March 16, 2022
To: Cotati City Council
From: Community Alliance with Family Farmers, Sonoma County Chapter Re: Proposed Urban Agriculture Ordinance
We applaud the City of Cotati’s interest in supporting agriculture and promoting local food access within city limits. This work is innovative and much needed. However, we have concerns that the proposed changes don’t go far enough in supporting urban agriculture and may not move fast enough for existing operations–those who are ready to feed our community now–to get this season’s seeds in the ground.
1. Extend "commercial crop production" to all zones. Reason - In addition to farming as a significant occupation and income source, urban agriculture includes very small-scale production that can provide supplemental income to residents while supplying neighbors with fresh, nutritious food, e.g. seniors or teenagers who could set up a card table and umbrella in their front yard to sell their extra produce.
● Comprehensive urban ag ordinances have been successfully implemented in other California communities, such as Sacramento.
● Urban agriculture is consistent with the language in Cotati’s general plan language ● It provides crucial food security and supplemental income to a wide range of people ● Urban agriculture promotes equity and diversity in agriculture by allowing those without access to farmland to get a foothold, especially those of limited means and from underserved communities.
● There are already many small-scale commercial enterprises operating in residential neighborhoods within city limits (i.e. Air BnB, home occupations)
2. CSA sales and on-site farm stands with produce grown on site should be allowed in all zones by right and on all parcel sizes; no permit required. ● Requiring a permit would be prohibitive for many small scale producers. A farm stand can be as simple as a card table and umbrella in the front yard. Anyone should be able to sell the extra food they grow or crops specifically for sale to their neighbors or others.
A minor use permit should be required for farm stands selling produce not grown on site or adjacent property and/or processed foods, as there should be standards to ensure that such produce is actually locally grown or raised and that processed foods are meeting appropriate requirements.
● California Retail Code does not distinguish between produce for sale or donated; it must meet the same standards and requirements. Growing food to donate is currently allowed everywhere.
● Both large and small farms offer CSA sales and on-site farm stands. They should be allowed because these are excellent ways to connect directly with consumers, providing ag/food education, maximum freshness and building neighborhood relationships and self reliance.
● Even micro-farms can be highly productive. There are many examples of very small farms with crops such as salad greens, berries, cut flowers and herbs (non-cannabis) bringing substantial income. And very modest income from produce sales could be an important supplement to some.
● Traffic may be reduced with multiple neighborhood farm stands as people can walk to get produce rather than driving to the store.
● Farm stand and CSA hours of operation should go to 7:00 pm seven days per week to accommodate those–both farmers and those purchasing food–who have regular jobs, school or other limitations.
3. Hours for machinery and mechanical equipment operation should be extended to 7:00 pm including weekends and holidays (or to the zone’s existing noise regulations). The majority of farmers nation-wide have outside employment and many do much of their work on weekends. In spring and summer when days are long, late afternoons and early evenings are critical times for such work.
● Farm machinery such as tractors are no louder than weed-whackers, dirt bikes, chain saws, leaf blowers and other residential machinery uses which are not regulated.
4. Increase the number of hens allowed to 20 per acre. The proposed number is too small for a viable operation and larger numbers can easily be managed with humane and environmentally-sound practices.
5. Community Gardens should be supported in all zones. Management of community gardens in city parks can be specified through a Request for Proposals process where requirements for the managing organization are outlined.
Thank you for your support of urban agriculture and for helping to make Cotati a healthier, more sustainable and more vibrant place to live.
Wendy Krupnick
Vice president, CAFF Sonoma County