HomeMy WebLinkAboutRESOLUTION 2026-021 N.C.S. 02-23-2026
Resolution No. 2026-021 N.C.S. Page 1 of 3
Resolution No. 2026-021 N.C.S.
of the City of Petaluma, California
RESOLUTION OF THE CITY COUNCIL OF THE CITY OF PETALUMA ADOPTING PETALUMA
FAIRGROUNDS FREE SPEECH ACTIVITIES GUIDELINES
WHEREAS, the City of Petaluma owns and operates the Petaluma Fairgrounds, a multi-use facility
located at 175 Fairgrounds Drive that serves as the site of the annual Petaluma Fair as well as a variety of public
and private events throughout the year; and
WHEREAS, the City affirms that the Petaluma Fairgrounds, including its event spaces and parking areas,
are limited public forums during scheduled events and not dedicated public parks or traditional public forums,
and may be regulated consistent with constitutional standards for such facilities; and
WHEREAS, the City recognizes and affirms the importance of protecting the rights of individuals to
engage in expressive activity under the First Amendment to the United States Constitution and Article I of the
California Constitution, while ensuring unobstructed, safe access and movement for Fairgrounds patrons and
emergency personnels; and
WHEREAS, the unique nature of the Fairgrounds, including its enclosed facilities, parking areas, and
heavily trafficked pedestrian access points during events, necessitates a reasonable and content-neutral framework
to regulate the time, place, and manner of expressive activity for the safety and convenience of all attendees; and
WHEREAS, the Petaluma Fairgrounds Free Speech Guidelines (“Guidelines”), attached hereto as Exhibit
A, establish reasonable regulations designed to balance the rights of those engaging in expressive activity with
the City’s interest in ensuring public safety, maintaining orderly event operations, and protecting emergency
access routes; and
WHEREAS, the Guidelines provide clear and equitable standards for use of designated free expression
zones, including rules for signage, sound amplification, spontaneous gatherings, and access to booth space during
events, while prohibiting viewpoint discrimination and promoting fair access to all speakers; and
WHEREAS, the Guidelines incorporate procedural safeguards to ensure due process for individuals
engaged in expressive activity, including opportunities to contest ejections, request return of confiscated items,
and seek on-site supervisory review of enforcement decisions; and
WHEREAS, the Guidelines are also intended to inform the public, event participants, and organizers
about their rights and responsibilities with respect to expressive activity at the Fairgrounds, thereby reducing
confusion and potential conflicts; and
WHEREAS, the City intends to ensure consistent and lawful implementation of the Guidelines by
providing clear operational procedures and training for City staff and event security on the content-neutral
enforcement of the Guidelines and the rights of the public under applicable law; and
WHEREAS, the Ninth Circuit Court of Appeals recently upheld a materially similar free speech policy
for the California State Fairgrounds as constitutional under both the federal and California constitutions in
Camenzind v. California Exposition & State Fair, 84 F.4th 1102 (9th Cir. 2023) (“Carmenzind”); and
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Resolution No. 2026-021 N.C.S. Page 2 of 3
WHEREAS, the City has modeled its Petaluma Fairgrounds Free Speech Guidelines on the policy upheld
in Camenzind, thereby ensuring that the Guidelines are aligned with current constitutional standards and judicial
precedent; and
WHEREAS, the Guidelines also recognize that when the City of Petaluma sponsors or curates events at
the Fairgrounds, it may lawfully exercise discretion over the content and participants in such events consistent
with the government speech doctrine, as affirmed by the United States Supreme Court in Pleasant Grove City v.
Summum, 555 U.S. 460 (2009), and such discretion does not convert curated spaces into public forums; and
WHEREAS, adoption of the Petaluma Fairgrounds Free Speech Guidelines reflects the City’s
commitment to upholding the rights of free expression while ensuring a safe and functional environment for all
Fairgrounds patrons and event participants; and
WHEREAS, the proposed action is exempt from the requirements of the California Environmental
Quality Act (CEQA) in accordance with CEQA Guidelines Section 15378(b)(4), in that approving this action
does not meet CEQA's definition of a “project,” because the action does not have the potential for resulting either
a direct physical change in the environment or a reasonably foreseeable indirect physical change in the
environment; and
WHEREAS, if this action were a “project” under CEQA, it would be exempt from CEQA pursuant to Section
15301 (Existing Facilities) of the CEQA Guidelines, as the Petaluma Fairgrounds Free Speech Activities
Guidelines applies only to the Petaluma Fairground which is an existing public facility, with negligible or no
expansion of existing or former use, and CEQA Guidelines Section 15305 (Minor Alterations to Land Use) as the
Guidelines would apply temporary events and temporary free speech activities at the Petaluma Fairgrounds.
NOW, THEREFORE, BE IT RESOLVED, by the City Council of the City of Petaluma as follows:
1. Declares the above recitals to be true and correct and are incorporated into this resolution as findings of the
City Council.
2. Finds that the proposed action is exempt from the requirements of the California Environmental Quality Act
(CEQA) in accordance with CEQA Guidelines Section 15378(b)(4), in that approving this action does not
meet CEQA's definition of a “project,” because the action does not have the potential for resulting either a
direct physical change in the environment or a reasonably foreseeable indirect physical change in the
environment. If this action were a “project” under CEQA, it would be exempt from CEQA pursuant to Section
15301 (Existing Facilities) of the CEQA Guidelines, as the Petaluma Fairgrounds Free Speech Activities
Guidelines applies only to the Petaluma Fairground which is an existing public facility, with negligible or no
expansion of existing or former use, and CEQA Guidelines Section 15305 (Minor Alterations to Land Use)
as the Guidelines would apply temporary events and temporary free speech activities at the Petaluma
Fairgrounds.
3. Adopts the Petaluma Fairgrounds Free Speech Activities Guidelines, (“Guidelines”) attached hereto as
Exhibit A, and authorizes the City Manager with the consent of the City Attorney to make subsequent minor
changes to the Guidelines.
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Under the power and authority conferred upon this Council by the Charter of said City.
REFERENCE: I hereby certify the foregoing Resolution was introduced and adopted by the
Council of the City of Petaluma at a Regular meeting on the 23rd day of February
2026, by the following vote:
Approved as to
form:
__________________________
City Attorney
AYES: Mayor McDonnell, Vice Mayor DeCarli, Council Members Barnacle, Cader
Thompson, Nau, Quint, Shribbs
NOES: None
ABSENT: None
ABSTAIN: None
ATTEST: ______________________________________________
City Clerk
______________________________________________
Mayor
Attachments: Exhibit A – City of Petaluma Fairgrounds Free Speech Activities Guidelines
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Fairgrounds Free Speech Activities Guidelines 1
City of Petaluma Fairgrounds Free Speech Activities Guidelines
Section I – Findings
The City of Petaluma (City) hereby adopts the Petaluma Fairgrounds Speech Activities
Guidelines (Guidelines). The City of Petaluma hereby finds that the Guidelines are intended to
set forth in writing the Fairgrounds policy governing the conduct of City employees as well as
members of the public under the First Amendment to the United States Constitution and Article I
of the California Constitution, on Petaluma Fairgrounds property, located at 175 Fairgrounds
Drive, Petaluma, CA (Fairgrounds). A map of the Fairgrounds is provided in Exhibit A,
attached hereto. A map of the designated free expression zones is provided in Exhibit B,
attached hereto. If the City operates any City-curated programming inside a paid gate (including
any “Community Resources Showcase” or similar City-curated program), the terms of such
City-curated programming are described in Exhibit C, attached hereto.
Nothing in these Guidelines is intended to regulate expressive activity occurring on public
streets, sidewalks, or public rights-of-way adjacent to the Fairgrounds; such areas are governed
by generally applicable law and Citywide regulations. These Guidelines are not intended to
enlarge upon nor create any rights guaranteed by existing law nor waive defenses or rights
available to the City, nor do they represent any admission that the facilities of Fairgrounds, or
any portion thereof, are open as a public forum. It is the policy of the City to allow, within the
parameters set forth herein, reasonable access to its grounds and designated free speech
expression zones for demonstrations for free speech activity as allowed by the First Amendment
to the United States Constitution and Article I of the California Constitution.
The City finds that, due to the unique nature of the Fairgrounds and the various events held on-
site, unrestricted or unregulated free speech activities could interfere with public safety,
emergency response operations, and the general ingress and egress of event patrons. Specifically:
1. Pedestrian & Traffic Flow Concerns – The Fairgrounds are surrounded by limited parking
areas that experience high volumes of vehicle and pedestrian traffic during events. Large,
unregulated gatherings or demonstrations near entry points, parking lots, or pedestrian
walkways could result in congestion, creating hazards for patrons and impeding access to
and from the Fairgrounds.
2. Emergency Services & Public Safety – The City finds that free and unobstructed access
for emergency medical personnel, fire services, and law enforcement is critical to
ensuring the safety of all attendees. Large groups engaged in free speech activities near
emergency access routes or within high-traffic zones could significantly delay or prevent
emergency response efforts. Additionally, unexpected crowd surges, physical
obstructions, or conflict between opposing groups could create a substantial public safety
risk.
3. Event Operations & Private Rentals – Many Fairgrounds events, including private rentals
and City-sponsored activities, rely on controlled access and orderly operations to ensure a
safe and enjoyable experience for attendees. The presence of large, unregulated
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Fairgrounds Free Speech Activities Guidelines 2
gatherings or disruptive activities within enclosed event spaces could interfere with event
logistics and attendees' ability to participate without undue interference or obstruction.
4. Minimization of Conflicts & Public Disturbances – While the City supports and
acknowledges the importance of free speech activities, it also finds that large-scale,
opposing demonstrations in close proximity may increase tensions, disrupt event
operations, or escalate into conflicts requiring law enforcement intervention. By
establishing designated free expression zones, the City seeks to ensure that those
engaging in free speech activities may do so without unduly interfering with others while
maintaining public order and safety.
The City recognizes that during times when the Petaluma Fair is not in session, certain areas of
the Fairgrounds may be accessible to the public for recreational use and resemble the character of
a public park. However, these areas are not dedicated public parks within the meaning of
traditional public forum doctrine. Rather, they remain part of a multi-use, event-oriented venue
subject to operational needs, maintenance, and permitted uses. Temporary recreational
accessibility does not remove the City’s ability to impose reasonable time, place, and manner
restrictions or other reasonable, viewpoint-neutral regulations consistent with the intended use of
the property consistent with the Fairgrounds’ overarching status as an event-focused venue.
When the Fairgrounds are used for Events or other scheduled activities, such areas may be
restricted or regulated accordingly. The mere accessibility of portions of the Fairgrounds for
public recreation outside of the Fair does not convert the Fairgrounds into a traditional public
forum. During the annual Petaluma Fair, or other Events, the City reserves the right to enforce
these Guidelines, including the designation of limited public forums and regulation of time,
place, and manner of expression. For clarity, during Events the City may operate enclosed and/or
ticketed areas (including areas within a paid gate) as nonpublic forum or as limited public forum
for only those speakers/activities expressly authorized by the applicable Event rules or
agreement, and may limit expressive activity in such areas to the terms of these Guidelines and
applicable agreements, while providing reasonable alternative channels for expression, including
the designated free expression zones.
These provisions are intended to act as guidelines for reasonable regulation of time, place and
manner of speech and are not intended to regulate the content of such speech. Nothing in these
Guidelines authorizes differential treatment based on the viewpoint of a speaker. For clarity,
during Events the area within any Paid Gate is not open for general public expressive activity
and is operated as a nonpublic forum, except for City-curated programming described in Section
VI and Exhibit C.
Section II – Definitions
For purposes of these Fairgrounds Guidelines:
1. “City-curated Showcase Program” – means any City-designed, City-controlled program or display
presented by the City inside a paid gate) where the City selects participants (if any) and retains final
editorial control over the message and materials, as further described in Exhibit C.
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2. “Enclosed Facility” – means any on-site structure contained on the Fairgrounds and any
enclosed or semi-enclosed building or structure of any nature whatsoever, including
buildings, barns, halls, pavilions, and similar structures, and areas enclosed by fencing or
separated by a paid gate.
3. "Event" – means any organized gathering, activity, or function held at the Fairgrounds
that is officially scheduled, permitted, or authorized by the City. This includes, but is not
limited to, fairs, festivals, concerts, exhibitions, trade shows, sporting events, or private
rentals, during which patrons and guests are expected to be in attendance.
4. "Fighting Words" - Fighting words are those words which when addressed to the
ordinary person are, as a matter of common knowledge, inherently likely to provoke an
immediate violent reaction. This definition shall be interpreted consistent with Chaplinsky
v. New Hampshire, 315 U.S. 568 (1942). City staff will not make final determinations that
speech falls within this narrow category absent law enforcement input when feasible and
will prioritize content-neutral enforcement of obstruction/safety rules.
5. “Free Expression Zone” – A free expression zone is a designated area located on-site as
established by the City, to which members of the public may be provided reasonable
access in accordance with these Guidelines for purposes of conducting free speech
activities. Free Expression Zones are located in visible, high-traffic areas. The designated
Free Expression Zone locations are shown in Exhibit B. For particular Events or site
conditions, the City may temporarily modify, relocate, expand, or reduce the Free
Expression Zone locations based on documented operational and safety needs, including
pedestrian/vehicular flow, emergency access, accessibility requirements, construction or
maintenance, ticketing/layout constraints, and the location of Event entry/exit points,
provided that any such modification is reasonable, viewpoint-neutral, and leaves open
reasonable alternative channels for expression. When practicable, the City will post or
make available an updated map or description of any temporary modifications for that
Event.
6. “Free Speech Activities” – means individual or group display of signs, picketing,
leafleting, collection of signatures or marching and any group activity involving the
communication or expression, either orally or by conduct of views and/or grievances, and
which affects, intends to affect, or has the propensity to effect the expression of that view
or grievance to others.
7. “Large Group” – A large group means more than 10 affiliated persons engaging in
coordinated free speech activity. A Large Group determination may consider coordinated
signage, shared staffing, coordinated messaging, and arrival/departure together; it does
not include coincidental presence of unrelated individuals.
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8. “Limited Public Forum” – A limited public forum is a space designated for expressive
activity but with access restricted to certain speakers or topics, wherein the public is
allowed access to a facility or facilities for specific purposes and where any public debate
or discussion on political or social issues is focused on a particular subject or subjects. A
limited public forum is a type of forum the City intentionally opens for a limited purpose;
restrictions in a limited public forum must be reasonable and viewpoint-neutral and
consistent with the purpose of the forum. In a limited public forum, the City may impose
reasonable, viewpoint-neutral restrictions that are consistent with the purpose of the
forum.
9. "Obscene" - Obscene means any sexually explicit material or communication which,
taken as a whole and applying contemporary community standards, appeals to prurient
interests, depicts or describes sexual conduct in a patently offensive way as specifically
defined by applicable law, and lacks serious literary, artistic, political, or scientific value.
This definition shall be interpreted consistent with Miller v. California, 413 U.S. 15
(1973), including its three-part test.
10. “On-site” – On-site means any activities occurring within the grounds or parking lot of
the Fairgrounds.
11. "Paid Gate" - A paid gate is a physical barrier or other demarcation separating an area
of the Fairgrounds, the entry past which is restricted and predicated upon purchase of
paid parking and/or an admission ticket, or possessing another form of entitlement
prior to entry, like an invitation from the City or permitee/licensee of the City. This can
include the general area of Fairgrounds enclosed by a fence, and/or any enclosed
facility within the Fairgrounds. “Paid Gate Area” means the area beyond a Paid Gate
where entry is restricted as described above.
12. “Public Forum” – A public forum is a space wherein the facilities are available to
members of the public for a free and open discussion or debate of political or social
issues.
13. "Sound Devices" - Sound devices include any loudspeakers, megaphones or other
devices, electrical or mechanical, which amplify or transmit sound waves.
14. “Spontaneous Expression” - Spontaneous expression means expressive activity in
response to Events coming into the public knowledge within the immediately
preceding forty-eight hours.
15. “True Threat” – A true threat means a statement or course of conduct that a
reasonable person would understand as a serious expression of an intent to commit
an act of unlawful violence against a particular individual or group of individuals.
For purposes of enforcement, determinations regarding “true threats” will be made
consistent with applicable constitutional standards, including the requirement of a
sufficient mental state (at least recklessness) as recognized in Counterman v.
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Colorado, 600 U.S. 66 (2023). For enforcement under these Guidelines, City staff
will refer suspected true threats to law enforcement consistent with applicable law
and constitutional standards.
16. Unprotected Incitement” (or “Incitement”) means speech that:
(1) is intended to incite or produce imminent lawless action; and
(2) is likely to incite or produce such action.
This definition shall be interpreted consistent with Brandenburg v. Ohio, 395
U.S. 444 (1969). Advocacy of unlawful conduct in the abstract, or mere
persuasion, does not constitute unprotected incitement.
Section III - On-Site Free Speech Activities
1. Findings: City finds that the Fairgrounds are operated primarily as an event-oriented
venue and are not generally held open as a traditional public forum. It is the policy of
City nevertheless, to allow free speech activity wherever said activity is not inconsistent
with the normal operations or activities of City; City finds, however, that due to the
unique nature of the Fairgrounds, there is limited access necessitating creation of free
expression zones. During Events, the City will direct organized expressive activity to
Free Expression Zones in order to protect ingress/egress, emergency access, and safe
operations, while providing reasonable alternative channels for communication. City
specifically finds that the buildings and grounds comprising Fairgrounds are generally
surrounded by parking areas under the control of City, but which areas become
congested with numerous vehicles during events. City further finds that pedestrian traffic
is generally confined to walkways to and from these parking areas to the gates of the
Fairgrounds and that the designated free expression zones are designed to balance the
interests of those engaged in free speech activity and being given reasonable access to
the patrons of Events at the Fairgrounds, and the safety of the patrons and prevention of
accidents or congestion which could lead to injury.
Further, City finds that these Guidelines in the providing of free expression zones are
balanced to protect the interests of patrons attending Events upon Fairgrounds from
inappropriate or inconsistent activity or conduct by those engaged in free speech activity,
with the interest of those engaged in such free speech activities. City’s solution to this
balancing of interests is designation of free expression zones and restrictions on time,
place and manner of said expressions to ensure reasonable access by those engaged in
free expression activity to those attending the Fairgrounds, while protecting the overall
safety of the public.
2. Free Expression Zones: City shall designate free expression zones on site for the purpose
of providing access for free speech activity. These zones shall be selected by City. The
area selected by City shall be selected to provide maximum reasonable access by those
involved in First Amendment activities to patrons of Fairgrounds, commensurate with
public safety as well as the safety of those individuals engaged in such activity, and shall
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interfere to the minimum extent possible with the free flow and passage of patrons to and
from the parking areas and Fairground. City officials shall remain flexible in the
application of space limitations and zone assignments to ensure that expressive activity is
not unduly burdened, especially in response to spontaneous Events. The zones shall be
clearly marked and may have a sign posted by City, which sign shall state that the views
expressed by those utilizing the free expression zones are not necessarily the views of
City. The Free Expression Zones are located outside any Paid Gate unless the City
expressly designates a temporary internal zone for a City-authorized purpose (e.g., City-
curated programming). The City does not open the Paid Gate Area for general public
expressive activity. The default free expression zones for the Fairgrounds are shown in
Exhibit B, attached hereto.
3. On-site Registration: Large groups are encouraged to register with City prior to each on-
site free speech Event. For those not meeting the definition of a “large group,”
registration is not mandatory but early registration may allow the applicant to select the
desired free expression zone The purpose of registration is not to censor in any way or
review discretionarily the content of the speech involved, but to allow sufficient
opportunity for City to assign space for free speech activities and to provide the
participants with copies of those rules governing the use of free expression zones.
Registration will be granted on a first-come, first-served basis. Registration requests
may be submitted up to 30 days in advance; the City encourages submission at least 48
hours in advance when feasible to assist with space planning. Interested parties may
obtain an application online or at the Petaluma Parks and Recreation office Monday
through Thursday from 10 a.m. to 4 p.m., located at 320 N McDowell Blvd Petaluma,
CA 94954. Completed applications may be submitted by fax, email or in person. The
application template is attached hereto as Exhibit D and the information to be provided
shall include:
a. The time of the planned Event;
b. The nature of the planned activity;
c. The approximate number of individuals in the group being registered.
d. A designated contact person, including a means of communication with said
person such as a street address, email address, and/or phone number; and
e. If funds are to be solicited, the applicant may (optionally) describe the general
purpose for which voluntary contributions will be used. Any such description is
requested for administrative planning and consumer-information purposes only
and will not be reviewed for approval or disapproval of any viewpoint.
Registration is voluntary and is not a precondition to engaging in protected speech,
except in the limited circumstances the City determines, based on specific and
articulable facts, that advance coordination is necessary to prevent substantial
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obstruction of access routes or to address a substantial and imminent public safety risk
that cannot reasonably be addressed through less restrictive means. Any decision to
require advance coordination for a Large Group must be approved by the supervising
City official on duty (or designee) and documented when practicable.
In review of registration, the City will not discriminate on the basis of content, ideas, or
beliefs. However, the City may require certain individuals or organizations to engage in
free speech activities in different areas of the Fairgrounds or maintain a reasonable
distance from other individuals or groups if separation is necessary to protect public
safety, prevent significant obstruction, or avoid imminent unlawful disturbances.
Separation shall only be required if there is a specific, articulable safety concern based
on credible evidence from law enforcement or Event security. A history of conflict
alone shall not be a sufficient basis for separation unless an immediate risk is present.
When separation is required, City staff will provide reasonable alternative locations that
allow substantially similar access to Event patrons, to the extent feasible.
The City may impose such separation requirements only if one or more of the following
objective criteria are met:
• Obstruction of Public Access: The proximity of groups creates an unreasonable
obstruction to pedestrian or vehicular traffic that cannot be mitigated through
other reasonable means.
• Verified Public Safety Risk: Law enforcement or safety officials determine that
the close presence of opposing groups within a confined space creates a
substantial and imminent risk to public safety that cannot be effectively
managed by other means.
Any decision to require separation of groups shall be based solely on objective safety
considerations and not on the content or viewpoint of the speech involved.
4. In order to accommodate the maximum number of individuals and groups within the
free expression zone while maintaining public safety, the number of individuals in each
designated space shall be limited based on a reasonable occupancy standard. City staff
may establish and post a maximum occupancy for each designated free expression zone
(or sub-area) based on the physical dimensions of the space, pedestrian flow,
accessibility requirements, and safety considerations. Any posted maximum occupancy
will be based on documented space/safety/accessibility considerations and applied
uniformly. Where space and event conditions allow, City officials may approve
reasonable modifications to group size limits or designated space allocations upon
request, provided that such accommodations do not pose a public safety risk or disrupt
the normal flow of event operations.
Each individual or group will be assigned a designated area within the free expression
zone that ensures adequate space for movement and visibility while preventing
overcrowding and obstruction.
5. Any organization(s) or individuals seeking to engage in free speech activities shall
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ensure their conduct and the use of any signs, banners, or other devices do not result in
injuries to patrons or property and prevent obstructions; persons engaged in free speech
activities shall comply with the following restrictions on time, place and manner:
a. Persons engaging in free speech activity shall not, individually or as a group, or
with the use of signs, banners, or other items, obstruct the ingress or egress of
persons, block pedestrian pathways, or interfere with emergency services in any
way. Participants must ensure that their activities do not create a hazardous or
unreasonably congested environment for event attendees, staff, or emergency
personnel;
b. No individual or group engaged in free speech activity shall represent to anyone
that the views they express are necessarily the views of City or that City in any
way condones or supports said views;
c. Patrons declining to listen, converse, provide a donation or signature, or accept
any item offered by those engaged in free speech activities shall not be pursued,
restrained, or touched once that patron has clearly indicated they wish to be left
alone;
d. No one using a free expression zone shall interfere with any other individual’s
or group’s use of any free expression zones, nor shall they establish a second
location for coordinated free speech activity outside their assigned area. This
provision does not prohibit incidental movement reasonably necessary to hand
literature to passersby consistent with subsection (m), provided that participants
do not obstruct ingress/egress and return to their assigned area;
e. Those individuals or groups engaged in free speech activities may provide one
table and chairs, and/or one shade structure as set forth more specifically in
Section III(6)(a-b) herein;
f. No one shall use signs or displays, or pass out or show literature or any other
thing which employs or displays fighting words, contains language or imagery
that is legally obscene, or constitutes unprotected incitement. City staff will not
restrict or direct cessation of expressive activity based on content
determinations unless the speech falls within an unprotected category as
determined by law enforcement when feasible, or unless immediate action is
necessary to address a specific and articulable safety risk. City staff may direct
the cessation of unlawful conduct (as determined by law enforcement when
feasible) and may require relocation or discontinuance of activity based on
objective safety/access impacts. City staff should prioritize content-neutral
responses (e.g., enforcing obstruction rules) and, when feasible, refer questions
about whether particular speech falls within an unprotected category to law
enforcement. City staff will not seize expressive materials based on content; any
seizure or evidentiary retention will be handled by law enforcement pursuant to
applicable law.
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g. No one shall use any sound devices which create a nuisance, are likely to create
hearing damage, or will create noise of sufficient volume to impinge on the
hearing and peace of the general public. No sound device shall be used to
broadcast any fighting words, words that are unprotected incitement or legally
obscene material. Use of all sound devices shall comply with all applicable
laws, including the City’s noise ordinance. City staff may require adjustment or
cessation of amplification based on objective criteria, including compliance
with applicable decibel limits (if any), interference with event announcements,
or documented safety/accessibility impacts; and City staff will, where feasible,
seek compliance through volume reduction, repositioning, or limiting duration
before requiring cessation. If a decibel limit applies under City ordinance or
event-specific rules, staff will use that limit where practicable; otherwise, staff
will document the objective basis for any determination that amplification is
materially interfering with event announcements, emergency communications,
or accessibility/safety. Where no specific decibel limit applies, staff will base
decisions on objective impacts such as interference with Event announcements,
emergency communications, accessibility, or documented safety/operational
disruption, and will document the observed impact when practicable.
h. Individuals or groups utilizing free expression zones outside of the paid gate
shall occupy such areas no earlier than one hour prior to the event and no later
than 30 minutes after the closing of the event, unless the City posts different
times for a particular Event based on operational needs. In order to give
everyone an opportunity to access free expression zones, please claim your spot
within one hour after the start time of the event to ensure space; if the space is
not so occupied, your space may be given to another interested party. All
equipment and articles brought into the free expression zone must be removed
daily;
i. If funds are solicited, they will not be demanded nor required in return for any
materials. This prohibition shall not be construed as preventing all solicitations
of voluntary contributions;
j. Any vehicles brought on the Fairgrounds by those persons engaged in free
speech activities shall be parked in the public lots and regular parking fees
shall be paid, if any;
k. The violation of any of the terms of these guidelines, depending on the
circumstances, can be grounds for the discontinuance by City of such activity,
expulsion off the Fairgrounds, citation by law enforcement, or arrest. Except
where immediate action is necessary to address an articulable safety risk or
unlawful conduct, City staff should provide a warning and an opportunity to
comply before requiring cessation or ejection. Staff should document the
reason for any ejection when practicable. Any ejection or exclusion decision
must be based on objective, viewpoint-neutral application of these Guidelines
or other applicable law, and not on anticipated or actual hostile audience
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reaction;
l. Individuals or groups utilizing the free expression zones shall not themselves,
nor shall they allow any of their employees, agents, or representatives, while
using an assigned free expression zone, be under the influence of alcohol or any
illegal substance;
m. Individuals or groups utilizing the free expression zones may distribute leaflets,
pamphlets or other materials, which may be handed to passersby. Distribution
and solicitation activity shall occur from within the assigned free expression
zone space, except for incidental steps reasonably necessary to hand literature
to willing passersby, after which participants must promptly return to their
assigned space,so long as the persons engaging in leafleting do not obstruct the
ingress or egress of persons or interfere in any way with those providing
emergency services. Leaflets or other material distributed by persons engaging
in free speech activity shall not be placed on cars, left unattended or be left in a
manner that can cause the leaflets to be blown away; materials must be
discarded in designated locations, such as waste or recycling receptacles; and
n. Individuals or groups may not use free expression zones for commercial sales or
solicitation of sales leads. However, this provision shall not apply to the sale or
distribution of expressive materials protected under the First Amendment,
including books, pamphlets, buttons, or other printed materials, provided that
such sales do not obstruct public access or event operations. These prohibitions
shall not be construed as preventing individuals utilizing free expression zones
from soliciting voluntary contributions.
o. Audience Reaction / Safety Response. City staff will not restrict or relocate
expressive activity based solely on anticipated or actual hostile audience
reaction. When feasible, the City will address safety risks through reasonable,
content-neutral crowd management and enforcement of laws against unlawful
conduct, consistent with public safety and operational needs.
6. To ensure accessibility, prevent obstructions, and maintain the orderly use of free
expression zones, the following equipment may be brought onto the Fairgrounds,
including, but not limited to, the free expression zones and inside the paid gate, for use
in free speech activities within the designated free expression zone:
a. Participants may use one (1) portable table per designated free expression zone
space, subject to the following conditions. The table must be a foldable, portable
card table or similar structure and must fit entirely within the designated free
expression zone space, and not block pedestrian pathways, emergency access
routes, or other public areas. Be securely positioned to prevent tipping or creating
a tripping hazard. Oversized tables, rigid non-folding tables, or any table that
extends beyond the designated free expression zone space are not permitted;
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b. Shade structures (pop-up tents with no walls) shall be limited to one per free
expression zone space, shall fit within the free expression zone; shall be flame
retardant and so labeled by the manufacturer, must fit within the designated free
expression zone space and anchored so as not to unreasonably obstruct visibility
or create a safety issue. Anchoring requirements may be specified by the City for
wind/safety conditions Non-compliant shade structures must be removed by the
participant upon request; if the participant declines, staff may require removal as
a condition of continued use of the zone and may remove/relocate the structure
only to address an immediate safety hazard. No lawn, beach, or patio-style
umbrellas, and any other unsecured or unstable shade structures are not permitted
due to their potential to create obstructions or safety hazards;
c. Signs, posters, placards, or banners shall not be permanently affixed, fastened, or
leaned against any City-owned wall, partition, building, structure, pole, or
planter. No attachment to City-owned structures is permitted. Additionally, signs,
posters, placards, or banners may be securely affixed to privately owned tables,
chairs, or structures brought by the individual, so long as they remain within the
designated free expression zone and do not extend into pedestrian walkways or
other restricted areas;
d. Any materials found to pose a safety risk or cause damage may be removed by
City officials only to the extent necessary to abate the physical hazard or prevent
damage. Any confiscation will be temporary and returned in accordance with
Section (III)(7) and will be handled by law enforcement pursuant to applicable
law. Any necessary pens, pencils, paper clips or clip boards and leaflets,
provided, however, that any leaflets shall be weighted so that they are secured
and not subject to being blown off the table.
7. Return of Confiscated Items: After the event is over and/or after the free speech activities
are concluded, or upon departure, upon request therefore, said material or displays will be
returned promptly to said organization or individuals absent contraband status or other
lawful basis for continued retention. When practicable, City staff will provide a brief
written receipt describing any item temporarily retained, the reason for retention, and the
process for reclaiming it.
8. Spontaneous Expression: Notwithstanding the Fairgrounds Guideline’s encouragement
of 48-hour registration for large groups, such a registration will not be required for
persons or groups engaging in spontaneous expression.
If spontaneous expression results in a gathering that exceeds the available space within a
designated free expression zone, the City shall make reasonable efforts to identify and
allocate additional space to accommodate demonstrators, provided such an expansion
does not create a substantial and imminent risk to public safety, obstruct emergency
access, or significantly disrupt event operations.
The City may relocate, expand, or adjust the designated free expression zones in real
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time to accommodate spontaneous demonstrators as conditions allow, ensuring that the
right to engage in expressive activities is not functionally restricted due to space
limitations. The assignment of additional space shall be determined based on safety
considerations, pedestrian flow, event capacity, and overall feasibility.
City officials shall make reasonable efforts to balance the need for access to spontaneous
speech opportunities with the necessity of maintaining a safe and orderly event
environment;
Section IV – Free Speech Activities Within an Enclosed Facility
1. Findings: Free speech activities are generally prohibited within enclosed facilities due
to congestion, safety concerns, and private rental agreements. During Events, the City
does not open Enclosed Facilities or the Paid Gate Area for general public expressive
activity. The City may restrict expressive activity in Enclosed Facilities and the Paid
Gate Area to maintain safe and orderly operations, consistent with applicable law. For
clarity, areas within a paid gate (including ticketed event areas) may be subject to
additional access controls and may be operated as nonpublic fora during events.
Nothing in this section limits City-curated programming inside a paid gate as described
in Exhibit C. For avoidance of doubt, the City-curated Showcase Program described in
Section VI and Exhibit C is City programming (government speech) and is the only
expressive activity the City authorizes inside the Paid Gate Area under these
Guidelines.
2. As an alternative, City has provided on-site free expression zones as noted in Section III
and it is the intent of City that these zones act to provide reasonable access to patrons
utilizing the enclosed facilities, rendering the need for free speech activities within the
enclosed facility unnecessary. The City intends the Free Expression Zones to serve as
the designated locations for organized expressive activity during Events. Nothing in this
Section IV limits or alters the City’s ability to operate City-curated programming inside
the Paid Gate Area as described in Section VI and Exhibit C.
3. Non-City Events / Private Rentals. For Events operated by a licensee/lessee or other
event organizer, expressive activity within enclosed facilities and/or within a paid gate is
governed by the terms of the applicable agreement and the organizer’s rules, subject to
applicable law. The City will provide reasonable alternative channels for expression
through the designated outdoor free expression zones, consistent with Section III.
4. City-curated Showcase Program (government speech). The City may operate City-
curated programming inside a Paid Gate as described in Section VI and Exhibit C.
Participation is by City invitation and limited to City-approved content and program
rules.
5. The City is not establishing a private booth/exhibit program for general public speakers
inside the Paid Gate Area under these Guidelines.
Section V - Violation of Fairgrounds Guidelines
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Any person or persons engaged in free speech activity who violates these guidelines may be
subject to the following:
a. If a large group commences free speech activity at the Fairgrounds without
preregistration, City officials may request that the group voluntarily register
and obtain a space allocation if available. Registration shall be encouraged but
shall not be required unless necessary to address public safety concerns,
pedestrian congestion, or interference with emergency services. Lack of
registration alone is not a violation and will not be the sole basis for any
enforcement action.
If all designated free expression zones are occupied, City officials shall make
reasonable efforts to identify alternative space for the group. Refusal to
register shall not be the sole basis for ejection from the Fairgrounds. However,
if a group’s activities result in substantial obstruction of public access, safety
hazards, or unlawful disturbances, City officials may take appropriate action,
including space reassignment or, if necessary, ejection.
b. If an organization or individual is engaged in activity in violation of these
Guidelines, City may take the following actions, where appropriate: issue a
warning, order that the activity shall be stopped, eject the person(s) in
violation of the Guidelines from the Fairgrounds, or if in violation of the law
issue a citation to the offender(s) or arrest the offender(s). Except where
immediate action is necessary to address an articulable safety risk or unlawful
conduct, City staff should provide a warning and a reasonable opportunity to
comply.
c. Anyone engaged in any violence or who provokes or incites any violence shall
be, without warning, immediately ejected from the Fairgrounds and may
additionally be subject to a citation or arrest.
d. Anyone displaying fighting words, legally obscene material, or material that is
unprotected incitement may be directed to cease unlawful conduct as
determined by law enforcement when feasible and/or to discontinue or
relocate activity consistent with these Guidelines. After the event is over
and/or after the free speech activities are concluded, or upon departure, upon
request therefore, said material or displays may be returned to said
organization or individuals. City staff will not seize expressive materials
absent immediate necessity to remove a physical hazard; any evidentiary
seizure will be handled by law enforcement pursuant to applicable law, and
individuals shall have an opportunity to contest the seizure or reclaim
materials that are not contraband. To the extent practicable, City staff will
document the basis for any temporary retention and provide a receipt as
described in Section III(7).
e. Anyone using any sound devices in a manner prohibited by these Guidelines
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shall immediately cease using said sound device in the prohibited manner
upon demand and/or may be directed to reduce volume, relocate, or case
amplification, and only if necessary to abate an immediate and significant
safety/operational risk or clear violation of an applicable decibel limit may the
device be temporarily restrained for the duration of the Event. Upon
conclusion of the Event or free speech activities, or upon departure, and upon
request therefore, a temporarily retained sound device shall be returned to the
individual or organization. Any seizure of a sound device shall be limited to
circumstances where the use creates a significant safety risk or is a clear
violation of established decibel limits, and the device shall be returned
promptly absent ongoing legal justification. Where feasible, City staff should
first seek compliance through volume reduction, relocation, or cessation
before temporary retention of equipment.
f. Nothing in these provisions regarding violations of Guidelines shall require City
to exhaust any remedies, to necessarily give any oral warnings, or to compromise
or limit in any way, any remedies provided by law.
g. Appeals. Any individual or group that is ejected from the Fairgrounds under these
Guidelines or their property confiscated may immediately request a review of the
ejection by the supervising City official on duty at the Fairgrounds at the time of
the incident. The supervisor shall assess whether the ejection was based on a
specific, articulable safety concern or a violation of these Guidelines and may
modify or reverse the decision as necessary. The supervisor should document the
outcome of the review when practicable. A request for review does not waive any
rights and does not preclude the person from seeking relief through other
available processes.
Section VI – Government Speech and City- Curated Showcase Program (Exhibit C)
1. The City may operate a City-curated Showcase Program inside a paid gate (the
“Showcase”) to present City-sponsored informational programming to event attendees,
including information about City services, public resources, and other topics selected by
the City for the event. The Showcase is intended to be City-curated programming, and the
City retains final editorial control over the content and presentation within the Showcase
area. The full terms of the Showcase are set forth in Exhibit C.
2. Participation in the Showcase, if any, is by City invitation. The City may select
participating organizations or agencies (if any) to support City outreach within the
Showcase, and may limit participation based on the Showcase’s City-defined purpose,
space limitations, operational needs, and the City’s selected topics for the event, as
described in Exhibit C. Participation is limited to the Showcase and does not create a
right of access to other areas within the paid gate.
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3. The City will maintain meaningful editorial control over the Showcase. All signage,
handouts, displays, demonstrations, and other materials used in the Showcase must be
City-approved and may be edited, limited, or declined by the City to ensure consistency
with the Showcase’s purpose and safe operations, as set forth in Exhibit C. The City may
require removal of non-approved materials from the Showcase area and may end
participation for noncompliance as described in Exhibit C. To maintain City control, the
City may require that all handouts and signage in the Showcase Area be produced, co-
branded, or distributed by the City, and may require Participants to use City-provided
talking points for interactions with attendees.
4. The City will clearly identify the Showcase as City-curated programming through
signage and branding stating that the Showcase is City-sponsored and that materials are
selected and approved by the City, as described in Exhibit C.
5. Nothing in this Section VI limits private expressive activity in the designated free
expression zones outside the paid gate, consistent with these Guidelines. The Showcase
does not replace the free expression zones and is separate from any private booth/exhibit
opportunities that may be offered for private speakers (if any) under Section IV.
6. Administration of the Showcase—including participant invitation (if any), content
approval, and operational rules—shall be governed by Exhibit C.
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Exhibit A
Fairgrounds Map
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EXHIBIT B
Default Fairgrounds Free Expression Zones Map
(Zones are highlighted in yellow)
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Exhibit C
City of Petaluma Curated Community Resources Showcase Program (Inside Paid Gate)
Petaluma Fairgrounds Free Speech Activities Guidelines
Section I – Purpose and Overview
A. Purpose. The City of Petaluma (City) may operate a City-curated “Community Resources
Showcase” (Showcase) inside a paid gate at the Petaluma Fairgrounds (Fairgrounds) as part of
City-sponsored programming. The Showcase is intended to communicate City-selected
information about public services, community resources, emergency preparedness, and other
topics identified by the City for the benefit of event attendees.
B. Nature of the Showcase. The Showcase is City programming. The City designs the Showcase,
selects the participating organizations (if any), and retains final editorial control over the content,
messaging, and presentation within the Showcase area. The City may require that any
information provided in the Showcase be presented as City-selected messaging, including
through City-produced materials and City-provided talking points.
C. Government speech; not a public forum. The Showcase is intended to constitute government
speech within the meaning of applicable law. Participation in the Showcase does not create an
open forum for private speech, does not confer any right of access to the paid gate, and does not
create a designated or limited public forum. The City’s selection of Showcase participants and
content is part of City-sponsored programming and may be made in the City’s discretion
consistent with the Showcase’s purpose and operational needs. The City does not intend to create
a designated public forum or limited public forum within the Showcase Area. The City retains
discretion to include or exclude Participants and materials based on the Showcase’s City-defined
purpose, operational needs, space constraints, and the City’s editorial judgments about the City’s
own message.
D. Separate channels for private expression. The City provides reasonable alternative channels
for private expressive activity through designated free expression zones outside the paid gate in
accordance with the Fairgrounds Free Speech Activities Guidelines.
Section II – Definitions
For purposes of this Exhibit C:
1. “Showcase” means the City-curated Community Resources Showcase program operated
by the City inside a paid gate.
2. “Showcase Area” means the specific location(s) within the paid gate designated by the
City for the Showcase, including any booth(s), table(s), display(s), or demonstration
area(s) operated under the Showcase program.
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3. “Participant” means an organization, agency, or individual invited by the City to
participate in the Showcase to support City outreach and to present City-approved
information within the Showcase Area.
4. “City-approved Content” means signage, displays, handouts, demonstrations, verbal
scripts, and other materials or messaging that the City has reviewed and approved in
writing for use within the Showcase Area.
5. “Partner Identification” means limited identification of a Participant (e.g., name and logo)
as a featured partner in the City’s Showcase, in a City-approved format.
Section III – Annual Themes and Program Scope
A. Annual themes. For each event, the City may identify one or more Showcase themes (e.g.,
family services, public health, emergency preparedness, housing assistance, sustainability
programs, civic engagement in City services). The City may revise themes to reflect City
priorities, operational needs, or community circumstances.
B. Scope. The Showcase is limited to informational outreach and engagement consistent with the
City’s selected themes. The City may determine the format, size, number of booths/tables, hours
of operation, staffing model, and any interactive components.
Section IV – Selection and Invitation of Participants
A. Invitation-only. Participation in the Showcase is by invitation from the City. The City may
reach out to and invite Participants directly. The City is not required to accept applications,
maintain an open enrollment process, or invite any particular organization.
B. Selection considerations. In selecting Participants, the City may consider factors such as:
1. Relevance to the City’s Showcase themes for that event;
2. Ability to provide direct services/resources to Petaluma residents or event attendees;
3. Demonstrated capacity to staff the Showcase Area at assigned times and comply with
program requirements;
4. Coverage needs to ensure the Showcase effectively addresses the City’s selected themes
(e.g., avoiding duplicative offerings and ensuring key topic areas are represented);
5. Coordination needs with City departments (e.g., emergency management, public safety,
public health, parks and recreation);
6. Operational and safety considerations, including crowd flow and space limitations.
C. No entitlement. Invitation for one event does not guarantee invitation for future events. The
City may modify the Showcase roster at any time in its discretion.
D. Participant role. Participants assist City outreach under the City’s program umbrella.
Participants may provide factual, service-oriented information consistent with City-approved
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Content and City-provided talking points. Participants may not distribute or display independent
materials or engage in independent advocacy within the Showcase Area.
Section V – City Control and Content Approval
A. Editorial control. The City retains final editorial control over all content, messaging, design,
and presentation within the Showcase Area. The City may require edits, limit topics, adjust
messaging, or decline materials that do not fit the Showcase’s purpose, format, or operational
constraints. The City may require that all handouts be distributed only from City-controlled stock
(e.g., placed on City tables or distributed by City staff) to ensure only City-approved Content is
provided within the Showcase Area.
B. Pre-approval requirement. All materials and messaging used within the Showcase Area must
be City-approved Content. This includes, without limitation:
1. Printed materials and handouts;
2. Signs, banners, posters, and display boards;
3. Digital media or video displays;
4. Demonstrations, props, and interactive activities;
5. Verbal scripts or talking points used to engage attendees (if the City provides or requires
them).
C. City-produced materials. The City may require that certain materials be produced or printed
by the City, or that Participant materials be incorporated into City-produced handouts.
D. On-site review. City staff may review materials on-site at any time. Unapproved materials
may not be displayed or distributed within the Showcase Area.
Section VI – Content and Conduct Limits Within the Showcase Area
A. Informational purpose. The Showcase is limited to informational outreach and engagement
related to City-approved Content and the City’s selected themes.
B. Prohibited activities within the Showcase Area. Unless expressly authorized in writing by the
City for the Showcase’s purpose, the following are prohibited within the Showcase Area:
1. Fundraising or solicitation of donations;
2. Commercial sales, marketing, or lead generation;
3. Partisan electioneering, ballot-measure advocacy, or campaign activity;
4. Independent advocacy unrelated to City-approved Content (including protest or
demonstration activity);
5. Distribution of materials not approved by the City;
6. Amplified sound unless authorized by the City and consistent with applicable rules.
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C. Respectful engagement. Participants must conduct themselves in a manner that supports safe
and respectful engagement with attendees and complies with all event safety rules and staff
directions.
Section VII – Operational Rules
A. Space and set-up. The City assigns space within the Showcase Area and controls layout,
signage placement, and any crowd-management features. Participants must remain within
assigned space and follow set-up/take-down instructions.
B. Staffing and supervision. The City will assign a City staff program lead (or designee) to
supervise the Showcase Area and to enforce content and operational requirements. The City may
require City staff presence in the Showcase Area. Participants must coordinate with the City’s
designated program lead.
C. Identification. Participants must wear City-approved identification (badge or lanyard) when
operating within the Showcase Area.
D. Accessibility and safety. All Showcase operations must comply with accessibility
requirements, fire/life-safety requirements, and crowd-flow needs. The City may modify
operations at any time for safety or accessibility.
Section VIII – Public Identification and Signage
A. Required signage. The City will post signage at or near the Showcase Area stating
substantially the following:
“City of Petaluma Community Resources Showcase. This is a City-curated program. Content and
materials displayed or distributed here are selected and approved by the City. Participating
organizations are featured partners supporting City outreach.”
B. Participant identification. Participant names/logos may appear only in City-approved format
(e.g., “Featured Partner”) and must not imply City endorsement beyond participation in the
City’s program.
Section IX – Compliance, Removal of Materials, and Termination of Participation
A. Compliance. Participants must comply with this Exhibit C, City staff directions, and
applicable event rules.
B. Removal of unapproved materials. City staff may require immediate removal of unapproved
materials. If necessary to address an immediate operational or safety need, City staff may
temporarily secure such materials for return to the Participant as soon as practicable.
C. Termination of participation. The City may terminate a Participant’s involvement in the
Showcase for noncompliance, safety concerns, or operational needs. When practicable, City staff
should provide a warning and a reasonable opportunity to cure before termination, unless
immediate action is necessary for safety or operational reasons.
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D. Review. A Participant may request an on-site review of a termination decision by the
supervising City official on duty. The supervisor may affirm, modify, or reverse the decision
based on the circumstances and may document the outcome when practicable.
Section X – Records and Transparency
A. Documentation. The City may maintain internal documentation of:
1. Showcase themes and program goals for the event;
2. Invited Participants and the general basis for selection (e.g., service category, theme
alignment, staffing capacity);
3. Content approval records (as appropriate).
B. Public communications. The City may publish a general description of the Showcase themes
and participating partners, consistent with the City’s communications practices.
Section XI – Relationship to Other Fair Activities and Free Expression Zones
A. Distinct from private exhibitor/vendor programs. The Showcase is separate from any
vendor/exhibitor booths, rentals, sponsorships, or other private participation programs governed
by event agreements or other policies.
B. Private expressive activity. Nothing in this Exhibit C limits the availability of designated free
expression zones outside the paid gate under the Fairgrounds Free Speech Activities Guidelines.
Individuals and organizations wishing to engage in private expressive activity during events may
do so in those designated areas consistent with those Guidelines.
Section XII – Severability
If any provision of this Exhibit C is held invalid, the remaining provisions shall remain in effect
to the fullest extent permitted by law.
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Invitation For Future Events Template
City of Petaluma
Community Resources Showcase (inside paid gate)
Invitation and participation terms (acknowledgment)
Event: Petaluma Fair (or other City-sponsored event)
Dates/times: [insert]
Theme (if any): [insert]
Location: Petaluma Fairgrounds, inside paid gate, Showcase Area [insert location]
City program lead: [name / title / phone / email]
1. Invitation and Status
The City of Petaluma invites [participant organization name] (Participant) to participate in
the City-curated Community Resources Showcase (Showcase). Participation is by invitation
only and is limited to the dates/times and location identified above. Participation does not
create any right of access to the Fairgrounds or paid gate outside the Showcase hours or
beyond this event.
2. Nature of the Program; City-Curated Programming
The Showcase is City programming. The City designs the Showcase, selects participants, and
retains final editorial control over the content, messaging, and presentation within the
Showcase Area. Participant acknowledges that the Showcase is intended to constitute City-
curated programming and government speech and is not a public forum for private speech.
Participant further acknowledges that any materials and messaging used in the Showcase
Area will be limited to City-approved Content and may be required to use City-produced
materials and City-provided talking points.
3. Participant Role
Participant’s role is to support City outreach by providing factual, service-oriented
information to attendees consistent with the City’s approved themes and materials.
Participant is a featured partner in the City’s program and is not an agent of the City.
Participant may not speak on behalf of the City regarding City policy, legal positions,
enforcement, or pending matters.
4. Content Approval and Materials
a. pre-approval required. All materials and messaging used within the Showcase Area must
be reviewed and approved in writing by the City (City-approved Content). This includes
signage, handouts, displays, digital content, demonstrations, and any scripted talking points if
provided by the City.
b. submission deadline. Participant will submit proposed materials to the City program lead
by: [date/time].
c. City edits and final authority. The City may require edits, substitutions, limitations, or
removal of any content to maintain the Showcase’s purpose, format, and operational needs.
d. unapproved materials prohibited. Participant will not display or distribute unapproved
materials in the Showcase Area. The City may require immediate removal of unapproved
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materials. Participant will not bring or display any signage, banners, flyers, petitions, or other
advocacy materials unless included in City-approved Content.
5. Prohibited Activities in the Showcase Area
Unless expressly authorized in writing by the City program lead, Participant will not engage
in the following within the Showcase Area:
• fundraising or solicitation of donations
• commercial sales, marketing, or lead generation
• partisan electioneering or ballot-measure advocacy
• protest/demonstration activity or independent advocacy unrelated to the City-
approved themes
• amplified sound
• distribution of materials not approved by the City
6. Operations, Staffing, and Conduct
a. staffing. Participant will staff the Showcase during assigned times and ensure
staff/volunteers follow City directions.
b. identification. Participant staff/volunteers will wear City-issued or City-approved
badges/lanyards while in the Showcase Area.
c. space and set-up. Participant will remain within the assigned footprint and comply with all
set-up/take-down instructions, accessibility rules, and safety requirements.
d. respectful engagement. Participant staff/volunteers will interact with attendees in a
respectful, non-harassing manner. If an attendee declines engagement, Participant will
disengage immediately.
7. Removal and Termination
The City may terminate Participant’s involvement in the Showcase for noncompliance, safety
concerns, or operational needs. When practicable, the City will provide a warning and a
reasonable opportunity to cure unless immediate action is necessary for safety or operations.
8. Acknowledgments
Participant acknowledges and agrees that:
• participation is limited to the Showcase Area under these terms
• the City controls the message and presentation in the Showcase Area
• the City may feature Participant identification only in a City-approved “featured partner”
format
• the City provides alternative channels for private expressive activity outside the paid gate
via designated free expression zones
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Participant organization: _______________________________
Authorized representative (name/title): ___________________
Signature: ________________________ Date: _____________
City program lead: __________________ Date: _____________
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Exhibit D
City of Petaluma
Petaluma Fairgrounds Free Expression Zone Registration / Space Request Form
Purpose
This form is used to request space within a designated free expression zone at the Petaluma
Fairgrounds (175 Fairgrounds Drive, Petaluma, CA). Registration is encouraged for large groups
(more than 10 affiliated persons engaging in coordinated free speech activity). Registration is not
required for smaller groups or for spontaneous expression, but early registration may help with
space assignment.
Submission
Submit by email, fax, or in person to:
City of Petaluma – Parks and Recreation
320 N McDowell Blvd, Petaluma, CA 94954
Office hours: Monday–Thursday, 10:00 a.m. to 4:00 p.m.
Email: [insert] Fax: [insert] Phone: [insert]
Timing
Applications may be submitted up to 30 days in advance and at any time prior to the planned
Event. Submission at least 48 hours in advance is encouraged for Large Groups when feasible,
but not required. For spontaneous expression (within the immediately preceding 48 hours), this
form is optional.
Part A – applicant / contact information
1. Group or organization name (if any): _______________________________
2. Primary contact person: __________________________________________
3. Mailing address: ________________________________________________
City/State/ZIP: ____________________________________________________
4. Email: __________________________ Phone: _______________________
5. Day-of-event contact (if different): _________________________________
Phone: __________________________ Email: _________________________
6. Are you a “large group” (more than 10 affiliated persons engaging in coordinated free
speech activity)?
☐ Yes ☐ No ☐ Not sure
Part B – activity information (for planning only; not for content review)
7. Date of planned activity: ____ / ____ / ______
8. Event you are attending (if known): ________________________________
(Example: Petaluma Fair, concert name, festival name, etc.)
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Fairgrounds Free Speech Activities Guidelines 27
9. Planned start time: ___________ a.m./p.m.
Planned end time: ___________ a.m./p.m.
10. Approximate number of participants expected: _______
11. Type of activity (check all that apply):
☐ Holding signs / banners
☐ Leafleting / handing out literature
☐ Picketing
☐ Collecting signatures
☐ Marching (within permitted areas)
☐ Other (describe): ______________________________________________
12. Will you use any sound amplification (megaphone/loudspeaker/other sound device)?
☐ No ☐ Yes (describe device): _____________________________________
Part C – zone preference / space needs
13. Preferred free expression zone (select one, if known; see Exhibit B map):
☐ Zone 1 ☐ Zone 2 ☐ Zone 3 ☐ Zone 4 ☐ No preference / first available
(If you don’t know the zone number, describe preferred location:
____________________)
14. Second choice (optional): _______________________________________
15. Accessibility needs / accommodation request (optional):
(Example: ADA access, proximity needs, interpreter, etc.)
16. Equipment you plan to bring (check all that apply):
☐ None
☐ One portable foldable table
☐ Chairs
☐ One shade structure (pop-up tent, no walls)
☐ Handheld signs / banners
☐ Other (describe): ______________________________________________
Part D – voluntary solicitation (optional)
17. Will you solicit voluntary contributions/donations?
☐ No ☐ Yes
If yes, optional description of the general purpose for which voluntary contributions will be used
(for administrative planning and consumer-information purposes only; not reviewed for
approval/disapproval of any viewpoint):
Docusign Envelope ID: 8518CA7D-FFC9-4EE8-AF46-3F645F3FBE7E
Fairgrounds Free Speech Activities Guidelines 28
Part E – acknowledgments and certification
18. Acknowledgments (initial each)
____ I understand that registration is used for space planning and distribution of the Fairgrounds
Free Speech Activities Guidelines, and is not a permit and is not used to review or approve the
content of speech.
____ I understand that space is assigned first-come, first-served, subject to availability, zone
capacity, pedestrian flow, accessibility, and public safety considerations.
____ I agree that participants will comply with the Fairgrounds Free Speech Activities
Guidelines, including rules on obstruction, ingress/egress, emergency access, harassment of
patrons, sound devices, and equipment limitations.
____ I understand that the City may require reasonable separation of groups only based on
objective safety/access criteria and, when feasible, will provide reasonable alternative locations
offering substantially similar access.
____ I understand that individuals/groups using free expression zones outside the paid gate may
occupy the zone no earlier than one hour prior to the event and no later than 30 minutes after the
event closes, and must remove equipment daily.
Certification
I certify that the information provided is accurate to the best of my knowledge.
Signature: ___________________________________ Date: ____ / ____ / ______
Printed name and title (if any): __________________________________________
Privacy notice (optional to include)
Contact information is collected for event-day coordination and administration of space
assignments. It will be used only for that purpose unless required to be disclosed by law.
City use only (do not fill out)
Date received: ____ / ____ / ______ Time: __________
Received by: ______________________ Method: ☐ Email ☐ Fax ☐ In person
Assigned zone and space location: ________________________________________
Max occupancy posted for assigned space: _______
Conditions / notes (if any): ______________________________________________
Docusign Envelope ID: 8518CA7D-FFC9-4EE8-AF46-3F645F3FBE7E
Fairgrounds Free Speech Activities Guidelines 29
City staff signature: ____________________________ Date: ____ / ____ / ______
If you want, I can format this into a two-page “fillable” layout (same content, nicer spacing) and
add a one-page handout that staff can give applicants with the Exhibit B map, the time window
rules, and the key do/don’t items.
Docusign Envelope ID: 8518CA7D-FFC9-4EE8-AF46-3F645F3FBE7E