To: Board of Supervisors
Department or Agency Name(s): Permit Sonoma
Staff Name and Phone Number: Scott Orr and Isabella Wotring, (707) 565-1900
Vote Requirement: Majority
Supervisorial District(s): Countywide
Title:
Title
2:00 P.M. Objective Design Standards (ODS) for Housing Development Projects
End
Recommended Action:
Recommended action
Hold a public hearing and adopt an Ordinance finding the action categorically exempt from CEQA pursuant to Sections 15061(b)(3) (common sense exemption) and 15308 (actions by regulatory agencies for protection of the environment), and amending Sonoma County Code Chapter 26 (Zoning Regulations) to establish an initial set of Objective Design Standards (ODS) applicable to multi-unit housing development projects (not including a single-family dwelling proposed with an ADU/JADU), to implement the Sonoma County General Plan Housing Element Policy HE-2c and Program 12b, including the staff-recommended policy option for parking area markings as incorporated in Exhibit A.
end
Executive Summary:
Updates to State housing law continue to reduce or eliminate local government discretion on housing development projects to streamline development approvals and increase housing supply. The State Housing Accountability Act (HAA), Housing Crisis Act, and various other State housing laws limit local governments’ ability to apply discretionary standards or otherwise deny, reduce the density of, or render infeasible housing development projects that comply with local objective standards.
Design standards apply to the build-out of property addressing physical characteristics such as the massing of structures, landscaping, lighting, access and circulation, common and private open space, and related features. Design standards within the County’s Zoning Regulations, design guidelines, and various area and specific plans are largely subjective and unenforceable under State housing law. Creating objective design standards for multi-unit housing development projects is necessary to ensure the County’s practice complies with State law and to implement Program 12b of the General Plan Housing Element, which commits the County to adopt objective design standards for multifamily and mixed-use housing projects by the end of 2025.
Initial Objective Design Standards (ODS) are proposed to establish basic standards universally applicable to multi-unit housing developments without impacting design characteristics unique to communities. Future efforts may create standards addressing community-specific context to accommodate unenforceable subjective design standards in adopted Local Guidelines and area and specific plans.
On November 6, 2025, the Planning Commission voted unanimously to recommend approval of the proposed Ordinance.
Permit Sonoma recommends adoption of initial Objective Design Standards applicable to multi-unit housing development projects, except those consisting solely of a single-family dwelling proposed with allowed accessory units.
Discussion:
Project Description and History
The Sonoma County Housing Element includes policies and programs to support housing production and to align the County’s housing entitlement practices with State mandates. Timely implementation of Housing Element programs is essential to maintaining the County’s Prohousing designation and the certified status of the adopted Housing Element. Program 12b of the Housing Element commits the County to adopt Objective Design Standards (ODS) for multifamily and affordable housing projects by the end of 2025.
An in-depth audit of the existing Zoning Code, General Plan, and area and specific plans determined few of the County’s design standards are objective and enforceable under applicable State regulations for housing projects.
An early draft of standards was created in Spring 2024, informed by the approach of other local jurisdictions, and modified to be broadly applicable to the rural unincorporated County. The early draft standards were discussed with professionals from the local development and design community as well as other jurisdictions with adopted ODS. Staff introduced the effort to develop ODS at a Planning Commission workshop on September 19, 2024.
The proposed Ordinance would establish an initial set of ODS for multi-unit housing development projects (except projects consisting solely of a single-family dwelling and ADU). This will fulfill the County’s Housing Element commitment under Program 12b, better align the County’s practice with State housing law, and support housing development by streamlining the permitting process, providing clarity and consistency to developers and community members, and ensuring housing projects are designed for livability and compatibility without limiting creativity or innovation.
Statutory Background and Definitions
State housing law continues to reduce or eliminate local government discretion on housing development projects. The Housing Accountability Act (HAA), Housing Crisis Act, and various other State housing legislation requiring mandatory ministerial processing, currently applicable or soon to be applicable to the County, all necessitate objective design standards for housing development projects.
Housing development projects (HDPs) are defined by the HAA to include: a housing-only development with more than one residential unit (inclusive of single or multifamily structures), certain types of mixed-use developments, transitional or supportive housing, and farmworker housing. HDPs may consist of detached or attached residential units and may occupy more than one parcel, provided that the units are part of the same development application. The HAA also defines the term “objective” with reference to standards, conditions, and policies to mean:
“Involving no personal or subjective judgment by a public official and being uniformly verifiable by reference to an external and uniform benchmark or criterion available and knowable by both the development applicant or proponent and the public official.” (Government Code Section 65589.5(h)(9)).
For HDPs that comply with applicable objective general plan, zoning, and subdivision standards and criteria, including design review standards, in effect at the time the application is deemed complete, the HAA requires local governments to find that the project would have a specific, adverse impact on public health or safety based on objective public health or safety standards to deny the project or condition it to be developed at a lower density. Any development standards, conditions, and policies must also facilitate and accommodate development at the density permitted on the site and proposed by the development. Further, the HAA requires findings of inconsistency or noncompliance with applicable requirements to be made within 30 to 60 days from the date the application is determined to be complete, depending on the quantity of units proposed.
Additional legislation such as Senate Bill 330 (The Housing Crisis Act), Senate Bill 35, and various other State housing laws provide further protections for housing development projects against subjective standards, requiring fully ministerial processing of certain projects, establishing processes to freeze applicable standards, limiting the number of hearings that may be required, and prohibiting jurisdictions from adopting new standards that are not objective. With limited existing objective design standards that are enforceable under State housing law, the County is restricted in its ability to ensure housing development projects are designed to maximize livability and compatibility.
Future Phases
Permit Sonoma recommends future efforts to create objective design standards addressing community-specific context to accommodate unenforceable subjective design standards in adopted Local Guidelines and area and specific plans, as well as standards for single-family dwellings within the Scenic Resource (SR) Combining District. A single-family dwelling proposed with an ADU is considered a housing development project under the Housing Accountability Act, and County actions on this type of development must comply with the Act. Permitting processes for single-family dwellings and ADUs are already largely ministerial, except that single-family dwellings within the SR Combining District currently require discretionary Administrative Design Review. Subjective design standards of the SR District are not enforceable under the HAA for these projects. Future adoption of objective standards that further implement the policies and criteria of the General Plan and Zoning Code Article 64 (Scenic Resources Combining District) relevant to single-family dwellings would provide equivalent protection of valuable scenic resources while expediting permitting for housing.
Approach to ODS
Proposed amendments add new Article 83 Objective Design Standards (ODS) to Chapter 26 (Zoning Regulations), as well as update other parts of the Zoning Code to cross-reference the new standards, organize existing standards, and clarify design review requirements. The proposed Ordinance applies ODS (Article 83) to both market rate and affordable housing development projects as defined in the Housing Accountability Act (Gov. Code Sec. 65589.5(h)(2)), except for projects consisting solely of a single-family dwelling and ADU.
The proposed Ordinance includes three main categories of standards:
• Structure Design. Standards to ensure that buildings are compatible with the overall character of the County, incorporating industry-standard features such as massing breaks, material differentiation, window and glass reflectivity, base-flood elevation concerns, and other architectural features. Subcategories include: Height; Massing Breaks; Rooflines; Façades; Entries; Windows and Other Openings; Material Finishes and Themes; Waste Collection Facilities; Utilities and Screening; and Sound Walls.
• Site Design. Standards for the overall layout and circulation of a site including access, screening of parking areas, and privacy concerns to support compatibility with adjacent development. Subcategories include: Parking Areas; Landscaping; Open Space; and Screening for Neighborhood Compatibility.
• Exterior Lighting. Standards to reduce glare and light pollution.
Community Engagement and Outreach
Staff sought input from the design and development community in summer 2024 through workshops and individual interviews. Representatives from various development and design firms participated in outreach, providing input on early draft standards, sharing their experience working with other jurisdictions with adopted ODS, and supplying insight on the impact of design requirements on project feasibility. Staff also spoke with staff from other jurisdictions to gain insight on their experience developing and applying ODS.
Planning Commission Review
On September 19, 2024, the Planning Commission held a workshop to provide feedback on a preliminary draft of ODS. The Commission supported the development of objective design standards in general and emphasized the importance of leaving room for creativity and “charm” in the standards. Visual interest and aesthetic compatibility with the surrounding area was cited as a top priority, and particular concern was expressed for large stretches of blank walls with minor differentiation between. The Commission recommended consideration of the following within the phases of ODS implementation: public art, massing breaks and façade features, landscaping, and open space. Staff developed initial ODS to include minimum standards for visual interest, livability, and compatibility including massing breaks, façade features, landscaping, and open space, while leaving room for creativity. Future phases will address community-specific standards for character and consider features such as public art.
On November 6, 2025, the Planning Commission held a public hearing to consider proposed amendments to establish the initial phase of ODS. The Commission unanimously voted to recommend adoption of the proposed Ordinance (Resolution No. 25-13, Attachment 2). The Commission also directed staff to revisit standards for sound wall massing breaks before bringing the item forward to the Board. The Commission did not include in the motion but additionally expressed concern regarding the sufficiency of minimum open space square footages and potential problems prescribing paint for marking parking areas when alternative parking surfaces are proposed. Staff reviewed massing break requirements for sound walls against requirements by other jurisdictions and does not anticipate proposed standards will be a barrier for developers. Staff does not recommend modification to open space requirements at this time as minimum open space square footages are simply carried over from the County’s existing objective standards for multifamily dwellings. Additionally, the HAA requires objective standards not to inhibit development at the density designated for a parcel. Increasing open space square footage requirements could conflict with the HAA if resulting in a reduced possible density of a project due to space limitations or cost burden. However, staff do recommend a minor modification of the Ordinance to address the Commission’s concern regarding requiring paint in parking areas, as discussed in the next section. The Commission additionally discussed options for developers to exceed Objective Design Standards. Once adopted, developers will still have opportunities for relief from Objective Design Standards such as through concessions under State Density Bonus Law when proposing an eligible quantity of affordable units, or by electing the application of existing discretionary design review standards.
Policy Option for Parking Area Markings
The Planning Commission commented on the narrow prescription of paint for the delineation of off-street parking spaces and circulation directions as a potential barrier for developers seeking to use alternative surfaces for parking areas. Following this discussion, staff developed a policy option which modifies language to allow paint or other permanent indicators to be used. This policy option is incorporated in Exhibit A under Section 26-86-010 (p) and included in staff’s recommendation to adopt the proposed Ordinance.
General Plan Consistency
The project is consistent with the Sonoma County General Plan as follows:
• The project is consistent with the Housing Element as it implements Program 12b and supports Policy HE-1c, Policy HE-2c by creating objective design standards for multifamily and mixed-use housing development projects. developments. Policy HE-6b is further supported by standards which promote sustainable development.
• The project is consistent with the Open Space and Resource Conservation Element Policies OSRC-1f, OSRC-2f, OSRC-4a, OSRC-4b, OSRC-5b, and OSRC-6a as proposed amendments include design standards for discretionary projects among which are provisions to prevent excess light pollution, encourage pedestrian and bicycle amenities, meet requirements for stormwater infiltration and detention, and promote compatibility with rural character through screening, massing, finishes, and architectural features.
• The project is consistent with the Environmental Justice Element Policies EJ-4f and EJ-7a as proposed amendments include provisions to promote physical activity and recreational opportunities as well as standards to decrease privacy issues and reduce exposure to heat in preparation of changing climatic conditions.
• The project is consistent with the Water Resources Element Policies WR-1c and WR-4e as amendments include compliance with Low-Impact Development standards for stormwater management and the County’s Water Efficient Landscape Ordinance which promotes water conservation.
• The project is consistent with the Public Facilities Element Policy PF-2v as standards include the undergrounding of utilities for new housing development projects.
Environmental Review
Permit Sonoma has determined that the proposed amendments to Chapter 26 (Zoning Code) are exempt from the California Environmental Quality Act (CEQA) under State CEQA Guidelines Section 15061(b)(3) (the common sense exemption) and Section 15308 (actions to protect the environment). CEQA Guidelines Section 15061(b)(3) provides that CEQA applies only to projects which have the potential for causing a significant effect (substantial adverse change) on the environment. It can be seen with certainty that there is no possibility the project will result in a direct or indirect adverse change in the environment because the code amendments do not make changes to allowed land uses or intensities and instead provide objective design standards where subjective standards previously applied, covering all the same topics and ensuring potential aesthetic impacts are addressed. Additionally, or alternatively, the ordinance is exempt under CEQA Guidelines Section 15308, which provides that actions by regulatory agencies to assure enhancement or protection of the environment are categorically exempt from CEQA. The proposed amendments would only enhance and improve protections of the environment because the objective standards are more specific and more restrictive than the current subjective design review standards, thus ensuring greater protections to aesthetic resources, and because the current subjective standards are often unenforceable under the HAA. Further, all projects currently reviewed under CEQA will continue to be subject to environmental review.
Recommendation
Recommended action
Adopt an ordinance (Attachment 1) finding the action categorically exempt from CEQA pursuant to Sections 15061(b)(3) (common sense exemption) and 15308 (actions by regulatory agencies for protection of the environment), and amending Sonoma County Code Chapter 26 (Zoning Regulations) to establish an initial set of Objective Design Standards (ODS) applicable to multi-unit housing development projects (not including a single-family dwelling proposed with an ADU/JADU), to implement the Sonoma County General Plan Housing Element Policy HE-2c and Program 12b, including the staff-recommended policy option for parking area markings as incorporated in Exhibit A.
Strategic Plan:
N/A
Racial Equity:
N/A
Was this item identified as an opportunity to apply the Racial Equity Toolkit?
No
Prior Board Actions:
August 22, 2023: Adoption of the 2023-2031 Housing Element
Fiscal Summary
N/A
Narrative Explanation of Fiscal Impacts:
N/A
Narrative Explanation of Staffing Impacts (If Required):
N/A
Attachments:
Attachment 1: Draft Ordinance with Exhibit A
Attachment 2: Planning Commission Resolution No. 25-13
Attachment 3: Planning Commission Staff Report, November 6, 2025
Attachment 4: PowerPoint Presentation
Attachment 5: Public Comments
Attachment 6: Legal Notice of Public Hearing with Pre-Adoption Summary and Affidavit
Related Items “On File” with the Clerk of the Board:
N/A