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San Joaquin County Community Development Dept. September 4, 2001 Page Three WEDDING RECEPTIONS AND PRIVATE PARTIES ARE NOT MARKETING EVENTS . It is our position that renting the Harmony Wynelands facilities to private parties for wedding receptions, parties or related celebrations simply does not come within the definition of "marketing events" as provided by the ordinance . It should be noted that the ordinance defines a marketing event as being "for the purpose of promoting the wine industry and marketing wine" and gives examples such as educational wine tours, non- profit fundraising, private seminars, and events for wine industry groups . (Ordinance Section 9-110 .4, Division 1) . The ordinance does allow wineries to hold (subject to some limitations) marketing events and special events, however, there is no mention of facility rental . Section 9-1075 . 1 makes it clear that "a major purpose of this ordinance is to guarantee that both winery and wine seller marketing events are accessory and are subordinate to the primary agricultural use. A strong nexus must exist between the marketing event and the production or storage of wine. The focus of marketing events should be wine. " It has been suggested in the past that merely having the owners wine available for a reception would be sufficient to justify facility rentals for parties, receptions, and the like . My clients believe in allowing great leeway for legitimate wine marketing activities such as tasting, lectures, new releases, meetings, retail sales, and supervised tours . They are adamantly opposed to defining the ordinance in such a way to allow a small land owner to rent out a hall attracting large numbers of people to engage in parties and receptions which include unregulated drinking, amplified music, noise, and trespass under the guise that somehow certain individuals are being introduced to the landowner' s wine. If that is justification, then such a landowner should also be entitled to hold rock concerts and sporting events under the theory that new people will be introduced to his wine.