Calistoga City Council
July 18, 2023

City of Calistoga’s 6th Cycle Draft Housing Element Page 4 August 24, 2022
A complete analysis should consider the likelihood of nonresidential development, performance standards, and development trends supporting residential development.

For additional information, see the Building Blocks at http://www.hcd.ca.gov/communitydevelopment/building-blocks/site-inventory-analysis/analysis-of-sites-andzoning.shtml#zoning.

Small Sites: The element identifies five parcels that are less than a half- acre in size (Table 5-3) and concludes that these parcels are contiguous and have common ownership (p. 5-9). However, sites smaller than a half-acre in size are deemed inadequate to accommodate housing for lower-income housing unless it is demonstrated that sites of equivalent size were successfully developed during the prior planning period for an equivalent number of lower-income housing units as projected for the site or unless the housing element describes other evidence to HCD that the site is adequate to accommodate lower income housing. (Gov. Code, § 65583.2, subd. (c)(2)(A).) For example, a site with a proposed and approved housing development that contains units affordable to lower income households would be an appropriate site to accommodate housing for lower-income households. (Gov. Code, § 65583.2, subd. (c)(2)(C).) The analysis could also describe the City’s role or track record in facilitating small-lot consolidation, conditions rendering parcels suitable and ready for lot consolidation, and policies or incentives offered or proposed to encourage and facilitate lot consolidation.

Suitability of Nonvacant Sites: The element identifies one nonvacant site to accommodate the regional housing need including four units for lower-income households. The element must provide an analysis demonstrating the potential for redevelopment. The methodology must consider factors including the extent to which existing uses may impede additional residential development, development trends, market conditions, any and other information that may prevent redevelopment of the site for additional residential development. Additionally, the element could discuss and regulatory or other incentives or standards to encourage additional residential development on these sites.

Environmental Constraints: While the element identified and analyzed potential environmental constraints for the identified sites and Citywide including flooding, special species, and archaeological resources, it should analyze any other potential environmental constraints or other conditions impacting RHNA sites such as fire hazard or earthquake risks. The element should be revised to include this information and programs should be added or revised as appropriate.

Electronic Sites Inventory: Pursuant to Government Code section 65583.3, subdivision (b), the City must utilize standards, forms, and definitions adopted by HCD when preparing the sites inventory. Please see HCD’s housing element webpage at https://www.hcd.ca.gov/community-development/housing-element/index.shtml for a copy of the form and instructions. The City/County can reach out to HCD at [email protected] for technical assistance. Please note, upon adoption of the housing element, the City/County must submit an electronic version of the sites inventory with its adopted housing element to [email protected].

N
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Item #8.5.

City of Calistoga’s 6th Cycle Draft Housing Element Page 5 August 24, 2022
Zoning for a Variety of Housing Types:
• Emergency Shelters: While the element discussed zoning and capacity for emergency shelters, the element must also identify and analyze any development standards (e.g., spacing, parking, concentration requirements) and other requirements imposed on emergency shelters. Lastly, the element must describe compliance with Government Code section 65583, subdivision a)(4)(A) or include a program to comply with this requirement. For your information, pursuant to Government Code section 65583, subdivision a)(4)(A), parking requirements should be limited to allowing sufficient parking to accommodate all staff working in the emergency shelter, provided that the standards do not require more parking for emergency shelters than other residential or commercial uses within the same zone.
• Supportive and Transitional Housing: The element states that the City permits supportive and transitional housing in all residential zones. Additionally, the element included Table 6-1 listing allowable uses per zoning district. However, this table did not reflect whether transitional and supportive housing are allowed in zones that allow for residential uses (e.g., downtown commercial, community commercial, etc.,). The element should reconcile this information and specifically clarify whether the City permits these types of housing as a residential use and only subject to those restrictions that apply to other residential dwellings of the same type in the same zone pursuant to Government Code section 65583 (a)(5).

Additionally, supportive housing shall be a use by-right in zones where multifamily and mixed uses are permitted, including nonresidential zones permitting multifamily uses pursuant to Government Code section 65651. The element must demonstrate compliance with these requirements and include programs as appropriate.
• Housing for Agricultural Employees: The element must demonstrate zoning is consistent with the Employee Housing Act (Health and Safety Code, § 17000 et seq.), specifically, sections 17021.5 and 17021.6. Section 17021.5 requires employee housing for six or fewer employees to be treated as a single-family structure and permitted in the same manner as other dwellings of the same type in the same zone. Section 17021.6 requires employee housing consisting of no more than 12 units or 36 beds to be permitted in the same manner as other agricultural uses in the same zone. For additional information and sample analysis, see the Building Blocks at http://www.hcd.ca.gov/communitydevelopment/building-blocks/housing-needs/farmworkers.shtml. • Manufactured Housing: The element provided information on permitting requirements for manufactured homes in the terms of accessory dwelling units and mobile homes. However, manufactured homes that are built on a permanent foundation must be allowed in the same manner and in the same zones as conventional or stick-built structures. Specifically, manufactured homes on a permanent structure should only be subject to the same development standards that a conventional single-family residential dwelling would be subject to. The R
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Item #8.5.

City of Calistoga’s 6th Cycle Draft Housing Element Page 6 August 24, 2022
element must demonstrate consistency with this requirement or add or modify programs as appropriate.

5. An analysis of potential and actual governmental constraints upon the maintenance, improvement, or development of housing for all income levels, including the types of housing identified in paragraph (1) of subdivision (c), and for persons with disabilities as identified in the analysis pursuant to paragraph (7), including land use controls, building codes and their enforcement, site improvements, fees and other exactions required of developers, and local processing and permit procedures... (Gov. Code, § 65583, subd. (a)(5).)
Land Use Controls: The element must identify and analyze all relevant land use controls impacts as potential constraints on a variety of housing types. The analysis should analyze land use controls independently and cumulatively with other land use controls.

While the element analyzed most relevant land use controls, it must identify and analyze any requirements for minimum or maximum unit sizes. Additionally, the element must analyze requirements related to multifamily parking (i.e., two spaces per unit). For example, the element could include a discussion about applicable development standards in different zones and how a hypothetical project could achieve maximum densities when applying those standards. The analysis should address any impacts on cost, supply, housing choice, affordability, timing, approval certainty and ability to achieve maximum densities and include programs to address identified constraints.

Local Processing and Permit Procedures: While the element analyzed most procedures and permitting requirements for various housing types, the element must specifically analyze the requirement of a use permit for multifamily housing for potential constraints on housing. Specifically, the element notes that a use permit is required for multifamily development in mixed-use zones (i.e., community commercial and downtown commercial) and approval findings include compatibility with surrounding uses.

Additionally, the City identified a portion of their RHNA in these zones. The analysis should address impacts on housing cost, supply, timing and approval certainty. For example, the element should analyze the required approval findings for impacts on approval certainty and the presence of processes or guidelines to promote certainty and add or modify programs as appropriate.

Constraints on Housing for Persons with Disabilities:
• Reasonable Accommodation: The element states the City has a reasonable accommodation procedure (p. 5-2), but it should also analyze the procedure for potential constraints. The analysis should address the process, application requirements, and associated fees and list and evaluate the actual approval findings. Depending on its analysis, the element must add or modify programs as appropriate.
• Licensed and Unlicensed Residential Care Facilities for Seven or More Persons:

The element states that these uses are permitted with a use permit in residential zones. Additionally, the element indicates that a use permit requires planning commission approval and triggers design review. For your information, zoning V
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City of Calistoga’s 6th Cycle Draft Housing Element Page 7 August 24, 2022
should simply implement a barrier-free definition of family instead of potentially subjecting persons with disabilities to special regulations such as the number of persons, population types, and licenses. The element must analyze this process as a potential constraint for impacts on housing choices, approval certainty, and objectivity for housing for persons with disabilities. Additionally, as part of this analysis, the element should also clarify the differences between “general” and “limited” residential care facilities. Based on a complete analysis, the element may need to add or modify programs to allow these uses with objectivity and certainty.

6. An analysis of potential and actual nongovernmental constraints upon the maintenance, improvement, or development of housing for all income levels, including… …the requests to develop housing at densities below those anticipated in the analysis required by subdivision (c) of Government Code section 65583.2, and the length of time between receiving approval for a housing development and submittal of an application for building permits for that housing development that hinder the construction of a locality’s share of the regional housing need in accordance with Government Code section 65584... (Gov. Code, § 65583, subd. (a)(6).)
Approval Time and Requests for Lesser Densities: While the element stated that there were no requests from the “public” to develop at densities below those identified in the inventory (p. 6-23), it must clarify and analyze requests from project applicants to develop at densities below those identified in the sites inventory. Additionally, the element must include an analysis of the length of time between receiving approval for a housing development and submittal of an application for building permits. The element must address any hinderance on the development of housing and include programs as appropriate.

7. Analyze any special housing needs such as elderly; persons with disabilities, including a developmental disability; large families; farmworkers; families with female heads of households; and families and persons in need of emergency shelter. (Gov. Code, § 65583, subd. (a)(7).)
Special Needs Households: While the element includes some data, a general discussion of housing challenges faced by special needs households, and proposed programs, it still must provide an analysis of the existing needs and resources for each special need group including seniors, female headed households, large households, extremely low-income households, and persons with disabilities. For example, the element should discuss the existing resources to meet housing needs (availability of shelter beds, number of large units, number of deed restricted units, community services, etc.,) and an assessment of any gaps in resources. Local officials, special needs service providers or County social and health service providers may be able to assist with information to complete the analysis. The element may need to add or revise programs and policies based on the outcomes of a complete analysis.

Farmworkers: While the element included data on the number of migrant farmworkers, the element must specifically quantify the number of permanent and seasonal farmworkers within the County (USDA Agriculture Census data).

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Item #8.5.

City of Calistoga’s 6th Cycle Draft Housing Element Page 8 August 24, 2022

8. Analyze existing assisted housing developments that are eligible to change to non-lowincome housing uses during the next 10 years due to termination of subsidy contracts, mortgage prepayment, or expiration of use restrictions. (Gov. Code, § 65583, subd. (a)(9) through 65583(a)(9)(D).).

The element states that the City has a portfolio of 203 affordable housing units, however, HCD’s records indicate that the City has 287 affordable housing units. The element should reconcile these figures and include the following projects in the inventory: Lincoln Avenue Apartments (77 assisted units located on 1855 Lincoln Avenue) and Calistoga Farm Worker Center (60 assisted units on 3996 North St.

Helena Highway).

B. Housing Programs

1. Include a program which sets forth a schedule of actions during the planning period, each with a timeline for implementation, which may recognize that certain programs are ongoing, such that there will be beneficial impacts of the programs within the planning period, that the local government is undertaking or intends to undertake to implement the policies and achieve the goals and objectives of the Housing Element... (Gov. Code, § 65583, subd. (c).)
Programs must demonstrate that they will have a beneficial impact within the planning period. Beneficial impact means specific commitment to deliverables, measurable metrics or objectives, definitive deadlines, dates, or benchmarks for implementation.

Deliverables should occur early in the planning period to ensure actual housing outcomes. The element must provide quantified objectives where appropriate and all programs should be evaluated to ensure provision of discrete timing (e.g., month and year) to account for how often the action will occur as well as to ensure a beneficial impact throughout the planning period. In addition, the element should be revised as follows:

Specific Commitments: The element includes several programs lacking specific commitments (e.g., “explore,” “consider,” etc.,). While the element can include programs to study certain topics, it includes a preponderance of programs that do not go beyond studying or exploring a particular action. Programs should be amended, as appropriate to include more specific and measurable actions. This includes but is not limited to Actions 1.2-2, 1.2-4, 1.2-6, 1.3-5, 2.1-6, and 2.2-3.

Implementation Actions: As noted above, programs must have clear outcomes or deliverables. Several programs include actions with no description of how those actions will be implemented (e.g., “encourage”, “assist”, “partner”, “maintain”, etc.,). For example, Program 1.2-1 states that the City will encourage new residential development to be built to the maximum density, however, does not describe how the City will encourage this action from occurring (e.g., develop requirements, pre-application meetings, etc.,). Programs should be amended, as appropriate to include AB
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City of Calistoga’s 6th Cycle Draft Housing Element Page 9 August 24, 2022
implementation steps. This includes but is not limited to Actions 1.2-1, 2.2-2, 1.2-3, 4.1- 2, 4.1-3, 4.1-7, and 4.2-1.

Ongoing Programs: Majority of the programs lists implementation timelines as “ongoing.” While this may be appropriate for some programs, programs with specific implementation actions must include completion or initiation dates resulting in beneficial impacts within the planning period. For example, Action 1.2-6 commits to partnering with the Chamber of Commerce to encourage options for workforce housing and consider programs to connect homeowners to employees in need of housing yet lists the timeline as “ongoing.” To address this, the program should include a timeline for when and how the City will engage and partner with organizations. This and other programs should include specific dates or benchmarks for implementation throughout the planning period. This includes but not is limited to Actions 1.2-6, 1.2-3, 1.3-3, 1.3-4,

2.1-2, 2.1-3, 2.3-1, 4.1-2, 4.1-3, 4.1-5, 4.2-2, 4.3-1, 4.3-2.

2. Identify actions that will be taken to make sites available during the planning period with appropriate zoning and development standards and with services and facilities to accommodate that portion of the city’s or county’s share of the regional housing need for each income level that could not be accommodated on sites identified in the inventory completed pursuant to paragraph (3) of subdivision (a) without rezoning, and to comply with the requirements of Government Code section 65584.09. Sites shall be identified as needed to facilitate and encourage the development of a variety of types of housing for all income levels, including multifamily rental housing, factory-built housing, mobilehomes, housing for agricultural employees, supportive housing, single-room occupancy units, emergency shelters, and transitional housing. (Gov. Code, § 65583, subd. (c)(1).)
As noted in Finding A4, the element does not include a complete site analysis, therefore, the adequacy of sites and zoning were not established. Based on the results of a complete sites inventory and analysis, the City may need to add or revise programs to address a shortfall of sites or zoning available to encourage a variety of housing types. In addition, the element should be revised as follows:

Publicly Owned Sites: The element identified City-owned sites to accommodate a portion of the RHNA. The element should include a program with numerical objectives that ensures compliance with the Surplus Land Act, provides incentives and actions along with a schedule to facilitate development of City-owned sites. Actions should include outreach with developers, issuing requests for proposals, incentives, fee waivers, priority processing and financial assistance.

3. Address and, where appropriate and legally possible, remove governmental and nongovernmental constraints to the maintenance, improvement, and development of housing, including housing for all income levels and housing for persons with disabilities. The program shall remove constraints to, and provide reasonable accommodations for housing designed for, intended for occupancy by, or with supportive services for, persons with disabilities. (Gov. Code, § 65583, subd. (c)(3).) As noted in Findings A5 and A6, the element requires a complete analysis of potential governmental constraints. Depending upon the results of that analysis, the City may AE
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City of Calistoga’s 6th Cycle Draft Housing Element Page 10 August 24, 2022
need to revise or add programs and address and remove or mitigate any identified constraints.

4. Develop a plan that incentivizes and promotes the creation of accessory dwelling units that can be offered at affordable rent… ….for very low, low-, or moderate-income households... (Gov. Code, § 65583, subd. (c)(7).)
The element is required to include a program that incentivizes or promotes accessory dwelling unit (ADU) development for very low-, low-, and moderate-income households.

While the element included Action 1.2-2, this program does not commit to anything beyond “considering” making amendments to the City’s ADU ordinance. First, HCD’s records indicate that the City has not updated it’s ADU ordinance to comply with recent state law from 2020-2022. The element must include a specific commitment to update the City’s ADU ordinance to be compliant with state law. Second, as noted, the element must include a program that incentivizes or promotes ADU development. Examples of incentives include pursuing funding opportunities, modifying development standards, and reducing fees beyond state law, increasing awareness, pre-approved plans, and homeowner/applicant assistance tools. Other strategies could include developing information packets to market ADU construction, targeted advertising of ADU development opportunities or establishing an ADU specialist within the planning department.

5. Promote and affirmatively further fair housing opportunities and promote housing throughout the community or communities for all persons regardless of race, religion, sex, marital status, ancestry, national origin, color, familial status, or disability, and other characteristics protected by the California Fair Employment and Housing Act (Part 2.8 (commencing with Section 12900) of Division 3 of Title 2), Section 65008, and any other state and federal fair housing and planning law. (Gov. Code, § 65583, subd. (c)(5).) As noted in Finding A1, the element must include a complete analysis of AFFH. Based on the outcome of that analysis, the element must add or modify programs.

C. Quantified Objectives
Establish the number of housing units, by income level, that can be constructed, rehabilitated, and conserved over a five-year time frame. (Gov. Code, § 65583, subd. (b)(1 & 2).)
Based on HCD’s review, the element included quantified objectives for various income categories for conservation, rehabilitation, and construction in two separate places of the element (p. 5-27 and p. 8-16). First, the element should reconcile these tables to consistently report quantified objectives for each income category. Secondly, the element must include quantified objectives for all income levels, including extremely low income households. Lastly, while the element included some quantifiable objectives for conservation, it must include objectives for the number of housing units that will be rehabilitated and conserved/preserved for all income levels (extremely low, very low, low, moderate, and above moderate).

AH
AI
AJ
Item #8.5.

HCD Response Letter Comment Overview: Page 1 of 29
Cit y of Ca list oga Re sp on se t o HCD 90-Da y Re vie w Com m e n t s (August 24, 2022) HCD
Com m e n t
Id e n t ifie r
HCD Com m e n t Cit y Re sp on se
A
Enforcem ent & Outreach: The elem ent currently
describes cases filed with the Fair Housing Enforce m ent Organization (FHEO), but it m ust also describe the City’s capacity to provide enforcem ent and outre ach, which can consist of actions such as the ability to investigate
com plain ts, obtain rem edies, or engage in fair housing testing. In addition, the elem ent m ust address
com pliance with existing fair housing laws, as well as any past or current fair housin g lawsuits, findings,
settlem ents, judgem ents, or com plain ts.

Clarify Existing Analysis (p. 3-10). Include directed context on FHEO. Redline to address HCD’s com m ents
B
Assessm ent of Fair Housing: The elem ent includes som e data and analysis regarding different patterns for various socio-econom ic characteristics (race and incom e).

However, a com plete analysis should include m aps and
data on all fair housing com ponents and analyze this
data for patte rns and tren ds at the local and regional level including integration and segregation (race, incom e, disability, and fam ilial status), disparities in access to opportu nity (education , environm ental, transportation, econom ic), and disproportionate housing ne eds (cost
burdened, overcrowded, substandard h ousing
conditions, h om elessness, and displacem ent risks). In addition to evaluating patterns and trends, the elem ent should analyze coincidences with other com ponents of
the assessm ent of fair housing. Lastly, the assessment should be com plem ented by local data and knowled ge,
including input from com m ents, and other relevant
factors as described below.

Expand and Refine Analysis (p. 3-7). Include m ore regional context on fair hou sing, i.e. how Calistoga com pares to Napa County as a whole. This would include TCAC m apping and identifying disproportionate housing n eeds in regional context.

Expand AFFH analysis (Approxim ately double the am oun t of additional analysis as the others in this category).

C
Other Relevant Factors: The elem ent m ust consider other relevant factors that have contributed to certain fair
housing conditions. This analysis m ust consider
inform ation that is unique to the City or region, such as Expand and Refine Analysis. (fit in p. 3-15). Perform historic research and interview experts at the City and/or UpValley Fam ily Centers to understand these factors.

Expand fair housing analysis.

Item #8.5.

HCD Response Letter Comment Overview: Page 2 of 29
HCD
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governm ental and nongovernm ental actions, historical
land use and zoning practices (e.g., past
redlining/greenlining, restrictive covenants, etc.),
disparities in investm ent to specific com m unities, or other inform ation th at m ay have im peded housing
choices and m obility.

D
Local Knowledge and Data: The elem ent should
com plem ent federal, state , and regional data with local data and knowledge where appropriate to capture
em erging trends and issues, including utilizing knowledge from local an d regional ad vocates, public com m ents, and service providers.

Expand and Refine Analysis. (fit in p. 3-15). Perform historic research and interview experts at the City and/or UpValley Fam ily Centers to understand these factors.

Review outreach and expand discussion of local knowledge .

E
Sites Inventory: The elem ent includes som e analysis on the distribution of sites identified to m eet the Regional Housing Needs Allocation (RHNA) regarding access to
opportu nity indicators (pp. 5-10-16). However, a full
analysis should address the incom e categories of
identified sites with respect to location, the num ber of sites and units by all incom e groups, and how that effects the existing patterns for all com ponents of the
assessm ent of fair housin g (e.g., enforcem ent and
outreach, segregation and integration , disproportionate housing needs including displacem ent). The elem ent
should also discuss whether the distribution of sites
im proves or exacerbates fair housing conditions an d add or m odify program s as appropriate .

Clarify Existing Analysis (p. 5-10). Apply fair housing analysis to Site Inventory and analyze whether the sites im prove or exacerbate fair housing conditions. Refine m ap and redline to discuss fair housing. Review program s as appropriate F
Contributing Factors and Sum m ary of Fair Housing
Issues: While the elem ent includes som e contributin g factors and a sum m ary of fair housing issues, based on a com plete analysis, the elem ent m ay need to add or revise the identification of contributing factors and fair housing issues.

Expand and Refine Analysis (p. 3-16). Review Contrib uting Factors after perform ing tasks A through E. Review A through E and determ in e if revisions are necessary.

May not need additional analysis, once review is com plete Item #8.5.

HCD Response Letter Comment Overview: Page 3 of 29
HCD
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G
Goals, Priorities, Metrics, and Milestones: Goals an d
actions m ust significan tly seek to overcom e contributing factors to fair housing issues. Currently, the elem e nt identifies program s to encourage and prom ote
afford able housing; however, m ost of these program s
are lim ited to conducting outreach and do not appe ar to facilitate any m eaningful change nor address
affirm atively furthering fair housing requirem ents.

Furtherm ore , the elem ent m ust include m etrics and
m ilestones for evaluating progress on program s, actions, and fair housing results. Given that m ost of the City is considered a low and m oderate resource com m unity, the elem ent could focus on program s that center on place - based strategies for econom ic and com m unity
revitalization, protecting residents from disaster-driven and investm ent-driven displacem ent, and enhancin g
housing m obility to encou rage the developm ent of m ore housing choices and affordable housing. Program s also
should be based on identified contributing factors, be
significant and m eaningfu l. The elem ent m ust add, and revise program s based on a com plete analysis and listing and prioritization of contributing factors to fair housing issues. Furtherm ore, the elem ent m ust include
geographic targeting, m etrics and m ilestones toward
affirm atively furthering fair housing (AFFH) outcom es. For m ore inform ation, please see HCD’s guidance at
https://www.hcd.ca.gov/com m unitydevelopm ent/affh/index.shtm l.

Council May Wish to Provide Policy Direction
Policy Qu e st ion : Are a d d it ion a l p o licie s/ p rogr a m s n e ce ssa r y? Provid e St a ff Re c. t o A t h rou gh F for Cou n cil H
Extrem ely Low Incom e (ELI) Households: While the
elem ent included the total num ber of projected ELI
households, it m ust quantify and analyze the num b er of existing ELI households by tenure.

Clarify Existing Analysis. Redline to address HCD’s com m en ts.

I Overpaym ent: While the elem ent quantified the total num ber of households overpaying by tenure (p. 4-29), it Clarify Existing Analysis. Redline to address HCD’s com m en ts Item #8.5.

HCD Response Letter Comment Overview: Page 4 of 29
HCD
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m ust quan tify the total nu m ber of lower-incom e
households overpaying by tenure.

J
Progress in Meeting the RHNA: The elem ent is counting
128 units as progress towards the RHNA including 69
units afford able to lower-incom e households. First, to count these units as progress towards RHNA, the
elem ent m ust dem onstrate the availability of these units within the planning period. To address this, the elem ent could discuss project status, schedule for com pletion, outreach with developm e nts, rem aining steps for
projects to receive final entitlem en ts and any other
relevant inform ation. Additionally, the elem ent m ust dem onstrate the afford ab ility for 1855 Lincoln Ave based on actual or projected sales prices, rent levels, or other m echanism s establishing afford ability in the plan ning period. For additional inform ation, see the Building
Blocks at http://www.hcd.ca.gov/com m unitydevelopm ent/building-blocks/housing-needs/projectedhousing-needs.shtm l.

Clarify Existing Analysis. Redline to address HCD’s com m en ts K
Sites Inventory: While the elem ent lists sites by parcel num ber, parcel size, zonin g, general plan designation, and describes existing uses for non-vacant sites
(Appendix 5-1), it m ust also identify the num ber of u nits that can be realistically accom m od ated on each site. For additional inform ation an d sam ple sites inventory, see the Building Blocks at http ://www.hcd.ca.gov/com m unitydevelopm ent/building-blocks/site -inventoryanalysis/inventory-of-land -suitable.shtm l.

Clarify Existing Analysis. Re -subm it Sites Inventory with Realistic Cap acity an alysis (L)
L
Realistic Cap acity: The elem ent provides assum ptions for buildout of sites in the inventory by m ultiplying the
m axim u m allowable density by the size of a parcel.

However, the elem ent m u st also provide support for
these assum ptions. For exam ple, the elem ent should
dem onstrate what specific trends, factors, and other
Expand and Refine Analysis. Com plete Realistic Capacity analysis Item #8.5.

HCD Response Letter Comment Overview: Page 5 of 29
HCD
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evidence led to the assum ptions. The estim ate of th e num ber of units for each site m ust be adjusted as
necessary, based on the land use controls and site
im provem ents, typical densities of existing or approved residential developm ents at a sim ilar afford ability le vel in that jurisdiction, an d on the current or planned
availability and accessibility of sufficient water, sewer, and dry utilities.

M
Additionally, for sites that have been identified in zones that allow for 100 percent nonresidential uses, the
elem ent m ust analyze the likelihood that residential will occur in nonresidential zones (e.g., com m unity
com m ercial and high den sity residential/office).For
exam ple, while the elem ent stated th at residential
densities are required and that m ultifam ily is allowe d excluding the ground floor, the elem ent should add ress other criteria including whether these zones allow for 100 percent com m ercial proje cts. A com plete analysis should consider the likelihood of nonresidential developm e nt, perform ance stand ards, and developm ent trends
supporting residential developm ent. For add ition al
inform ation, see the Building Blocks at
http://www.hcd.ca.gov/com m unitydevelopm ent/building-blocks/site -inventoryanalysis/analysis-of-sites-and-zoning.shtm l# zoning.

Expand and Refine Analysis
N
Sm all Sites: The elem ent identifies five parcels that are less than a half-acre in size (Table 5-3) and concludes that these parcels are contiguous and have com m on
ownership (p. 5-9). However, sites sm aller than a halfacre in size are deem ed inadequate to accom m od ate housing for lower-incom e housing unless it is
dem onstrated that sites of equivalent size were
successfully developed during the prior planning period for an equivalent num ber of lower-incom e housing units Expand and Refine Analysis
Item #8.5.

HCD Response Letter Comment Overview: Page 6 of 29
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as projected for the site or unless the housing element describes other evidence to HCD that the site is adequate to accom m odate lower incom e housing. (Gov. Cod e, §
65583.2, subd.(c)(2)(A).) For exam ple, a site with a
proposed and approved h ousing developm ent that
contains units affordab le to lower incom e households
would be an appropriate site to accom m odate housing
for lower-incom e househ olds. (Gov. Code, § 65583.2,
subd.(c)(2)(C).) The analysis could also describe the City’s role or track record in facilitating sm all-lot consolid ation, conditions rendering parcels suitable and ready for lot consolidation, and p olicies or incentives offered or
proposed to encourage and facilitate lot consolidation.

O
Suitability of Nonvacant Sites: The elem ent identifies one nonvacant site to accom m odate the regional housin g
need including four units for lower-incom e households.

The elem ent m ust provide an analysis dem onstratin g the potential for redevelopm ent. The m ethod ology m ust
consider factors including the extent to which existing use s m ay im pede additional residential developm ent, developm ent trends, m arket conditions, any and other
inform ation that m ay prevent redevelopm ent of the site for additional residential developm ent. Addition ally, the elem ent could discuss and regulatory or other incentives or standards to encourage additional residential
developm ent on these sites.

Expand and Refine Analysis
P
Environm en tal Constraints: While the elem ent identified and analyzed poten tial en vironm ental constrain ts for the identified sites and Citywide including flooding, special species, and archaeological resources, it should analyze any other poten tial environm ental constraints or other conditions im p acting RHNA sites such as fire hazard or earthquake risks. The elem ent should be revised to
include this inform ation and program s should be added Clarify Existing Analysis
Item #8.5.

HCD Response Letter Comment Overview: Page 7 of 29
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or revised as appropriate.

Q
Electronic Sites Inventory: Pursuant to Governm en t Code section 65583.3, subdivision (b), the City m ust utilize standards, form s, an d definitions adop ted by HCD when preparing the sites inventory. Please see HCD’s housing elem ent webpage at https://www.hcd.ca.gov/com m unitydevelopm ent/housing-elem ent/index.shtm l for a copy of the form and instructions. The City/Coun ty can reach out to HCD at [email protected] for technical
assistance. Please note, upon adoption of the housing
elem ent, the City/Coun ty m ust subm it an electronic
version of the sites inventory with its adopted housing elem ent to [email protected].

Clarify Existing Analysis
R
Zoning for a Variety of Housing Types: Emergency Shelters:

While the elem ent discussed zoning and capacity for
em ergency shelters, the elem ent m ust also identify and analyze any developm ent standards (e.g., spacing,
parking, concentration requirem ents) and other
requirem ents im posed on em ergency shelters. Lastly, the elem ent m ust describe com pliance with Govern m ent
Code section 65583, subdivision a)(4)(A)or include a
program to com ply with this requirem ent. For your
inform ation, pursuan t to Governm en t Code section
65583, subdivision a)(4)(A), parking requirem ents should be lim ited to allowing sufficient parking to accom m odate all staff working in the em ergency shelter, provided that the standards do not require m ore parking for
em ergency shelters than other residential or com m ercial uses within the sam e zone.

Expand and Refine Analysis
S
Supportive and Transitional Housing: The elem ent states that the City perm its supportive and transitional h ousing in all residential zones. Additionally, the elem ent included Table 6-1 listing allowable uses per zoning district.

However, this table did not reflect whether transitional Clarify Existing Analysis
Item #8.5.

HCD Response Letter Comment Overview: Page 8 of 29
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and supportive housing are allowed in zones that allow
for residential uses (e.g., downtown com m ercial,
com m unity com m ercial, etc.,). The elem ent should
reconcile this inform ation and specifically clarify whether the City perm its these types of housing as a residential use and only subject to those restrictions that apply to other residential dwellings of the sam e type in the sam e zone pursuant to Govern m ent Code section 65583 (a)(5).

Additionally, supportive h ousing shall be a use by-right in zones where m ultifam ily and m ixed uses are perm itted, including nonresidential zones perm itting m ultifam ily uses pursuant to Govern m ent Code section 65651. The
elem ent m ust dem onstrate com pliance with these
requirem ents and include program s as appropriate.

T
Housing for Agricultural Employees: The elem ent m ust
dem onstrate zoning is consistent with the Em ployee
Housing Act (Health and Safety Code , § 17000 et seq.), specifically, sections 17021.5 and 17021.6. Section
17021.5 requires em ploye e housing for six or fewer
em ployees to be treated as a single -fam ily structure and perm itted in the sam e m anner as other dwellings of the sam e type in the sam e zone. Section 17021.6 requires
em ployee housing consisting of no m ore than 12 un its or 36 beds to be perm itted in the sam e m anner as other
agricultural uses in the sam e zone. For additional
inform ation and sam ple analysis, see the Building Blocks at http ://www.hcd.ca.gov/com m unitydevelopm ent/building-blocks/housingneeds/farm workers.shtm l.

Clarify Existing Analysis
U
Manufactured Housing: Th e elem ent provided inform ation on perm itting requirem ents for m anufactured hom es in the term s of accessory dwelling units and m obile hom es.

However, m anufactured h om es that are built on a
perm anent foundation m ust be allowed in the sam e
Clarify Existing Analysis
Item #8.5.

HCD Response Letter Comment Overview: Page 9 of 29
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m anner and in the sam e zones as conventional or stickbuilt structures. Specifically, m anufactured hom es on a perm anent structure should only be subject to the sam e developm ent standards that a convention al single -fam ily residential dwelling would be subject to. The elem ent
m ust dem onstrate consistency with this requirem ent or add or m odify program s as appropriate.

V
Land Use Con trols: The elem ent m ust identify and
analyze all relevant land u se controls im pacts as potential constraints on a variety of housing types. The analysis should analyze land use controls independently an d
cum ulatively with other land use controls. While the
elem ent analyzed m ost relevant land use controls, it
m ust identify an d analyze any requirem ents for
m inim um or m axim um un it sizes. Additionally, the
elem ent m ust analyze requirem ents related to
m ultifam ily parking (i.e., two spaces per unit). For
exam ple, the e lem ent cou ld include a discussion about applicable developm ent standards in different zones and how a hypothetical project could achieve m axim um
densities when applying those standards. The analysis
should address any im pacts on cost, supply, housin g
choice, affordab ility, tim in g, approval certainty an d ability to achieve m axim um densities and include program s to address identified constraints.

Expand and Refine Analysis
W
Local Processing and Perm it Procedures: While the
elem ent analyzed m ost procedures and perm itting
requirem ents for various housing types, the elem ent
m ust specifically analyze the requirem ent of a use perm it for m ultifam ily housing for potential constraints on
housing. Specifically, the elem ent notes that a use perm it is required for m ultifam ily developm ent in m ixed-use zones (i.e., com m unity com m ercial and down town
com m ercial) and approval findings include com patib ility Expand and Refine Analysis
Item #8.5.

HCD Response Letter Comment Overview: Page 10 of 29
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with surrounding uses. Additionally, the City identified a portion of their RHNA in these zones. The analysis should address im pacts on housing cost, supply, tim ing an d
approval certain ty. For exam ple, the elem ent should
analyze the required approval findings for im pacts on
approval certain ty and the presence of processes or
guidelines to prom ote certainty and add or m odify
program s as appropriate.

X
Con st ra in t s on Hou sin g for Pe rson s w it h Disa b ilit ie s:
• Reasonable Accommodation: The elem ent states
the City has a reasonable accom m od ation
procedure (p. 5-2), but it should also analyze the
procedure for potential constraints. The analysis
should address the process, application
requirem ents, and associated fees and list and
evaluate the actual approval findings. Depending
on its analysis, the elem ent m ust add or m odify
program s as appropriate.
• Licensed and Unlicensed Residential Care
Facilities for Seven or More Persons: The elem ent
states that these uses are perm itted with a use
perm it in residential zone s. Additionally, the
elem ent indicates that a u se perm it requires
planning com m ission app roval and triggers
design review. For your inform ation , zoning
should sim ply im plem en t a barrier-free definition
of fam ily instead of poten tially subjecting persons
with disabilities to special regulations such as the
num ber of persons, population types, and
licenses. The elem ent m ust analyze this process
as a potential constraint for im pacts on housing
choices, approval certainty, and objectivity for
housing for persons with disabilities. Addition ally,
as part of this analysis, th e elem ent should also
clarify the differences between “general” and
Expand and Refine Analysis
Item #8.5.

HCD Response Letter Comment Overview: Page 11 of 29
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“lim ited” residential care facilities. Based on a
com plete analysis, the elem ent m ay need to add
or m odify program s to allow these uses with
objectivity and certainty.

Y
Approval Tim e and Reque sts for Lesser Densities: While the elem ent stated that th ere were no requests from the “public” to develop at densities below those identified in the inventory (p. 6-23), it m ust clarify and an alyze
requests from project app licants to develop at densities below those identified in the sites inventory. Additionally, the elem ent m ust include an analysis of the length of tim e between receiving approval for a housing
developm ent and subm ittal of an application for building perm its. The elem ent m ust address any hinderance on
the developm ent of housing and include program s as
appropriate.

Expand and Refine Analysis
Z
Special Needs Households: While the elem ent includes
som e data, a general discussion of housing challenges
faced by special needs households, and proposed
program s, it still m ust provide an analysis of the existing needs and resources for each special need group
including seniors, fem ale headed households, large
households, extrem ely low-incom e households, an d
persons with disabilities. For exam ple, the elem ent
should discuss the existing resources to m eet housing
needs (availability of shelter beds, num ber of large units, num ber of deed restricted units, com m u nity services, etc.,) and an assessm ent of any gaps in resources. Local officials, special needs service providers or County social and health service providers m ay be able to assist with inform ation to com ple te the analysis. The elem ent m ay need to add or revise program s and policies based on the outcom es of a com p lete analysis.

Expand and Refine Analysis
Item #8.5.

HCD Response Letter Comment Overview: Page 12 of 29
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AA
Farm workers: While the elem ent included data on the
num ber of m igran t farm workers, the elem ent m ust
specifically quantify the n um ber of perm anen t and
seasonal farm workers within the Coun ty (USDA
Agriculture Census data).

Clarify Existing Analysis
AB
The elem ent states that th e City has a portfolio of 203 afford able housing units, however, HCD’s records
indicate that the City has 287 affordable housing u nits.

The elem ent should reconcile these figures and include the following projects in the inventory: Lincoln Avenue Apartm ents (77 assisted units located on 1855 Lincoln
Avenue) and Calistoga Farm Worker Center (60 assisted
units on 3996 North St. Helena Highway).

Expand and Refine Analysis
Hou sin g Act ion s: Program s m ust dem onstrate th at they will have a beneficial im pact within the plan ning period. Beneficial im pact m eans specific com m itm ent to deliverables, m easurable m etrics or objectives, definitive deadlines, dates, or benchm arks for im plem entation. Deliverables should occur early in the planning period to ensure actual housin g outcom es. The elem ent m ust provide quantified objectives where appropriate and all programs should be evaluated to ensure provision of discrete tim ing (e.g., m onth and year) to account for how often the action will occur as well as to ensure a beneficial im pact through out the planning period. In addition , the elem ent should be revised as follows:

AC
Specific Com m itm ents: Th e elem ent includes several program s lacking specific com m itm ents (e.g., “explore,” “consider,” etc.,). While th e elem ent can include program s to study certain topics, it includes a preponderance of program s that do not go b eyond studying or exploring a particular action. Program s should be am ended, as
appropriate to include m ore specific and m easurable
actions. This includes but is not lim ited to Actions 1.2-2,

1.2-4, 1.2-6, 1.3-5, 2.1-6, and 2.2-3.

All Actions revised.

AD
Im plem en tation Actions: As noted above, program s m ust have clear outcom es or deliverables. Several program s include actions with no description of how those actions will be im plem ented (e.g., “encourage”, “assist”, “partne r”, “m ain tain”, etc.,). For exam ple, Program 1.2-1 states that Expand and Refine Analysis. All Actions revised.

Exam ple: “2.2-2” should b e “1.2-2.” 2.2-2 is: Assist developers in seeking funding for afford able housing from at least three sources: (1) local banks seeking to m eet their obligations under the Com m unity Reinvestm en t Act, (2) investors seeking LowItem #8.5.

HCD Response Letter Comment Overview: Page 13 of 29
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the City will encourage new residential developm ent to be built to the m axim um density, however, does not
describe how the City will encourage this action from
occurring (e.g., develop requirem ents, pre -application m eetings, etc.,). Program s should be am ended, as
appropriate to include im plem entation steps. This
includes but is not lim ited to Actions 1.2-1, 2.2-2, 1.2-3,

4.1-2, 4.1-3, 4.1-7, and 4.2-1.

Incom e Housing Tax Credits, and (3) federal and state funds, including those available under the HOME program.

AE
Ongoing Program s: Majority of the program s lists
im plem entation tim elines as “ongoing.” While this m ay be appropriate for som e program s, program s with specific im plem entation actions m ust include com pletion or
initiation dates resulting in beneficial im pacts within the planning period. For exam ple, Action 1.2-6 com m its to partnering with the Ch am ber of Com m erce to encourage options for workforce housing and consider program s to connect hom eowners to em ployees in need of housing
yet lists the tim eline as “ongoing.” To address this, the program should include a tim eline for when and how the City will engage and partn er with organizations. This and other program s should in clude specific dates or
benchm arks for im plem e ntation throughout the planning period. This includes but not is lim ited to Actions 1.2-6,

1.2-3, 1.3-3, 1.3-4, 2.1-2, 2.1-3, 2.3-1, 4.1-2, 4.1-3, 4.1-5,

4.2-2, 4.3-1, 4.3-2.

Expand and Refine Analysis. All Actions revised.

AF
Publicly Owned Sites: The elem ent identified City-owned sites to accom m od ate a p ortion of the RHNA. The
elem ent should include a program with nu m erical
objectives that ensures com pliance with the Surplus Land Act, provides incentives and actions along with a
schedule to facilitate developm ent of City-owned sites.

Actions should include outreach with developers, issuing requests for proposals, in centives, fee waivers, priority processing and financial assistance.

Expand and Refine Analysis. Actions revised accordingly.

Item #8.5.

HCD Response Letter Comment Overview: Page 14 of 29
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AG
As noted in Findings A5 and A6 [HCD Identifier V th rough Y], the elem ent requires a com plete analysis of pote ntial governm ental constraints. Depending upon the results of that an alysis, the City m ay need to revise or add
program s and address an d rem ove or m itigate any
identified constrain ts.

Clarify Existing Analysis
AH
The elem ent is required to include a program that
incentivizes or prom otes accessory dwelling unit (ADU) developm ent for very low-, low-, and m oderate -incom e households. While the elem ent included Action 1.2-2, this program does not com m it to anything beyond
“considering” m aking am e ndm ents to the City’s ADU
ordinance. First, HCD’s records indicate that the City has not updated it’s ADU ordinance to com ply with recent
state law from 2020-2022. The elem ent m ust include a
specific com m itm ent to u pdate the City’s ADU ordinance to be com plian t with state law. Second, as noted, th e elem ent m ust include a program that incentivizes or
prom otes ADU developm ent. Exam ples of incentives
include pursuing funding opportu nities, m odifying
developm ent standards, and reducing fees beyond state
law, increasing awareness, pre -approved plans, and
hom eowner/applican t assistance tools. Other strate gies could include developing inform ation packets to m arket ADU construction, targeted advertising of ADU
developm ent opportunitie s or establishing an ADU
specialist within the plann ing departm ent.

Clarify Existing Analysis. In corporate Napa-Son om a ADU Center’s com m ents:
https://m-group.box.com /s/ubrbeihc6557rt6045tocl0cefwqvaoc AI
As noted in Finding A1 [HCD Com m ent Iden tifier A
through G], the elem ent m ust include a com plete analysis of AFFH. Based on the outcom e of that analysis, the
elem ent m ust add or m od ify program s.

Expand and Refine Analysis. May not need addition al analysis, once review is com plete
AJ Based on HCD’s review, the elem ent included quantified objectives for various incom e categories for conservation , Expand and Refine Analysis
Item #8.5.

HCD Response Letter Comment Overview: Page 15 of 29
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rehabilitation , and construction in two separate places of the elem ent (p. 5-27and p. 8-16). First, the elem ent
should reconcile these tables to consistently report
quantified objectives for each incom e category. Secondly, the elem ent m ust include quantified objectives for all incom e levels, including extrem ely low incom e
households. Lastly, while the elem ent included som e
quantifiable objective s for conservation, it m ust include objectives for the num ber of housing units that will be rehabilitated and conserved/preserved for all incom e
levels (extrem ely low, very low, low, m oderate, and above m oderate).

Cit y of Ca list oga Re sp on se t o HCD 90-Da y Re vie w Le t t e r (8.24.202) Goal, Policy, Act ion Re vision s
Policy #
Re fe re n ce HCD Comment Cit y Re sp on se
GOAL 1 – HOUSING SITES. Maximize opportunities for the development of housing to accommodate anticipated growth and facilitate mobility within the ownership and rental housing markets.

Objective 1.1 – Ensure t ha t a n a dequa t e a m ount of la nd is a va ila ble for residential development for all economic segments of the community and to meet the city’s regional share of housing needs.

A1.1-1
When reviewing proposed residential
developm ent projects and proposals to
downzone residential properties or reclassify
residentially-designated property to other
use s, con sider the potential im pact on the
ability of the City to provid e adequate sites
for residential developm e nt for all econom ic
Revise Action: Prohibit downzone or reclassification to non-residential uses of residentially designated property.

Item #8.5.

HCD Response Letter Comment Overview: Page 16 of 29
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segm ents of the com m unity and achieve its
quantified housing objectives.

A1.1-2
Ensure that any am endm ents to the Housing
Elem ent or other General Plan elem ents
m ain tain intern al consistency within the
General Plan as a whole.

Revise policy: Tim ing ongoing. Planning and Building Departm ent, Planning Com m ission , City Council responsible partie s. Action within one year of Housing Elem ent certification A1.1-3
Evaluate General Plan objectives, policies,
and actions for consistency with State law
and am end as needed to ensure consistency
with objective design standards and Housing
Elem ent objectives to encourage housing.

Review of General Plan should include, but
are not lim ited to: Objective LU 1.4, LU P1.4-
1, LU A1.4-1, Objective LU 3.2, LU P3.2-1, LU
A3.2-1, LU P4.1-4, Objective CI 1.1, CI P1.1-1,
OSC P5.2-1, OSC P5.2-4.

Revise policy: Tim ing ongoing. Planning and Building Departm ent, Planning Com m ission , City Council responsible partie s. Action within one year of Housing Elem ent certification A1.1-4
Modify m un icipal code to allow for
m ultifam ily housing on vacant or
underutilized portions of lots larger than one
acre if allowed under zoning and land use
controls. New housing would require
sufficient distance from e xisting uses to
m itigate noise, health, an d safety risks. An
entrance to the lot separate from the
entrance for the existing use m ay be ideal.

Revise policy: Tim ing ongoing. Planning and Building Departm ent, Planning Com m ission , City Council responsible partie s. Action within one year of Housing Elem ent certification Objective 1.2 – Ma ke effe ct ive use of resident ia l de velopm ent sit es.

A1.2-1
En cou ra ge new residential developm ent to
be built to the m axim um num ber of dwelling
units prescribed by the General Plan for
specific properties, subject to conform ance
with the City’s residential design guidelines
and the General Plan ’s residential design
policies.

Revise policy: Within one year of Housing Elem ent certification, amend Zon ing Code to specify m inim um residential density within the range prescribed by the General Plan for m ulti-fam ily and com m ercial properties, subject to conform ance with the City’s residential design guidelines and the General Plan’s residential design policies.

Item #8.5.

HCD Response Letter Comment Overview: Page 17 of 29
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A1.2-2
Consider am end m ents to the Zoning Code’s
regulations for accessory dwelling units to
encourage their developm ent, such as
incentives to build and rent out accessory
dwelling units to lower incom e com m u nity
m em bers and local workers.

Revise Policy: Within one year of Housing Elem ent certification, am end Zon ing Code’s regulations for accessory dwelling units to encourage their developm ent, such as incentives to build and rent out accessory dwelling units to lower incom e com m unity m e m bers and local workers.

A1.2-3
Continue to partner with the Housing
Authority of the City of Napa (HACN),
Napa/Sonom a Collaborative, and other nonprofits to educate hom eowners on accessory dwelling units and encourage increased
construction.

Revise Policy: Within one year of Housing Elem ent certification, am end the ADU ordinance to include provisions less restrictive than state law requirem ents, such as:
 Allowing two-story ADUs
 ADUs on corner lots
 Front yard setbacks that m atch the m ain house
 Reduced side or rear yard setbacks
 No parking replacem ent required
Defining “attached” for pu rposes of a Junior ADU created out of an attached garage as “connected by a com m on wall, or by a com m on roof, covered walkway, carport or garage, not m ore than twen ty feet (20') wide.”
A1.2-4
Consider am end m ents to the Zoning Code
to perm it housing cooperatives, adaptive
reuse of m otels, and single residence
occupancies (SROs) in residential and m ixeduse zones.

Revise Policy: Within one year of Housing Elem ent certification, am end the Zon ing Code to perm it adap tive reuse of inns and m otels and housing cooperatives in residential and com m ercial zones.

A1.2-5
Conduct two public workshops with
hom eowners on the viability of long-term
rentals as a housing solution to
accom m od ate workforce housing. Invite
restaurants, hotels, and other hospitalityrelated com panies to participate in these public workshops.

Revise Policy: Within one year of Housing Elem ent certification. Plan ning and Building Departm ent, Cham ber of Com m erce
A1.2-6
Partner with the Ch am ber of Com m erce to
encourage restaurants, h otels, and other
hospitality-related com p anies to work with
second hom e/vacation hom e hom eowners
to provide long-term lease agreem ents for
tem porary workforce housing. Consider
programs to connect interested
Revise Policy: Within one year of Housing Elem ent certification, expand contract with the Cham ber of Com m erce to include annual outreach events (open house, workshop, presentation , etc.) involving hospitality-related com panies and second hom e/vacation hom e homeowners to help facilitate the provision of long-term lease agreem ents for tem porary workforce housing.

Item #8.5.

HCD Response Letter Comment Overview: Page 18 of 29
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Re fe re n ce HCD Comment Cit y Re sp on se
hom eowners with em ployers or workers in
search of affordable housing opportunities.

A1.2-7
Adopt objective design standards for
residential developm ent, which will be
applied to projects eligible for m inisterial
review.

Revise Policy: Within one year of Housing Elem ent certification. Plan ning and Building Departm ent, Planning Com m ission , City Council
Objective 1.3 – Provide public services a nd fa cilities needed for the development of housing.

A1.3-1
Continuously update the Capital
Im provem en t Program to ensure that sewer,
water, and street im prove m ents facilitate
residential developm ent.

Revise Policy: Annually. Public Works Departm ent
A1.3-2
Provide periodic reports to the City Council
on the available water sup ply and
wastewater treatm ent cap acity as part of the
annual General Plan Progress Reports.

Revise Policy: Annually. Planning and Building Departm ent A1.3-3
Update reasonable, nexus-based
im pact/connection fees on developm ent
projects to support adequ ate sewer, water
and transportation services, and parks and
cultural facilities.

Revise Policy: Within one year of Housing Elem ent certification, update reasonable, nexusbased im pact/connection fees on developm ent projects to support adequate sewer, water and transportation services, and parks and cultural facilities.

A1.3-4
Periodically review and update
developm ent-related im p act/connection fees
to ensure that fees are com m ensurate with
the cost to the City for providing required
infrastructure. Consider reduction in fees for
100 percent afford able housing projects and
the afford able portion of other projects.

Revise Policy: Conduct an nual reviews of developm ent-related im pact/conne ction fees and update accordingly to ensure that fees are com m ensurate with the cost to the City for providing required infrastructure.

A1.3-5
Consider using the Affordable Housing Fund
to subsidize all or part of the water and
wastewater connection fe es for affordable
housing projects and affordable units.

Revise Policy: Subsidize all or part of developm ent im pact and connection fees for affordable housing projects with funding assistance from sources such as TOT, in-lieu fees, developm ent agreem ents, inclusionary housing and/or grant fun ding to support provision of short-term , pre -developm ent, acquisition, and/or construction funding.

Item #8.5.

HCD Response Letter Comment Overview: Page 19 of 29
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Re fe re n ce HCD Comment Cit y Re sp on se
A1.3-6
Ensure that active transp ortation grant
funding for safe street initiatives is aligned
with housing strategies.

Revise Policy: Ongoing. Planning and Building Departm ent, Public Works Departm en t A1.3-7
Incorporate housing policies and Calistogaspecific policies from the Blue Zones Project Upper Napa Valley Blueprint, including but
not lim ited to adop ting a sm oke -free
ordinance for m ultifam ily housing properties
that covers all exclusive -use areas, interior
unit spaces, as well as com m on areas not
already covered by state law. Identify other
housing policies from the Blueprint
appropriate for incorporation into City policy
as appropriate.

Revise Policy: Within one year of Housing Elem ent certification. Plan ning and Building Departm ent, Planning Com m ission , City Council
GOAL 2 – HOUSING DEVELOPMENT. Promote housing that meets the needs of extremely low-, low- and moderate-income households, particularly those who work in Calistoga.

Objective 2.1 – Encoura ge t he development of a fforda ble housing.

A2.1-1
Ensure com pliance with State -mandated
density bonuses and other incentives for
projects that reserve units for extrem ely low-
, very low-, low-, and m od erate -incom e
households.

Revise Policy: Ongoing. Planning and Building Department A2.1-2
Maintain the City’s Afford able Housing Fund
as a source of funding for afford able
housing to extrem ely low-, very low-, lowand moderate -incom e households.

Revise Policy: Conduct an nual assessm ents to m onitor the City’s Affordable Housing Fund and convey to public (via City website, notices at the public counter, etc.) as a source of funding for afford able housing to extrem ely low-, very low-, low-and moderate -incom e households.

A2.1-3
Allocate, as econom ic resources perm it, a
portion of any tax revenue resulting from
new developm ent, including transient
occupancy tax (TOT), to support housing
opportu nities for extrem ely low-, very low-,
low-and moderate -incom e households,
including for use in land banking,
Revise Policy: Ongoing. Within two years of Housing Elem ent certification, pursue the purchase of property for the construction of affordable and/or special-needs housing utilizing revenue from sources such as TOT, in-lieu fees, developm ent agreem ents, inclusionary housing and/or grant fun ding
Item #8.5.

HCD Response Letter Comment Overview: Page 20 of 29
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developm ent of affordable housing, or other
uses that will lead to m ore affordable
housing.

A2.1-4
Use loan repaym ents from the 1980s CDBG
residential rehabilitation program to fu nd
program s and projects th at benefit
extrem ely low-, very low-, low-and
moderate -incom e househ olds.

Revise Policy: Ongoing. Funds from this account are used annually to support contract services with the City of Napa Housing Authority (grant applications and program adm inistration), Napa Valley Com m unity Action (hom eless services), Napa Valley Fair Housing and Rebuilding Calistoga.

A2.1-5
Change the zoning on hou sing opportunity
sites to allow m inisterial review of housing
developm ent projects when a m inim u m of
20 percent of the units in the developm ent
are affordab le to extrem ely low-, very low-,
low-, or m oderate -incom e households.

Revise Policy: Within one year of Housing Elem ent certification. Plan ning and Building Departm ent, Planning Com m ission , City Council
A2.1-6
Consider adop ting CASA (Com m ittee to
House the Bay Area) Com pact Elem ent # 7,
which would provide an expedited approval
process and financial incentives for the
provision of on-site housing units affordable
to the m issing-m iddle incom e ranges, which
includes households that earn 80 to 120
percent AMI.

Revise Policy: Within one year of Housing Elem ent certification Planning and Building Departm en t, Planning Com m ission Within one year of Housin g Elem ent certification , ad opt CASA (Com m ittee to House the Bay Area) Com pact Elem en t # 7, which would provide an expedited approval process and financial incentives for the provision of on-site housing units afford able to the m issing-m iddle incom e ranges, which includes households that earn 80 to 120 percent AMI.

Objective 2.2 – Pursue st a t e a nd federa l funding a ssist a nce a ppropria t e t o Ca list oga ’s needs for afforda ble housing.

A2.2-1
Use local funding to leverage funding
available from federal, state, county, and
private funding sources for affordable
housing and housing for special needs
groups.

Revise Policy: Ongoing. Meet with the Housing Authority of the City of Napa (HACN) at least annually to review upcom ing Notices of Funding Availability (NOFA) for the purpose of identifying opportunities to m atch local fun ds with federal, state, coun ty, and private funding sources for affordable housing and housing for special needs groups.

A2.2-2
Assist developers in seeking funding for
afford able housing from at least three
sources: (1) local banks seeking to m eet their
obligations under the Com m unity
Reinvestm ent Act, (2) investors seeking LowIncom e Housing Tax Credits, and (3) federal Revise Policy: Conduct an nual outreach events (workshops or webinars, City website notices, public counter m aterial, p ostings, regional coordination with HACN and others, etc.) targeting developers in seeking funding for affordable housin g from at least three sources: (1) local banks seeking to m eet their obligations under the Com m unity Reinvestm ent Act, (2) investors seeking Low-Incom e Housing Tax Credits, and (3) federal and state funds, including those available under the HOME program .

Item #8.5.

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and state funds, including those available
under the HOME program .

A2.2-3
Explore potential for a partnership between
the Planning and Building Departm ent and
the Cham ber of Com m erce to host annual
workshops on rental assistance resources
and services.

Revise Policy: Within one year of Housing Elem ent certification, expand contract with the Cham ber of Com m erce to include form alize a partn ership (in conjunction with Policy A1.2-6) with the Planning and Building Departm ent to host an annual workshop on re ntal assistance resources and services.

Objective 2.3 – Address the impacts of nonresidential development and market-rate residential development on the demand for, and the development of, affordable housing.

A2.3-1
Charge afford able housin g linkage fees on
nonresidential developm e nt that are
deposited in the Affordable Housing Fund to
be used, in part, to increase the supply of
afford able housing. Periodically review and
revise the fees as necessary.

Revise Policy: Within one year of Housing Elem ent certification, conduct a code audit of CMC Chap ter 17.08 Affordab le Housing to ensure that fu nds generated by the policies (including nonresidential linkage fees) are sufficient to increase the supply of affordable housing.

Periodically review and revise the fees as necessary.

GOAL 3 – EXISITING HOUSING. Maintain the City’s housing stock and protect the affordability of affordable units.

Objective 3.1 – Minimize the loss of existing housing units.

A3.1-1
Where the loss of affordable housing occurs
through dem olition or con version, these
units shall be replaced on-site or elsewhere.

The City Cou ncil m ay allow the paym ent of
an in-lieu fee to the Affordable Housing Fund
for lost units in addition to any afford able
housing linkage fee in cases where the
proposed uses clearly provide other benefits
to the City.

Revise Policy: Ongoing. Planning and Building Departm ent, City Council A3.1-2
Continue to actively enforce the Zoning
Code’s prohibition of vacation rentals (i.e.,
the renting of hom es for fewer than 30
days).

Revise Policy: Ongoing. Planning and Building Departm ent, Police Departm en t Item #8.5.

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Objective 3.2 – Minimize the conversion of affordable units to market-rate units.

A3.2-1
Monitor deed-restricted affordable housing
projects to ensure com pliance with
afford ability requirem en ts and restrictions.

Revise Policy: Ongoing. Monitoring reports verifying rents and household incom es com pleted by Housing Authority of th e City of Napa annu ally.

Planning and Building Departm en t, Housing Authority of the City of Napa A3.2-2
Continue to ad m inister th e Mobile Hom e
Rent Stabilization Ordinan ce and defend it
against legal challenges. Monitor the
effectiveness of the Ordinance and revise if
necessary to m axim ize its effectiveness.

Revise Policy: Ongoing. Planning and Building Departm ent, City Council GOAL 4 – SPECIAL NEEDS. Address the housing needs of special-needs population groups, including seniors, farmworkers, people with disabilities including developmental disabilities, large families, and female-headed households.

Objective 4.1 – Promote housing for special-needs population groups.

A4.1-1
Approve residential density bonuses and
incentives consistent with the provisions of
State law for senior housing projects and
any other special needs focused housing
proposed.

Revise Policy: Ongoing. Planning and Building Departm ent, Planning Com m ission A4.1-2
Collab orate with Napa County, the
agricultural industry, and non-profit
organizations to assess the needs, plans,
and funding for developin g farm worker
housing to m eet the needs of perm anent
and seasonal laborers.

Revise Policy: Ongoing. Meet with the Housing Authority of the City of Napa (HACN) and the Napa Coun ty Housing Authority at least annually to continue to provide annu al funding to the Napa Coun ty Housing Authority to support the thre e farm worker housing centers, including the Calistoga Center.

A4.1-3
Collab orate with Napa County and nonprofit organizations to assess the needs of the hom eless by participating in efforts to
survey this population an d providing funding
or other support to ensure the provision of
shelters on a regional basis.

Revise Policy: Ongoing. Meet annually with Napa County and non-profit organ izations annually to ensure that th e City’s annual fun ding to Com m unity Action Napa Valley continues to be sufficient to support hom eless services.

A4.1-4
Provide inform ation abou t the 211-phone
system , which provides assistance to
persons in need of em ergency shelter.

Revise Policy: Ongoing. The City provides this inform ation at city offices and on its website.

Planning and Building Departm en t, Police Departm ent
Item #8.5.

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A4.1-5
Maintain an up-to-d ate Housing Resources
page on the City’s website that provides
inform ation on the City’s housing program s
and links to the websites of local housing
organizations and housin g agencies that
provide addition al housin g program s.

Revise Policy: Conduct an nual assessm ent of City’s Housing Resources webpage to update and refresh local housing program s and links to local housing organizations and housing agencies that provide affordable housing program s.

A4.1-6
As part of the project review process,
provide incentives to m arket-rate rental
housing projects of 10 or m ore units that
provide affordable three -and four-bedroom
units, which m ay include waivers from or
m odifications to developm ent stand ards as
determ ined to be appropriate through the
developm ent review process.

Revise Policy: Ongoing. Planning and Building Departm ent, Planning Com m ission A4.1-7
Encourage developers of afford able housing
projects to designate a share of the units for
the disabled, including developm entally
disabled persons.

Revise Policy: Ongoing
Planning and Building Departm en t, Planning Com m ission, City Council. With in one year of Housing Elem ent certification, am end zoning ordinance to establish regulatory concessions or waivers for projects including units deed restricted for developm entally disabled persons.

A4.1-8
Am end Zoning Code Chap ter 17.04,
Definitions, to update the definition for “Low
Barrier Navigation Center” consistent with
state law. Am end the Downtown
Com m ercial Zoning District to allow low
barrier navigation centers as a perm itted use
by right.

Revise Policy: Within one year of Housing Elem ent certification. Plan ning and Building Departm ent, Planning Com m ission , City Council
Objective 4.2 – Financially support housing for special-needs population groups.

A4.2-1
Maintain the City’s Afford able Housing Fund
as a source of funding for housing for
special-needs population groups.

Revise Policy: Within one year of Housing Elem ent certification, am end CMC Ch apter 17.08 Affordable Housing to earmark a percent of the City’s Affordable Housing Fun d (as increased % of TOT) as a source of funding for housing for special-needs population groups.

A4.2-2
Allocate, as econom ic resources perm it, a
portion of any tax revenue resulting from
new developm ent, including transient
occupancy tax (TOT), to support housing
opportu nities for special-needs population
Elim in ate Action – com bin ed with A4.2-1
Item #8.5.

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groups.

A4.2-3
Use loan repaym ents from the CDBG
account to fund program s and projects that
benefit special-needs population groups.

Revise Policy: Ongoing. Funds from this account are used annually to support contract services with the City of Napa Housing Authority (grant applications and program adm inistration), Napa Valley Com m unity Action (hom eless services), and Rebuilding Calistoga.

Objective 4.3 – Pursue state and federal funding assistance appropriate to Calistoga’s needs for special-needs housing.

A4.3-1
Use local funding to leverage funding
available from federal, state, county, and
private funding sources for special needs
groups.

Revise Policy: Annually, pursue funding available from federal, state , county, and private funding sources for special needs groups.

A4.3-2
Maintain a Housing Resou rces page on the
City’s website that provide s inform ation on
resources for special-needs population
groups and links to the websites of local
housing organizations an d housing agencies.

Revise Policy: Conduct qu arterly updates of the Housing Resources page on the City’s website that provides inform ation on resources for special-needs population groups and links to the websites of local housing organizations and housin g agencies.

Objective 4.4 – Provide access to housing for people with disabilities including developmental disabilities.

A4.4-1
Enforce State requirem en ts for accessibility
and adaptability in rem od eled and new
housing projects.

Revise Policy: Revise Policy: Conduct an nual assessm ents of City’s enforcement of State requirem ents for accessibility and adap tability in rem odeled and new housing projects.

A4.4-2
Enforce the City’s Universal Design Policy
that requires accessible design features to
be incorporated into newly-constructed and
substantially-rehabilitated single -fam ily and
duplex residences to the m axim u m feasible
extent, and update as necessary.

Revise Policy: Within one year of Housing Elem ent certification, update the City’s Universal Design Policy that requires accessible design features to be incorporated into newlyconstructed and substantially-rehabilitated single -fam ily and duplex residences to the m axim um feasible extent, and update annually as necessary.

A4.4-3 Seek grants to retrofit existing housing to
provide disabled accessibility.

Revise Policy: Annually, pursue grant funding to retrofit existing housing to provide disabled accessibility.

Item #8.5.

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A4.4-4
Inform the public about th e City’s reasonable
accom m od ations provisions that allow
m odifications to the City’s developm ent
standards for persons with disabilities
seeking equal access to housing.

Revise Policy: Within one year of Housing Elem ent certification, inform the public via the City website about the City’s reasonable accom m odation s provisions that allow m odifications to the City’s developm ent standards for persons with disabilities seeking equal access to housing.

Objective 4.5 – Support farmworker and other workforce housing models.

A4.5-1
Conduct two public workshops with worker
organizations and cooperative housing
specialists on the viability of cooperative
housing as a housing solution to
accom m od ate workforce housing.

Revise Policy: Within one year of Housing Elem ent certification. Plan ning and Building Departm ent, Cham ber of Com m erce
A4.5-2
Invite m ajor em ployers and worker
organizations, as well as local organizations
such as Fair Housing Napa Valley and the
UpValley Fam ily Center, to a public forum in
order to identify clear needs and available
resources for workforce housing
opportu nities.

Revise Policy: Within one year of Housing Elem ent certification. Plan ning and Building Departm ent, Cham ber of Com m erce
A4.5-3
Collab orate with Coun ty and local
organizations such as Fair Housing Napa
Valley and the Up Valley Fam ily Center to
bring m ore bilingual/m ultilingual service
providers to existing farm worker housing
centers.

Revise Policy: Within one year of Housing Elem ent certification, collaborate with County and local organizations such as Fair Housing Napa Valle y and the UpValley Fam ily Center to ensure that city fund ing contributions are sufficient to adeq uately provide bilingual/m ultilingual service to existing farm worker housing centers and expand budgets if necessary.

A4.5-4 Seek grants and funding opportunities for
farm worker fam ily housin g in Calistoga.

Revise Policy: Elim inate – resolved by A 4.1-2:

Meet with the Housing Authority of the City of Napa (HACN) and the Napa Cou nty Housing Authority at least annu ally to continue to provide an nual funding to the Napa Coun ty Housing Authority to support the three farm worker housing centers, including the Calistoga Center.

GOAL 5 – HOUSING MAINTENANCE. Maintain and enhance the physical condition and aesthetic qualities of existing residential neighborhoods.

Objective 5.1 – Preserve and improve the quality of existing housing.

Item #8.5.

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A5.1-1
Offer technical assistance to aid
hom eowners in m ain taining, upgrading, and
im proving their property.

Revise Policy: Conduct an nual outreach events (workshops or webinars, City website notices, public counter m aterial, direct m ailings, etc.) targeting low-incom e hom eown ers to offer technical assistance in m aintaining, upgrading, and im proving their property.

A5.1-2
Provide funding and coop erate with
volunteer groups such as Rebuilding
Calistoga to help lower-incom e households
m ain tain and upgrade the ir property.

Revise Policy: Annually, pursue CDBG Gran t funding to fund coordin ation with volunteer groups such as Rebuilding Calistoga help lower-incom e households m ain tain and upgrade their property.

A5.1-3
Continue to correct health and safety issues
identified during routine b uilding perm itting
and inspection activities.

Delete – defer to state law.

A5.1-4
Develop and adopt a procedure as part of
the City’s Code Enforcem e nt Program for the
City to in tervene when a property is
becom ing seriously deteriorated, especially
if it is of historic significance.

Revise Policy: Within one year of Housing Elem ent certification. Plan ning and Building Departm ent, Police Departm ent
A5.1-5
Maintain an annu al inspection program to
enforce health and safety codes and abate
unsafe living conditions in the City’s m ultifam ily housing com plexes and m obile hom e parks.

Revise Policy: Ongoing. The City inspects one m obile hom e park annually and all m ulti-fam ily housing is inspected annually. Planning and Building Departm ent, Fire Departm ent Objective 5.2 – Encourage private investment in older residential neighborhoods and the private rehabilitation of housing.

A5.2-1
Maintain good repair of streets, sidewalks,
and other m unicip al system s in older
residential neighborhood s.

Delete – Housing Elem ent does not regulate public right-of-way. Regulated General Plan Mobility Ele m ent and CMC title 12 and Capital Im provem ent Program m ing A5.2-2
Allow the application of th e State’s Historic
Building Code to qualified hom es in order to
provide flexibility in rehabilitation and
m odification efforts.

Revise Policy: Ongoing. Planning and Building Departm ent.

A5.2-3
Publicize the City’s Mills Act program to
encourage owners of qualified owneroccupied hom es to actively participate in the rehabilitation , restoration , preservation, and
m ain tenance of their historic property in
Revise Policy: Conduct an nual outreach events (workshops or webinars, City website notices, public counter m aterial, direct m ailings, etc.) publicizing the City’s Mills Act program to encourage owners of qualified owner-occupied hom es to actively participate in the rehabilitation , restoration , preservation, and m ainte nance of their historic property in exchange for a reduction in their property taxes.

Item #8.5.

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exchange for a reduction in their property
taxes.

Objective 5.3 – Ensure new housing development complements Calistoga’s rural small-town community identity, incorporates quality design, and complies with objective design standards when applicable.

A5.3-1
The City’s residential design standards, the
General Plan’s Ch aracter Area Overlay
Districts, and objective design standards
when adopted shall be considered in the
review of proposed residential projects.

Revise Policy: Ongoing. Planning and Building Departm ent, Planning Com m ission A5.3-2
As part of the project review process,
encourage new residential subdivisions of
ten or m ore lots or units to provide a range
of lot sizes and designs to the extent
feasible, and avoid “cookie cutter”
approaches to subdivision design.

Revise Policy: Include elem ents in objective design standards referenced in A1.2-7an d A5.3-1 related to site design and lot configurations to ensu re context sensitivity.

A5.3-3
Consider applying objective design
standards referenced in A1.2-7an d A5.3-1 for
non-m inisterial review developm ent
projects.

Revise Policy: Include elem ents in objective design standards referenced in A1.2-7an d A5.3-1 related to non-m inisterial review developm ent projects .

GOAL 6 – STREAMLINING. Remove governmental constraints to the maintenance, improvement, and development of housing, where feasible.

Objective 6.1 – Streamline the City’s permit review process, simplify regulations, and minimize fees to promote the provision and maintenance of housing.

A6.1-1
Allow use of the Historic Building Code to
facilitate the rehabilitation of historic
residences.

Revise Policy: Ongoing. Planning and Building Departm ent.

A6.1-2
Modify the Zoning Ordinance so that parcels
in the Site Inventory identified in previous
Housing Elem ents ("Reuse Sites") with at
least 20 percent of the units affordable to
lower-incom e households are eligible for byright processing with m inisterial review.

Before m odification of the Zoning
Revise Policy: By January 2026. Planning and Buildin g Departm ent, Plan ning Com m ission, City Council
Item #8.5.

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Ordinance, the City should consider
identification of any biological or cultural
resources on the Reuse Sites that m ay
im pact the developm ent viability of the
identified sites.

A6.1-3
Allow the joint utilization of parking spaces
where it can be dem onstrated that shared
use will not result in an unacceptable im pact
on parking in the public right-of-way or on
off-street parking lots.

DELETE: Conveyed by CMC Section 17.36.040 Join t Utilization of Parking Spaces.

GOAL 7 – ANTI-DISCRIMINATION. Prevent housing discrimination on the basis of race/ethnicity, color, national origin, sex (including gender identity and sexual orientation), religion, age, ancestry, marital status, children, familial status, or disability.

Objective 7.1 – Provide housing opportunities for all persons regardless of race/ethnicity, color, national origin, sex (including gender identity and sexual orientation), religion, age, ancestry, marital status, children, familial status, or disability.

A7.1-1
Provide bilingual inform ation abou t fair
housing at public location s, including
displaying printed m aterials at City Hall,
providing printed m aterials to the UpValley
Fam ily Cen ter, and including links to fair
housing resources on the Housing
Resources page of the City’s website.

Revise Policy: Conduct an nual outreach events (workshops or webinars, City Housing Resources page, public postings, public counter and UpValley Fam ily Center m aterial, direct m ailings, etc.) providing bilingual inform ation abou t fair housing and including links to fair housing resource s.

A7.1-2
Provide financial support to, and work with
local organizations, such as Fair Housing
Napa Valley and the UpValley Fam ily Center,
to provide m ulti-lingual landlord-tenant
education, conciliation , an d the intake of
discrim ination com plaints, investigation, and
enforcem ent.

Revise Policy: Conduct an nual outreach events (workshops or webinars, City Housing Resources page, public postings, public counter and UpValley Fam ily Center m aterial, direct m ailings, etc.) targeted to local organizations, such as Fair Housing Napa Valley and the UpValley Fam ily Center, to provide m ulti-lingual land lord-tenan t education , conciliation , and the intake of discrim ination com plaints, investigation, and enforcem ent.

A7.1-3
Include a Fair Housing Marketing Plan as
part of housing opportunities created
through the City’s afford able housing
programs.

Revise Policy: Within one year of Housing Elem ent certification, con tract for the creation of a Fair Housing Marketing Plan as part of housing opp ortunities created through the City’s afford able housing program s.

Item #8.5.

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A7.1-4
Continue to im ple m ent fair housing
practices in affordable housing program s,
such as the HOME residential rehabilitation
program.

Revise Policy: Ongoing. Planning and Building Departm ent.

A7.1-5 Consider adop ting a just cause eviction
ordinance.

Revise Policy: Within one year of Housing Elem ent certification, ad opt a just cause eviction ordinance.

GOAL 8 – SUSTAINABILITY. Reduce energy use and greenhouse gas production in existing and new residential development.

Objective 8.1 – Reduce energy demand in new and existing housing through conservation and efficiency.

A8.1-1
Publicize the availability of weatherization
and energy-efficiency program s for existing
residences that are offere d by utility
com panies and other organizations.

Revise Policy: Conduct an nual outreach events (workshops or webinars, City Housing Resources page, public postings, public counter, direct m ailings, etc.) to publicize the availability of HERO and CalFirst loan program s for weatherization and energy-efficiency program s for existing residences that are offered by utility com panies and other organizations.

A8.1-2
Ensure efficient water use for irrigation by
adopting the State’s stand ards for waterefficient landscape design.

Revise Policy: Within one year of Housing Elem ent certification. Plan ning and Building Departm ent, City Council
A8.1-3
Fund energy conservation im provem ents
through local rehabilitation program s to
assist lower-incom e households in lowering
energy expenses.

Revise Policy. Ongoing. The current HOME rehabilitation program includes funding for energyefficiency im provem ents. Annually, ensure continue d funding for HOME rehabilitation program for energy conservation im provem ents to assist lower-incom e households in lowering energy expenses.

A8.1-4
Consider a local ordin ance (i.e. “reach
codes”) prom oting energy efficient house
construction to reduce energy consum ption
beyond what is required in State codes, in
newly built residential developm ent.

Revise Policy: Within one year of Housing Elem ent certification, ad opt a local ordinance (i.e. “reach codes”) prom oting energy efficient house construction to reduce energy consum ption beyond what is required in State codes, in newly built residential developm en t.

Item #8.5.

STATE OF CALIFORNIA - BUSINESS, CONSUMER SERVICES AND HOUSING AGENCY GAVIN NEWSOM, Governor

DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT

DIVISION OF HOUSING POLICY DEVELOPMENT
2020 W. El Camino Avenue, Suite 500
Sacramento, CA 95833
(916) 263-2911 / FAX (916) 263-7453
www.hcd.ca.gov
February 28, 2023
Jeff Mitchem, Director
Planning and Building Department
City of Calistoga
1232 Washington Street
Calistoga, CA 94515
Dear Jeff Mitchem:

RE: City of Calistoga’s 6th Cycle (2023-2031) Revised Draft Housing Element Thank you for submitting the City of Calistoga’s (City) revised draft housing element received for review on December 30, 2022. Pursuant to Government Code section 65585, subdivision (b), the California Department of Housing and Community Development (HCD) is reporting the results of its review. In addition, HCD considered comments from David Kellogg pursuant to Government Code section 65585, subdivision (c).

The revised draft element addresses many statutory requirements described in HCD’s August 24, 2022 review; however, revisions will be necessary to comply with State Housing Element Law (Article 10.6 of the Gov. Code). The enclosed Appendix describes the revisions needed to comply with State Housing Element Law.

For your information, pursuant to Assembly Bill 1398 (Chapter 358, Statutes of 2021), if a local government fails to adopt a compliant housing element within 120 days of the statutory deadline (January 31, 2023), then any rezoning to make prior identified sites available or accommodate the regional housing needs allocation (RHNA) shall be completed no later than one year from the statutory deadline pursuant to Government Code sections 65583, subdivision (c) and 65583.2, subdivision (c). Otherwise, the local government’s housing element will no longer comply with State Housing Element Law, and HCD may revoke its finding of substantial compliance pursuant to Government Code section 65585, subdivision (i). Please be aware, if the City fails to adopt a compliant housing element within one year from the statutory deadline, the element cannot be found in substantial compliance until these rezones are completed.

Chapter 654, Statutes of 2022 (AB 2339), adds specificity on how cities and counties plan for emergency shelters and ensure sufficient and suitable capacity. Future submittals of the housing element may need to address these statutory requirements.

For additional information and timing requirements, please see HCD’s memo at https://www.hcd.ca.gov/sites/default/files/docs/planning-and-community/ab2339- notice.pdf.

ATTACHMENT 5 - HCD Comment & City Response (60-day Review) Item #8.5.

Jeff Mitchem, Director

Public participation in the development, adoption and implementation of the housing element is essential to effective housing planning. Throughout the housing element process, the City should continue to engage the community, including organizations that represent lower-income and special needs households, by making information regularly available and considering and incorporating comments where appropriate. Please be aware, any revisions to the element must be posted on the local government’s website and to email a link to all individuals and organizations that have previously requested notices relating to the local government’s housing element at least seven days before submitting to HCD.

Several federal, state, and regional funding programs consider housing element compliance as an eligibility or ranking criteria. For example, the CalTrans Senate Bill (SB) 1 Sustainable Communities grant; the Strategic Growth Council and HCD’s Affordable Housing and Sustainable Communities programs; and HCD’s Permanent Local Housing Allocation consider housing element compliance and/or annual reporting requirements pursuant to Government Code section 65400. With a compliant housing element, the City will meet housing element requirements for these and other funding sources.

For your information, some general plan element updates are triggered by housing element adoption. HCD reminds the City to consider timing provisions and welcomes the opportunity to provide assistance. For information, please see the Technical Advisories issued by the Governor’s Office of Planning and Research at:
https://www.opr.ca.gov/planning/general-plan/guidelines.html.

HCD appreciates the hard work and dedication your team provided during the review.

We are committed to assisting the City in addressing all statutory requirements of State Housing Element Law. If you have any questions or need additional technical assistance, please contact Chelsea Lee, of our staff, at [email protected].

Sincerely,
Paul McDougall
Senior Program Manager
Enclosure
Item #8.5.

City of Calistoga’s 6th Cycle (2023-2031) Revised Draft Housing Element Page 1 February 28, 2023

APPENDIX

CITY OF CALISTOGA
The following changes are necessary to bring the City’s housing element into compliance with Article 10.6 of the Government Code. Accompanying each recommended change, we cite the supporting section of the Government Code.

Housing element technical assistance information is available on HCD’s website at https://www.hcd.ca.gov/planning-and-community-development/hcd-memos. Among other resources, the housing element section contains HCD’s latest technical assistance tool, Building Blocks for Effective Housing Elements (Building Blocks), available at https://www.hcd.ca.gov/planning-and-community-development/housing-elements/buildingblocks and includes the Government Code addressing State Housing Element Law and other resources.

A. Housing Needs, Resources, and Constraints

1. Affirmatively further[ing] fair housing in accordance with Chapter 15 (commencing with Section 8899.50) of Division 1 of Title 2…shall include an assessment of fair housing in the jurisdiction. (Gov. Code, § 65583, subd. (c)(10)(A).) Enforcement & Outreach: While the revised element now discusses outreach capacity for fair housing issues and includes an analysis of fair housing complaints, it must still describe the City's compliance with existing fair housing laws and regulations. For additional information, please see pages 28-30 on HCD’s Affirmatively Furthering Fair Housing (AFFH) Guidance Memo at https://www.hcd.ca.gov/communitydevelopment/affh/docs/AFFH_Document_Final_4-27-2021.pdf.

Integration and Segregation (Income, Disability and Familial Status): The revised element included some information on overall household size, households with children, and data on race by block groups. However, the element must still analyze local and regional trends and patterns across neighborhoods for income, disability, and familial status. The analysis should consider neighborhood concentrations of specific households (income, disability, and familial status) and analyze coincidences across various fair housing components.

Disparities in Access to Opportunities: The revised element briefly summarizes educational access throughout the City and noted the City’s TCAC scores for access to various opportunities; however, the element still needs to include a complete local and regional analysis of patterns and trends for all components (economic, environmental, transportation and educational). A comprehensive analysis should include local and regional disparities of access to educational, environmental, and economic opportunities through local, state and federal data.

Disproportionate Housing Needs: The element included minor revisions noting potential displacement risks throughout the City. However, a complete analysis should evaluate local and regional trends and patterns related to cost-burdened and overcrowded 1 2
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households, substandard housing conditions, and homelessness across census tracts, census blocks or neighborhoods. The analysis should also analyze coincidences across other fair housing components including any neighborhood level concentrations.

Other Relevant Factors: While the revised element includes some information on wildfire risks from an academic study, this does not address HCD’s prior finding. Please see HCD’s August 24, 2022 (prior review) for additional information.

Local Knowledge and Data: The element was not revised to address this requirement.

Please see HCD’s August 24, 2022 (prior review) for additional information.

Sites Inventory: The element was not revised to address this finding. Please see HCD’s August 24, 2022 (prior review) for additional information.

Contributing Factors and Summary of Fair Housing Issues: While the element includes some contributing factors and a summary of fair housing issues, based on a complete analysis, the element may need to add or revise the identification of contributing factors and fair housing issues.

2. Include an analysis and documentation of household characteristics, including level of payment compared to ability to pay, housing characteristics, including overcrowding, and housing stock condition. (Gov. Code, § 65583, subd. (a)(2).) Analyze any special housing needs such as elderly; persons with disabilities, including a developmental disability; large families; farmworkers; families with female heads of households; and families and persons in need of emergency shelter. (Gov. Code, § 65583, subd. (a)(7).)
Extremely Low Income (ELI): HCD’s prior review found that the element must quantify existing ELI households and provide an analysis of the needs and challenges for these households. While the element now provides a quantification, it still must analyze the existing needs and resources. For example, the element should discuss the existing resources to meet housing needs (availability of shelter beds, number of large units, number of deed restricted units, community services, etc.,) and an assessment of any gaps in resources. Local officials, special needs service providers or County social and health service providers may be able to assist with information to complete the analysis.

The element may need to add or revise programs and policies based on the outcomes of a complete analysis.

Overpayment: The element was not revised to address this requirement. Please see HCD’s prior review for additional information.

3. An inventory of land suitable and available for residential development, including vacant sites and sites having realistic and demonstrated potential for redevelopment during the planning period to meet the locality’s housing need for a designated income level, and an analysis of the relationship of zoning and public facilities and services to these sites. (Gov. Code, § 65583, subd. (a)(3).)
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Realistic Capacity: The element was revised to indicate that the City is relying on minimum densities to calculate realistic capacity assumptions. While that is a generally acceptable approach, the element noted that the minimum density for the CC, DC, and R-3 zones is 20 units per acre (p. 5-17). However, in other areas of the element, the densities for these zones indicate that the minimum density is either a range between 10-20 units per acre or allows up to 20 units per acre (pp. 5-21 and 6-2). The element also indicates in the actual sites inventory (attached at the end of the element), that the minimum densities for several zones is ten units per acre. The element must consistently and accurately indicate each sites zone and the allowable densities. Based on a revised analysis, the element may need to adjust assumptions.

Additionally, the revised element notes that 100 percent residential and nonresidential uses are allowed in nonresidential zones and the City’s pipeline projects were able to develop with residential given the City’s performance standards. However, to address this finding, the element still should specifically analyze the likelihood of 100 percent nonresidential uses in these zones. As found in the prior review, to complete this analysis, the element should consider the likelihood of nonresidential development, performance standards, and development trends supporting residential development.

For additional information, see the Building Blocks at https://www.hcd.ca.gov/planningand-community-development/housing-elements/building-blocks/analysis-sites-andzoning.

Electronic Sites Inventory: Pursuant to Government Code section 65583.3, subdivision (b), the City must utilize standards, forms, and definitions adopted by HCD when preparing the sites inventory. Please see HCD’s housing element webpage at https://www.hcd.ca.gov/community-development/housing-element/index.shtml for a copy of the form and instructions. The City can reach out to HCD at [email protected] for technical assistance. Please note, upon adoption of the housing element, the City/County must submit an electronic version of the sites inventory with its adopted housing element to [email protected].

Zoning for a Variety of Zoning Types:
• Emergency Shelters: In response to HCD’s prior review, the element includes reference to development standards for emergency shelters in Chapter 17.22 of the City’s ordinance (p. 6-4). However, the element must still identify and analyze these standards (e.g., spacing and parking requirements). In addition, the element was not revised to address parking requirements for emergency shelters. Please see HCD’s prior review for additional information. • Supportive and Transitional Housing: In response to HCD’s prior review, the element now includes revisions that clarify how supportive and transitional housing are permitted in residential zones (p. 5-4). However, as found in HCD’s prior review, the element still must indicate whether these uses are allowed in zones that allow for residential uses (Table 6-1). Additionally, the element still needs to demonstrate compliance with requirements related to supportive housing as a by-right use in zones where multifamily and mixed uses are 10 11
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permitted (Government Code section 65651). Please see HCD’s prior review for additional information.
• Housing for Agricultural Employees: The revised element states that while the City does not define farmworker and employee housing in the zoning code, it generally complies with the Employee Housing Act. However, the element should include a program specifically defining and zoning to fully comply with the requirements under Employee Housing Act (Health and Safety Code, § 17000 et seq.).

4. An analysis of potential and actual governmental constraints upon the maintenance, improvement, or development of housing for all income levels, including the types of housing identified in paragraph (1) of subdivision (c), and for persons with disabilities as identified in the analysis pursuant to paragraph (7), including land use controls, building codes and their enforcement, site improvements, fees and other exactions required of developers, and local processing and permit procedures... (Gov. Code, § 65583, subd. (a)(5).)
Land Use Controls (Parking): HCD’s previous review found that the City requires two spaces per multifamily unit. The element included an analysis to evaluate this requirement as a potential constraint on development. The analysis noted that because the City allows projects to meet parking requirements through various ways (covered, garage, off-street parking), parking is not an impediment to development. However, requiring two spaces for smaller bedroom units such as studios and one-bedroom units is considered a constraint by increasing project costs and reducing available land to develop actual units and also impacting a projects ability to meet maximum densities.

The element should be revised to modify or include a program committing to adopting reduced parking requirements for smaller bedroom units (e.g., studio and one bedroom).

Local Permit Process and Procedures: The element should address public comments on this revised draft submittal and discuss compliance with the Permit Streamlining Act and intersections with CEQA and timing requirements, including streamlining determinations and add or modify programs as appropriate.

Constraints on Housing for Persons with Disabilities:
• Reasonable Accommodation: In response to HCD’s prior review, the element includes revisions describing the City’s reasonable accommodation procedures.

This information identified that application fees are identical to those for a minor conditional use permit, approximately 850 dollars. The element should analyze these fees as potential constraints on housing for persons with disabilities and include a program as necessary to remove constraints.
• Licensed and Unlicensed Residential Care Facilities for Seven or More Persons:

While the element notes that the City allows special needs housing by-right in all residential zones (p. 6-22), as found in HCD’s prior review, the element still must 14 15
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identify and evaluate how the City permits unlicensed and licensed group homes.

Please see HCD’s prior review for additional information.

5. An analysis of potential and actual nongovernmental constraints upon the maintenance, improvement, or development of housing for all income levels, including the availability of financing, the price of land, the cost of construction, the requests to develop housing at densities below those anticipated in the analysis required by subdivision (c) of Government Code section 65583.2, and the length of time between receiving approval for a housing development and submittal of an application for building permits for that housing development that hinder the construction of a locality’s share of the regional housing need in accordance with Government Code section 65584... (Gov. Code, § 65583, subd. (a)(6).)
Approval Time and Requests for Lesser Densities: The element was not revised to address this finding. Please see HCD’s prior review for additional information.

B. Housing Programs

1. Include a program which sets forth a schedule of actions during the planning period, each with a timeline for implementation, which may recognize that certain programs are ongoing, such that there will be beneficial impacts of the programs within the planning period, that the local government is undertaking or intends to undertake to implement the policies and achieve the goals and objectives of the Housing Element... (Gov. Code, § 65583, subd. (c).)
As found in HCD’s prior review, programs must demonstrate that they will have a beneficial impact within the planning period. Beneficial impact means specific commitment to deliverables, measurable metrics or objectives, definitive deadlines, dates, or benchmarks for implementation. Deliverables should occur early in the planning period to ensure actual housing outcomes. The element must provide quantified objectives where appropriate and all programs should be evaluated to ensure provision of discrete timing (e.g., month and year) to account for how often the action will occur as well as to ensure a beneficial impact throughout the planning period.

2. Identify actions that will be taken to make sites available during the planning period with appropriate zoning and development standards and with services and facilities to accommodate that portion of the city’s or county’s share of the regional housing need for each income level that could not be accommodated on sites identified in the inventory completed pursuant to paragraph (3) of subdivision (a) without rezoning, and to comply with the requirements of Government Code section 65584.09. Sites shall be identified as needed to facilitate and encourage the development of a variety of types of housing for all income levels, including multifamily rental housing, factory-built housing, mobilehomes, housing for agricultural employees, supportive housing, single-room occupancy units, emergency shelters, and transitional housing. (Gov. Code, § 65583, subd. (c)(1).)
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As noted in Finding A3, the element does not include a complete site analysis; therefore, the adequacy of sites and zoning were not established. Based on the results of a complete sites inventory and analysis, the City may need to add or revise programs to address a shortfall of sites or zoning available to encourage a variety of housing types. In addition, the element should be revised as follows:

Publicly-Owned Sites: The element was not revised to address this finding. Please see HCD’s prior review for additional information.

Small Sites: The revised element included an analysis demonstrating that small sites (less than 0.5 acres) can be feasible for development due to being contiguous lots and having common ownership, making the sites ripe for lot consolidation. However, the element should include a program establishing incentives and actions to encourage and promote lot consolidation efforts.

3. Address and, where appropriate and legally possible, remove governmental and nongovernmental constraints to the maintenance, improvement, and development of housing, including housing for all income levels and housing for persons with disabilities. The program shall remove constraints to, and provide reasonable accommodations for housing designed for, intended for occupancy by, or with supportive services for, persons with disabilities. (Gov. Code, § 65583, subd. (c)(3).) As noted in Findings A4 and A5, the element requires a complete analysis of potential governmental and nongovernmental constraints. Depending upon the results of that analysis, the City may need to revise or add programs and address and remove or mitigate any identified constraints.

4. Develop a plan that incentivizes and promotes the creation of accessory dwelling units that can be offered at affordable rent…for very low, low-, or moderate-income households... (Gov. Code, § 65583, subd. (c)(7).)
The element identified Program A1.2-2 indicating the City will consider amending accessory dwelling units (ADU) regulations to include incentives for development.

However, as found in the prior reviews, the element should specify what type of potential or actual incentives the City will be establishing. Additionally, the element included Program A1.2-3 to conduct outreach. However, the program should include additional information about what type of outreach and the frequency of the action.

Lastly, given the City’s reliance on ADUs, the element should include a program committing to frequent monitoring and adjusting the projected assumptions if they do not actualize during the planning period. Specifically, the program should commit to monitor ADU production and affordability throughout the course of the planning period and implement additional actions if not meeting target numbers anticipated in the housing element. If necessary, additional actions should be taken in a timely manner (e.g., within six months). The degree of additional actions should be in stride with the degree of the gap in production and affordability. For example, if actual production and affordability of ADUs is far from anticipated trends, then rezoning or something similar would be an appropriate action. If actual production and affordability is near anticipated trends, then measures like outreach and marketing might be more appropriate 20 21
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5. Promote and affirmatively further fair housing opportunities and promote housing throughout the community or communities for all persons regardless of race, religion, sex, marital status, ancestry, national origin, color, familial status, or disability, and other characteristics... (Gov. Code, § 65583, subd. (c)(5).)
Goals, Priorities, Metrics, and Milestones: As noted in Finding A1, based on a complete analysis, the element may need to revise or include additional programs to address fair housing issues. Additionally, as found in the prior review, the element must include goals and actions that significantly seek to overcome contributing factors to fair housing issues. Please see HCD’s August 24, 2022 (prior review) for additional information. 26 Item #8.5.

4854-3477-8729 v1
City of Calistoga Response to HCD 60-Day Review Comments (February 28, 2023) HCD
Comment
Identifier
HCD Comment City Response
1 Fair Housing Law compliance. Expanded Analysis: Fair Housing Enforcement & Capacity and Fair Housing Enforcement & Outreach. Page 3-10 – 3-11. Expanded analysis.
2 Local and regional trends and
patterns across neighborhoods
for income, disability, and familial
status. (economic, environmental,
transportation and educational).

Expanded Analysis: Assessment of Fair Housing. Page 3-9, Table 3-1: Allocation of Opportunity Site By Census Block Group. Expanded data /analysis - pages 3-16, 3-18, 3-19. 3 Local and regional trends and
patterns related to cost-burdened
and overcrowded households,
substandard housing conditions,
and homelessness across census
tracts, census blocks or
neighborhoods.

Expanded Analysis: Fair Housing Enforcement & Capacity. Pages 3-10 – 3-30. Expanded analysis. 4 Evaluate local regional trends
related to cost-burdened and
overcrowded households.

Expanded Analysis: Cost-Burdened Households. Page 3-28 – 3-32. Expanded analysis. 5 Other Relevant Factors – Wildfire
Risks
Expanded Analysis: Wildfires; Racially Restrictive Covenants; Local Knowledge; Senior Support; Labor and Migration Patterns. Pages 3-30 – 3-33.
6 Local Knowledge and Data See response to #2 above and pages 3-23-26. 7 Sites Inventory including income
categories of identified sites with
respect to location, the number of
sites and units by all income
groups.

Expanded Analysis: Affordability Levels: Very Low, Low, Mod, Above Mod. Pages 5-17 – 5-27. 8 Contributing factors and summary
of fair housing issues.

Expanded Analysis: Contributing Factors to Fair Housing Issues. Pages 8-20 – 8-22. Table 8-1:

Contributing Factors to Fair Housing Issues.
9 ELI HH – analysis Expanded Analysis: Household Income. Table 4-11 Income by Tenure. Pages 4-14 – 4-15. 9 Overpayment Expanded Analysis: Overpayment. Pages 4-30 – 4-31. 10 Realistic capacity; minimum
densities
Expanded Analysis: Pg. 5-21, 6-2. Discussion has been cleaned up to clearly indicate that the minimum density is 10 du/ac. Make sure that is consistent. Check pages 5-21 and 6-2.

Item #8.5.

4854-3477-8729 v1
HCD
Comment
Identifier
HCD Comment City Response
11 Realistic capacity; likelihood
residential
Expanded Analysis: Minimum Density: 10 du/ac. Pages 5-21, 6-2. 5-17/18. Discuss pipeline/projects and residential occurring in these areas. 12 Emergency shelters –
development standards and AB
139
Expanded Analysis: Emergency Shelters. Pages 6-4 – 6-5. Action A6.1-4 (Page 8-16). Identify development standards related to spacing and parking from the City’s ordinance and discuss it in the element. Plug in AB 139 program language into program.The City will amend emergency shelter parking requirements to comply with GC AB139/Government Code section 65583, subdivision (a)(4)(A), by October 2024. Added Action A6.1-4 (p 8-14). 13 Supportive and transitional
housing
Expanded Analysis: Page 6-2 and 6-5. Table 6-1: Housing Types Allowed by Zoning District. Action

6.1-5 (Page 8-16). Table 6-1: revise table to indicate that transitional and supportive housing are allowed in all residential zones. Supportive housing by-right; needs to comply with AB 2162.

Permanent supportive housing. Add permanent supportive housing as a use that is allowed by right in zones where multifamily and/or mixed-uses are permitted, including nonresidential zones permitting multifamily uses in compliance with Government Code section 65651.

Table 6.1 revised. Added Action 6.1-5 (p 8-14)
14 Ag housing/EHA Expanded Analysis: Housing for Agricultural Employees. Page 6-4. Action 6.1-6 (p 8-16). 6-4. Define this type of housing and include in program. To ensure compliance with the Employee Housing Act (Health and Safety Code, § 17000 et seq.), the City will review its zoning code and make amendments to specifically define and explicitly make this housing an allowable use.

Table 6.1 revised. Added Action 6.1-6 (p 8-14)
15 Land use controls – parking Policy Revised/Added: Action 6.1-4, Action 6.1-7 (Page 8-16).

Reduce parking standards for multifamily housing specifically to 1) address any actual or potential constraints on project feasibility and reaching maximum densities specifically for smaller bedroom types such as studio and one-bedroom multifamily units require fewer parking spaces.

Table 6.2 revised. Added Action 6.1-8 (p 8-15)
15 Land use controls – compliance
with permit streamlining act.

Policy Revised/Added: Constraints section
Include a discussion that addresses public comments regarding timely CEQA processing 16 Reasonable accommodation Policy Revised/Added: Program included committing to reducing fees for RA Item #8.5.

4854-3477-8729 v1
HCD
Comment
Identifier
HCD Comment City Response
The City will review fee reductions for reasonable accommodation to ensure the process does not act as a constraint on persons with disabilities.

Added Action 6.1-8 (p 8-16)
17 Group homes Policy Revised/Added. Action 6.1-9 (Page 8-17). Plug in language into program: Allow for residential care facilities of six or fewer to be regulated in the same manner as a single-family dwelling unit in all zones, including Specific Plan areas, where single-family dwelling units are allowed. Amend the Zoning Code and permit procedures to allow group homes of seven or more persons in all residential zone districts with objective standards to promote approval certainty similar to other residential uses of the same form and consistent with State law and fair housing requirements.

Added Action 6.1-10 (p 8-15)
17, 18 Nongov constraints – approval
times and densities:

Programs – Publicly Owned
Sites
Programs – Small Sites
Programs – ADUs
Policy Revised/Added: Action 2.1-6 (Page 8-6); Action 6.1-10 (Page 8-15); Action 6.1-12 (Page 8-15) combined with Action 6.1-10; Action 1.2-2 (Page 8-2). 19 Programs (general finding) All applicable programs revised to specify metrics and milestones re: frequency of action, timelines of progress or completion, and explicitly detail how program actions will be performed. 21 Programs – Publicly owned sites Added Action 6.1-10 (p 8-15) 21 Programs – Small Sites Added Action 6.1-10 (p 8-15)
23 Programs – ADUs; needs
monitoring, adjustments and
strong incentives/actions.

Revised/Added Policy: A1.2-2.
24 AFFH enforcement Expanded Analysis & Revised/Added Policy: Action 4.4-1, Page 8-12. 25 AFFH integration and segregation Expanded Analysis & Revised/Added Policy: Chapter 4 AFFH. Integration & Segregation, Page 3-11 – 3-13.
26 AFFH access to opportunities Expanded Analysis & Revised/Added Policy: Economic Opportunity & Outcomes, Page 3-23 – 3-26.

Item #8.5.

4854-3477-8729 v1
HCD
Comment
Identifier
HCD Comment City Response
AFFH
Cont.

AFFH disproportionate housing
needs
Expanded Analysis & Revised/Added Policy: Disproportionate Housing Needs & Displacement Risk, Pages 5-27 – 5-28.

AFFH
Cont.

AFFH other relevant factors Expanded Analysis & Revised/Added Policy: Other Relevant Factors, Page 3-30.

AFFH
Cont.

AFFH local data/knowledge Expanded Analysis & Revised/Added Policy: Response to #2, 3, 4 above.

AFFH
Cont.

AFFH Sites Inventory Expanded Analysis & Revised/Added Policy: Pages 5-25.

AFFH
Cont.

AFFH Contributing factors Expanded Analysis & Revised/Added Policy: Table 8-1, Pages 8-21, 22.

AFFH
Cont.

AFFH Programs Expanded Analysis & Revised/Added Policy: Pages 8-20 – 8-22. Table 8-1.

Item #8.5.