Community Response and Input Letter:
Local Food Production and Urban Agriculture in Cotati
November 3rd, 2022
Roy Smith
To:
City of Cotati Council Members.
Dear City staff, Council members, and Mayor,
Thank you for your ongoing work to promote and ensure the re-establishment of food production within the Cotati jurisdiction.
I have lived within a few miles of the Cotati Hub since 1978. My family gardened and farmed here into the early 1990's. I have watched as the population of our County has swollen and our ability to feed ourselves has declined. Our local history is one of a transition from selfsufficiency and food export to one of massive dependence and import. As a community, we are both dependent on the wider global economy and at the mercy of global food supplies.
The County General Plan, and Cotati Staff, have accurately identified the crucial importance of restoring urban and peri-urban food production and other residence-based economic activity.
Cotati now has the task and mandate to encourage, support, and facilitate food-related cottage industry within our residential zones.
However, the Local Food Ordinance (as of the October 11th Agenda) serves to restrict and chill local food production before it can even begin. The proposed ordinance treats residential family production as a nuisance that must be controlled, taxed, and monitored. It seeks to require invasive limits on how and when one can work in one's own home. Rather than supporting the home producer, it burdens her with permit fees, City, County, and State regulations. It subjects her to the censure and intrusion of any contrary neighbor or regressive government agent.
The ordinance can be improved via the following:
– Provide that all Produce, Garden, and Cottage Industry Stands are permitted “by-right” in all residential zones, without restriction.
– Protect Cotati residents by shielding them from County or State regulations under the provision of direct Producer → Patron sales.
– Recognize that residence-based production is by default organic, low-impact, lowmechanization, environmentally conservative, and pro-social. – Recognize that urban and peri-urban food production is not, and has never been, a nuisance activity.
– Reverse the language regarding the primary use of our homes and neighborhoods to emphasis the ability to provide food and livelihood over the exclusion of such activities.
If the current ordinance cannot be revised to truly support local food production, I request that this provision be shelved and taken up by future Councils in this or other jurisdictions.
Please see page 2-3 for specific line revisions to the 17.42 Ordinance.
Recommended 17.42 Ordinance Revisions
Revisions: F. Produce Stands and Garden Stands.
1. A produce stand shall not exceed a total floor area of four hundred square feet. A Garden Stand shall not exceed a total floor area of one hundred square feet. (Why? Production and sales will determine this. No benefit to the community is achieved with such intimate levels of regulation.)
2. Incidental items for sale that are not produced at an on-site or adjacent agricultural operation, such as bottled water, packaged snacks, or nonfood items, shall not exceed 10% of sales area or gross sales receipts, whichever is less, at a Produce Stand. Such items are prohibited at Garden Stands. Produce stands selling such items must provide a trash receptacle for customers’ use. (This restriction acts in direct opposition to the General Plan goal of economic divirsification, or any goal of entreprenueral development.)
3. Produce stands and Garden Stands may sell produce grown on-site or on an adjacent site within 1/4 mile, eggs produced on-site or at an adjacent site within 1/4 mile, and prepared food items made from produce ingredients grown on-site or on an adjacent site within Sonoma County, and produced and sold according to Cottage Food Operation registration and permit requirements of the County of Sonoma Department of Health Services and any requirements of the State of California.. (The role of the City of Cotati is to protect and expand the rights of local residents to care for themselves and their community. The City does not serve the public by insisting that all possible restrictions are applied to local producers.)
Revisions: 17.42.220 Community Gardens.
A. The use of mechanized equipment shall be limited in decibel noise to equipment typically found in residential uses, and subject to the same limitations in use. An exception is initial site preparation for planting, which may take place for a total of no more than 3 weekdays per year, between the hours of 9am and 5pm.
B. Cultivated areas shall be subject to five-foot setbacks from property lines. (Unreasonable and unnecessary).
C. Prior to cultivation, the soils shall be analyzed for potential toxicity or contamination that would render the site unsuitable for food crops.
D. A management plan addressing the governance structure of the garden, hours of operation, noise and vermin control, maintenance, responsible water use, security requirements, rules related to pesticide, herbicide, rodenticide, or synthetic fertilizer use, and other operating rules must be submitted to the City prior to initiation of any site preparation or gardening activities.
E. A primary point of contact for the community garden, including name, address, and phone number, shall be updated annually with the City and posted in public view at the garden site. (...provided to the City along with the management plan.) Revisions: 17.42.230 Market Gardens:
A. The use of mechanized equipment shall be limited in decible noise to equipment typically found in residential uses, and subject to the same limitations in use. An exception is initial site preparation for planting, which may take place for a total of no more than 3 weekdays per year, between the hours of 9am and 5pm.
B. The area of cultivation and related activities shall be limited to a total of one half-acre maximum, which may be non-continguous on the property. (Why include such a limitation? Unnecessary) C. Cultivated areas shall be subject to five-foot setbacks from property lines. (Unreasonable and uneccesary).
D. An on-site Garden Stand is allowed, up to a total floor area of one two hundred square feet and located out of the public right-of-way.
D. The Garden Stand may be operated a maximum of two any number of days per week between the hours of 7am and 7pm, and must be temporary in nature and dismantled and stored out of site of the public when not in operation (Uneccesary restriction to any functional Cottage economic activity). A minimum of two motor vehicle parking spaces, either on-street or off-street out of the public right-of-way, shall be required for operation of a Garden Stand, in accordance with Section
17.36.050.
E. A dwelling unit is required on the property as a primary land use. (A dwelling may be secondary to the primary activity of farming, but should be included for those working the land.) Revisions: 17.42.240 Urban Agriculture Standards:
A. Urban Agriculture land uses shall not be adversely affected by development of adjacent properties and the surrounding neighborhood in terms of noise, water runoff, pesticide runoff, equipment operation, hours of operation, odor, vermin, security, or vehicular traffic.