairies occur in the Valley Ford area.
The climate and topography of western Sonoma County have largely determined the extensive type of
agricultural uses found there. While the non-prime soils and lack of year-round water supply do not lend
themselves to the cultivation of crops, the coastal hills are among the best lands for grazing livestock in
the State. The cool, moist climate generally produces better rangeland than inland, reducing the need for
supplemental feed and irrigated pasture. [Page IV 2]
Policv AR-6d: Follow these guidelines for approval of visitor sewing uses in agricultural areas, such as
wine or cheese tasting:
1) the use promotes and markets only agricultural products grown or processed in Sonoma County.
2) the use is compatible with existing agricultural production activities in the area.
3) the use will not require the extension of sewer and water.[Page 242]

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It is evident from the creation of a new separate Agricultural Element that it anticipates the rush
for coastal lands, something not envisioned in 2001. The former plan mentions tasting rooms
only once (above) and never even entertains the possibility of large winery operations, bottling
plants, and event centers as agricultural support services on the coast. These are industrial and
commercial activities, not agriculture. Rather than protecting the rural coastal environment as

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intended in the original plan, many of the new additions appear to put primary importance on
protecting the welfare of Sonoma County agriculture by stressing economic value foremost
and commercial promotion. Especially objectionable is the new policy that states: Policy CAR-2b: The Agriculture land use category shall be applied based on the capability of the land to
produce agricultural products. (GP2020). Many coastal lands are quite capable of producing
agricultural products, like Chardonnay grapes, but only at the cost of the natural beauty of this
unique coastal environment.
I think there is a place for sustainable agriculture, including vineyards, on our coast, but this plan
proposes no scale or proportion. Once upon a time in Sonoma County, almost all of our wineries
were family owned and operated businesses. The small vintners were our neighbors, who cared
about the conservation and preservation of this very special region. When an operation is part of
a large corporate entity, there is a fundamental change in its relationship with the community.
These corporate interests have historically wielded much influence in Sonoma County politics.
Now that wineries are transforming from small, locally owned operations to beautiful beads in a
much longer corporate chain, that influence is sometimes being used to develop and capitalize on
our precious rural areas. And in many cases they take something they cannot give back. This
Agricultural Element seems to make the case for economic development, rather than preserving
the coast with sustainable agricultural and ranching practices.
I therefore request that all sections below be deleted from the Sonoma County Local Coastal Plan
Update Preliminary Draft June 2015
Agricultural Visitor-Serving Uses - Agricultural Tourism
While agricultural tourism is not in high demand on the Sonoma County Coast, it may become so in the
future. The benefits and potential adverse impacts of visitor-serving uses vary by agricultural industry.
Agricultural tourism would contribute to supporting the economic success of the agricultural industry on
the Coast. It is important to recognize that agricultural tourism directly promotes the sale of agricultural
products. Activities such as special events attract customers, build a customer base, market products, and
build customer loyalty. However, the economic benefits of agricultural tourism must be balanced against
associated impacts such as increased traffic, particularly in areas or along routes where multiple visitorserving uses may be hosting events at the same time. In addition, visitor-serving uses must supplement
agricultural production, not replace it. In extensive agricultural areas, some conflicts between visitors
and agricultural practices would be less severe due to the greater amount of land available to separate
the activities. In these areas, small scale lodgings and some outdoor recreational uses could promote the
agricultural activity and provide a secondary income source for the farmer or rancher without hindering
the primary use of the land. The Agricultural Resources Element promotes the County's agricultural
industry by establishing policies which allow specific, limited
[Agricultural Resources Element Page C-AR-12]
Policy C-AR-2b: The Agriculture land use category shall be applied based on the capability of the land to
produce agricultural products. (GP2020)
Policy C-AR-2d: Plans for State and County recreational uses should address impacts to and protection
of agricultural lands and include policy calling for avoiding conversion of agricultural land to
incompatible recreational uses. (New)[Page C-AR-18]
Policy C-AR-4a: Agricultural processing shall be defined as the action of changing an
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agricultural product from its natural state to a different form, including bottling, canning,
packaging, and storing agricultural products, such as grapes to wine, apples to juice or sauce,
etc. (New) [Page C-AR-20]
In cases where the proposed processing use would process only products grown on- site, such use would
not be subject to this concentration policy. (Existing LCP Revised)
Goal C-AR-5: Allow new visitor-serving uses in agricultural areas that are limited in scale and location
and are beneficial to the agricultural industry and farm operators and compatible with long-term
agricultural use of the land.
Objective C-AR-5.1: Allow visitor-serving uses which promote agriculture and enhance marketing of
Sonoma County agricultural products and are secondary and incidental to agricultural production. !3
[Page C-AR-21]
Objective C-AR-5.2: Facilitate County agricultural production by permitting limited agricultural support
uses that support local agricultural activities and are not detrimental to the long-term agricultural use in
the area.
Policy C-AR-5a: Visitor-serving uses which promote agricultural production shall be defined as tasting
rooms, sales and promotion of products grown or processed in the County, educational activities and
tours, incidental sales of items related to local area agricultural products, and promotional events which
support and are incidental to local agricultural production. (GP2020 revised) [Page C-AR-22]
(8) Activities that promote and market agricultural products such as tasting rooms, sales and promotion
of products grown or processed in the County, educational activities and tours and incidental sales of
items related to local area agricultural products are allowed. (GP2020 Revised) (Existing LCP Revised:
Policy AR-6d on page 242 and Recommendation 1 on page 53 of Existing LCP) [Page C-AR-23]
Sincerely,
Hannah Clayborn
22050 Timber Cove Rd.
Jenner, CA 95450

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