July 2, 2020


Todd Tamura, Chair, and

Sonoma County Board of Zoning Adjustments

Scott Orr, Deputy Director

Permit Sonoma

2550 Ventura Ave.

Santa Rosa, CA 95403




RE: Sonoma Solstice project, UPE16-0086, 3890 Old Redwood Highway Santa Rosa, CA 


Dear Commissioners,


Here are Sonoma County Conservation Action’s comments on the Sonoma Solstice project:


For nearly 30 years, Conservation Action has worked to protect the beauty and natural resources of Sonoma County for future generations.  Under the inspiration of our legendary founder Bill Kortum, we’ve long been dedicated to fighting for the preservation of open space and Community Separators. Protecting Sonoma County land isn’t only about preserving its natural beauty for future generations – it’s also about protecting our rural heritage, promoting city-centered growth, preventing sprawl, maintaining community identities, and taking care with the Wildland-Urban Interface. 


We believe the Solstice project should be denied. This is, essentially, a 24-room hotel and major event center. Approval of the full-scale project would set a dangerous precedent for allowing intense hospitality development, including third-party rentals for weddings, on Resources and Rural Development (RRD) land. Such an expansive interpretation of RRD zoning would be especially egregious in a Community Separator and should be rejected. 




Community Separator policy

The project is on a 22-acre parcel in the Windsor-Larkfield-Santa Rosa Community Separator zoned RRD. 


In November 2016, Measure K asked the voters:  “In order to preserve rural open space and agricultural land, maintain community identities, and prevent sprawl, shall the ‘Community Separators Protection Ordinance’ be adopted to amend the Sonoma County General Plan to require voter approval of changes to the General Plan that increase the allowed density or intensity of development within Community Separators until December 31, 2036 …” Voters approved Measure K by an 81.5 % majority.


The BZA must make a finding that the project is consistent with Community Separator policy. (Mitigated Negative Declaration, p. 80)


RRD zoning

There are nearly 8,000 parcels of RRD-zoned land in Sonoma County which represents roughly half the land area of the County. 


As relevant here, RRD zoning is “intended to allow very low density residential development and recreational and visitor-serving uses where compatible with resource use and available public services.” (Emphasis added) (Sonoma County Code, Sec. 26-10-005; see also 26-10-100; 6-10-200; LU – 5.1, – 5b; OSRC – 1.2)


The Code itself cites several visitor-serving uses that are allowed in RRD with a use permit. Hotels” or “event centers” are not listed as allowable uses. None of the cited low density visitor use examples is remotely similar to a 24-room hotel with a major event center:


Recreational vehicle parks, tent camps or campgrounds, lodging and other recreational or visitor serving uses which do not interfere or detract from the purposes of this district …”  (Sec. 26-10-020 (ee)) 


Sonoma Fire Complex 

The project parcel is located within the perimeter of the Sonoma Complex Fire (see Tubbs Fire). Its decrepit buildings were severely burned in the 2017 fire. 


The County prohibits vacation rentals within the burn zones of the Sonoma Fire Complex.  



Project Summary

We estimate the lodging portion of the project has about 24 bedrooms. There are 12 “cottages” with one to three bedrooms in each. The units range from nearly 450 to 1,050 sq ft. and have kitchens and decks. There is a 13th unit for staff, as well as a 1,330 sq ft reception and general store building. 


The project also features an event center. There is an “event barn” of 9,861 sq ft with commercial kitchen. A Special Events tent will supplement the event barn capacity. The project proposes 100 events, including weddings and dining events, for up to 250 guests, with an annual event capacity of over 10,000 people. The project provides on- and off-site parking for 100+.  Services include dining, alcohol service, amplified music until 10 pm, and pool bar. There would be up to 24 employees.


In all, new construction totals 23,025 sq ft. The project footprint appears to cover at least one third of the 22-acre parcel. 




Hotel-scale visitor lodging with major event center is inconsistent with RRD zoning 

“Very low density” lodging and visitor-serving uses are allowed under the RRD zoning on this parcel. (Sec. 26-10-005) 


 “Very low density” lodging in RRD-zoned land is limited to:

  • Campgrounds, RV parks, tent cabins (Sec. 26-10-020 (ee))
  • Bed and Breakfast Inns (up to 5 rooms) (Sec. 26-10-020 (ii)) with additional limitations, such as prohibition of events per Sec. 26-88-118
  • Hosted rentals (within a single-family home where owners must be on site) (Sec. 26-10-010 (dd))
  • Farm stays (where owners must be on site, up to 5 rooms) (Sec. 26-10-010 (gg))
  • Vacation rentals* (home or a guesthouse, up to 5 rooms) (Sec. 26-10-010 (ff))) with additional rooms and limitations in Sec. 26-88-120: For example, guests on site are limited to a maximum of 12 overnight guests and a total of 18 people on site during the day
              *Vacation rentals are not allowed in the Sonoma Complex burn zone 


The 12 “cottages” with one to three bedrooms and extra services (e.g., dining, pool, alcohol service, events, general store) are functionally a hotel in several buildings. Hotels are defined as a building or buildings with six or more guest rooms for transient occupancy and may include a variety of services, such as restaurants and meeting facilities. (Emphasis added) (Sec. 26-02-140) 


This hospitality project is not “very low density” in the context of rural Sonoma County. We use an estimate of 24 guest rooms for the hotel because this captures the human density of the lodging component. Additionally, there is the major event center, quantified at 100 events per year, or 10,000 people, and up to 24 employees. The RRD zoning code regarding visitor serving use has some specificity – it allows “very low density” uses and gives examples such as RV parks, campgrounds etc. The combination of hotel and event center cannot be deemed “very low density” development on RRD land. Would a Marriott Hotel with “rural feel” be ok?


Beyond the language in the RRD zoning code, we look to the County’s own permit history to guide our understanding of appropriate visitor-serving uses on RRD land. As we understand the County’s permit history document, there is no precedent (unless possible grandfathering of legal, non-conforming uses) for allowing a hotel with an event center on RRD-zoned land. Indeed, “comparable projects” cited by the Solstice developer’s brochure show other comparable developments to this use are all located in commercial zoning (LC, C1, or K) or in cities. 


Community Separator consistency finding

Community Separator policy requires strict scrutiny of the development’s density and intensity, and the BZA must make a finding that the project will not “increase the allowed density or intensity of development within [the] Community Separator.” 

State law requires that preserving Community Separators be given planning priority over other considerations, such as interpretations based on pre-existing uses. This guidance, codified as Gov. Code Section 65041.1, prioritizes Community Separators.  Briefly, the priorities are to: a. Promote infill development and rehabilitation and utilization of existing infrastructure, including water, sewer, and transportation. b. Protect the state’s natural and working lands, including “greenbelts,” agricultural land, lands of cultural and historic significance, wetlands, and wildlands. c. Develop in an efficient manner that limits sprawl and minimizes costs to taxpayers.

Community Separators are anti-urban sprawl. The BZA’s finding will have consequences. There are thousands of parcels zoned RRD. We are concerned approval of this project would set a development-inducing precedent for rural lands. More commercialization of rural lands, more weddings, visitor-packed events, restaurants, bars, and music. It would endanger our rural heritage – a very precious commodity and a unique quality associated with Sonoma County life. Sprawl is also an inefficient and costly development pattern, as State law establishes. The voters knew this, and they overwhelmingly supported infill development, preservation of rural character and watershed protection. 


It is not appropriate for this body to go around the vote of the people.


Final words – Public Safety 

Conservation Action is concerned about inappropriate or unnecessary development in the Wildland-Urban Interface. Science tells us that urban or semi-urban development in the WUI creates increased fire risks. That affects the entire community.


This project is in a fire zone. Were it a vacation rental with multiple rooms, it could not be approved. The BZA should not approve a project that sets a bad precedent for fire safety in our rural lands.  


Thank you for considering our comments.


Michael Allen, Board Chairman       


Janis Watkins, Executive Board member