Calistoga City Council
August 1, 2023

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECOMMENDED FINAL page 4-48
Farmworkers living in market-rate housing are also likely to experience overcrowding. In order for most market rate residences to be affordable on a farmworker’s income, it would be necessary for two or more families to share a house or apartment intended for single-family occupancy. A consequence of families sharing an apartment or house is that overcrowding becomes a financial necessity.

Napa County Housing Authority manages three 60-bed farmworker centers in the county, including one in Calistoga. These farmworker centers are dormitory style housing designed for single males and are nearly always at full capacity. Additional farmworker housing, particularly family farmworker housing, is a high priority for the county. Calistoga Family Apartments is an affordable housing development that was built in 2015 and was designed to accommodate family farmworker housing, but additional affordable housing is still needed.

Farmworkers are also supported by many programs coordinated through UpValley Family Centers as well as the Napa Valley Farmworker Foundation.

TABLE 4-28 FARMWORKERS POLICIES AND PROGRAMS
6th Cycle Policies/Actions Carried Over or Minor
Modifications from the 5th Cycle Housing Element
New 6th Cycle Policies/Actions
• Action A4.1-2 Collaborate with Napa County,
the agricultural industry, and non-profit
organizations to assess the needs, plans, and
funding for developing farmworker housing
to meet the needs of permanent and
seasonal laborers.
• Policy P4.5-3 - Provide wrap-around
services for farmworkers, including
housing for farmworker families.
• Action A4.5-3 - Collaborate with
County and local organizations such as
Fair Housing Napa Valley and the
UpValley Family Center to bring more
bilingual/multilingual service
providers to existing farmworker
housing centers.
• Action A4.5-4 - Seek grants and
funding opportunities for farmworker
family housing in Calistoga.

Large Families
Large family households are defined by the U.S. Census Bureau as households comprised of five or more persons. Large families face an above-average level of difficulty in locating adequately-sized, affordable housing due to the limited supply of large units. Large families are generally served by housing units with three or more bedrooms, but very few rental projects offer three- or four-bedroom units. Even when larger units are available, the cost is higher than that of smaller units, and large families with low incomes may not be able to afford units of sufficient size, particularly in multi-family housing where the units are typically smaller.

In Calistoga, for large households with five or more persons, most units (56.4 percent) are renter occupied (Figure 4-23). Larger households in Calistoga also tend to have less income than smaller households. In 2017, 59 percent of large households were very low-income, earning less than 50 percent of AMI (Figure 4-24).

Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECOMMENDED FINAL page 4-49
FIGURE 4-23 HOUSEHOLD SIZE BY TENURE
Source: ABAG/MTC Data Packet; U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019) FIGURE 4-24 HOUSEHOLD SIZE BY HOUSEHOLD INCOME LEVEL
Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECOMMENDED FINAL page 4-50
Source: ABAG/MTC Data Packet; U.S. Department of Housing and Urban Development (HUD), Comprehensive Housing Affordability Strategy (CHAS) ACS tabulation, 2013-2017 release
TABLE 4-29 LARGE FAMILIES POLICIES AND PROGRAMS
6th Cycle Policies/Actions Carried Over or Minor
Modifications from the 5th Cycle Housing Element
New 6th Cycle Policies/Actions
• Policy P4.1-5 Encourage larger residential
development projects to provide a range of
unit sizes.
• Policy P5.3-2 Encourage larger residential
subdivisions to provide a range of lot sizes
and designs.
• Policy P4.1-7 Encourage ADUs as an
inexpensive and effective method to
expand opportunities for large
families.
• A4.1-9 - Conduct annual public
workshops with childcare operators,
community-based organizations, and
other groups focused on supporting
female householders in addressing
their needs
Families with Female Heads of Households
Single-parent households, particularly female-headed households, generally have lower incomes and higher living expenses, often making the search for affordable, decent, and safe housing more difficult. In 2019, 8.1 percent of households in Calistoga were headed by females. Female-headed households with children may face particular housing challenges, with pervasive gender inequality resulting in lower wages for women. Moreover, the added need for childcare can make finding a home that is affordable more challenging. In Calistoga, no female-headed households fall below the Federal Poverty Line.

FIGURE 4-25 HOUSEHOLD TYPE
Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECOMMENDED FINAL page 4-51
Source: ABAG/MTC Data Packet; U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019) The policies and programs designed to support large families, are listed in Table 4-2730, can also serve to support families with female heads of households.

TABLE 4-30 FEMALE-HEADED HOUSEHOLDS POLICIES AND PROGRAMS 6th Cycle Policies/Actions Carried Over or Minor
Modifications from the 5th Cycle Housing Element
New 6th Cycle Policies/Actions
• Policy P4.1-5 Encourage larger residential
development projects to provide a range of
unit sizes.
• Policy P5.3-2 Encourage larger residential
subdivisions to provide a range of lot sizes
and designs.
• Policy P4.1-7 Encourage ADUs as an
inexpensive and effective method to
expand opportunities for large
families.
• A4.1-9 - Conduct annual public
workshops with childcare operators,
community-based organizations, and
other groups focused on supporting
female householders in addressing
their needs
• A4.1-9 - Conduct annual public
workshops with childcare operators,
community-based organizations, and
other groups focused on supporting
female householders in addressing
their needs
• A2.1-3 - Continuously identify
properties for purchase that would be
well-suited to the construction of
affordable and/or special-needs
housing.
• A4.2-1 - Amend Zoning Code to
include housing for special-needs
populations, particularly farmworkers
and female householders with
children, as eligible for revenue from
the City’s Affordable Housing Fund.
• A4.2-2 - Use loan repayments from
the CDBG account to fund programs
and projects that benefit special-needs
population groups, particularly
farmworkers and female householders
with children.
• A4.3-2 - Conduct updates of the
Housing Resources page on the City’s
website that provides information on
Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECOMMENDED FINAL page 4-52
resources for special-needs population
groups
Unhoused Families and Persons
Homelessness remains an urgent challenge in many communities across the state, reflecting a range of social, economic, and psychological factors. Rising housing costs result in increased risks of community members experiencing homelessness. Far too many residents who have found themselves housing insecure have ended up unhoused or homeless in recent years, either temporarily or longer term.

Addressing the specific housing needs for the unhoused population remains a priority throughout the region, particularly since homelessness is disproportionately experienced by people of color, people with disabilities, those struggling with addiction, and those dealing with traumatic life circumstances.

Calistoga coordinates with Napa County and the Napa County Network of Care for services targeting individuals and families experiencing homelessness. Resources include:
• Family Service of Napa Valley: Provides information regarding permanent housing and support services for homeless or at risk of homeless individuals. • Veterans’ Housing and Homeless Services: Provides services for veterans experiencing homelessness.
• Catholic Charities: Provides information about housing for at-risk young adults and transitional programs for individuals experiencing homelessness.

Families and persons in need of transitional and supportive housing or emergency shelter include those who are without homes as well as those who are temporarily displaced from their homes due to abuse, evictions, or natural disasters. It is difficult to measure the numbers of people in these categories since the situation is often temporary, and those without homes relocate frequently in search of jobs or housing.

The needs of those using available transitional and supportive housing services and emergency shelter services can vary from basic shelter to development of skills for becoming self-sufficient and/or maintaining and obtaining permanent housing.

According to the Calistoga’s point-in-time (PIT) count, there were zero unhoused individuals in Calistoga in 2020. Napa County’s Housing and Homeless Programs reported seven clients in the Homelessness Management Information System (HMIS) with a last known address in Calistoga in 2020.

TABLE 4-31 UNHOUSED FAMILIES AND PERSON POLICIES AND PROGRAMS 6th Cycle Policies/Actions Carried Over or Minor
Modifications from the 5th Cycle Housing Element
New 6th Cycle Policies/Actions
Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECOMMENDED FINAL page 4-53
• Action A4.1-3 Collaborate with Napa County
and non-profit organizations to assess the
needs of the homeless by participating in
efforts to survey this population and
providing funding or other support to
ensure the provision of shelters on a
regional basis.
• Action A4.18 Amend Zoning Code
Chapter 17.04, Definitions, to update
the definition for “Low Barrier
Navigation Center” consistent with
state law. Amend the Downtown
Commercial Zoning District to allow
low barrier navigation centers as a
permitted use by right.
•

PROJECTED HOUSING NEEDS
Projected Population and Job Growth
As the regional council of governments for the San Francisco Bay Area, the Association of Bay Area Governments (ABAG) makes projections for increases in population and the number of households for each jurisdiction in the nine-county Bay Area. Plan Bay Area 2050 Final Blueprint is the most recent in ABAG’s series of demographic, economic, and land use changes in coming decades. The projections outlined in Plan Bay Area 2050 cover the period from 2015 through 2050. Based on the economic composition of the Bay Area and expected growth nationwide, the region is projected to add approximately 1.4 million jobs between 2015 and 2050. Napa County is projected to gain 5,000 more households between 2015 and 2050, representing a 10 percent increase.8 Over the same period of time, the county is projected to experience a job growth of 21 percent between 2015 and 2050, resulting in approximately 15,000 new jobs.9 Regional Housing Needs Allocation
State law provides a process for determining each local jurisdiction's fair share of future housing needs, called the Regional Housing Needs Allocation (RHNA). The process begins with the State Department of Housing and Community Development (HCD) assigning each regional council of governments a needed number of new housing units for that region. For the planning period of 2023 through 2031, HCD has assigned a total need of 441,176 new housing units to the nine-county Bay Area.

ABAG has the responsibility of determining the “fair share” of regional housing need that should be assigned to each city and county in the region. Following extensive discussions and collaboration with Bay Area jurisdictions, ABAG has determined that Calistoga’s share of the Bay Area housing need for the planning period is 119 units.

Table 4-31 identifies the RHNA for new construction in Calistoga during the planning period which is distributed among income categories to ensure that each jurisdiction in the Bay Area plans for housing for households of every income, adjusted to include its need for extremely low-income housing. State law requires that the City determine the subset of the very low-income regional need that constitutes the community’s need for extremely low-income housing. The City is using the most conservative estimate for extremely low-income household by using HCD’s Regional Housing Need Determination for extremely low-income households the Bay Area which estimates that 59.8 percent of the very low-income RHNA is for extremely low-income 8 Association of Bay Area Governments (ABAG), Plan Bay Area 2050 Final Blueprint (January 21, 2021) 9 Association of Bay Area Governments (ABAG), Plan Bay Area 2050 Final Blueprint (January 21, 2021) Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECOMMENDED FINAL page 4-54
households. This option aligns with HCD’s guidance to use U.S. Census data to calculate the percentage of very low-income RHNA that qualifies for extremely low-income households, as HCD uses U.S. Census data to calculate the Regional Housing Need Determination.

TABLE 4-32 CALISTOGA SHARE OF REGIONAL HOUSING NEEDS, 2023-2031 Income groups No. of Units Share of Total
Extremely low (≤30% of AMI10) 19 16%
Very low (31-50% of AMI) 12 10%
Low (51- 80% of AMI) 19 16%
Moderate (81 - 120 % of AMI) 19 16%
Above Moderate (>120 % of AMI) 50 42%
Total Units 119
Source: ABAG 2021
Table 4-28 shows the regional housing needs allocation for all Napa County jurisdictions, divided among four household income levels. Of incorporated jurisdictions, Tthe preponderance majority of units were allocated to the cities of American Canyon and Napa, which include designated Priority Development Areas that are near high levels of transit service and where a large number of new jobs are projected. Other considerations in determining the allocations include directing affordable housing to high opportunity areas, while incorporating equity adjustments which ensure that lower income housing is equitably distributed and not over concentrated in certain jurisdictions.

TABLE 4-32 COUNTYWIDE REGIONAL HOUSING NEEDS ALLOCATIONS, 2023-2031 Jurisdiction Total Very Low
(<50%)
Low
(50-80%)
Moderate
(80-120%)
Above Moderate
(>120%)
American
Canyon
446 112 65 75 194
Calistoga 119 31 19 19 50
Napa 1,939 504 291 319 825
St. Helena 254 103 59 26 66
Yountville 72 19 11 12 30
Unincorporated 1,014 369 213 120 312
County Totals 3,844 1,158 658 571 1,477
10 Area median income established by HUD on an annual basis Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECOMMENDED FINAL page 4-55
Source: ABAG 2021
Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECOMMENDED FINAL page 5-1
CHAPTER 5: HOUSING SITES AND RESOURCES
Calistoga is required to identify sites that meet the City's "fair share" of existing and future housing needs by California Housing Element law. This fair share, as allocated to the City by ABAG/MTC, is sorted by income level: Very Low, Low, Moderate, and Above Moderate Income.

The City was allocated 119 units through this process: 31 Very Low, 19 Low, 19 Moderate, and 50 Above Moderate-Income units. To ensure that sufficient capacity exists in the housing element to accommodate the Regional Housing Needs Allocation (RHNA) throughout the planning period, the California Department of Housing and Community Development (HCD) recommends jurisdictions create a buffer in the housing element inventory of at least 15 to 30 percent more capacity than required. Calistoga has provided a 30 percent buffer across all income levels for a total of 155 units.

TABLE 5-1 RHNA ALLOCATION
Very
Low
Low Moderate
Above
Moderate
Total
Total
Affordable
RHNA
Allocation
31 19 19 50 119 69
+Buffer
(30%)
9 6 6 15 36 21
Total 40 25 25 65 155 90
The City goes well above this RHNA allocation and buffer, with 280 units (184 affordable). This number includes units in "Pipeline" projects (128 units, 85 affordable) and projected Accessory Dwelling Units (24 units, 21 affordable) as well as sites selected in the City, at minimum density (128 units, 78 affordable). Refer to Table 5-2 for a detailed breakdown of projected housing units by affordability level.

TABLE 5-2 PROJECTED HOUSING UNITS
Total Units Affordable Units
Pipeline Units 128 85
Accessory Dwelling Units 24 21
Opportunity Sites 128 98
Total 280 204
Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECOMMENDED FINAL page 5-2
Housing Opportunities and Resources
A variety of housing programs are offered by governmental and nonprofit agencies that assist in the provision, rehabilitation and retention of housing, primarily for lower to moderate-income households. Additionally, there are a large number of private developers who can assist in providing affordable housing in Calistoga.

Housing Authority of the City of Napa
The City has long received support services from the Housing Authority of the City of Napa (HACN), including affordable housing policy and development assistance, and direct services related to affordable housing contract monitoring and grant application assistance.

In addition, HACN oversees Section 8 Housing vouchers, which includes 29 participants from Calistoga. Other housing services provided by HACN include income verification and loan document preparation for the City’s Down Payment Assistance Program and any subordination requests associated with existing deed restricted for-sale affordable housing units.

HACN recently worked with the City to secure a $500,000 Community Development Block Grant to establish an owner-occupied housing rehabilitation program that began in 2021.

Disabled Housing Resources
The City’s Zoning Code allows supportive housing, transitional housing, and limited residential care by right in the R-1, R-2, and R-3 zoning districts, and general residential care in these districts with a conditional use permit.

Convalescent and senior care facilities are allowed with a use permit in the Community Commercial Zoning District. State law pre-empts local regulation on group homes that serve six or fewer persons.

Chapter 17.60 of the Calistoga Zoning Code allows the Planning and Building Director to approve requests for reasonable accommodation made by any disabled person when the application of a zoning law or other land use regulation, policy, or practice acts as a barrier to fair housing opportunities. A request for reasonable accommodation may include a modification or exception to the rules, standards and practices for the siting, development and use of housing or housing-related facilities that would eliminate regulatory barriers and provide a disabled person equal opportunity to housing of their choice. A nominal processing fee is charged for these requests.

The City has also adopted a Universal Design Policy stating that accessible design features shall be incorporated into newly constructed and substantially rehabilitated single-family and duplex residences to the maximum feasible extent. To implement this policy, housing designers and contractors are required to incorporate as many accessibility features into their plans for newly constructed and substantially rehabilitated single-family and duplex residences as is feasible. Builders of new for-sale homes must provide a checklist of available universal accessibility features to the home buyer.

The City and the Housing Authority of the City of Napa (HACN) provide funding to housing rehabilitation programs. Napa County provides support services for low-income blind, disabled, and elderly adults through its In-Home Supportive Services program. Twenty disabled persons received the Section 8 housing assistance described above.

Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECOMMENDED FINAL page 5-3
Senior Services
The Napa/Solano Area Agency on Aging and Napa County work together to make services and resources, including those related to housing, accessible to seniors. A County eligibility worker visits the UpValley Family Center weekly and is available to help seniors determine if they are eligible for various programs and assist with application paperwork. The UpValley Family Center has also provided one-time assistance for seniors unable to pay their space rent.

As discussed previously, the City has adopted a Mobile Home Rent Stabilization Ordinance, which controls rent increases for mobile homes that are largely occupied by senior citizens and others on fixed and limited incomes. The City has incurred more than $185,000 in legal fees defending the ordinance.

Farmworker Housing Services
The Napa County Housing Authority manages three farmworker housing centers in Napa County (Calistoga, Mondavi, and River Ranch) that are designed to serve the short-term housing needs of unaccompanied male residents during peak agricultural seasons. These Centers are available to farmworkers who work in Napa County. Beds are available on a per-bed, per-night charge. Changes in farming and climate have led to yearround need and opportunity for farmworkers, and the majority of lodgers in the County Centers remain in lodging consistently across the season. That said, many also look for additional employment in spring and summer to maximize their earnings, travelling to other areas on days off for additional agricultural work.

The dormitory-style housing in each center has 60 beds (30 rooms with 2 beds each), for a total of 180 beds.

None of the centers are open year-round; each is closed for portions of the period from November to February, when the demand for labor goes down. However, the months during which they close are staggered, such that at least one of the centers is open during any given month of the year. In 2017, the Calistoga center was closed for 50 days (November 11 to December 31).

In addition to the three CHDC centers, there are five licensed farmworker housing facilities that provide an estimated 104 beds. There are 80 additional private farmworker housing facilities with accommodations for fewer than five farmworkers.

The City has amended the definition of “one-family dwelling” in the Zoning Code to includes employee housing for six or fewer persons as provided by California Health and Safety Code Section 17021.5, and has consented to the inclusion of planted vineyard acreage within the City limits in a county assessment area to acquire, construct, lease, and maintain farmworker housing.

In 2013, the City approved the 48-unit Calistoga Family Apartments project that is targeted to very low- and low-income farmworker households. It includes one-, two- and three-bedroom units, laundry facilities, clubhouse, community building with a kitchen and computer room, two playgrounds, barbeque area and onsite vehicle and bicycle parking. The project is located adjacent to the Napa River and Logvy Community Park, which includes a swimming pool and playfields, and is within walking distance to all of the community’s schools.

It is also within close proximity to the downtown and bus transit. Processing of the project’s use permit, design review and variance applications was expedited by City staff, and the project was approved at a single public hearing by the Calistoga Planning Commission. The project is funded in part by the U.S. Department of Agriculture’s Section 514/516 Farm Labor Housing Program.

Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECOMMENDED FINAL page 5-4
Accessory Dwelling Unit Services
The Napa Sonoma ADU Center was founded in 2019 through the Napa Valley Community Foundation for the purpose of increasing affordable housing supply by helping homeowners design, build, and lease Accessory Dwelling Units (ADUs). The ADU Center provides homeowner outreach and education, feasibility assessments, referrals, and tenant recruitment. It also connects prospective ADU builders with pre-approved designs and supports Napa and Sonoma counties by recommending process streamlining. The ADU Center is supported with funding from SB 2.

In addition, Napa Sonoma collaborative is ADU designs for various agencies in Napa and Sonoma County. It is anticipated that the City of Calistoga will have ADU designs ready for planning permits.

Homeless Services
The UpValley Family Center provides both a venue for outreach and an opportunity for the Napa County Health and Human Services to have a local presence in coordinating the delivery of homeless services in Calistoga.

Napa County contracts with Adobe Services to operate two shelters:
• South Napa Shelter – 69-person capacity
• Winter Shelter (November to April) – 55-person capacity In addition, Adobe Services provides outreach, housing navigation, and housing tenancy & sustaining service programs.

The County also contracts with Catholic Charities to run manage the Rainbow House Family Shelter, which has seven family units and averages an occupancy of 30 persons (the average is because this is driven bybased on family size rather than beds available).

All shelters in Napa County are known as "low-barrier" and all housing programs are operated under the principles of "Housing First." There is no sobriety requirement for entry into shelter or for assistance with housing placement and support.

Community Action Napa Valley also offers long- and short-term assistance to help families and individuals avoid homelessness by maintaining the housing they currently have. Funds may be available for rental deposits, lapsed rent, utilities and shallow on-going rental subsidy. If authorized, those payments are paid directly to the landlord or vendor. Its Rapid Rehousing program helps homeless households move into and maintain sustainable housing. Rental subsidies may be available while intense case management helps to keep the households housed.

Hartle Court Apartments, operated in Napa by the Progress Foundation, offers 18 single-bedroom apartments and six two-bedroom apartments to those transitioning from homelessness or foster care. To qualify to live in one of the two-bedroom units, one must between the ages of 18 and 25 and just leaving the foster care system.

These apartments will serve as transitional housing, so tenants may stay up to two years. The single-bedroom units are permanent housing for people ages 18 and older and can be rented to anyone who is low-income, homeless and has a psychiatric disability. All the ground-level units are adaptable to people with physical disabilities. Residents will not pay more than 30 percent of their income to live at the apartments and will receive continued assistance from support professionals.

Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECOMMENDED FINAL page 5-5
To facilitate the provision of transitional and supportive housing services within Calistoga, the Zoning Code treats transitional and supportive housing as residential uses subject to the same permitting processes and without undue special regulatory requirements, consistent with Government Code Section 65583(a)(5). The Calistoga Zoning Code also allows emergency shelters without a use permit or other discretionary action in the Community Commercial (CC) Zoning District (consistent with Government Code Section 65583(a)(4)), except that an administrative use permit is required if it is located within a General Plan-designated entry corridor in order to ensure that the design of development is consistent with the rural, small-town qualities of the City.

The CC Zoning District is generally located in areas where transit service exists and where basic necessities can be purchased. There are 16 vacant sites within the CC Zoning District that could accommodate development of an emergency shelter (this number is inclusive of the proposed project at 1855 Lincoln Avenue and 5 housing opportunity sites). These sites range from 5,000 square feet to over 5 acres. The City’s Growth Management System exempts projects sponsored by public and non-profit organizations that provide medical, dental, social services and the like for residents of Calistoga. An emergency shelter is a land use that would be considered exempt from the City’s Growth Management System regulations under this provision.

Fair Housing Services
The City supports fair access to housing for all persons without regard to race, color, religion, sex, marital status, national origin, or ancestry. The City contracts with Fair Housing of Napa Valley, a private 501(c)(3) non-profit corporation dedicated to promoting and developing fairness and equality of housing opportunity for all people, to assist on local issues related to rental housing and tenant rights, housing discrimination and fair housing advocacy
Referral Services
The UpValley Family Center, which maintains an office in Calistoga, provides a wide range of social services, including referrals to affordable housing, interim housing and fair housing resources. The City provides annual funding to the Family Center to support these services.

Down Payment Assistance
In 2009, the City established a down payment assistance program for low- and moderate-income households with members who live or work in Calistoga. The program allows for a maximum city subsidy of 4 percent of the purchase price or $15,000, whichever is less, in the form of a deferred interest-free loan. The buyer is required to provide a minimum of two percent of the purchase price of the unit as down payment and closing cost contribution. To date, only one loan in the amount of $12,000 has been made at an interest rate of three percent. The program’s lack of success is probably attributable to the relatively small amount that is contributed by the City, considering the high cost of local housing prices. The City of Napa recently increased its maximum loan amount to $100,000, and reduced its interest rate to one percent. The program should be re-evaluated for possible modifications that would improve its success.

Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECOMMENDED FINAL page 5-6
Acquiring and Managing Affordable Housing
The Housing Authority of the City of Napa (HACN) administers funding and operates programs in Calistoga.

Along with the City of Calistoga, HACN works with several entities that acquire and manage affordable housing in the City, including:
• Adobe Services
• Bridge Housing
• Burbank Housing
• Crown Real Property Management
• Embrace Calistoga
• William Squire
• Winn Residential
The City will also study establishing a City-sponsored agency to acquire and manage affordable housing.

Financial Resources
Affordable Housing Fund
The Affordable Housing Fund is a special-purpose fund established by the City to preserve and expand the stock of affordable housing through construction, acquisition, rehabilitation and provision of subsidies. There is currently a balance of approximately $2.1 million in this fund.

Linkage Fees
The Affordable Housing Fund is funded primarily through the assessment of a fee on new employmentgenerating uses. The basis for this “linkage fee” is the fact that the development of non-residential uses in the City generates a need for additional workers, many in lower-income categories. Restaurants and wineries generate the most significant numbers of households below 65 percent of the area’s median income level, while tourist accommodation and commercial uses also generate substantial numbers of households in the 65 to 80 percent of area median income bracket. Additionally, many commercial jobs are comprised of retail where wages are below those in other commercial land use sectors (e.g. office, light industrial).1 Calistoga’s attractiveness and market orientation towards single-family ownership limits the availability of multifamily housing. Local workers compete for a limited housing supply with retirees who may have built substantial equity in their prior homes or higher-income households who have more flexibility regarding where they choose to live. As a result of this type of demand on the City’s housing supply, it is difficult for lower-wage workers to find suitable housing in the City without a program designed to bring the cost of housing down to an affordable range. The cost to construct new housing units is higher than can be supported by the rents that many workers can pay. The difference between costs and affordable rent levels is considered an “affordability gap.” The linkage fee is assessed on new commercial and industrial projects, and additions to existing facilities. The fee is paid in conjunction with issuance of a building permit in the amounts noted below.

Land Use Fee
Retail $3.74 per square foot
Restaurant $3.74 per square foot
1 EPS, Nonresidential Housing Linkage Fee Nexus Study, 2014.

Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECOMMENDED FINAL page 5-7
Office $2.59 per square foot
Industrial $1.90 per square foot
Tourist Accommodation $1,726.99 per guest room
Linkage fees are also negotiated as part of development agreements.

In-Lieu Fees
Additional contributions to the Affordable Housing Fund are generated by fees paid in lieu of constructing the affordable housing required by the City’s inclusionary housing program (see description under Government Constraints section). The fee was set at $12,000 per unit in a project. Action A2.1-7 requires the City conduct an Inclusionary Housing Nexus Study and engage with the local development community and affordable housing advocates to evaluate the Inclusionary Housing Ordinance and in-lieu fee requirements for effectiveness in providing affordable housing under current market conditions.

Loan Repayments
The Affordable Housing Fund occasionally receives loan repayments associated with the Down Payment Assistance Program and second mortgages that the City holds on homes that were purchased under a first-time homebuyer program.

Affordable Housing Subsidies
The City has supported the development of affordable housing through financial allocations and in helping to secure project funding from public and private sources. • In 2003, the City allocated $540,000 for the development of the 18-unit Saratoga Manor project, which is comprised of 18 two- and three-bedroom units available for purchase by low-income families. Two non-profit organizations, Calistoga Affordable Housing (CAH) and Burbank Housing Development Corporation collaborated to construct the project. The City also committed to reducing development fees. The combined subsidy from the City was approximately $30,000 per housing unit. • In 2006 and 2007, the City assisted CAH in obtaining funding for two affordable housing projects.

These efforts resulted in $7.8 million of funding (including $3.1 million from the HOME Program) for the Palisades Apartments in 2008.
• In 2007, the City provided an $80,000 loan to CAH to fund the Lakewood I Multi-Family Rental Rehabilitation Project which includes eight deed-restricted very low-income units (including four deedrestricted farmworker units). • In 2012, the City approved variances in support of a 48-unit rental farmworker project developed by Corporation for Better Housing. The City also assisted the developer with its state and federal funding applications.

These and other non-profit organizations can be important providers of affordable housing in the community, and the city will continue to work with them as it implements this Housing Element.

Public Funding Sources
There are a number of programs potentially available to assist the City in increasing and improving its affordable housing stock.
• HOME program funds can be used to develop and support affordable rental housing and homeownership affordability. For Calistoga, these funds are made available on an annual competitive basis through the State’s small cities program. Allowed activities include acquisition, rehabilitation, construction, and rental assistance. HOME funds were used to support construction of the Palisades Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECOMMENDED FINAL page 5-8
Apartments and will be used to rehabilitate owner-occupied housing in the community, beginning in 2014.
• The federal Section 8 Rental Assistance Program provides rental subsidies to very low-income families.

A portion of the family’s monthly rent is paid in the form of a subsidy directly to the landlord by the Housing Authority of the City of Napa (HACN). Participants pay approximately 30 percent of their adjusted gross income to the landlord for rent. HACN staff assure that Section 8-assisted housing is safe and of high quality by requiring owners to meet housing quality standards and local codes. Section 8 vouchers currently assist 29 households in Calistoga. Of these vouchers, 20 are held by disabled persons.
• Community Development Block Grant funds have been used by Calistoga for housing rehabilitation loans, infrastructure improvements, public facilities and public services. Proceeds from those activities are deposited into a revolving loan fund established from low-interest loans for rehabilitation and could be a resource for housing stock preservation. An owner-occupied rehab program was launched in 2021 with Community Development Block Grant funds.
• Under the Community Reinvestment Act, federal law requires that banks, savings and loans, thrifts, and their affiliated mortgaging subsidiaries annually evaluate the credit needs for public projects in communities where they operate.
• The Low-Income Housing Tax Credit Program provides federal and state tax credits for private developers and investors who agree to set aside all or an established percentage of their rental units for low-income households for no less than 30 years. The recently constructed Calistoga Family Apartments project was the beneficiary of tax credits.
• Proposition 41, the Veterans Housing and Homeless Prevention Bond Act of 2014, authorized $600 million of general bonds to provide multi-family housing for veterans and their families. To access funds in this program, the City would work with veteran organizations in addition to nonprofit housing developers.
• State Permanent Local Housing Allocation (PLHA) funding, of which each jurisdiction receives an annual allocation. Calistoga has used this funding for a planning grant to promote ADU construction in the City. In addition to this non-competitive funding, there are competitive grants for projectspecific funds. • The United States Department of Agriculture (USDA) administers several funding programs to support farm labor housing and multifamily housing. Corporation for Better Housing used these funding sources to develop Calistoga Family Apartments in the City in 2019.

Preserving Affordable Housing
Several of the above sources can be used to preserve existing affordable housing, most notably the City's Affordable Housing Fund, Community Development Block Grant Funds, or Low-Income Housing Tax Credit Program funding.

Overall Site Selection Process
The sites best suited to meet RHNA requirements for the 2023-2031 planning period were determined by funneling down from examining all parcels available from the previous housing element cycle ("Reuse Sites"), then filtering by HCD's size requirements, and then applying an AFFH lens to the remaining sites. This process resulted in seven ideal housing opportunity sites for the City of Calistoga.

Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECOMMENDED FINAL page 5-9
Prior Identified Sites
There are 36 sites that were identified in prior housing elements, called “reuse sites” in this document, still available from the 5th Cycle planning period in Calistoga. Of these sites, 24 of are vacant and 12 of are nonvacant.

FIGURE 5-1 5TH CYCLE HOUSING ELEMENT OPPORTUNITY SITES
The use of these sites was preferred due to the community's familiarity from the previous Housing Element cycle and because of the streamlined process in the 6th Housing Element Cycle regulation that permits sites with an allowed density of 20 units/acre for use if they provided 20 percent of their total units to low-income affordability levels and allowed ministerial review of development. Of the 36 Reuse Sites, 15 are zoned CC, DC, or R-3 – all of which allow up to 20 units/acre.

Size Requirements
State law (AB 1397, Low, Chapter 375, Statutes of 2017) includes site requirements. HCD recommends using sites between 0.5 acres and 10 acres as opportunity sites, as these are most suitable for development of affordable housing. Of the 36 Reuse Sites, 13 were appropriately sized.

Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECOMMENDED FINAL page 5-10
In two instances, parcels that are under 0.5 acres in size but are part of a group of contiguous parcels under common ownership were included as a single site of suitable size. This is because any potential housing development could take advantage of the entire group's footprint across parcel lines (see “Small and Large Sites” section).

FIGURE 5-2 5TH CYCLE HOUSING ELEMENT OPPORTUNITY SITES – SITE SIZES AFFH
A crucial part of identifying appropriate sites for additional housing in the 6th Housing Element Cycle is to determine if they work to affirmatively further fair housing (AFFH). Additional AFFH analysis is available in Chapter 3. This AFFH lens was also used to focus housing on the parcels with the greatest access to resources within Calistoga.

Parcels were mapped to determine if they were within a 15-minute walk of the following categories:
- Public transit
- Food
- Parks
- Employment
Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECOMMENDED FINAL page 5-11
- Healthcare
- Schools
The sites located within these zones are optimal for growth and development as the sites could increase the density within the City of Calistoga without straining existing City resources or expanding town city borderslimits. Transit
FIGURE 5-3 TRANSIT ACCESS
Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECOMMENDED FINAL page 5-12
Groceries
FIGURE 5-4 FOOD ACCESS
Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECOMMENDED FINAL page 5-13
Parks
FIGURE 5-5 PARK ACCESS
Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECOMMENDED FINAL page 5-14
Employers and Employment Centers
FIGURE 5-6 EMPLOYMENT ACCESS
Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECOMMENDED FINAL page 5-15
Health Clinics
FIGURE 5-7 HEALTHCARE ACCESS
Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECOMMENDED FINAL page 5-16
Schools
FIGURE 5-8 SCHOOL ACCESS
6th Cycle Sites
The above analysis resulted in seven sites made up of 10 parcels that can support Calistoga's RHNA obligations for the 6th Housing Element Cycle.

Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECOMMENDED FINAL page 5-17
FIGURE 5-9 6TH CYCLE HOUSING SITES
Affordability Levels (“Aff. Levels”): V.L.: Very Low; Low, Mod.: Moderate; A.M.: Above Moderate.

These sites have capacity at maximum density for 255 units.

None of the sites in the Sites Inventory include residential units that are occupied by or subject to affordability agreements.

All of the sites in the Sites Inventory are in areas zoned for at least for 4 units of housing per parcel, complying with AB 725.

Realistic Capacity – Minimum Density
In order to determine realistic capacity on the 6th Cycle Housing Element sites, Calistoga is using minimum densities to calculate the projected residential development capacity of its sites.2 The use of minimum density in the housing element means that adjustment factors (i.e., zoning, affordability, infrastructure, environmental, and nonresidential/nonvacant adjustments) are not required. 2 Government Code section 65583.2(c)(1)
Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECOMMENDED FINAL page 5-18
TABLE 5-3 6TH CYCLE HOUSING SITES
Map
List APN/Address Acres
Units
Zoning Vacant? At Max.

Density
At Min.

Density
Affordability
Level
A 011-062-009 1.88 38 19
Above
Moderate
Community
Commercial (CC)
YES
B
011-062-008
1861 Lincoln Ave. 1.03 21 10 Very Low Community
Commercial (CC)
YES
C 011-072-020 6.12 122 61 Low Community
Commercial (CC) YES
D
011-050-024
865 Silverado Tr.

1.00* 20 10 Low Light Industrial (LI) NO
E 011-101-002 1.12 22 11 Very Low Community
Commercial (CC) YES
Sum F 1.06 21 11
Above
Moderate
YES
F
011-214-001
1420 Anna St.

0.32 6 3
Above
Moderate
Multifamily Residential/
Office (R3)
YES
F 011-214-002 0.29 6 3
Above
Moderate
Multifamily Residential/
Office (R3) YES
F
011-214-006
1402 Anna St.

0.45 9 5
Above
Moderate
Community Commercial
(CC)
YES
Sum G 0.56 11 6 Moderate YES
G 011-215-001 0.31 6 3 Moderate Multifamily Residential/ Office (R3)
YES
G 011-215-011 0.25 5 3 Moderate Multifamily Residential/ Office (R3) YES
Total 12.77 255 128
*=Only 1 acre of the 14.31-acre parcel will be used for residential. See “Site D – Larger than 10 Acres” analysis below.

As described earlier in the AFFH section, these sites are within walking distance of many necessary amenities that support the equitable production of new affordable housing.

A fuller discussion of Affirmatively Furthering Fair Housing in Chapter 3 discusses integration and segregation, racially and ethnically concentrated areas of poverty, areas of opportunity, and disproportionate housing needs including displacement. Due to the small size of Calistoga (four census block groups, and a single school district), and the lack of any racially and ethnically concentrated areas of poverty or affluence within the City, these sites do not exacerbate any existing conditions. Rather, the 6th Cycle sites improve integration and support Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECOMMENDED FINAL page 5-19
supply disproportionately needed in the City by providing mixed-income housing within areas of Calistoga that are best suited for housing in terms of convenient access to amenities.

RHNA Progress
There are 128 pending units in Calistoga's "pipeline" that can be counted towards its RHNA allocation for the 2023-2031 planning period. These units come from two projects: Silverado Terrace (50 units, 8 of which are affordable for low-income households) and 1855 Lincoln (128 units, 16 of which are affordable for moderateincome households, 45 for low-income households, and 24 for very low-income households).

TABLE 5-4 PIPELINE PROJECTS
Name
Very Low Low Moderate
Above
Moderate
Total
Total
Affordable
Silverado Terrace 0 8 0 42 50 8
1855 Lincoln 24 37 16 1 78 77
Total 24 45 16 43 128 85
Silverado Terrace
• Project Status. Use Permit approved.
• Schedule for Completion. Anticipated construction commencement – Q2 2023. • Remaining Steps. Building permit submittal.
• Mechanism for affordability (Inclusionary?). 8 low-income units to be constructed on-site. No specific data available at time of document publication. 1855 Lincoln
• Project Status. Use Permit approved and Building Permit issued. • Schedule for Completion. Occupancy anticipated – Q3 2023 • Remaining Steps. Finalize construction.
• Affordability Demonstration. 100% affordable unit construction on-site. Covenant(s) required prior to issuance of Certificate of Occupancy.

AB 1233: 5th Cycle Shortfall Review
Calistoga had adequate sites available in its previous Housing Element cycle and is not required to accommodate any unaccommodated need. There is no rezoning necessary as per Government Code section 65584.09 Alternative Methods to Accommodate RHNA (ADUs)Calistoga makes use of the "safe harbor option" to project future annual Accessory Dwelling Unit (ADU) production from 2018-2020 for the 6th Cycle planning period in order to determine the number of units projected to be built. With three ADUs built annually from 2018-2020, there will be a projected 24 ADUs built during the 6th Cycle Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECOMMENDED FINAL page 5-20
TABLE 5-5 ADU PERMITS
Year ADUs Receiving
Building Permit
2018 2
2019 3
2020 4
Average 3
Following ABAG/MTC guidance, these 24 ADUs can be distributed across affordability levels as shown in the following table:

TABLE 5-6 PROJECTED ADUS
Very
Low
Low Moderate
Above
Moderate
Total
Proportion 30% 30% 30% 10% 100%
ADUs 7 7 7 3 24
Environmental Constraints
Environmental factors can constrain residential development in a community by increasing costs and reducing the amount of land suitable for housing. Environmental constraints in Calistoga include hillsides, geologic hazards, and risk from wildfires. These housing opportunity sites are not in any of the listed hazard areas. • Hillsides: Hillsides are an integral part of the community’s image and identity. Preserving the hillsides is an important community goal, and policies related to hillside development balance environmental protection, property rights, and community values. The Rural Residential-Hillside Zoning District provides for development that will preserve the environmental and scenic benefits of these areas and avoid development that would result in an unacceptable hazard from fire, flood, landslide, or natural disaster.
• Geologic Hazards: Calistoga is vulnerable to geological conditions of concern including flood zones, earthquakes, liquefaction areas and landslides. California is known for being a seismically active region and the City takes necessary precautions, including building structures in accordance with the latest California Building Codes. The City with the County of Napa and other jurisdictions within the county have developed a new Hazard Mitigation Plan (2020). This plan is required by FEMA to be updated every 5 years.
• Risk from Wildfires: Calistoga is bordered by natural, undeveloped hillsides and mountains. The majority of these natural, undeveloped areas are very high, high, and moderately high Hire Hazard Severity Zones by the California Department of Forestry and Fire Protection. The City and County’s Local Hazard Mitigation Plan (2020) discusses the risk for Calistoga and the strategies to mitigate Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECOMMENDED FINAL page 5-21
wildfire potential.

There opportunity sites have capacity to accommodate 128 new housing units. In addition, the opportunity site are all reuse sites with no increase in density allowances. The City’s existing water and sewer treatment system can support the projected new development, and a water supply assessment is not necessary. Cultural and biological resources may impact the housing opportunity sites. These resources and their impacts are addressed in the environmental analysis document for the Housing Element.

Appropriate Density
Every site in the Sites Inventory currently allows for densities between 10 (minimum) to 20 (maximum) du/ac.

This means they meet the "default" density for suburban jurisdictions such as Napa County, which is 20 du/ac, without requiring a rezoning.

The following land use designations in Calistoga allow 20 du/ac. Bolded ones are used in the 6th Cycle Sites Inventory.
• Community Commercial
• Downtown Commercial
• High Density Residential/Office
Capacity
The sites in the Sites Inventory have capacity for a maximum of 128 total units This is based on the total site acres (12.77 acres) multiplied by the minimum density of 10 units/acre. Of these 128 units, 98 are allocated for very low, low, and moderate units.

The Site Inventory is provided as Appendix 5-1.

Nonresidential Development
Sites A, B, D, and E are on parcels zoned CC (Community Commercial), which allows residential or nonresidential uses. This zoning designation allows development of 100 percent non-residential uses on a parcel.

There is an established track record of 100-percent residential use in the CC zone. It isThe CC zone is home to Calistoga's two pipeline projects – both sited on Lincoln Avenue, where the 6th Cycle sites are located.

Development and performance standards support the production of housing in Calistoga’s CC zone. The CC zone also allows for 100-percent nonresidential projects, however, there have been no new 100-percent nonresidential projects in the CC zone over the last 10 years. The commercial market in Calistoga is unusually narrow due to the city’s relatively remote location.

The pipeline projects are substantially similar in size and location to the four parcels on the Site Inventory that are zoned CC. Both pipeline projects developed above minimum densities. These development trends demonstrate the likelihood of residential development at (conservatively) the minimum allowed density during the 6th Cycle.

Item #8.2.

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TABLE 5-7 PIPELINE PROJECTS AND OPPORTUNTIY SITES IN THE CC ZONE Address APN(s) Acres
Units
Projected
Projected
Density
(du/ac)
% of Max.

Density
(20 du/ac)
Pipeline Projects
1506 Grant Street
(Silverado Terrace)
011-101-001;
011-101-009

1.93 50 26 130%
1855 Lincoln Avenue 011-050-044 2.87 78 27 135%
Opportunity Sites
011-062-009 1.88 19 10 50%
1861 Lincoln Avenue 011-062-008 1.03 10 10 50%
865 Silverado Terrace 011-050-024 1.00 10 10 50%
011-101-002 1.12 11 10 50%
Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECOMMENDED FINAL page 5-23
Use of Prior Identified Sites
FIGURE 5-10 REUSE SITES IN THE 6TH CYCLE
Site "D" is a nonvacant site that was used in a previous planning period. Sites "A", "B", "C", and "F" have been vacant for the past two planning periods. Sites "E" and "G" are vacant but were identified only in the 5th Cycle Housing Element.

Sites "A", "B", "C", "D", and "F" will be required to be rezoned within three years of the beginning of the planning period to allow residential use by right at 20 du/ac, for housing developments in which at least 20 percent of the units are affordable to lower income households. Sites "E" and "G" currently allow residential uses at 20 units/acre and are between 0.5 and 10 acres in size.

Infrastructure
Municipal Codes deems public water and sewer available if parcels are within 1,000 feet (water) and 200 feet (sewer) of the parcel's property line. Based on this definition, public water/sewer are available for all these sites.

Additionally, per the City’s Infrastructure Element (2020) of the General Plan, the water and wastewater treatment system can support projected development through 2035. The water and sewer demand determined from the City’s Standardized Use Table for Resource Management is higher than the number of housing units Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECOMMENDED FINAL page 5-24
that would be developed from the opportunity sites. Table 5-7 provides a summary of the City’s water and sewer demand. For the full Standardized Use Table, refer to Appendix C.

TABLE 5-8 WATER AND SEWER DEMAND
Multifamily 2-bedroom
unit (Acre feet per year)
Availability (Acre
feet per year)
Availability
(Multifamily Units)
Water 0.249 1751 715
Sewer 0.146 233 1,286
Source: City of Calistoga
Additional infrastructure that was analyzed was the provision of dry utilities. AT&T is the primary telecommunications provider in the City and has reported that their systems have sufficient capacity to support the anticipated new housing development. PG&E maintains the electric grid and the delivery of energy to customers. City staff has tried reaching PG&E multiple times to determine electrical capacity but have been unable to get a response. Staff believes that there is sufficient capacity to support the new development planned by the Housing Element.

Small and Large Sites
Of the 10 parcels in Calistoga’s site inventory, four are between 0.5-10 acres. One parcel (Site D) is larger than 10 acres and the sites that compose Sites F and G are under 0.5 acres in size.

Site D – Larger than 10 Acres
Site D currently contains the Calistoga Beverage Company facility that was purchased by Calistoga Vintner Services in September 2021. More information on the site can be found in the “Nonvacant Site Analysis” section.

There is ample vacant space on the parcel for a 1-acre residential development. Action A1.1-4 directs for the modification of the municipal code to allow for multifamily housing on vacant or underutilized portions of lots larger than one acre if allowed under zoning and land use controls.

Sites F and G – Smaller than 0.5 Acres
Sites F and G both consist of parcels under common ownership that can be combined and redeveloped for housing.

Under the Minimum Density capacity standards used in the housing element, F is not allocated for development into lower-income housing (it is instead allocated towards meeting moderate-income housing needs) and therefore does not need to comply with Small Site Analysis.

Site G is owned by the City of Calistoga. The two parcels are contiguous and were purchased with the express purpose of development for use of lower-income housing. There are no constraints on merging the two parcels in order to produce affordable housing.

Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECOMMENDED FINAL page 5-25
Sites and AFFH
The sites in the Site Inventory help to affirmatively further fair housing by expanding housing options throughout the City for various income levels, particularly in areas of the City most proximate to transit, grocery stores, parks, and employment centers.

Segregation and Integration
The seven sites, totaling 12.77 acres, are all in the Community Commercial (along Lincoln Avenue) or R-3 (off Washington Street) zoning designations. These sites are all reuse sites from previous Housing Element Cycles that will allow for higher density development with ministerial review, inclusive of housing for a variety of income levels and allowing for greater mobility of households into better-resourced areas of Calistoga.

The sites in the Site Inventory offers affordable housing opportunities in high resource areas that are within a 15-minute walk of:
• Vine Transit
• Groceries
• Parks
• Health Clinics
• Schools
• Employment centers (defined as Downtown Commercial – Design District zoned parcels along southern Lincoln Avenue)
Development in these sites is not constrained by topographical or other environmental constraints.

Patterns of segregation by race and ethnicity, persons with disability, familial status, age, and income are described in Chapter 3: Affirmatively Furthering Fair Housing. The City’s sole census tract is predominantly White with a substantial Hispanic or Latino minority, and small Black or African American, Asian, and Pacific Islander populations. The Othering and Belonging Institute listed Calistoga’s census tract as an area with “LowMedium Segregation.”3 Sites to accommodate affordable housing are distributed along Lincoln Avenue, the City’s primary transportation corridor, in order to better connect affordable units (allocated to lower-income and moderateincome households) to resources (see Figures 5-3 through 5-8). There are no identified concentrations of populations with disabilities within City boundaries (see Table 3-4 in Chapter 3). The housing opportunity sites designed for affordable units are on relatively flat ground with better access to sidewalks than the City as a whole.

Figure 5-11 demonstrates that the sites designated to accommodate Calistoga’s lower-income households are in or adjacent to census block groups with relatively high median household incomes, compared to the City as a whole.
3 Racial Segregation-Integration OBI 2020, available at https://affh-data-and-mapping-resources-v-2-0-cahcd.hub.arcgis.com/datasets/CAHCD::racialsegregation-integration-obi-2020/about.

Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECOMMENDED FINAL page 5-26
FIGURE 5-11 MEDIAN INCOME BY BLOCK GROUP
Racially or Ethnically Concentrated Areas
As shown in Figure 3-5, the City does not have any racially or ethnically concentrated areas of poverty or areas of affluence and the identification of sites to accommodate the City’s RHNA is not expected to alter this finding. Through providing increased affordable housing opportunities in Calistoga, the housing site strategy will increase diversity throughout the community. The City has included actions A7.1-1, A7.1-2, and A7.1-3 in order to conduct outreach about fair housing in Calistoga and the Napa region, as well as create a Fair Housing Marketing Plan, to ameliorate any nearby concentrated areas of poverty by advertising opportunities in Calistoga.

The sites in the Site Inventory are located in Block Groups 1 and 2. As discussed in the Fair Housing Chapter, neither of these block groups contain Racially and Ethnically Concentrated Areas of Poverty and Affluence.

The sites allow for affordable housing options for residents below median income levels in areas of the City that are most proximate to transit, grocery stores, parks, and employment centers.

Block Groups 3 and 4 do not have any housing opportunity sites. However, accessory dwelling units (ADUs) provide opportunities for affordable units in areas of Calistoga such as these. Based on historical patterns of ADU production, there is a projection of 24 ADUs built during this Housing Element cycle.

Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECOMMENDED FINAL page 5-27
Access to Opportunity
Calistoga’s lone census tract is a “moderate” resource area, and it shares the same broad economic, education, and environmental characteristics with surrounding unincorporated Napa Coutny. • Economic: The TCAC economic score (0.21) is relatively low compared to the state as a whole. • Education: The TCAC education score (.39) is slightly higher, but still somewhat low. All of Calistoga is served by the same school district.
• Environment: The TCAC environmental score (.70), however, is quite high.

All of Calistoga’s sites to accommodate very low and low income households include opportunities for moderate and/or above moderate income households, promoting equitable access to opportunities.

Census Blocks 1 and 4 are "Low Resource" rural areas according to the 2022 TCAC/HCD Opportunity Map, while Census Blocks 2 and 3 is a "Moderate Resource" rural area. These relatively low scores are due to lower Economic Scores in rural Napa County compared to the state as a whole. All areas of Calistoga are covered by the Calistoga Joint Unified School District
As discussed in the "Segregation and Integration" section, all sites in the Site Inventory have relatively high access to opportunity for Calistoga, within 15-minute walks of transit, grocery, parks, and employment centers.

Because all sites in the Site Inventory are reuse sites from previous Housing Element Cycles that will use an Affordable Housing Overlay for higher density development with ministerial review, there will be fewer governmental constraints (such as a required General Plan amendment or zoning change).

Transportation
To improve economic access via transit, all the City’s sites for lower income households are along Calistoga’s transit corridor of Lincoln Avenue. Parcels allocated for above moderate and moderate income households are within 15-minute walking distance of transit (see Figure 5-3: Transit Access).

Disproportionate Housing Needs and Displacement Risk
There are no residential units currently existing on any of the sites identified in the Site Inventory (see Nonvacant Sites Analysis, below).

The Urban Displacement Map identifies the entire City of Calistoga as a site of Ongoing Displacement. The site strategy aims to alleviate this displacement by siting new housing development in areas that do not currently have housing.

Calistoga, like the vast majority of Napa County, has an estimated “Lower Displacement Risk” as defined by the Urban Displacement Project. There is a relatively high proportion of cost-burdened renters in Calistoga (65 percent of renters pay 30 percent or more of their household income on housing costs) compared to small cities south of Calistoga in Napa Valley such as St. Helena and Yountville (approximately 46 percent and 56 percent of renters are cost burdened, respectively). Affordable housing in Calistoga will alleviate this cost burden without contributing to displacement risk.

In addition, the ADUs projected in underutilized single-family parcels will be joined by SB 9 parcels. The City has already seen 3 SB 9 applications since the law was passed in 2021. This will provide for additional rental Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECOMMENDED FINAL page 5-28
opportunities at a range of income levels and reduce displacement potential. To further address the potential for displacement of lower income renter households, action A3.1-2 will continue to prohibit vacation rentals.

Nonvacant Sites Analysis
Of the seven sites, there is one nonvacant site in the Site Inventory: Site D (APN: 011050024000), which currently contains the Calistoga Beverage Company facility that was purchased by Calistoga Vintner Services in September 2021.

Site D is used for 10 of the 128 units Calistoga is using to meet its 6th cycle RHNA, or 7.8 percent. In addition, because the sites allocated go far over the RHNA requirement of 119 units (69 affordable), the RHNA obligations could be met in the event Site D does not develop with housing.

The structure on Site D takes up approximately 6 acres of the 14.31-acre site, fronting Silverado Trail on the northern edge of the parcel. The site can still support one acre of housing development fronting Lincoln Avenue on the southwestern edge of the parcel. This one acre of housing would make up approximately 7 percent of the site, essentially giving the site a .07 nonvacant site adjustment factor.

Residential development on adjacent sites in the same zoning district point to development trends and market conditions that support housing on this site. This housing development would neighbor the two "pipeline" projects currently underway in Calistoga: Silverado Terrace and 1855 Lincoln Avenue. It would also not affect any current use or moderate expansion by Calistoga Vintner Services, who are planning to use the existing structure for warehousing a maximum of 8,000 barrels of wine using only one third of the existing 123,600- square foot structure.

Action A1.1-4 directs for the modification of the municipal code to allow for multifamily housing on vacant or underutilized portions of lots larger than one acre if allowed under zoning and land use controls. The intention of this action to serve as a regulatory incentive to encourage residential development on parcel D, specifically.

Water and Sewer Priority Requirements (SB 1087)
State law requires water and sewer providers to grant priority for service allocations to proposed developments that include units affordable to lower income households. Pursuant to these statutes, upon adoption of its Housing Element, the City will provide the Element to the Calistoga Water Department.

New Housing Opportunities
Table 5-8 identifies housing units that are under construction or that have been approved and could be constructed during the planning period.

Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECOMMENDED FINAL page 5-29
TABLE 5-9 APPROVED AND UNDER-CONSTRUCTION HOUSING
Income Category
Project Name Total Units VL L M AM Affordability
Determination
Silverado Terrace 50 0 8 0 42 Inclusionary policy
1855 Lincoln 78 24 37 16 1
Totals 128 24 45 16 43
Source: City of Calistoga
Development Site Inventory
In addition to the approved housing identified above, Table 5-3 identifies 7 sites in Calistoga (illustrated in Figure 5-10) that provide realistic development opportunities for the provision of housing to all income segments within the community.

Most of the properties in the inventory below are vacant; one is underutilized (the Calistoga Beverage Company Warehouse could take on housing on the Lincoln Avenue side of the parcel).

Therefore, in combination with the approved units identified in Table 5-8, the City can readily accommodate its RHNA of 119 units for the planning period. It is important to note that identification of a site in this inventory does not restrict or require that it be developed exactly as described in the inventory. Likewise, sites that are not identified in the inventory are not precluded from developing with residential uses that would help fulfill the City’s regional housing need. The purpose of preparing the site inventory and analysis is to comply with state law that requires the City to demonstrate it has adequate housing sites for meeting projected housing needs.

Potential Development Constraints
Sites identified for potential residential development in the City were analyzed to determine their relationship to public facilities and services and existing or potential physical constraints to development. Of the seven identified sites, none have significant constraints that may limit its development. The following sub-sections provide a general discussion of potential development constraints known to exist within the City.

Public Services
In 1998, the city purchased 500 acre-feet per year of domestic water from the City of American Canyon’s North Bay Aqueduct entitlement. In 2000, an additional 925 acre-feet of water per year was purchased from Kern County. These purchases, combined with the city’s original North Bay Aqueduct entitlement and its Kimball Reservoir water supply is projected to provide an adequate water supply in Calistoga through 2035. The City recently completed construction of a 1.5-million-gallon water tank on Mt. Washington to improve storage capacity and better manage municipal water supply during peak demand times. The City expanded its wastewater treatment plant in 2003. This expansion provides sufficient capacity to accommodate demand projected through 2035.

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CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECOMMENDED FINAL page 5-30
Flooding
Certain areas of Calistoga lie within the 100-year floodplain of the Napa River and are at risk of flooding.

Residential areas known to be prone to flooding include areas around Silver Street, from Gold Street to Spring Street, between the river and Myrtle Street; a crescent-shaped area around Washington Street, starting southeast of Oak Street, rising up Lake Street and Fourth Street, and extending to Second Street; and the area from Pine Street southeast to the City limits, between the river and Foothill Boulevard. Policies and actions contained in the Safety Element will ensure that new development would not be exposed or vulnerable to risks associated with flooding.

Another part of Calistoga that could be subject to flooding is property downstream of the Kimball Reservoir.

If the dam were to fail, inundation could occur in the northern part of the Planning Area as far south as Tubbs Lane. South of Tubbs Lane, dam failure would cause the Napa River to overflow its banks through the rest of the City. The risk of dam failure is small, so the impact of additional development within the dam inundation area is not considered to be a significant constraint.

Special Status Species and Sensitive Natural Communities Occurrences of several plant and animal species with special status have been recorded or are suspected to exist within Calistoga. Most of these are associated with the forest, woodland, and grassland along the fringe of City limits and the outer Planning Area. A few species have been reported from the floor of the valley, generally associated with the aquatic habitat of the Napa River and the freshwater marsh in geyser-fed swales where disturbance has been limited. Development of a few of the sites will result in the loss of grassland and savannah; however, they are not considered to be particularly sensitive resources, and therefore, their potential loss is not considered to be a constraint to development.

Archaeological Resources
Archaeological resources known to exist within the City include remnants of Native American villages and campsites and other evidence of habitation. Prehistoric archaeological sites are generally located along seasonal and/or perennial watercourses, at or near vegetation ecotones, and at the base of foothills. There is a possibility that sites located in these areas may contain undiscovered archaeological and paleontological resources that could be impacted from development activities involving ground removal or disturbance. Policies contained in the General Plan's Community Identity Element require pre-development consultation with tribal representatives and will ensure respectful treatment of resources.

Summary of Objectives
The summary of quantified objectives can be found at the end of Chapter 8: Housing Policies and Programs.

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CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECOMMENDED FINAL page 6-1
CHAPTER 6: CONSTRAINTS TO THE DEVELOPMENT OF HOUSING
This section of the Housing Element evaluates potential constraints to new housing development in the City.

Constraints that can pose a barrier to the construction of new housing can be grouped into two categories.

Governmental constraints are barriers imposed through government policies and procedures, such as development standards, application processing times, and development fees. Non-governmental constraints are development barriers that are outside of the control of local jurisdictions, for example, construction costs, land costs, and financing costs. However, local governments can adopt policies and procedures to address these constraints and increase the ease of developing new housing.

Governmental Constraints
State law requires each Housing Element to include an analysis of potential and actual governmental constraints on the maintenance, improvement, and development of housing for all income levels and persons with disabilities.

Governmental regulations and exactions are designed to achieve desirable land use patterns, coordinate development with infrastructure expansion, finance capital improvements, equitably distribute the cost of public services, maintain the ambiance of existing neighborhoods, improve the urban environment, and preserve open space and unique ecosystems. However, they should be evaluated to determine whether they are excessive and represent an unnecessary constraint on the availability or affordability of housing being built or contribute to the loss of existing affordable housing.

In its efforts to remove governmental constraints, Calistoga must also be guided by Government Code Section 65580(e), which notes that the City also has “…the responsibility to consider economic, environmental, and fiscal factors and community goals set forth in the general plan…” The most direct government effect on housing production is the regulation of land use through the General Plan and Zoning Code. Every municipality in the Bay Area plans for the location of housing and the number of units that can be built on a property by designating and zoning land for different types of uses and by specifying the range of dwelling units allowed (the density) in each residential land use category. Development standards, such as minimum lot sizes and building setbacks also affect the type and cost of housing that may be developed.

Calistoga mitigates the effects of land use controls on housing production by:
• Providing a range of zoning categories and densities to allow for all types of housing. • Permitting and encouraging mixed-use developments that combine housing with other uses. • Providing incentives for affordable housing and accessory dwelling units, as well as single-family residences on existing residential lots of record.

Calistoga General Plan
Calistoga’s General Plan includes a wide range of residential land use designations, including:
• Rural Residential-Hillside (0.5 units/acre),
• Rural Residential (1 unit/acre),
• Low Density Residential (1 to 4 units/acre),
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CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECOMMENDED FINAL page 6-2
• Medium Density Residential (4 to 10 units/acre), and
• High Density Residential (10 to 20 units/acre).

The Downtown Commercial and Community Commercial land use designations allow for mixed-use development, including multi-family residential within a density range of 10 to 20 units per acre. Minimum densities are required for most of the designations in order to maximize residential development on a limited supply of land and achieve a balance and variety of housing types. Consistent with state law, density bonuses may be approved for projects that include dedicated affordable housing and senior housing to exceed the maximum density otherwise allowed.

The maximum densities allowed for the High Density Residential land use designation are not an impediment to the development of affordable multi-family projects. The Calistoga Senior Apartments project, which serves very low- and low-income seniors, was approved in 2016 with a 58 percent density bonus.

Zoning Code
Zoning Districts
The City regulates the type, location, and scale of development through its Zoning Code. The Code includes a wide range of residential zoning districts that allow a variety of housing types, including single-family, multifamily, second units, mobile homes, transitional and supportive housing, and residential care. Table 6-1 demonstrates the types of housing allowed by zoning district.

TABLE 6-1 HOUSING TYPES ALLOWED BY ZONING DISTRICT
Zoning District Residential Uses Allowed By-Right Residential Uses Allowed with a Use Permit
Rural Residential (RR)
One one-family dwelling per lot
One accessory dwelling unit per lot
One junior accessory dwelling unit per
lot
Supportive housing
Transitional housing
Residential care, limited
Residential care, general
Rural Residential –
Hillside (RR-H)
One accessory dwelling unit per lot
One junior accessory dwelling unit per
lot
One one-family dwelling per
lot
Supportive housing
Transitional housing
One-Family Residential
(R-1 & R-1-10)
One one-family dwelling per lot
One accessory dwelling unit per lot
One junior accessory dwelling unit per
lot
Supportive housing
Transitional housing
Residential care, limited
Residential care, general
Two-Family Residential
(R-2)
One one-family dwelling per lot
One accessory dwelling unit on a lot with
a one-family dwelling
One junior accessory dwelling unit per
lot
Residential care, general
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CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECOMMENDED FINAL page 6-3
One duplex or two one-family dwellings
on a lot of at least 9,000 square feet
Supportive housing
Transitional housing
Residential care, limited
Multifamily
Residential/Office (R-3)
Multifamily dwellings
One or more accessory dwelling units
within the multifamily dwelling
Maximum of two detached accessory
dwelling units on a lot with a multifamily
dwelling
Supportive housing
Transitional housing
Residential care, limited
Convalescent and congregate
care facilities
Residential care, general
Mobile Home Park
(MHP)
Residential mobile homes
Mobile home parks
Permanent apartment units,
for managers of the park
Downtown Commercial
(DC)
Supportive housing
Transitional housing
Multifamily dwellings above
the first floor
Live-work units
Community Commercial
(CC)
Emergency shelters
Supportive housing
Transitional housing
Multifamily dwellings above
the first floor
Live-work units
Residential care facilities for
the elderly
Skilled nursing facilities
Each district ensures that the type of residential development is consistent with and implements the City’s General Plan land use designations. For example, the R-3 Zoning District implements the “High Density Residential” General Plan land use designation, which is intended for multi-family development, by allowing multi-family dwelling units as a permitted use (i.e., not subject to a use permit).

State law requires jurisdictions to analyze the zoning and availability of a variety of housing types, which are discussed below. Due to Calistoga’s small size, the City coordinates with non-profits and countywide efforts to provide housing supportive services to meet the countywide citywide housing needs of the most vulnerable populations.

Multifamily Rental Housing
Multifamily rental housing refers to a building or portion of a building that is rented out and used as a residence for more than one household living independently of each other. Multifamily rental housing includes duplexes, triplexes, and apartments.

One duplex or two one-family dwellings are permitted by right on a lot of at least 9,000 square feet in the R-2 zoning district (Chapter 17.18). Multifamily rental housing is permitted by right in the R-3 zoning district and are permitted with a use permit in the Downtown Commercial and Community Commercial zoning districts (Chapter 17.19, and 17.21-17.22).

Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECOMMENDED FINAL Housing for Agricultural Employees
Agricultural employees are people whose primary incomes are earned through agricultural labor. This population tends to have high rates of poverty, have unstable incomes, live in housing with high rates of overcrowding, and have low rates of homeownership.

Farmworker housing is not explicitly discussed in the City’s Zoning Code, but can be provided through different housing types, such as multi-family housing, manufactured housing, single-room occupancy units, cooperative housing, and accessory dwelling units. Many of these housing types are allowed by right in the residential zoning districts and discussed in further detail in their respective sections. Cooperative housing is a form of housing where residents have joint ownership over the property and share amenities. Additionally, Napa County Housing Authority manages three farmworker centers in the county, including one in Calistoga, that provide housing and social services. Farmworker housing is treated as a single-family structure and is subject to family dwelling fees and taxes, and Calistoga also otherwise complies with the Employee Housing Act (Health and Safety Code, § 17000 et seq.).

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 type of housing an allowable use (see action A6.1-6).

Emergency Shelters
Emergency shelters are defined as “housing with minimal supportive services for homeless persons that is limited to occupancy of six months or less by a homeless person. No individual or household may be denied emergency shelter because of an inability to pay” (Gov. Code, § 65582).

As per Section 17.04.227 of the zoning code, “Emergency Shelter” as defined by the City “shall mean housing with minimal supportive services for homeless persons that is limited to occupancy of six months or less by a homeless person. (Ord. 685 § 2, 2012).”
As per Chapter 17.22 of the Zoning Code, emergency shelters are permitted by right in the Community Commercial zoning district. A maximum of 20 beds are permitted in each emergency shelter and can provide temporary shelter to residents for no more than 180 days in any 12-month period. The shelter shall conform to all development standards of the zoning district.

This section also describes the client intake/waiting area, external lighting, security personnel, and on-site facility management. The client intake/waiting area shall be provided at minimum of 10 square feet per bed with a minimum of 100 square feet. The waiting area will not be adjacent in a right of way, but if the waiting area is to be outdoors, the intake/waiting area shall be screened with a six-foot-tall, landscaped screen or decorated wall with shade and rain provisions.

The site will also have adequate external lighting and security personnel during the hours the shelter is in operation.

For staffing, at least one facility member is on site at all hours the facility is open. Additional staff shall be provided as necessary to ensure that at least one staff member is provided in all segregated sleeping areas, as appropriate (17.22.020(A)(10)).

For minimum parking requirements, the housing element includes a program that requires emergency shelters to provide for a number of parking spots only sufficient to accommodate staff and not exceeding the standards for the other uses in the underlying CC zone. The City will amend emergency shelter parking requirements to comply with AB139/Government Code section 65583, subdivision (a)(4)(A) (see action A6.1-4). page 6-4
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CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECOMMENDED FINAL page 6-5
Low Barrier Navigation Centers
Low Barrier Navigation Centers is a housing first solution to address homelessness. These temporary shelters provide services and are focused on transitioning individuals experiencing homelessness into permanent housing.

Currently, low barrier navigation centers are not identified as a permitted or conditionally permitted use in any zoning district. However, due to the similarities between this use and transitional housing, it could potentially be allowed in the RR, R-1, R-1-10, R-2, and R-3 zoning districts subject to a “similar use” determination by the Planning Commission (Chapter 17.14 and 17.16-17.19). Low barrier navigation centers could also be allowed with a use permit in the RR-H zoning district if determined to be a similar use by the Planning Commission (Chapter 17.15).

Action A4.1-8 further reduces barriers to the construction of navigation centers by directing the City to amend the Downtown Commercial Zoning District to permit low barrier navigation centers as a by-right use within one year of the Housing Element’s certification.

Transitional and Supportive Housing
Transitional housing refers to rental housing (residential) developments that are operated under program requirements that require the termination of assistance and recirculating of the assisted unit to another eligible program recipient at a predetermined future point in time that shall be no less than six months from the beginning of the assistance. (Ord. 1004 § 7, 2014).

Supportive housing has no limit on length of stay and is occupied by the target population. This type of housing has onsite and offsite services that assists residents in retaining the housing, improving their health status, and maximizing their ability to live and, when possible, work in the community (Ord. 1004 § 6, 2014).

Calistoga’s zoning code permits transitional housing in all residential zoning districts by right (Chapter 17.14 and 17.16-17.19). Transitional housing developments in the Rural Residential – Hillside district are allowed with a use permit (Chapter 17.15).

Calistoga’s Zoning Code permits supportive housing in all residential zoning districts by right (Chapter 17.14 and 17.16-17.19). Supportive housing developments in the Rural Residential – Hillside district are allowed with a use permit (Chapter 17.15).

Permanent supportive housing as a use that will be allowed by right in zones where multifamily and/or mixeduses are permitted, including nonresidential zones permitting multifamily uses in compliance with Government Code section 65651 (see action A6.1-5).

Licensed Care Facilities
The California Welfare and Institutions Code declares that mentally- and physically disabled persons are entitled to live in normal residential surroundings, and that the use of property for the care of six or fewer disabled persons is a residential use for the purpose of zoning. A state-authorized, certified, or licensed family care home, foster home, or group home serving six or fewer disabled persons or dependent and neglected children on a 24-hour-a-day basis is considered a residential use that is permitted in all residential zones. No jurisdiction may impose stricter zoning or building and safety standards on these homes than is otherwise required for homes in the same district.

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CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECOMMENDED FINAL page 6-6
In accordance with state law, the Zoning Code permits licensed residential or community care facilities with six or fewer beds by right in the R-1, R-2, and R-3 residential zoning districts, and allows facilities serving more than six persons in these districts with a use permit (Chapter 17.16-17.19).

Single-Room Occupancy (SRO) Units
Single-room occupancy residential units (SROs) are a form of affordable housing consisting of a single room typically between 200 to 350 square feet. They are located in multi-tenant buildings and typically include shared bathroom and kitchen facilities.

Currently, SRO housing is not identified as a permitted or conditionally permitted use in any zoning district.

However, it could potentially be allowed in the R-3, Downtown Commercial, or Community Commercial zoning districts subject to a “similar use” determination by the Planning Commission (Chapter 17.19, 17.21-

17.22). Applicable General Plan land use densities for the subject zoning districts would limit the number of SRO units in a given project to a maximum of 20 units per acre, although these densities could be higher if rooms do not include cooking facilities and are therefore not considered dwelling units in the traditional sense.

Action A1.2-4 directs the City to amend the Zoning Code to permit adaptive reuse of inns, motels, housing cooperatives and non-storefront commercial space for long-term housing.

Manufactured Homes
Manufactured homes are houses that are transportable, built on a permanent chassis, and designed for use with or without a permanent foundation when attached to the required utilities. Manufactured homes do not include recreational vehicles. Due to the much lower cost of construction and labor costs needed to build a manufactured home, this housing type provides an affordable housing solution. Manufactured homes on a permanent structure are subject to the same development standards and permitting requirements as a conventional single-family residential dwelling.

Mobile homes and accessory dwelling units can be manufactured homes. These two types of manufactured homes are discussed in the sections below.

Mobile Home Parks
Mobile home parks include any property that has a minimum of two mobile homes, manufactured homes, recreational vehicles, and/or lots that are held for rent or lease.

Mobile homes are permitted with a use permit in the Mobile Home Park zoning district (Chapter 17.20) and are subject to design review. The Mobile Home Park zoning district includes development standards for the design of the park site and individual mobile home sites. The zoning district is intended to protect existing mobile home sites from being converted to conventional housing or other uses.

Accessory Dwelling Units
Accessory dwelling units (ADUs) are attached or detached residential dwelling units that provides complete independent living facilities and is located on a lot with a proposed or existing primary residence. ADUs are a cost-effective housing type because they do not require new land or major infrastructure improvements. ADUs tend to be smaller and are thereby more affordable by design. However, because many ADUs are rented to family and friends of the homeowner, if homeowners are primarily White then the families and potential friends of the homeowners could be predominantly White. Relying too heavily on ADUs for affordable housing could inadvertently exacerbate patterns of segregation, but they can still be an effective strategy for increasing the supply of smaller rental housing units in single family home neighborhoods.

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CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECOMMENDED FINAL page 6-7
The Calistoga Zoning Code allows ADUs on all lots where a single family or multifamily dwelling is proposed or exists (Chapter 17.37). The City has reduced barriers to building ADUs through less restrictive development standards and expediting the application review and approval process. ADUs that comply with the development regulations in the City’s Zoning Code shall be approved without discretionary review within 60 days of receipt of the completed development application. The City has also waived impact fees for ADUs smaller than 750 square feet and waived utility connection fees for all ADUs that are not constructed at the same time as the primary dwelling unit.

The City also partnered with the Napa Sonoma ADU, which is a non-profit that helps homeowners in Napa and Sonoma County to construct ADUs. Napa Sonoma ADU provides resources to guide homeowners through the process of planning, permitting, and constructing an ADU, including free feasibility consultations, example floor plans, and a list of design and construction vendors.

Development Standards
Provisions in the Zoning Code specify minimum lot areas, lot widths, lot depths and setbacks, and maximum lot coverage and building heights. Additional development regulations specify parking requirements.

Development standards applicable to residential development are summarized in Table 6-2 and Table 6-3.

These standards are typical of many California communities and contribute to the protection of the public health, safety and welfare, and the maintenance of the City’s quality of life.

Building Height and Lot Coverage
The Zoning Code limits the height of residential buildings to a maximum height of 25 feet in residential zones and 30 feet in commercial zones. However, heights up to 35 feet are allowed where a finding can be made that the taller building height would be more compatible with surrounding buildings due to their special historical, architectural or aesthetic interest, and that the taller building height does not encroach on the light or views of adjacent properties.

This provides more than enough height to accommodate two-story construction but can make it difficult to construct a three-story building with sufficient height to accommodate a pitched roof on a parcel designated for high density and mixed-use development. Furthermore, the Zoning Code measures building height at the point that is half the distance between the ridge and eave on a gable roof, rather than to the highest point of the roof, thereby allowing additional height for sloped roofs.

Limits on lot coverage and building height have not been a constraint to the development of housing for any income groups, including affordable housing projects. All of the projects have been two-story, and the lot coverages for the Palisades Apartments and Calistoga Family Apartments were 26% and 15%, respectively.

Unit Sizes
The Zoning Code does not establish direct regulations regarding minimum and maximum unit sizes. Minimum unit sizes are based on standard requirements under the California Building Code. The City has adopted the California Building Code, with local amendments, as Title 15 of the Calistoga Municipal Code; the amendments do not result any substantial differences to unit size standards. Maximum unit sizes for single family and multifamily units are not specifically established in the Zoning Code. Unit size has not been an impediment to the development of housing, as minimum standards are consistent with broadly adopted code standards and there are no maximum size standards. Accessory dwelling unit (ADU) size limitation are comparable to State standards for ADUs. Studio and one-bedroom ADUs are limited to 850 square feet; two or more bedroom ADUs are limited to 1,000 square feet. ADUs created through addition to an existing primary dwelling may not exceed 50 percent of the primary dwelling living area.

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CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECOMMENDED FINAL page 6-8
Setbacks
Setback requirements in the Zoning Code reflect the importance of maintaining adequate buffering between adjoining properties to avoid potential use conflicts. These setbacks are typical of similar communities and have not appeared to be an impediment to the development of housing. The Downtown Commercial district does not require any setbacks unless located adjacent to or across the street from a parcel located in a residential zoning district. The Community Commercial district requires front setbacks and side setbacks for corner parcels. Similar to the Downtown Commercial district, additional setbacks are required if the development is located adjacent or across the street from a residential zoning district.

Table 6-2 provides residential development standards, by square feet, for each zoning district.

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CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – PUBLIC REVIEW DRAFT page 6-9
TABLE 6-2 RESIDENTIAL DEVELOPMENT STANDARDS
Development
Standard
Zoning Districts
RR-H RR R-1 R-1-10 R-2 R-3 MHP
Minimum Lot Area Varies1
20,000 –
80,000
square feet2
6,000 sq. ft.
(interior)
7,000 sq. ft.
(corner)
10,000 sq. ft
(interior)
12,000 sq. ft.
(corner)
9,000 sq. ft.
(interior)
10,000 sq. ft.
(corner)
9,000 sq. ft.
(interior)
10,000 sq. ft.
(corner)
3,500 sq. ft.

Minimum Lot Width Varies1 100 feet 70 feet (corner)
60 feet (interior)
120 feet (corner)
100 feet
(interior)
100 feet (corner)
90 feet (interior)
10 feet (corner)
90 feet (interior) 50 feet
Minimum Lot Depth Varies1 200 feet 100 feet 100 feet 100 feet 120 feet 70 feet Minimum Front
Setback Varies1 20 feet 20 feet 20 feet 20 feet 15 feet 10 feet Minimum Side
Setback Varies1
15 feet
(corner)
10 feet
(interior)
5 – 20 feet3 5 – 20 feet3 5 – 20 feet3 5 – 15 feet3 5 – 10 feet5 Minimum Rear
Setback Varies1 20 feet 20 feet 20 feet 20 feet
10 feet (one
story)
15 feet (two
story)
5 feet
Maximum Height Varies1 25 feet 25 feet 25 feet 25 feet 25 feet n/a Maximum Lot
Coverage 40% 30%
50% (lots ≤7,200
sf)
40% (lots >7,200
sf)4
50% (lots ≤7,200
sf)
40% (lots 7,200-
10,000 sf)
35% (lots
>10,000 sf)4
40% 40% 50%
Off-Street Parking6 2 spaces
per unit
2 spaces per
unit 2 spaces per unit 2 spaces per unit 2 spaces per unit 2 spaces per unit 2 spaces per
unit + 1 space
per 5 units
Usable Open Space 300 sq. ft. per
unit
500 sq. ft. per
unit
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CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECOMMENDED FINAL page 6-10
1 Determined on a case-by-case basis through a slope/density formula. 2 Varies depending on access to City water and sewer. 3 Varies based on building height. 4 Additional lot coverage allowed for accessory dwelling units. 5 Varies depending on surrounding structures.
6 One additional parking space is required for each detached accessory dwelling unit and junior accessory dwelling unit built on a lot with a multifamily dwelling.

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CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECCOMENDED FINAL page 6-11
Table 6-3 provides residential development standards, in square feet, by commercial zoning district, TABLE 6-3 RESIDENTIAL DEVELOPMENT STANDARDS – COMMERCIAL ZONING DISTRICTS Development
Standard DC District CC District
Minimum Lot Area 5,000 square feet 5,000 square feet
Minimum Lot Width 30 feet 50 feet
Minimum Lot Depth None None
Minimum Front
Setback 0 feet / 20 feet1 10 feet / 20 feet1
Minimum Side
Setback
0 feet / 5 feet2 (interior)
0 feet / 15 feet2 (street
side)
0 feet / 5 feet2 (interior)
10 feet / 20 feet2 (street
side)
Minimum Rear
Setback 0 feet / 10 feet3 0 feet / 10 feet3
Maximum Height 30 feet / 25 feet4 30 feet / 25 feet4
Max. Lot Coverage 80 percent5 60 percent5
Max. Floor Area
Ratio6 2.0 0.8
Off-street Parking 2 spaces per unit 2 spaces per unit
1 Front yard setback distance increases if site is located directly across the street from a residential zoning district 2 Side yard setback distances increase if site is located directly across the street from a residential zoning district 3 Rear yard setback distance increases if site abuts or is adjacent to a residential zoning district 4 Maximum building height reduced when site abuts or adjoins a parcel in a residential zoning district 5 May be increased by use permit
6 The residential portion of mixed use development projects is excluded from floor area ratio calculation.

Parking
The Zoning Code prescribes minimum parking requirements for residential uses to minimize potential off-site impacts from overflow parking. One-family dwellings, multifamily dwellings and duplexes share the same parking requirement of two spaces per dwelling unit. These have not proved to be an impediment to housing development. Furthermore, parking is not required to be covered, which differs from the covered parking requirement of most jurisdictions. Additionally, the shared use of parking facilities is allowed for mixed usetype projects, which can reduce the number of overall required parking spaces.

The City code will be amended to address and remove potential constraints on project feasibility and any impediments to reaching maximum densities because of by off-street parking and loading requirements, especially for smaller unit types such has studio and one-bedroom units (see action A6.1-8).

Development Standards and Conceptual Development
The Zoning Code standards provide the framework for development for potential projects based on the Zoning District and projects can be designed around the applicable standards to achieve maximum base densities established in the General Plan.

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For a single-family development or single-family subdivision, a hypothetical project located in the R-1 or R-1- 10 zoning districts would consist of one single-family residence per lot, consistent with the height limits, setbacks, and other applicable development standards. A single-family subdivision would include interior residential lots that are a minimum of 6,000 square feet in the R-1 district and have a density of 4 to 10 units per acre with the Medium Density Residential land use designation. The land use and zoning designation represent many single-family properties. A 43,560 square foot (one acre) site could be subdivided into seven approximately 6,200 square foot single family lots.

For a multifamily development example, a hypothetical project located on a 10,890 square foot (0.25 acre) site with a High Density Residential (10-20 units/acre) land use designation and R-3 zoning designation can be developed with 5 units. It would also be under a 25 foot height limit and 40% lot coverage, in addition to accommodating setback, open space, and parking standards. The land use and zoning designation intends for higher density residential and could be found in proximity to the downtown area. The lot size is slightly larger than the minimum lot size. For such a development, the framework could conceptually allow for a two-story apartment with five approximately 700-800 square foot units, given a 25 foot height limit and 4,356 square feet (40 percent of the 10,980 square foot site) occupied by the building.

Larger residential developments are subject to the City’s affordable housing requirements under Chapter 17.08 of the Municipal Code, which would open up projects to eligibility for California Government Code 65915 (State Density Bonus law) density bonus units, waivers/exceptions, and incentives/concessions to facilitate development. Ownership projects with 20 or more dwelling units and rental projects of five or more units are required to provide inclusionary housing units: at least 20 percent of units would be affordable to moderate income households or at least 10 percent of units would be affordable to low income households. These percentages meet the minimum thresholds for use of State Density Bonus law provisions, which may allow for adding bonus units above the base density and reducing standards should they physically prevent the project from being built or create barriers to development.

Land Use Controls established in the General Plan and Zoning Code have allowed for predictability in determining housing type and density allowed. The cost of development is not affected by development standards beyond what applicants may reasonably expect for new development, including the expectation that the City would have some parameters for development such as height limits, setbacks, open space requirements, and parking requirements. Allowable housing type and amount of development can be determined by the land use designation and zoning designations. Housing affordability requirements are established clearly in the Affordable Housing requirements, Chapter 17.08 of the Zoning Code. New development is reviewed for compliance with development standards in the Zoning Code and consistency with General Plan policies.

Design review applies to new developments and findings of approval need to be made. Although the review process may increase the time and cost of development, a discretionary review process for new residential development is not uncommon as part of the development review process that allows the approval body to evaluate projects and determine that projects meet applicable standards and guidelines. Nonetheless, with the inclusion of objective development standards that would be prepared (Action A1.2-7) and more streamlined approval processes (Policy P6.1-1), the City aims to provide a more predictable and faster approval process for applicable residential projects. Applicants have not indicated that land controls represented a significant unexpected cost prohibiting development and achieving maximum densities.

Accessory Dwelling Units
Accessory dwelling units (ADUs) and junior accessory dwelling units (JADUs) are an affordable and efficient means of increasing the housing stock. Between 2017 and 2020, 11 ADUs were permitted, compared to zero ADUs permitted between 2013 and 2016. The number of ADUs is expected to substantially increase in the future due to state laws that reduce barriers to development and expedite the permitting process.

Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECCOMENDED FINAL page 6-13
The City has streamlined processing for accessory dwelling units by relaxing development standards and requiring all ADU applications to be ministerially reviewed per State Housing Laws. The City has eliminated parking requirements for ADUs and JADUs located on a lot with a single-family primary dwelling and reducing minimum rear and side setback requirements for newly constructed ADUs. Furthermore, the accessory dwelling is not counted towards the maximum density allowed by the General Plan land use designation that the unit is located on, and additional lot coverage allowances are allowed in certain zoning districts to accommodate second units.

There are a number of development standards included in Chapter 17.37 of the Zoning Code that could constrain their development. These requirements include, but are not limited to:
• Occupation by the property owner of either the primary dwelling or JADU • Maximum ADU floor areas are restricted to 1,000 square feet The Zoning Code allows the establishment of planned development districts in which the development standards may be specifically tailored to the project that is proposed, allowing design flexibility. Both the Palisades Apartments and La Pradera Apartments affordable housing projects have their own planned development districts.

Short-Term Rentals
The City prohibits the rental of homes for less than 30 days in all residential zones. This is intended to protect the City’s housing stock and preserve the neighborhood character. Violators will be required to pay a penalty and cease operations.

Processing and Permit Procedures
The Zoning Code states the type of residential uses permitted within the City’s residential and commercial zoning districts and specifies whether the use is permitted by right, requires administrative review, or approval of a use permit. Uses permitted by right are those that are allowed without discretionary review as long as the project complies with all development standards. Uses requiring administrative review are approved by the Planning and Building Director, which allows some flexibility on the part of the City to ensure basic health and safety, and general welfare concerns are met. Use permits are subject to approval by the Planning Commission.

Many uses subject to a use permit also require design review, which is processed concurrently with the use permit application. Findings for use permit and design review approval include that the project is consistent with the General Plan, the use is compatible with surrounding uses, meets certain design objectives, and addresses basic public health, safety, and general welfare concerns.

The time required to process a project varies greatly from one project to another and is directly related to the size and complexity of the proposal and the number of actions or approvals needed to complete the process.

Table 6-4 identifies general processing timeframes for various planning permits. It should be noted that projects do not necessarily have to complete each step in the process (i.e., small-scale projects consistent with the General Plan and Zoning Code would not require an environmental impact report, General Plan amendment, rezone or variance). It should also be understood that multiple applications for a project are usually processed concurrently.

The City has a consolidated and streamlined permitting process in order to expedite building and planning applications as much as possible. For example, most design review occurs at the administrative level and final maps are only considered at the City Council level. When a project requires rezoning or amendment of the General Plan, the City strongly encourages that those requests be processed concurrently.

Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECCOMENDED FINAL page 6-14
TABLE 6-4 GENERAL TIMEFRAMES FOR PERMIT PROCEDURES
Type of Approval Processing Time1 Review Body(ies)
Administrative Approval2 3 weeks Planning & Building Director Use Permit 4-6 weeks Planning Commission
Design Review 4-6 weeks Planning Commission
Variance 2 months Planning Commission
Parcel Map 3 months Planning Commission
Subdivision Map 6 months Planning Commission, City Council Environmental Review3
(Mitigated) Negative
Declaration 2 to 4 months Planning Commission
Environmental Impact Report 6 to 12 months Planning Commission 1 Assumes project is exempt from the California Environmental Quality Act (CEQA). 2 Includes administrative permits and administrative Design Review. 3 Estimate of additional processing time required to prepare review required by CEQA.

Design Review – Ministerial Review
Design review of proposed residential development is required in order to ensure conformance with the Calistoga General Plan, to promote high quality design and a harmonious relationship of buildings, to preserve the unique character and ambiance of Calistoga, to ensure compatibility of new development with existing development, and to promote the preservation of historic structures.

The Planning and Building Director is empowered to grant design review approval for one-family dwelling units and accessory structures in the RR, R-1/R-1-10, and R-2 Zoning Districts. Applications for permanent supportive housing in the RR, R-1/R-1-10, R-2, and R-3 Zoning Districts are also eligible for a streamlined ministerial review process. Following the amendment of the Zoning Code to permit navigation centers by-right in the DC Zoning District, navigation centers in this zoning district will also be subject to ministerial review.

Design proposals that are ministerially reviewed are not reviewed by the Planning Commission and the design review approval process typically takes approximately 4 weeks. Calistoga is not currently subject to streamlined ministerial review under SB-35 for residential developments as the City has met its prorated very low-, low-, and above moderate- income RHNA in the last Annual Progress Report.

Under the ministerial review process, proposed designs are evaluated for consistency with the following:
• Is in accord with all applicable provisions of the Zoning Code. • Is consistent with the City’s objective design standards.

Objective design standards are development standards that are clearly defined and involve no subjective judgement from public officials or City staff. They often include ratios, measurements, and other clear criteria.

Design Review – Planning Commission
The Planning Commission conducts design review for all other types of residential development applications.

Potential applicants are encouraged to submit their preliminary plans for review by City department representatives at no cost to the applicant, and/or the Planning Commission, for a nominal fee. The applicants obtain feedback that can be readily incorporated into the final project design.

Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECCOMENDED FINAL page 6-15
The design review process often results in an improved design that benefits both future project residents as well as neighbors. The Planning Commission includes an architect who can facilitate the non-design professional members’ understanding of project designs.

In approving a design review application, the Director or Commission must find that the proposed design:
• Is in accord with the General Plan and any applicable planned development. • Is in accord with all applicable provisions of the Zoning Code. • Is consistent with any adopted design review guidelines to the extent possible. • Will not impair or interfere with the development, use or enjoyment of other property in the vicinity or the area.

The design review approval process is typically completed within four to six weeks. Even the Calistoga Family Apartments project that required preparation of a mitigated negative declaration was recently approved within three months of the application’s initial submittal.

The review of project site plans, elevation drawings and landscaping plans is guided by adopted Residential Design Guidelines, which help facilitate projects through the review process by eliminating ambiguity in design expectations. They also promote both variation in design and compatibility with the desirable qualities of existing development. Manufactured homes located outside of mobile home parks are subject to the same design standards as conventionally constructed housing.

The multi-family design guidelines are intended to encourage designs that maximize common space, blend with the surrounding community, limit views of parking facilities from public streets, provide architectural compatibility of accessory buildings, and direct on-site lighting on driveways and walkways and away from adjacent properties. All of these standards are compatible with the typical design of recently constructed affordable housing projects. The Zoning Code and General Plan also provide guidelines for residential development that occurs in commercial areas and on hillsides in order to promote compatible design.

Use Permit for Multifamily Residential Development
Multifamily residential zones in the Downtown Commercial (DC) and Community Commercial (CC) zones require approval of a use permit. The need for a use permit in these areas would add to permitting and fees on new development, although the City does maintain multifamily as a use permitted by right in other areas (e.g., the R-3 zone). An application requiring a use permit would be subject to application fees and potentially longer review due to the public hearing process, which could increase costs and time for development. Some of the time and costs can be streamlined through the concurrent review with the design review associated with the project, which also require the preparation of public hearing materials and a public hearing. The use permit requirement has not been a constraint for multifamily development as application fees were not significant compared to the overall cost of a development and the use permit request is processed concurrently with design review for new construction with approval at the same public hearing. For example, the Silverado Terrace project over the previous Housing Element cycle was a 50-unit multifamily development with stacked flat and live-work units in the CC zone, which included entitlement requests for design review, use permits, and tentative map approval that were considered concurrently.

As many findings for use permit approval overlap with design review approval, the use permit findings would not present a significant additional barrier for approval beyond what is required for design review. The findings for approval of a use permit include 1) consistency with the General Plan, 2) consistency with the zoning code, 3) determination that the use would not impair or interfere with development, use or enjoyment of other Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECCOMENDED FINAL page 6-16
properties in the vicinity, 4) consistency with and enhancing Calistoga’s history of independently owned businesses, and 5) determining it is resident-serving in the case of formula businesses. The applicable findings for design review approval for new development share similar findings. They include: 1) consistency with the General Plan, 2) consistency with the zoning code, 3) determination that the use would not impair or interfere with development, use or enjoyment of other properties in the vicinity, and 4) consistency with design review guidelines.

Although the use permit requirement does not necessarily result in an additional major impediment for multifamily residential that otherwise also requires design review with comparable findings, the Housing Element includes actions that would improve predictability in project design and support findings of consistency with policies and regulations. Action A1.2-7 involves adopting objective design standards, and Action A5.3-1 requires consideration of objective design standards in proposed residential projects. Action A1.1-3 calls for evaluation General Plan objectives, policies, and actions for consistency with State law and amend as needed to ensure consistency with objective design standards and Housing Element objectives.

Building Permits
Upon submittal of a complete set of plans for a typical single-family residence, plan check is conducted, and a building permit is issued within approximately two to four weeks, and about four to six weeks for a typical multi-family plan check. The City sometimes contracts with a consultant for more complex plan checks in order to expedite their review; however, such plan checks are done on a time and materials basis to minimize the cost.

The permit process only increases in complexity and duration when the circumstances of individual projects warrant extra consideration on the part of staff and officials. This is especially true of the environmental review component of the process, yet the City of Calistoga has little flexibility to change this, since the California Environmental Quality Act specifies procedures that local jurisdictions must observe in reviewing the potential environmental impacts of development projects.

Growth Management and Senate Bill- 330 (SB 330)
Growth has been a significant issue in Calistoga for nearly three decades. The City’s Growth Management System was established as a regulatory mechanism for ensuring that population and employment growth is commensurate with the City’s ability to provide essential public services and facilities. The System has been designed to facilitate and implement goals and policies contained in the Calistoga General Plan. Its primary objectives included:
• Prioritize projects with housing that is affordable to lower-income households. • Promote infill development over new development at the edges of town. • Reduce dependency on the automobile by providing a mix of housing types in areas located close to services, transit and City parks.
• Provide a balance of residential and non-residential growth to ensure the community’s unique quality of life and economic well-being.

Consistent with the General Plan, the Growth Management System is based on an annual growth rate of 1.35 percent. Based on Calistoga’s average household size, the 1.35 percent growth rate equates to approximately 28 new units annually. The City’s Regional Fair Share Housing total allocation of 119 units for the 2023 - 2031 planning cycle.

Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECCOMENDED FINAL page 6-17
Under SB -330, jurisdictions are prohibited from imposing a housing cap in order to reduce minimize barriers to new housing. This prohibition on housing caps is effective until January 1, 2030. Consequently, the Growth Management System is currently suspended and policies and programs implementing the Growth Management System have been removed from the Housing Element.

When SB -330 expires, the City will have the option to reinstate the Growth Management System, which would be implemented through an annual allocation process. Preference for residential allocations is generally given to projects that include one or more of the following:
• The majority of a project’s deed restricted units count towards fulfillment of the City's remaining regional housing need in the very low-, low-, and moderate-income housing categories • Housing for moderate-income households
• Housing proposed as part of a mixed-use development project • Housing proposed on vacant, underdeveloped or redeveloped land with necessary public infrastructure in place
• Housing for special need housing groups or populations Allocations are not required for the following types of development:
• Second dwelling units
• Dwellings that are replaced, including mobile homes or an approved mobile home site • Select developments that the City has entered into a development agreement with • The construction of a single-family residence on an existing lot of record • Minor subdivisions that include a maximum of three lots in total where not more than two lots have been newly created
• Intensification of existing uses, a mixed use, a change of use, or additions to existing structures that result in an increase in floor area of no more than 10 percent Fees and Other Exactions
Water and Sewer Upgrades
According to the City’s Infrastructure Element (2020) of the General Plan, there are adequate water supplies to support future development. Future projects include continued maintenance of the aging water distribution infrastructure and pursuing opportunities to increase water supply sources, such as the expansion of the recycled water program, construction of wells with wellhead treatment outside of the City limits, expansion of the water treatment plant, improved peak delivery, banking water from the California State Water Project (SWP), and increased water use efficiency.

The City’s wastewater collection faces challenges relating to the age of the infrastructure. The Infrastructure Element directs the City to prepare a wastewater master plan and identifies a range of improvements, including development-level installations and upgrades such as grease interceptors to reduce discharge into the treatment system.

Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECCOMENDED FINAL page 6-18
The City has a strong stormwater pollution prevention program. The City is required by state law to trap particles that are five millimeters or larger in runoff water before they enter the stormwater system. Systems to capture particles are currently being installed through development projects. The City plans to prepare a master plan of the storm drainage system to identify improvements. Additional upgrades to the system include general maintenance and replacement of drainpipes and the installation of new drainpipes and inlets on Spring Street between Myrtle Street and the Napa River.

For a complete list of planned and completed water and wastewater capital improvement projects from 2021 to 2031, refer to Appendix D and E.

Development Impact Fees
The impact fees generate funding for capital facilities and equipment investments associated with the police, fire, cultural/recreation, City administration, and transportation functions. These one-time charges on new development are used to cover the cost of capital equipment and facilities that are required to serve new growth.

The fees are typically collected upon issuance of a building permit, though in some cases on issuance of a certificate of occupancy or final inspection. While these fees may affect housing prices, the only alternatives would be their payment by existing Calistoga taxpayers or no further residential development, neither of which is feasible.

The City Council elected to adopt fees below the maximum supportable level, in part to avoid deterring development in the community. They are similar to those of similar communities in the vicinity. The fees are based on the estimated reasonable costs of providing the services and the construction, reconstruction and maintenance of the related facilities, which were derived from a detailed analysis and projections regarding the City’s system costs, improvements and revenue needs. As of 2022, the City is working to update its development impact fees and the General Plan maintenance fee.

ADUs are exempt from utility connection fees unless the ADU is constructed with a new single-family dwelling.

JADUs and ADUs less than 750 square feet are exempt from impact fees. ADUs that are 750 square feet or larger will be charged an impact fee proportional to the unit’s size. Exempting JADUs and ADUs from utility connection fees has reduced barriers to building second units and has stimulated the growth of ADU development in the City.

Processing and Permit Fees
Generally, the fees associated with processing planning and building permit applications are consistent with other communities. All development impact and processing fees are publicly published on the City’s website.

Table 6-5 summarizes development fees, including impact, processing, and permit fees. Table 6-6 identifies these fees as a percentage of development costs. For a typical 2,000-square foot detached home, development fees would be approximately 13.3 percent of total cost. For a 5-unit multi-family apartment building, development fees would be approximately 13.9 percent of the total per unit cost. For a 750-square foot accessory dwelling unit, the development fees consist of approximately 14.1 percent of the total estimated unit cost. The per unit fee portion as a percentage of total cost for new single-family and multi-family development is relatively low compared to other jurisdictions in the county.

The City Council has the authority to reduce development fees for affordable housing developments.

Refer to the City website for the City’s current zoning map, development standards, and a complete list of fees associated with development.

Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECCOMENDED FINAL page 6-19
TABLE 6-5 ESTIMATED RESIDENTIAL PROCESSING AND PERMIT FEES (2021) Cost Category SingleFamily2
MultiFamily3
Accessory
Dwelling
Unit4
Agency Fees
Paid To Notes
Planning
Entitlements1 $850 $500 --
Planning &
Building
Department
Development Impact
Fees $79,062 $66,879 $16,928
City Administrative $3,078 $2,622 $1,708
Cultural/Recreational $7,105 $6,053 $3,943 Public Works Excise Tax $125 $125 $125
Fire $2,593 $2,209 $1,439 Fire
Police $689 $586 $382 Police
Transportation $11,299 $7,006 $6,271 Public Works
Wastewater $27,812 $27,316 -- Public Works
Water $18,201 $15,862 -- Public Works
School $8,160 $5,100 $3,060
Calistoga Joint
Unified School
District
$4.08/ square
foot for
residential
development
Building Permit / Plan
Review $12,000 $8,000 $2,600 Planning & Building
Total Cost per Unit $91,912 $75,379 $19,528 1 Includes cost of design review on a per unit basis 2 Based on a 2,000 square foot home having a valuation of $600,000 3 Based on a 3-bedroom apartment in a 5-unit complex 4 Based on a 750 square foot ADU. JADUs and ADUS less than 750 square feet shall not be charged any impact fees, and JADUs and ADUs less than 500 square feet are exempt from school impact fees. Utility connections fees shall not be charged for ADUs unless it is constructed at the same time as a new single-family dwelling. Utility connections are also not required for JADUs or ADUs created by converting existing space.

TABLE 6-6 DEVELOPMENT FEES AS PERCENTAGE OF DEVELOPMENT COSTS Single-Family3 Multi-Family4 Accessory
Dwelling Unit5
Total estimated cost per unit1 $691,912 $543,260 $164,528 Fee portion of cost per unit2 $91,912 $75,379 $19,528
Percentage of total development
cost

13.3% 13.9% 11.9%
1 Includes land, design and construction, permits, fees and other costs 2 From Table 6-5 3 Based on 2,000 square foot home having a valuation of $600,000 4 Based on a 3-bedroom apartment in a 5-unit complex 5 Based on a newly constructed 750 square foot detached ADU that is built at a different time than the dwelling Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECCOMENDED FINAL page 6-20
Inclusionary Housing Program
The cost of land and its relatively limited availability within the City create market conditions that make it difficult for the for-profit private sector to produce housing that is affordable to moderate- and lower-income households. In the interest of facilitating development of housing that is affordable at these income levels, the City requires certain residential projects to contribute to the production of affordable housing within the City.

Under the inclusionary housing requirement, residential ownership projects consisting of five to 19 units shall pay an in-lieu fee to the Affordable Housing Fund, which is used for the construction and preservation of housing affordable to very low-, low-, and moderate-income households. Residential ownership projects that consist of 20 or more units and rental projects of five or more units must either deed restrict a minimum of 20 percent of the units in the project at a cost affordable to moderate-income households or provide a minimum of 10 percent of the project’s units at a cost affordable to low-income households. Alternatives to the 20 percent on-site inclusionary requirement, such as payment of in-lieu fees, dedication of land, provision of off-site inclusionary units, or other equivalent action that would provide a comparable or superior benefit to the onsite requirement, may be considered by the City Council.

Developers must enter into an agreement with the City that sets forth the provisions of affordability for the project before the issuance of a building permit or the approval of a final map if the project involves a division of land. Inclusionary housing requirements for residential (or commercial) development projects for which a development agreement has been entered into with the City are negotiated as a term of the development agreement.

Under the auspices ofThrough the inclusionary housing requirements, the City negotiated the dedication of land (now developed with the Palisades Apartments affordable housing project), construction of on-site housing units, and agreements that resulted in the payment of several million dollars of in-lieu housing fees.

These fees are deposited into the City’s Affordable Housing Fund and may be used to subsidize the development of affordable housing. In 2017, these fees were used to fund the Calistoga Senior Apartments, which provided 30 low-income units for seniors, including 23 very low-income units.

Action 2.1-7 requires the City Conduct an Inclusionary Housing Nexus Study and engage with the local development community and affordable housing advocates to evaluate the Inclusionary Housing Ordinance and in-lieu fee requirements for effectiveness in providing affordable housing under current market conditions.

Affordable Housing Incentives
In addition to the incentives provided under California State’s density bonus (Government Code Section 65915), the City may grant an additional density bonus. City Council may also decide to grant additional financial incentives to make a qualifying project economically feasible, such as subsidies for infrastructure improvements or development fees, and/or City sponsorship of mortgage bond financing.

Codes and Enforcement
The City has adopted the California Building Standards Code and all of the appendices, including Appendix Q:

Tiny Houses, in 2019. The City may adopt amendments to the State Code where local conditions warrant more-restrictive regulations. In the case of Calistoga, climatic, geographical, and topographical conditions justify a more restrictive Fire Code, such as the following requirements:
• Illuminated or reflective address numbers
• Automatic fire sprinkler systems for all one- and two-family dwellings regardless of square footage as well as for certain building additions, alterations, repairs, and changes in occupancy Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECCOMENDED FINAL page 6-21
While code requirements might increase the cost of providing housing, they also provide an important safeguard for the local population, particularly given more frequent wildfire events in the surrounding areas.

The City enforces its codes on a “complaint basis.” Code enforcement is the responsibility of the Planning Department and the Building Official. While the enforcement of building and housing codes could conceivably reduce the number of units and increase the cost of housing, code enforcement provides a public benefit in that it ensures that housing is safe and sanitary. This is especially important for low-income households who may not have the option of moving elsewhere if the housing they live in is not maintained.

On- and Off-Site Improvements
The Subdivision Ordinance requires a subdivider to provide the following infrastructure and improvements:
• paved streets
• concrete curbs and gutters
• street name and traffic control devices
• street trees
• sanitary sewage collection and pumping system
• water distribution and fire protection systems
• storm water drainage systems
• undergrounded utility lines
• fences and landscaping along the rear of lots backing onto streets or highways • parkland
Developers may also be required to provide off-site improvements necessary for the general health, safety, and welfare. In some instances, off-site improvements may be reimbursed using connection fees that have been collected from other projects, or by establishing a reimbursement fund that subsequent developers in the area pay into.

The local street width standard is two travel lanes and two parking lanes. Sidewalks may be required along nonrural streets and highways. With sidewalks and easements, total right-of-way width is a minimum of 56 feet, although it is wider in some areas. This design is intended to adequately accommodate traffic, parking, pedestrians, and drainage. These standards may be modified if warranted by individual circumstances, and therefore are not a constraint on development.

The extent to which these improvements are required varies according to the size, type, and intensity of the proposed development and capacity and availability of offsite utilities. Moreover, these requirements are typical of those in similar communities, and necessary for the health and welfare of those living in the subdivision or to mitigate impacts on the surrounding community. Many of the requirements, such as those for street paving, street name signs, and traffic control signs, have little impact on housing construction since the street network is already completed in most areas of the City.

Submit a water and sewer allocation study comparing project with existing baseline. Purchase additional allocation(s) of water and/or wastewater as necessary.

Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECCOMENDED FINAL page 6-22
Water and Sewer Improvements
Conditions of approval for water and sewer improvements are prepared on a case-by-case basis. The City requires projects to ensure water distribution and sewer collection systems can support new development. All developments are required to prepare a water/sewer demand study and purchase additional baselines as necessary. Projects are typically required to establish a water and wastewater baseline for the property with the City.

To establish sanitary sewer capacity, the applicant may be required to include the following interventions in the project prior to approval:
• Providing evidence that the sewer lateral is structurally-sound and correctly sloped by videoing the sewer lateral with a Public Works employee present and providing the City with a copy of the video. • Providing oil/grease interceptors.
• Designing sewer grades such that ultimate finish floors are a minimum 12 inches above upstream manhole or clean out rim elevations. Inadequate elevation differentials or grade on private laterals, as determined by the City, must be mitigated by either raising finish floor elevations or installing privately-owned and operated sewer lift stations with grinder/ejector pumps on site. • Connection to the City’s sewer if the development is within 200 feet of public sewer main (CMC 13.08.140). • All existing wells, septic tanks and associated pipelines shall be abandoned per abandonment permit from Napa County Environmental Health.
• All trench cuts within public paved roads shall be replaced per City of Santa Rosa Standard 215. • Improving offsite sewer infrastructure to meet the new demand.

The City’s typical conditions of approval regarding water requirements include the following:
• Water laterals meter and backflow device shall be per City of Santa Rosa Standard 874. • If fire sprinklers are required, possible upsizing of the water lateral and meter may be required along with the fire sprinkler hydraulic analysis. The new combination water service connection shall follow City of Santa Rosa Standard 870 and include three-way valving at the existing main point of connection. The project must also request or pay for fire hydrant flow information to run the required analysis with. • The applicant or owner is responsible for hiring and paying for their own fire consultant and paying for any lateral replacement that is required to meet fire pressure and flows required by the sprinkler system.

The fire sprinkler consultant will need to compute all hydraulics throughout the on-site fire sprinkler system, including elevation losses in the lateral line from the main in the street through the lateral pipe, meter, and backflow devices. Also, most residential water laterals are not large enough to provide adequate flow/pressure for sprinklers and have to be enlarged to accommodate this. It is good practice for the fire consultant to run on-site flow/pressure tests to determine existing hydraulics on the property and investigate the lateral size by potholing and measuring to confirm existing conditions prior to running any calculations.
• The City owns the water laterals to the meter. Provide field measurements of the lateral and meter sizes, and an on-site flow test.
• All new water meters shall be radio-read Badger meter(s) and called out as such on plans.

Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECCOMENDED FINAL page 6-23
• Developments shall connect to City water main if it is within 1,000 LF (CMC 13.04.170). • All new water laterals shall be made of polyethylene SDR 9 (200psi minimum) materials; copper is not allowed. Existing laterals shall be replaced with polyethylene SDR 9 (200psi minimum) materials. Per Santa Rosa Standards, #12 wire tracer wire shall be installed along all polyethylene pipes. • All trench cuts within public paved roads shall be replaced per Santa Rosa Standard 215. • Improve offsite water infrastructure to meet the new demand.

Constraints to Housing for the Disabled
This section provides an analysis of governmental constraints on the development, maintenance, and improvement of housing for persons with disabilities. Calistoga’s Zoning Code defines family as “one person living alone, or two or more persons occupying a dwelling unit and living together as a single housekeeping unit that is characterized by the following: (A) Shared use of a single common kitchen; (B) Shared household expenses; (C) Shared use of a common entry to the dwelling unit; (D) Shared use of all or virtually all areas of the dwelling unit at all times; and (E) Occupation of the unit under a single lease if the unit is not occupied in part by the owner.” This definition is consistent with state law and does not distinguish between related and unrelated persons nor does it impose a numerical limitation on the number of people who constitute a family.

Consequently, this definition does not have the effect of discriminating against the siting of group homes for people with disabilities.

The City code will be amended in order to ease constraints to housing for the disabled (see Action A6.1-10).

These amendments will:
• Allow for residential care facilities of six or fewer people to be regulated in the same manner as a singlefamily dwelling unit in all zones, including Specific Plan areas, where single-family dwelling units are allowed.
• Revise 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.

Reasonable Accommodation
According to Section 17.60.070 of the Municipal Code, a written decision to grant or deny a request for reasonable accommodation must be consistent with fair housing laws and shall be based on the following findings: 1) The Housing which is the subject of the request, will be used by a disabled person under fair housing laws; 2) The request for reasonable accommodation is necessary to make specific housing available to a disabled person under fair housing laws; 3) The requested reasonable accommodation will not impose an undue financial or administrative burden to the City; 4) The requested reasonable accommodation will not require a fundamental alteration in the nature of a City program or law, including but not limited to land use and zoning, and; 5) The requested reasonable accommodation will not result in a direct threat to the public health or safety of other individuals or substantial physical damage to the property of others.

As described above, the City facilitates permit processing for all types of housing and retrofit efforts through its rapid processing times for most housing projects. In addition, most retrofit improvements for accessibility, such as installation of ramps, do not require design review, and are only subject to inspection for building permit approval in order to ensure safety compliance. To keep in conformance with State ADA requirements, the City adopts the California Building Standards Code every three years and amends local code provisions as Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECCOMENDED FINAL page 6-24
needed. In addition, the City has established a Building Standards Advisory and Appeals Board to hear and decide on disabled access issues as they relate to Building Code provisions specific to unreasonable hardships.

As further described above, no specific limitations or restrictions are contained in the Zoning Code concerning special needs housing, as they are allowed by right in all residential zones. Additionally, the Zoning Code provides for the approval of requests for reasonable accommodation by the Planning and Building Director. A request for reasonable accommodation may be made by any disabled person when the application of a zoning law or other land use regulation, policy, or practice acts as a barrier to fair housing opportunities. A request for reasonable accommodation may include a modification or exception to the rules, standards and practices for the siting, development and use of housing or housing-related facilities that would eliminate regulatory barriers and provide a disabled person equal opportunity to housing of their choice. If an applicant needs assistance in making the request, the Planning and Building Department endeavors to provide the assistance necessary to ensure that the process is available and expedient for the applicant.

The submittal and review process for a reasonable accommodation request is a staff level review under the Planning and Building Division, unless the application is associated with another entitlement request requiring a higher level of review. As a staff level review, the application review would not be a significant hinderance in terms of processing. Moreover, the reasonable accommodation procedures in the Zoning Code specifically exclude any required noticing or public hearings, which expedites required processing time. An applicant may submit a request for reasonable accommodations as an application through the Planning Division. The application would include applicant and owner information, property address, use of the property, claim of disability under fair housing laws, accommodation from policy or regulation being sought, explanation of why the accommodation is necessary, and other information that may be necessary to facilitate proper consideration of the request. Application fees are the same as those for a minor conditional use permit (or an administrative review use permit); the base fee for an administrative review use permit was $850 as of the latest fee schedule.

Fees cover the costs needed for time spent processing and reviewing applications.

The approving authority will issue a written decision to grant or deny a request for reasonable accommodation consistent with fair housing laws and based on consideration of the following findings:

1. The housing, which is the subject of the request, will be used by a disabled person under fair housing laws;

2. The request for reasonable accommodation is necessary to make specific housing available to a disabled person under fair housing laws;

3. The requested reasonable accommodation will not impose an undue financial or administrative burden on the City;

4. The requested reasonable accommodation will not require a fundamental alteration in the nature of a City program or law, including but not limited to land use and zoning; and

5. The requested reasonable accommodation will not result in a direct threat to the public health or safety of other individuals or substantial physical damage to the property of others.

The findings (1 and 2) for approval allow for the granting of necessary requests to make housing available to persons covered under fair housing laws. The findings (3, 4, and 5) also provide for changes reasonable for personal accommodation, which should consist of minor exceptions to certain general development standards on a site. As such, a request should be minor in nature and reasonably be able to meet the findings that proposed modifications would not impose undue burden on the City, fundamentally change City programs or laws, or create a threat to public health and safety. The approving authority may impose any conditions of approval deemed reasonable and necessary to ensure that the reasonable accommodation will comply with the findings.

Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECCOMENDED FINAL page 6-25
Reasonable accommodations follow the same appeals process as other Planning applications should the appeal of a determination be sought.

The City will review and reduce its fees for requesting reasonable accommodation by October 2025 to ensure the process does not act as a constraint on persons with disabilities (see action A6.1-9).

Non-Governmental Constraints
Non-governmental constraints are those that are not created by a local government but may be alleviated or reduced through government actions.

Construction Costs
Housing prices are influenced partly by the types of construction materials used. Homes in Calistoga are generally of wood frame construction and finished with stucco or wood siding. This type of construction is the least-expensive conventional method (brick, stone and concrete block are more costly). Composition shingle and built-up roofs, which are found on a large share of the community’s homes, are also the least expensive, followed by wood shingle, wood shake, concrete tile, metal tile and clay tile.

The cost of lumber and wood products accounts for approximately one-third of the costs of materials used to build a home. The Covid-19 pandemic caused large fluctuations in the cost of lumber. Prior to the pandemic in 2020, lumber cost approximately $350 per thousand board feet. At its peak, lumber cost $1,514 per thousand board feet in May 2021, but has decreased to $770 per thousand board feet in July 2021.1 This high cost of lumber adds tens of thousands of dollars to the cost of constructing a new home. Although lumber prices demonstrate a downward trend of returning to pre-pandemic prices, current lumber costs are still approximately 80 percent more expensive than they were in early 2020.

Labor costs are the single biggest expense in a home’s construction after land. Over the long term, direct construction costs (including materials and labor) have decreased as a proportion of total costs due to a dramatic drop in the number of person-hours required to construct a unit, and the use of less-skilled (and therefore, lower-paid) workers because of a greater use of prefabricated materials.

The City can minimize construction costs by not requiring more costly kinds of building materials on residences, such as clay tile roofs. However, there is little within the City’s power to affect the cost of skilled labor and building materials.

In 2021, the construction cost of a 2,690 square foot single family home in Calistoga had a valuation of $400,000 and an 11,500-square foot townhome development with six units had a valuation of $1.34 million.

Land Costs
Approximately 25 percent of housing costs are attributable to land costs in most real estate markets. A major component of this cost is land speculation. Land costs are also affected by such factors as zoning density, the availability of infrastructure, the existence or absence of environmental constraints, and the relative amount of similar land available for development.
1 Fastmarkets Random Lengths
Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECCOMENDED FINAL page 6-26
Land costs in Calistoga vary depending on the size of the parcel and its location. A 20,958 square foot unimproved lot zoned as R-3 located near Downtown Calistoga was sold for $915,000 in 2019. The property already had water and sewer services available. A 19,182 square foot vacant lot zoned as R-R was sold for $599,000 in 2021.

Financing Costs
Financing costs can pose additional barriers to housing development. Securing loans for first-time homebuyers as well as loans to finance construction can limit the ability of prospective homeowners to purchase a home.

Home Financing
Mortgage credit is difficult to obtain for most first-time buyers and the recent tightening of underwriting standards also hinders the ability of households at the low and middle tiers to move up.

Mortgage rates are currently at historic lows. Besides lowering monthly interest payments for buyers, low interest rates allow existing homeowners to refinance their homes, thereby lowering monthly housing costs and perhaps preserving their ownership status.

In federally designated, high-cost counties, which includes Napa County, conventional and FHA loan limits have been increased to $816,500 for one living-unit homes as of 2021 to assist homebuyers. In the past, mortgages for homes more expensive than what is covered by a conventional conforming loan, commonly known as “jumbo loans,” were more difficult to obtain, even for well-qualified buyers. However, jumbo loan rates are often competitive and can be lower than conforming loans. Lenders are currently offering rates that are on average half a percentage point lower than those on the conforming loans backed by Fannie Mae and Freddie Mac and are increasingly holding these jumbo loans on their books as a revenue enhancer. As the Federal Housing Finance Agency, which regulates Fannie and Freddie, seeks to boost the two agencies' reserves against losses from mortgage defaults, it has raised fees and other costs for borrowers. Since Fannie and Freddie don't back jumbo mortgages, those fees don't apply and therefore aren't passed on to borrowers.

The City of Calistoga assisted 27 low- and moderate-income first-time homebuyers in purchasing homes in the Palisades, Emerald Oaks, and Silverado Place Subdivisions by providing each buyer with a “silent second” mortgage to close the gap between the appraised value of the homes and the price affordable to the particular household. A deed restriction was recorded on each property that required the City be provided with an option to purchase the home in the event of re-sale in order to try to keep the homes in the community’s affordable housing inventory.

Many major financial institutions and mortgage lenders that finance housing have offices in nearby cities.

Homes sales are occurring in all parts of the community, and there is no evidence of mortgage-deficient areas in the community for new construction or rehabilitation loans.

The ability to accumulate a down payment is a formidable barrier to many potential homebuyers. Low-income households find it difficult to make the transition from rental to ownership units because they cannot accumulate a down payment while renting. Similarly, very low-income households may be unable to obtain rental housing because they cannot accrue the necessary security deposits and first and last months’ rents.

Construction Financing
Overall, construction financing usually represents a small portion of total housing costs. Financing costs for construction are affected partly by how early in the development process loans must be taken out and how long the loans must be carried. Project delays can increase total interest payments, as well as create greater financial Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECCOMENDED FINAL page 6-27
risk for a project. Construction financing for higher-density in-fill projects is generally harder to obtain than for conventional single-family construction.

Approval Times
The length of time between a project’s approval and building permit issuance in many cases is determined by the applicant. The range of time between entitlements and building permits typically ranges from 6 months to 18 months for projects developed in the City of Calistoga. The average time between entitlements and building permit approval is roughly typically ranges from 9 to 24 months.

Densities
In some cities, new development projects on vacant and underutilized land may be proposed at densities that are well below what is allowed by zoning. This may be a reflection of the real estate market, developer and builder preferences, environmental conditions, or regulatory constraints that make it difficult to build the allowable number of units. This has not been an issue in Calistoga.

The City has taken a number of steps to ensure that its land supply is used efficiently, including requiring that projects be developed within the density ranges set by the General Plan. Single family detached homes are not permitted in most of the higher density districts, including commercial zoning districts where housing is allowed.

The site inventory uses minimum density – 10 du/ac – to calculate realistic capacity assumptions. Recent development proposals – captured in Table 5-4 (Pipeline Projects) are much higher. Silverado Terrace has a projected density of 26 du/ac (130 percent of the maximum density allowed of 20 du/ac) and 1855 Lincoln Avenue has a projected density of 26 du/ac (135 percent of the maximum density allowed of 20 du/ac). There have been no other residential developments in areas that allow non-residential development in the past 10 years.

Community Acceptance of Residential Development
Public resistance to residential development proposals, especially affordable, multi-family and/or in-fill projects, can result in lengthy and expensive review processes as well as the loss of potential units. In general, Calistoga residents are accepting of development if such concerns as privacy impacts, additional traffic, and contributions to the City’s small-town character are addressed. There were no requests from any developers to develop at densities below those identified in the City’s 5th Cycle Housing Element.

Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECOMMENDED FINAL page 7-1
CHAPTER 7: ENERGY CONSERVATION
State law requires that Housing Elements identify opportunities for energy conservation. New residential development is an opportunity to address statewide and local energy efficiency goals. Integrating energy conservation standards into new housing can reduce energy costs for buildings in the long run and also reduce the City’s housing stock’s impact on the environment. The use of green building strategies can reduce energy usage through energy and water efficient design practices and appliances. Encouraging or requiring new development to source energy from renewable sources is another strategy for creating greener, more energyefficient buildings.

Energy Conservation Initiatives
New homes and residential additions are subject to the California Building Code, which includes stringent energy efficiency requirements under Title 24, Part 6: California Energy Code, 2022 and Title 24, Part 11:

California Green Building Standards Code, 2022. In December 2022, the Calistoga City Council directed City staff to formulate recommendations for Municipal Code (Title 15) amendments in 2023 related to enhanced energy “reach” codes aimed at reducing greenhouse gas emissions.

Landscaping projects that are 500 square feet or larger are required to conform to the state’s water-efficiency landscape standards, which also minimizes the amount of energy required for water transport and irrigation.

The City has not adopted any restrictions on the design or placement of photovoltaic energy systems (i.e., solar panels) on residential property in order to encourage their installation. Additionally, as per Assembly Bill 178, residential construction built between January 1, 2020 and January 1, 2023 that is intended to repair or replace a residential building destroyed as the result of a disaster is only required to comply with photovoltaic requirements in effect at the time of the original building’s construction. The replacement or repaired building is not required to comply with any additional or conflicting photovoltaic requirements at the time of replacement.

Opportunities for improving energy conservation in the design of residential development include ensuring the consistency of tentative tract maps with Section 66473.1 of the Subdivision Map Act, which requires the designs of subdivisions to provide for future passive or natural heating or cooling opportunities. The City also requires the planting of trees along streets and in parking lots to reduce heat island effects.

To encourage energy efficiency improvements to the City’s existing housing stock, the City has joined the CaliforniaFIRST and California Home Energy Renovation Opportunity (HERO) Programs that allow residential property owners to finance the installation of energy- and water-efficient improvements, and renewable energy systems. Both programs are Property-Assessed Clean Energy (PACE) Programs, which allows the property owners to pay the loans back as a line item on their property tax bill.

Additionally, the HOME grant that the city recently received for owner-occupied residential rehabilitation will require each of the rehabilitated homes to be upgraded to meet the current state energy code.

Calistoga joined Marin Clean Energy’s (MCE) Community Choice Aggregate program in 2018. Through this program, PG&E customers in Calistoga have the option of purchasing their electricity from renewable energy sources. PG&E customers are automatically enrolled in MCE’s Light Green 60% Renewable Energy service, which provides customers with 100 percent carbon-free energy, including 60 percent from renewable energy sources.

Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECOMMENDED FINAL page 7-2
The City has initiated an extensive water conservation effort that will have the added benefit of reducing the energy used for water transport. The program offers rebates for residential toilet and washer replacement with water-efficient models and turf replacement with low-water use landscaping or artificial turf. Free residential water audits of both homes and landscaping are offered and kits containing water conservation devices, such as low-flow shower heads and faucet aerators, are distributed.

Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECOMMENDED FINAL page 8-1
CHAPTER 8: HOUSING POLICIES AND PROGRAMS
Objective H-1.1 Ensure that an adequate amount of land is available for residential development for all economic segments of the community and to meet the City’s regional share of housing needs.

Policies
P1.1-1 Maintain a supply of residentially-designated land at appropriate densities that is adequate to accommodate Calistoga’s share of the regional housing need and accommodate projected housing needs.

P1.1-2 Encourage the development of housing in combination with commercial uses.

P1.1-3 Encourage the development of housing where public services are available.

P1.1-4 Ensure the location and construction of new development minimizes wildfire risk, including through fire hardening design strategies.

Actions
A1.1-1 Amend Zoning Code to provide that the City shall not change the general plan or zoning designations with respect to land where housing is an allowed use to a less intensive use, in order to maintain supply of residentially designated land at higher densities, unless there are corresponding changes to create no net loss in residential capacity.

Time Frame: Within two years of Housing Element certification.August 2025 Responsible Entities: Planning and Building Department, Planning Commission, City Council A1.1-2 Ensure that any amendments to the Housing Element or other General Plan elements maintain internal consistency within the General Plan as a whole.

Time Frame: Ongoing
Responsible Entity: Planning and Building Department, Planning Commission, City Council A1.1-3 Evaluate General Plan objectives, policies, and actions for consistency with State law and amend as needed to ensure consistency with objective design standards and Housing Element objectives to encourage housing.

Time Frame: Within two years of Housing Element certification August 2025 Responsible Entity: Planning and Building Department, Planning Commission, City Council Goal H-1 Maximize opportunities for the development of housing to accommodate anticipated growth and facilitate mobility within the ownership and rental housing markets.
* REFERS TO ACTIONS AFFIRMATIVELY FURTHING FAIR HOUSING (x13) Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECOMMENDED FINAL page 8-2
Objective H-1.2 Make effective use of residential development sites.

Policies
P1.2-1 Maximize the efficiency of residential development.

P1.2-2 Promote the development of accessory dwelling units (ADUs) on lots with single-family residences.

P1.2-3 Accommodate alternative types of housing (e.g., shared housing, clustered housing, co-housing, cottage-style housing, and non-profit housing co-operatives) in areas designated for medium- and high-density residential development and commercial uses.

P1.2-4 Accommodate a diverse range of housing types, including single-family homes, townhomes, apartments, duplexes/triplexes, and condominiums to meet the varied needs of residents.

P1.2-5 Promote opportunities for the development of workforce housing, which serves workers who make moderate incomes from 80 to 120 percent of area median income (AMI).

Actions
A1.2-1 Amend Zoning Code to specify minimum residential density no less than 50 percent of the maximum number of dwelling units prescribed by the General Plan, subject to conformance with the City’s design guidelines and all applicable General Plan policies.

Time Frame: Within two years of Housing Element certification August 2025 Responsible Entities: Planning and Building Department, Planning Commission, City Council *A1.2-2 Amend Zoning Code’s regulations for accessory dwelling units (ADUs) pursuant to AB 671 to encourage their development. The amendment shall include , such as incentives to build and to rent out accessory dwelling units to lower income community members and local workers.

Incentives include:
a. Streamlining processing procedures for ADU to ensure applications are processed within a maximum of 60 days.
b. Promote pre-approved ADU plans to prospective ADU applicants. Pre-approved plans can come from the Napa/Sonoma Collaborative. Use of these plans will reduce upfront costs to the applicant and reduce processing times.
c. Modify ADU development standards (such as size, front setbacks, parking, height, and fee reductions) to be less restrictive than state law.
d. Consider providing reduced fee rates for ADUs that are deed-restricted to lower-income households not related to the resident of the primary dwelling. a.e. Monitor ADU production to ensure that Housing Element objectives (3 units per year for 24 total ADUs) are met.

Time Frame: Within two years of Housing Element certificationAugust 2025 for a through d; e is ongoing
Responsible Entity: Planning and Building Department, Planning Commission, City Council A1.2-3 The City will track new accessory dwelling units to collect information on the use and affordability of these units. Halfway through the planning period (2027), if it is determined these units are not meeting a lower-income housing need, the City shall ensure other housing sites are available to Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECOMMENDED FINAL page 8-3
accommodate any unmet portion of the lower-income RHNA. Establish cooperative arrangement with the Housing Authority of the City of Napa (HACN), Napa/Sonoma Collaborative, and other non-profits to educate homeowners on accessory dwelling units and encourage increased construction. Consider amending CMC Chapter 17.37 to include provisions less restrictive than state law requirements. (Examples for Council to consider: size, front setbacks, parking, height, fee reductions, etc.)
Time Frame: Within two years of Housing Element certificationOngoing Responsible Entity: Planning and Building Department
*A1.2-4 Amend the Zoning Code to permit adaptive reuse (for long-term housing) of inns, motels, housing cooperatives and non-storefront ground floor commercial space in residential and commercial zones.

Time Frame: Within two years of Housing Element certification August 2025 Responsible Entity: Planning and Building Department, Planning Commission, City Council *A1.2-5 Conduct two public workshops with homeowners on the viability of long-term rentals of vacation homes or second homes (not legally transient commercial occupancy) as a housing solution to accommodate workforce housing. Invite restaurants, hotels, and other hospitalityrelated companies to participate in these public workshops, which are focused on connecting homeowners to opportunities to make available their properties for workforce housing. Time Frame: Within two years of Housing Element certificationConduct first workshop by October 2024 and second by October 2025, and annually thereafter at a time that is peak vacation home usage (?) thereafter.

Responsible Entity: Planning and Building Department, Chamber of Commerce *A1.2-6 Work with a community organization to sponsor annual outreach events (open house, workshop, presentation, etc.) involving hospitality-related companies and as well as owners of second home/vacation homes or second homes (not legally transient commercial occupancy) homeowners to help facilitate the provision of long-term lease agreements for temporary workforce housing.

Time Frame: Within two years of Housing Element certificationFirst event to take place by July 2024, annual thereafter
Responsible Entity: Planning and Building Department
A1.2-7 Adopt objective design standards for multi-family qualifying residential development, which will be applied to projects eligible for ministerial review.

Time Frame: Within two years of Housing Element certificationDecember 2025 Responsible Entity: Planning and Building Department, Planning Commission, City Council Objective H-1.3 Provide public services and facilities needed for the development of housing.

Policy
P1.3-1 Ensure that sufficient services are provided to meet the existing and future needs of residents.

Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECOMMENDED FINAL page 8-4
Actions
A1.3-1 Continuously update the Capital Improvement Program to ensure that sewer, water, and street improvements facilitate residential development.

Time Frame: First report in 2025, annually thereafterAnnually Responsible Entity: Public Works Department
A1.3-2 Provide periodic annual reports to the City Council on the available water supply and wastewater treatment capacity as part of the annual General Plan Progress Reports.

Time Frame: AnnuallyFirst report in 2025, annually thereafter Responsible Entity: Planning and Building Department
A1.3-3 Conduct a fee study or studies and adopt updated nexus-based development impact/connection fees to be imposed on development projects to support adequate sewer, water and transportation services, and parks and cultural facilities.

Time Frame: Within two years of Housing Element certificationDecember 2026 Responsible Entity: Planning and Building Department
A1.3-4 Conduct annual reviews of development-related impact/connection fees and ensure that fees are commensurate with the cost to the City for providing required infrastructure, particularly for 100 percent affordable housing projects and the affordable portion of other projects.

Time Frame: Conduct annual reviewsAnnually after completion of A1.3-3 Responsible Entities: Planning and Building Department, City Council *A1.3-5 Establish a program to subsidize all or part of development impact and connection fees for affordable housing projects with funding assistance from sources such as TOT, in-lieu fees, development agreements, inclusionary housing and/or grant funding to support provision of shortterm, pre-development, acquisition, and/or construction funding.

Time Frame: Within two years of HE certificationDecember 2026 Responsible Entities: Planning and Building Department, City Council A1.3-6 Ensure that active transportation grant funding for safe street initiatives is aligned with housing strategies.

Time Frame: Ongoing
Responsible Entities: Planning and Building Department, Public Works Department A1.3-7 Incorporate housing policies and Calistoga-specific policies from the Blue Zones Project Upper Napa Valley Blueprint, including but not limited to adopting a smoke-free ordinance for multifamily housing properties that covers all exclusive-use areas, interior unit spaces, as well as common areas not already covered by state law. Identify other housing policies from the Blueprint appropriate for incorporation into City policy as appropriate.

Time Frame: Within two years of Housing Element certificationDecember 2026 Responsible Entity: Planning and Building Department, Planning Commission, City Council Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECOMMENDED FINAL page 8-5
Objective H-2.1 Encourage the development of affordable housing.

Policy
P2.1-1 Provide incentives for the development of affordable housing.

Actions
A2.1-1 Ensure compliance with State-mandated density bonuses and other incentives for projects that reserve units for extremely low-, very low-, low-, and moderate-income households.

Time Frame: OngoingReview compliance at end of every January, beginning January 2024 Responsible Entity: Planning and Building Department
A2.1-2 Monitor 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 affordable housing to extremely low-, very low-, low-and moderate-income households.

Time Frame: Annual assessmentsOngoing. Provide outreach materials beginning January 2024.

Responsible Entity: Planning and Building Department, City Council A2.1-3 Continuously identify properties for purchase that would be well-suited toPursue the purchase of property for the construction of affordable and/or special-needs housing. The purchase would usetilizing revenue from sources such as TOT, in-lieu fees, development agreements, inclusionary housing and/or grant funding.

Time Frame: Within two years of Housing Element certification.Ongoing. Begin research in March 2025
Responsible Entity: Planning and Building Department, City Council A2.1-4 Use loan repayments from the 1980s CDBG residential rehabilitation program to fund programs and projects that benefit extremely low-, very low-, low- and moderate-income households.

Time Frame: Ongoing. Funds from this account are used annually to support contract services with the City of Napa Housing Authority (grant applications and program administration), Napa Valley Community Action (homeless services), Napa Valley Fair Housing and Rebuilding Calistoga.

Responsible Entity: City Council
A2.1-5 Change the zoning on housing opportunity sites to allow ministerial review, as may be required by state law, of housing development projects when a minimum of 20 percent of the units in the development are affordable to extremely low-, very low-, low-, or moderateincome households.

Time Frame: Within two years of Housing Element certification August 2025 Responsible Entity: Planning and Building Department, Planning Commission, City Council Goal H-2 Promote housing that meets the needs of extremely low-, low- and moderateincome households, particularly those who work in Calistoga.

Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECOMMENDED FINAL page 8-6
A2.1-6 Adopt a program which would provideModify the Zoning Code to develop an expedited approval process and financial and regulatory incentives (such as a density bonus or parking reduction) for developments that comply with existing zoning standards as well as all of the following:
a. Eligible for SB-35
b. At least 20 percent of onsite housing units are deed-restricted to households making earning 80%-160% of AMI (“missing middle” salariesincomes) with average affordability not to exceed 110% AMI
c. Provide prevailing wages and safe working conditions for all workers d. Utilize apprentice labor
e. Complies with all SB 35 labor standards
the provision of on-site housing units affordable to the missing-middle income ranges, which includes households that earn 80 to 160 percent AMI (suchThis Action is based on as CASA, Committee to House the Bay Area Compact Element #7).

Time Frame: Within three years of Housing Element certificationDecember 2026 Responsible Entities: Planning and Building Department, Planning Commission, City Council A2.1-7 Conduct an Inclusionary Housing Nexus Study and engage with the local development community and affordable housing advocates to evaluate the Inclusionary Housing Ordinance and in-lieu fee requirements for effectiveness in providing affordable housing under current market conditions.

The nexus study establishes the maximum fee that may be charged to mitigate the impacts of new development on the need for affordable housing. Amend the Inclusionary Housing Ordinance as appropriate, to enhance the Program's effectiveness. This program may be done in collaboration with other Napa County jurisdictions.

Time Frame: Initiate study by July 2025 2024, and adopt updated ordinance and in-lieu fee by 2026 2025 as deemed appropriate.

Responsible Entity: Planning and Building Department, Planning Commission, City Council Objective H-2.2 Pursue state and federal funding assistance appropriate to Calistoga’s needs for affordable housing.

Policy
P2.2-1 Use state and federal funding assistance, to the extent these subsidies are available and appropriate to Calistoga, to assist people in need of affordable housing and developers interested in constructing affordable housing.

Actions
A2.2-1 Meet with the Housing Authority of the City of Napa (HACN) annually to review upcoming Notices of Funding Availability (NOFA) for the purpose of identifying opportunities to match local funds with federal, state, county, and private funding sources for affordable housing and housing for special needs groups.

Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECOMMENDED FINAL page 8-7
Time Frame: AnnuallyFirst meeting by July 2024, annually thereafter Responsible Entity: Planning and Building Department
A2.2-2 Conduct outreach events (workshops, forums, or webinars, City website notices, public counter material, postings, regional coordination with HACN and others, etc.) to assist affordable housing developers in seeking funding for affordable housing from at least three sources: (1) local banks seeking to meet their obligations under the Community Reinvestment Act, (2) investors seeking Low-Income Housing Tax Credits, and (3) federal and state funds, including those available under the HOME program.

Time Frame: First meeting by July 2024, annually thereafterAnnually Responsible Entity: Planning and Building Department
*A2.2-3 Work with a community organization to formalize a partnership (in conjunction with Policy A1.2-6) with the Planning and Building Department to host an annual workshop on rental assistance resources and services.

Time Frame: Within two years of Housing Element certificationFormalize partnership by December 2024, annual workshops thereafter
Responsible Entity: Planning and Building Department
Objective H-2.3 Address the impacts of nonresidential development and market-rate residential development on the demand for, and the development of, affordable housing.

Policy
P2.3-1 Offset the impact of new nonresidential development and market-rate residential development on the need for, and the provision of, housing affordable to extremely low-, very low-, low-, and moderate-income households.

Actions
A2.3-1 Charge Continue to charge affordable housing linkage fees on nonresidential development (CMC

17.08.040) that are deposited in the Affordable Housing Fund (CMC 17.08.040(G)) to be used, in part, to increase the supply of affordable housing. Conduct biennial annual review and revise update the fees as necessaryappropriate to reflect current market conditions.

Time Frame: Within two years of Housing Element certificationOngoing Responsible Entity: Planning and Building Department
Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECOMMENDED FINAL page 8-8
Goal H-3 Maintain the City’s housing stock and protect the affordability of affordable units.

Objective H-3.1 Minimize the loss of existing housing units.

Policies
P3.1-1 Discourage the loss of existing housing by new development, expansion of existing development, and conversion to nonresidential uses.

P3.1-2 Prohibit the conversion of mobile home parks to other uses.

P3.1-3 Prohibit vacation rentals to maximize housing available to serve the needs of the community members.

Actions
A3.1-1 Where the loss of affordable housing occurs through demolition or conversion, these units shall be replaced on-site or elsewhere. The City Council may allow the payment of an in-lieu fee to the Affordable Housing Fund for lost units, in addition to any affordable housing linkage fee in cases where the proposed uses clearly provide other benefits to the City.

Time Frame: Ongoing
Responsible Entities: Planning and Building Department, City Council A3.1-2 Continue to actively enforce the Zoning Code’s prohibition of vacation rentals (i.e., the renting of homes for fewer than 30 days).

Time Frame: Ongoing
Responsible Entities: Planning and Building Department, Police Department Objective H-3.2 Minimize the conversion of affordable units to market-rate units.

Policies
P3.2-1 Monitor affordable housing projects to ensure their continued occupancy by eligible individuals and households.

P3.2-2 Control rent increases on mobile home park spaces.

Actions
A3.2-1 Monitor deed-restricted affordable housing projects to ensure compliance with affordability requirements and restrictions.

Time Frame: Ongoing. Monitoring reports verifying rents and household incomes completed by Housing Authority of the City of Napa annually.

Responsible Entities: Planning and Building Department, Housing Authority of the City of Napa A3.2-2 Continue to administer the Mobile Home Rent Stabilization Ordinance and defend it against legal challenges. Monitor the effectiveness of the Ordinance and revise if necessary to maximize its effectiveness.

Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECOMMENDED FINAL page 8-9
Time Frame: Ongoing
Responsible Entities: Planning and Building Department, City Council Goal H-4 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 H-4.1 Promote housing for special-needs population groups.

Policies
P4.1-1 Provide incentives to projects providing housing for special-needs population groups.

P4.1-2 Provide information on local services and housing resources to special-needs population groups.

P4.1-3 Collaborate with Napa County and non-profit organizations to promote housing for special-needs population groups.

P4.1-4 Improve disabled accessibility to existing residences and promote universal design in new residences.

P4.1-5 Encourage larger residential development projects to provide a range of unit sizes.

Actions
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.

Time Frame: Ongoing
Responsible Entity: Planning and Building Department, Planning Commission *A4.1-2 Meet with the Housing Authority of the City of Napa (HACN) and the Napa County Housing Authority annually, and continue to provide annual funding to the Napa County Housing Authority to support the three farmworker housing centers, including the Calistoga Center.

Time Frame: Annually. Continue to provide annual funding to the Napa County Housing Authority to support the three farmworker housing centers, including the Calistoga Center.Funding is ongoing.

Responsible Entity: Planning and Building Department
A4.1-3 Collaborate annually with Napa County and non-profit organizations to assess the needs of the homeless by participating in efforts to survey this population and annually consider providing funding or other support to ensure the provision of shelters on a regional basis.

Time Frame: AnnuallyConsider providing funding on an annual basis through general fund. The City provides annual funding to Community Action Napa Valley to support homeless services.

Responsible Entities: Planning and Building Department, City Council A4.1-4 Provide information about the 211-phone system, which provides assistance to persons in need of emergency shelter.

Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECOMMENDED FINAL page 8-10
Time Frame: Ongoing. The City provides this information at City offices and on its website.

Responsible Entities: Planning and Building Department, Police Department *A4.1-5 Conduct quarterly assessment of City’s Housing Resources webpage to update and refresh local housing programs and links to local housing organizations and housing agencies that provide affordable housing programs and resources with information on tenant and landlord rights and responsibilities.

Time Frame: Conduct quarterly assessmentFirst assessment by December 2023, quarterly (every three months) thereafter.

Responsible Entity: Planning and Building Department
*A4.1-6 As part of the project review process, provide incentives to market-rate rental housing projects of 10 or more units that provide affordable three- and four- bedroom units, which may include waivers from or modifications to development standards as determined to be appropriate through the development review process.

Time Frame: Ongoing
Responsible Entities: Planning and Building Department, Planning Commission A4.1-7 During permit review, require that developers of affordable housing projects comply with state and federal laws related to provision of units for the disabled, including developmentally disabled persons.

Time Frame: During permit review on a project-by-project basis Responsible Entities: Planning and Building Department, Planning Commission, City Council A4.1-8 Amend Zoning Code Chapter 17.04, Definitions, to update the definition for “Low Barrier Navigation Center” consistent with state law. Amend the Downtown Commercial Zoning District to allow low barrier navigation centers as a permitted use by right.

Time Frame: Within two years of Housing Element certification August 2025 Responsible Entities: Planning and Building Department, Planning Commission, City Council A4.1-9 Conduct annual public workshops with childcare operators, community-based organizations, and other groups focused on supporting female householders, minority and singleparent householders in addressing their needs. Workshops shall be followed by action plans no more than three months after workshop conclusion.

Time Frame: First workshop by December 2024, annually thereafter Responsible Entities: Planning and Building Department, Planning Commission, City Council Objective H-4.2 Financially support housing for special-needs population groups.

Policy
P4.2-1 Provide local funding to support housing for special-needs population groups.

Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECOMMENDED FINAL page 8-11
Actions
A4.2-1 Amend CMCZoning Code Chapter 17.08 Affordable Housing to include housing for special-needs populations, particularly farmworkers and lower-income, female and single-parent householders with children. as eligible for revenue from the City’s Affordable Housing Fund.

Time Frame: Within two years of Housing Element certification August 2025 Responsible Entity: Planning and Building Department, Planning Commission, City Council A4.2-2 Use loan repayments from the CDBG account to fund programs and projects that benefit specialneeds population groups, particularly farmworkers and lower income, female and single-parent householders with children.

Time Frame: Ongoing. Funds from this account are used annually to support contract services with the City of Napa Housing Authority (grant applications and program administration), Napa Valley Community Action (homeless services), and Rebuilding Calistoga.

Responsible Entity: City Council
Objective H-4.3 Pursue state and federal funding assistance appropriate to Calistoga’s needs for special-needs housing.

Policy
P4.3-1 Use state and federal funding assistance, to the extent these subsidies are available and appropriate to Calistoga, to assist special-needs population groups in need of affordable housing and developers interested in constructing such housing.

Actions
A4.3-1 Continue to pursue grant funding available from federal, state, county, and private funding sources for special needs groups and convey on the Housing Resources page on the City’s website.

Time Frame: Ongoing
Responsible Entity: Planning and Building Department
A4.3-2 Conduct updates of the Housing Resources page on the City’s website that provides information on resources for special-needs population groups, particularly farmworkers and female householders with children, and links to the websites of local housing organizations and housing agencies.

Time Frame: First assessment by December 2023, quarterly (every three months) thereafter.Quarterly
Responsible Entity: Planning and Building Department
Objective H-4.4 Provide access to housing for people with disabilities including developmental disabilities.

Policy
P4.4-1 Maximize accessibility to housing units for people with disabilities.

Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECOMMENDED FINAL page 8-12
Actions
A4.4-1 Enforce State requirements for accessibility and adaptability in remodeled and new housing projects.

Time Frame: Ongoing, as part of code enforcement
Responsible Entity: Planning and Building Department
A4.4-2 Review the City’s Universal Design Policy that requires accessible design features to be incorporated into newly constructed and substantially rehabilitated single-family and duplex residences to the maximum feasible extent, and update as necessary.

Time Frame: Within two years of Housing Element certificationAugust 2025 Responsible Entity: Planning and Building Department
A4.4-3 Pursue Partner with a local or regional community-based organization to identify and pursue grant funding to that can serve to retrofit existing housing to provide disabled accessibility.

Time Frame: AnnuallyIdentify partner by December 2024, meet at least annually thereafter Responsible Entity: Planning and Building Department
A4.4-4 Inform the public about the City’s reasonable accommodations provisions that allow modifications to the City’s development standards for persons with disabilities seeking equal access to housing.

Time Frame: OngoingPut on City website by December 2023, update as appropriate Responsible Entity: Planning and Building Department
Objective H-4.5 Support farmworker and other workforce housing models.

Policy
P4.5-1 Promote development of cooperative housing as a long-term solution to workforce housing needs.

P4.5-2 Collaborate with major local employers to identify gaps in knowledge and resources among inneed local workers.

P4.5-3 Provide wrap-around services for farmworkers, including housing for farmworker families.

Actions
*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 accommodate workforce housing.

Time Frame: Within two years of Housing Element certificationFirst workshop by December 2025, second no more than 4 years thereafter
Responsible Entity: Planning and Building Department, Chamber of Commerce *A4.5-2 Invite major employers and worker organizations, as well as local organizations such as Fair Housing Napa Valley and the UpValley Family Center, to a public forum in order to identify clear needs and available resources for workforce housing opportunities.

Time Frame: Within two years of Housing Element certification Forum held by December 2025 Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECOMMENDED FINAL page 8-13
Responsible Entity: Planning and Building Department, Chamber of Commerce A4.5-3 Meet with County and local organizations such as Fair Housing Napa Valley and the UpValley Family Center to ensure that City funding contributions are sufficient to adequately provide bilingual/multilingual service to existing farmworker housing centers and expand budgets if necessary.

Time Frame: Within two years of Housing Element certificationJuly 2024 Responsible Entity: Planning and Building Department
Objective H-5.1 Preserve and improve the quality of existing housing.

Policies
P5.1-1 Enforce health and safety codes and abate unsafe living conditions, giving property owners ample opportunities to correct deficiencies within a reasonable time frame.

P5.1-2 Encourage homeowners to maintain their property in a safe condition.

P5.1-3 Make use of governmental programs targeted at the rehabilitation of housing for lower-income households.

Actions
A5.1-1 Conduct outreach events (workshops, forums, or webinars, City website notices, public counter material, direct mailings, etc.) targeting low-income homeowners to offer technical assistance in maintaining, upgrading, and improving their property.

Time Frame: Conduct annual outreach eventsFirst event by July 2024, annually thereafter Responsible Entity: Planning and Building Department
A5.1-2 Meet with volunteer groups such as Rebuilding Calistoga to coordinate in pursuing CDBG Grant funding to help lower-income households maintain and upgrade their property.

Time Frame: First meeting by July 2024, annually thereafterAnnually Responsible Entity: Planning and Building Department, City Council A5.1-3 Continue to correct health and safety issues identified during routine building permitting and inspection activities.

Time Frame: Ongoing, on project-by-project basis
Responsible Entities: Planning and Building Department, Fire Department A5.1-4 Develop and adopt a procedure as part of the City’s Code Enforcement Program for the City to intervene when a property is becoming seriously deteriorated, especially if it is of historic Goal H-5 Maintain and enhance the physical condition and aesthetic qualities of existing residential neighborhoods.

Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECOMMENDED FINAL page 8-14
significance. For residential properties with historic significance, intervention should include all feasible attempts to rehabilitate building before considering demolition.

Time Frame: Within three years of Housing Element certification July 2026 Responsible Entities: Planning and Building Department, Police Department Objective H-5.2 Encourage private investment in older residential neighborhoods and the private rehabilitation of housing.

Policy
P5.2-1 Support the maintenance and revitalization of Calistoga’s older residential neighborhoods, defined as the Town Center outward, including R-2, R-3, and mixed-use zones.

Actions
A5.2-1 Maintain good repair of streets, sidewalks, and other municipal systems in older residential neighborhoods.

Time Frame: Ongoing
Responsible Entity: Planning and Building Department
A5.2-2 Allow the application of the State’s Historic Building Code to qualified homes in order to provide flexibility in rehabilitation and modification efforts.

Time Frame: Ongoing, on project-by-project basis
Responsible Entity: Planning and Building Department
A5.2-3 Conduct outreach events (workshops, forums, or webinars, City website notices, public counter material, direct mailings, etc.)workshops or webinars, City website notices, public counter material, direct mailings, etc.) publicizing the City’s Mills Act program to encourage owners of qualified owner-occupied homes to actively participate in the rehabilitation, restoration, preservation, and maintenance of their historic property in exchange for a reduction in their property taxes..

Time Frame: Annually First event by July 2024, annually thereafter Responsible Entity: Planning and Building Department
Objective H-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.

Policies
P5.3-1 Encourage good design that incorporates and/or respects neighborhood and community characteristics.

P5.3-2 Encourage larger residential subdivisions to provide a range of lot sizes and designs.

Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECOMMENDED FINAL Actions
A5.3-1 The City’s residential design standards, the General Plan’s Character Area Overlay Districts, and objective design standards when adopted shall be considered in the review of proposed residential projects.

Time Frame: Ongoing
Responsible Entities: Planning and Building Department, Planning Commission A5.3-2 Amend CMCZoning Code Chapter 17.41 Design Review to include elements in objective design standards referenced in A1.2-7 and A5.3-1 related to site design and lot configurations to ensure context sensitivity.

Time Frame: Within two years of Housing Element certificationAugust 2025 Responsible Entities: Planning and Building Department, Planning Commission A5.3-3 Amend CMCZONING CODE Chapter 17.41 Design Review to include elements in objective design standards referenced in A1.2-7and A5.3-1 related to non-ministerial review of development projects.

Time Frame: Within two years of Housing Element certificationAugust 2025 Responsible Entity: Planning and Building Department, Planning Commission, City Council Objective H-6.1 Streamline the City’s permit review process, simplify regulations, and minimize fees to promote the provision and maintenance of housing.

Policies
P6.1-1 Maintain development and permitting procedures that are efficient and do not constrain the production of housing.

P6.1-2 Reduce parking requirements for residential uses that share commercial parking, where appropriate.

P6.1-3 Ensure that parking requirements for senior housing are the minimum necessary to provide adequate parking.

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

Time Frame: Ongoing
Responsible Entity: Planning and Building Department
A6.1-2 Modify the Zoning Ordinance so that parcels in the Site Inventory identified in previous Housing Elements ("Reuse Sites") with at least 20 percent of the units affordable to lower-income households are eligible for by-right processing with ministerial review, as may be required by state law.

Before modification of the
page 8-15
Goal H-6 Remove governmental constraints to the maintenance, improvement, and development of housing, where feasible.

Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECOMMENDED FINAL page 8-16
Zoning Ordinance, the City should consider identification of any biological or cultural resources on the Reuse Sites that may impact the development viability of the identified sites.

Timeframe: By January 20262024
Responsibility: Planning Division, Planning Commission, City Council A6.1-3 Amend CMC 17.36 to Aallow the joint shared useutilization of parking spaces where it can be demonstrated that shared usethis will not result in an unacceptable impact on parking in the public right-of-way or on off-street parking lots. This demonstration can include a parking study thatn examinesation of actual parking useage or by assigning peak parking usage times to different permitted uses.

Time Frame: Ongoing August 2025, in conjunction with A6.1-4, A6.1-7 Responsible Entity: Planning and Building Department.

A6.1-4 Amend CMCZoning Code Chapter 17.36 Off-Street Parking and Loading to ensure that emergency shelter parking requirements (staff parking only) comply with AB 139/Government Code Section 65583, subdivision (a)(4)(A).

Time Frame: By October 2024 August 2025, in conjunction with A6.1-3, A6.1-7 Responsible Entity: Planning and Building Department.

A6.1-5 Amend CMCZoning Code as necessary to ensure compliance with Government Code Section 65651 requiring that Supportive and Transitional Housing be permitted by-right in zones where multifamily and/or mixed-uses are permitted.

Time Frame: By August 2025October 2024
Responsible Entity: Planning and Building Department.
*A6.1-6 Amend CMCZoning Code as necessary to ensure compliance with the Employee Housing Act (Health and Safety Code, § 17000 et seq.) in defining and allowing Agricultural Housing.

Time Frame: By August 2025October 2024
Responsible Entity: Planning and Building Department.

A6.1-7 Amend CMC as necessary to ensure compliance with the Employee Housing Act (Health and Safety Code, § 17000 et seq.)
Time Frame: By October 2024
Responsible Entity: Planning and Building Department.

A6.1-87Amend CMCZoning Code 17.36 Off-Street Parking and Loading to address any actual or potential constraints on project feasibility and reaching maximum densities specifically for smaller bedroom unit types such as studio and one-bedroom units.

Time Frame: By August 2025October 2025, in conjunction with A6.1-3, A6.1-4 Responsible Entity: Planning and Building Department.

A6.1-98City will review fee reductions for reasonable accommodation procedures to ensure that permit review process does not act as a constraint on persons with disabilities.

Time Frame: By October 20252024
Responsible Entity: Planning and Building Department.

Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECOMMENDED FINAL page 8-17
A6.1-910 Amend CMCZoning Code as necessary to ensure compliance with State law fair housing requirements related to provisions for residential care facilities and group homes.

Time Frame: By August 2025October 2025
Responsible Entity: Planning and Building Department.
*A6.1-110 The City owns eleven (11) small sites (.12-.45 ac) totaling 2.82 acres to support residential development. For these sites, The City will maintain compliance with the Surplus Land Act throughout the housing element period. As such, the City will establish by establishing a range of actions to facilitate and encourage housing development on all city-owned sites. These actions will consider including proactive outreach and marketing with developers, requests for proposals, development incentives, fee waivers, priority process, financial assistance (if feasible), etc.

If developers respond and commit to developing on these sites, the City will expeditiously process necessary approvals (entitlements, development agreements, etc.,) pursuant to the following key milestones:
• Release available sites and requests for proposals to develop on publicly owned sites and establish a schedule of actions to facilitate development by July 2024. • Target development agreements within 6 months of response or interest from developers.
• Facilitate entitlements and approvals within one year of an application.

The City has identified city-owned sites to support development. The City will maintain compliance with the Surplus Land Act throughout the housing element period, new program and key milestones for the development of the sites are as follows:
a. Execute contract for development feasibility study (July 2025) b. Issue RFP for affordable housing development, prioritizing projects with Extremely Low-Income units (pending outcome of feasibility analysis) (July 2026) c. Execute contract with developer (November 2028)
d. Development Entitlement (November 2027)
e. Complete construction of at least 6 affordable housing units (2031).

The City will establish a range of actions to facilitate and encourage development of these sites. These actions will consider proactive outreach and marketing with developers, requests for proposals, development incentives, fee waivers, priority process, financial assistance (if feasible), etc.

Time Frame: OngoingAs per milestone
Responsible Entity: Planning and Building Department, Planning Commission, City Council.

A6.1-12 The City plans to make suitable City-owned sites available through the Surplus Land Act process over the planning period, for a potential development of xxx units. If developers respond and commit to developing on these sites, the City will expeditiously process necessary approvals (entitlements, development agreements, etc.,) within two years.

Time Frame: Ongoing
Responsible Entity: Planning and Building Department.

Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECOMMENDED FINAL page 8-18
Objective H-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.

Policies
P7.1-1 Support fair and equal housing opportunities for all Calistoga residents and work to eliminate discriminatory housing practices.

P7.1-2 Support organizations that provide equal housing services to Calistoga residents.

Actions
A7.1-1 Conduct outreach events (workshops, forums, or or webinars City Housing Resources page, public postings, public counter and UpValley Family Center material, direct mailings, etc.) providing bilingual information about fair housing at City Hall and including links to fair housing resources.

Time Frame: First event by July 2024, annually thereafter Responsible Entity: Planning and Building Department
A7.1-2 Consider contributing annual funding and conduct annual outreach events (workshops, webinars, or forums advertised on the City Housing Resources page, public postings, public counter and UpValley Family Center material, direct mailings, etc.) for local organizations, such as Fair Housing Napa Valley and the UpValley Family Center, to provide multi-lingual landlord-tenant education and conciliation and publicize the intake process for discrimination complaints.

Time Frame: First event by July 2024, annually thereafter Responsible Entities: Planning and Building Department, City Council *A7.1-3 Release a request for proposals for the creation of a Fair Housing Marketing Plan as part of housing opportunities created through the City’s affordable housing programs.

Time Frame: Within two years of Housing Element certificationJuly 2025 Responsible Entity: Planning and Building Department
A7.1-4 Continue to implement fair housing practices in affordable housing programs, such as the HOME residential rehabilitation program.

Time Frame: Ongoing
Responsible Entity: Planning and Building Department
A7.1-5 Begin the process of adopting a just cause eviction ordinance.

Time Frame: Within two years of Housing Element certificationJuly 2025 Responsible Entity: Planning and Building Department, Planning Commission, City Council Goal H-7 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.

Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECOMMENDED FINAL page 8-19
Objective H-8.1 Reduce energy demand in new and existing housing through conservation and efficiency.

Policies
P8.1-1 Promote the use of energy conservation features in the design of new and remodeled residential structures.

P8.1-2 Encourage sustainable design and construction practices in new residential development projects.

Actions
A8.1-1 Conduct annual outreach events (workshops, or webinars, or forums, advertised by, the City Housing Resources page, public postings, public counter, direct mailings, etc.) to publicize on the City’s website the availability of HERO and CalFirst loan programs for weatherization and energyefficiency programs for existing residences that are offered by utility companies and other organizations.

Time Frame: Annual outreach eventsFirst event by July 2024, annually thereafter Responsible Entity: Planning and Building Department
A8.1-2 Ensure efficient water use for irrigation by adopting the state’s standards for water-efficient landscape design.

Time Frame: Within two years of Housing Element certificationAugust 2025 Responsible Entity: Planning and Building Department, City Council A8.1-3 Conduct annual outreach events (workshops, forums, or webinars, City website notices, public counter material, direct mailings, etc.)workshops or webinars, City Housing Resources page, public postings, public counter, direct mailings, etc.) to publicize on the City’s website the availability of HOME rehabilitation funding for energy conservation improvements to assist lowerincome households in lowering energy expenses.

Time Frame: Annually First event by July 2024, annually therafter Responsible Entity: Planning and Building Department, City Council A8.1-4 Adopt a local ordinance (i.e. “reach codes”) promoting energy efficient house construction to reduce energy consumption beyond what is required in State codes, in newly built residential development.

Time Frame: Within two years of Housing Element certificationJanuary 2025 Responsible Entity: Planning and Building Department, City Council Goal H-8 Reduce energy use and greenhouse gas production in existing and new residential development.

Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECOMMENDED FINAL page 8-20
Contributing Factors to Fair Housing Issues
In Chapter 3, the “Identification of Fair Housing Issues” section identifies two overarching fair housing issues in Calistoga, each assigned a priority level:
• Disparities in Access to Opportunity (High Priority)
• Disproportionate Housing Needs (Medium Priority)
Disparities in Access to Opportunity
Per the analysis in Chapter 3, certain segments of Calistoga’s population (farmworkers, female-headed households) face disproportionate housing challenges including access to necessary resources and connectivity to communitybased organizations. This is particularly acute for female-headed households living in Census Tract 2020, Block Groups 1 and 3.

Contributing Factors
• Lack of affordable in-home or community-based supportive services • Lack of affordable, accessible housing in a range of unit sizes • Access to employment and transportation
• Lack of regional cooperation
• Lack of outreach towards segments of Calistoga’s population Disproportionate Housing Needs
Cost burden is a substantial issue in Calistoga, particularly among renters citywide and for all households in Census Tract 2020, Block Group 2.

Contributing Factors
• Availability of affordable units in a range of sizes
• High levels of overpayment create displacement risk
• Less overall awareness of resources provided by the public sector • Second “vacation” homes place strain on existing housing stock, creating displacement risk City Actions to Affirmatively Further Fair Housing
The following table describes City Actions that will be taken to respond to fair housing issues and their contributing factors:

Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECOMMENDED FINAL page 8-21
TABLE 8-1: CONTRIBUTING FACTORS TO FAIR HOUSING ISSUES
AFFH
Identified Fair
Housing Issue
Contributing Factors Meaningful Actions
Disparities in
Access to
Opportunity
(High Priority)
• Lack of affordable inhome or community-based
supportive services
• Lack of affordable,
accessible housing in a
range of unit sizes
• Access to employment and
transportation
• Lack of regional
cooperation
• Lack of outreach towards
segments of Calistoga’s
population
City Action: Collaborate with the Housing Authority of the City of Napa and the Napa County Housing Authority to support the three farmworker housing centers, including the Calistoga Center. Coordination meetings shall occur at least annually.

Primary Responsible Entity: Planning and Building Department City Action: Provide incentives to market-rate rental housing projects that provide affordable 3- bedroom and/or 4-bedroom units.

Primary Responsible Entity: Planning and Building Department City Action: Conduct annual workshops with childcare facilities, community-based organizations, and other groups focused on supporting female householders in addressing their needs. Workshops shall be followed by action plans no more than three months after workshop conclusion. The first workshop will take place by December 2024. Workshop locations should be in or easily accessible to Census Tract 2020 Block Groups 1 and 3.

Primary Responsible Entity: Planning and Building Department City Action: Conduct public workshops with worker organizations, cooperative housing specialists, major employers, and local organizations to identify clear needs, available resources, and the viability of cooperative housing as potential solutions for workforce housing opportunities. The first workshops shall be held by December 2025.

Primary Responsible Entity: Planning and Building Department City Action: Amend Calistoga Municipal Code to ensure compliance with Employee Housing Act by August 2025.

Primary Responsible Entity: Planning and Building Department City Action: Release a Request for Proposals to create a Fair Housing Marketing Plan by July 2025.

Primary Responsible Entity: Planning and Building Department Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECOMMENDED FINAL page 8-22
Disproportionate Housing
Needs
• Availability of affordable
units in a range of sizes
• High levels of
overpayment create
displacement risk
• Less overall awareness of
resources provided by the
public sector
• Second “vacation” homes
place strain on existing
housing stock, creating
displacement risk
City Action: Permit adaptive residential reuse of inns, motels, and ground-floor commercial space by August 2025.

Primary Responsible Entity: Planning and Building Department City Action: Conduct public workshops and annual outreach events to promote long-term lease agreements for workforce housing in vacation homes, beginning in 2024.

Primary Responsible Entity: Planning and Building Department City Action: Establish a program to subsidize development impact and connection fees for affordable housing projects by December 2026.

Primary Responsible Entity: Planning and Building Department City Action: Host annual workshops on rental assistance resources and services with partner organization, beginning in 2025.

Primary Responsible Entity: Planning and Building Department City Action: Promote on City’s Housing Resources webpage local housing programs, organizations, and agencies that provide affordable housing programs and resources. Promotion will begin by the end of 2023.

Primary Responsible Entity: Planning and Building Department City Action: Amend Calistoga Municipal Code to remove constraints on project feasibility and reaching maximum densities, specifically for smaller unit types, by August 2025.

Primary Responsible Entity: Planning and Building Department City Action: Develop at least 6 units on City-owned land (Site G) by December 2029 Primary Responsible Entity: Planning and Building Department City Action: Amend the Zoning Code’s regulation for Accessory Dwelling Units (ADUs) in order to incentivize the development of 24 ADUs, 21 of which affordable to very low, low, and moderate income households, by the end of the planning period.

Primary Responsible Entity: Planning and Building Department Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECOMMENDED FINAL page 8-23
Quantified Objectives
The following quantified objectives are based on the Housing Element’s identification of existing and projected housing needs, potential housing development sites and financial resources, and the Element’s analysis of constraints to the development and maintenance of housing. This information has been used to establish reasonable estimates of what these programs and policies can accomplish.

The tables below estimate the number of units that could be constructed, rehabilitated, and conserved/preserved during the planning period (i.e. June 30, 2022 through January 15, 2031). The quantified objectives do not represent a ceiling, but rather set a minimum goal for the City to achieve, based on needs, resources, and constraints.

Construction Objectives
The quantified objectives for housing construction are based on the approved and under-construction housing units shown in Table 5-3 and Table 5-4 as well as and projected accessory dwelling units in Table 5-6. Refer to Chapter 5: Housing Sites and Resources for details on the methodology for estimating pipeline units and accessory dwelling unit projections. The 128 potential units exceeds the City’s share of regional housing needs for the period (i.e., 119), with the City meeting housing targets for units affordable to very low-, low-, moderate-, and above moderate- income households. The city’s construction objectives are its RHNA target.

TABLE 8-1 2 CONSTRUCTION OBJECTIVES FOR HOUSING, 6TH CYCLE: 2023 – 2031 Target Income
Group
Construction
Objective
Extremely Low (0-30%
AMI) 61
Very Low (031 - 50% of
AMI) 631
Low (51 - 80% of AMI) 190
Moderate (81 - 120% of
AMI) 1119
Above Moderate (120%
of AMI) 5050
Total 128119
Rehabilitated Housing Objectives
The rehabilitated housing objectives are the number of units that may be rehabilitated during the planning period. Based on the City’s past grant history, Calistoga’s Housing Rehabilitation Program is estimated to result in the rehabilitation of 16 homes over the planning period.

Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECOMMENDED FINAL page 8-24
TABLE 8-31 REHABILITATED HOUSING OBJECTIVES
CDBG Funding 12 Units
HOME Rehabilitation Program 4 Units
Total 16 Units
Special Housing Needs Objectives
The special housing needs objectives are the number of units that will be provided for special needs groups. They are based on the Calistoga Family Apartments project, which was completed in 2015.

TABLE 8-42 SPECIAL HOUSING NEEDS OBJECTIVES
Units by Special Needs Group
Disabled
accessible
1 Disabled
adaptable 2
Farmworke
r household
Hearing
impaire
d3
Calistoga Family Apartments 3 22 48 1
1 Incorporates the principles of Universal Design
2 Entry to first floor is disabled-accessible, and an accessible path of travel is provided within unit 3 Designed with special lighting and equipment such as paging devices from the entryway to the rooms, vibrating alarm systems, computer teletype technology, strobe lighting to alert residents to smoke or fire Conserved Affordable Housing Objectives
The conserved affordable housing objectives are the number of units whose affordability will be preserved during the planning period through deed restrictions and the City’s mobile home park rent stabilization ordinance.

TABLE 8-4 5 CONSERVED AFFORDABLE HOUSING OBJECTIVES
No. and Target Income Groups
Housing with long-term
affordability restrictions1 17 moderate income units
Mobile home park rent
stabilization ordinance 556 low and moderate income units Total 573 low and moderate income
units
1 Table 4-21: Restricted Affordable Housing Units (as of 2021) Summary of Objectives
Many programs and policies reduce barriers and create opportunities for a balanced community. These goals are essential to meeting the City’s housing needs, but are more qualitative in general.

Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECOMMENDED FINAL page 8-25
Based on the City’s past grant history, Calistoga’s Housing Rehabilitation Program is estimated to result in the rehabilitation of 16 homes over the planning period Calistoga will also work to preserve the 17 housing units allocated for moderate incomes in the Palisades Subidivision, which is currently at moderate risk of expiration. In addition, the mobile home park rent stabilization ordinance will continue to preserve affordability of Calistoga’s 556 mobile home park units.

The affordability of these units is based on a 2013 survey.

Calistoga reasonably expects that a total of 128 280 units will be constructed, 40 units will be rehabilitated, and 17 will be preserved, as described by the tables below:

TABLE 8-5 6 PROJECTED HOUSING SUMMARY OF UNITS CONSTRUCTED, REHABILITATED, AND CONSERVED Income
Category New Construction Rehabilitation Conservation/ Preservation Extremely
Low 6140 8 161
Very
Low* 31 412 172333
Low 19 4 161
Moderate 19 0 79
Above
Moderate 50 0 0
Sub-Totals 119 16 573
TOTAL 869 708 units
*=Calistoga is allocating 59.8 percent of the very low income RHNA towards extremely low-income households TABLE 8-6 7 NEW HOUSING UNITS BY AFFORDABILITY
Type of Unit Number of Units
New Affordable
Units 773658
New Market Rate
Units 9650
Total Units 869708
Item #8.2.

CITY OF CALISTOGA 2023 – 2031 HOUSING ELEMENT – RECOMMENDED FINAL page 8-26
Item #8.2.

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
August 24, 2022
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) Draft Housing Element Thank you for submitting the City of Calistoga’s (City) draft housing element received for review on June 23, 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 YIMBY Law and Greenbelt Alliance pursuant to Government Code section 65585, subdivision (c).

The draft element addresses many statutory requirements; 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 accommodate the regional housing needs allocation (RHNA), including for lower-income households, shall be completed no later than one year from the statutory deadline. 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 rezones to accommodate a shortfall of sites pursuant to Government Code section 65583, subdivision (c), paragraph (1), subparagraph (A) and Government Code section 65583.2, subdivision (c) are completed.

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 ATTACHMENT 4 - HCD Comment & City Response (90-day Review) Item #8.2.

Jeff Mitchem, Director

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 of your team during the review. We are committed to assist 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 #8.2.

City of Calistoga’s 6th Cycle Draft Housing Element Page 1 August 24, 2022

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 http://www.hcd.ca.gov/community-development/housing-element/housing-elementmemos.shtml. Among other resources, the housing element section contains HCD’s latest technical assistance tool, Building Blocks for Effective Housing Elements (Building Blocks), available at http://www.hcd.ca.gov/community-development/building-blocks/index.shtml 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: The element currently describes cases filed with the Fair Housing Enforcement Organization (FHEO), but it must also describe the City’s capacity to provide enforcement and outreach, which can consist of actions such as the ability to investigate complaints, obtain remedies, or engage in fair housing testing. In addition, the element must address compliance with existing fair housing laws, as well as any past or current fair housing lawsuits, findings, settlements, judgements, or complaints.

Assessment of Fair Housing: The element includes some data and analysis regarding different patterns for various socio-economic characteristics (race and income).

However, a complete analysis should include maps and data on all fair housing components and analyze this data for patterns and trends at the local and regional level including integration and segregation (race, income, disability, and familial status), disparities in access to opportunity (education, environmental, transportation, economic), and disproportionate housing needs (cost burdened, overcrowded, substandard housing conditions, homelessness, and displacement risks). In addition to evaluating patterns and trends, the element should analyze coincidences with other components of the assessment of fair housing. Lastly, the assessment should be complemented by local data and knowledge, including input from comments, and other relevant factors as described below.

Other Relevant Factors: The element must consider other relevant factors that have contributed to certain fair housing conditions. This analysis must consider information that is unique to the City or region, such as governmental and nongovernmental actions, historical land use and zoning practices (e.g., past redlining/greenlining, restrictive covenants, etc.), disparities in investment to specific communities, or other information that may have impeded housing choices and mobility.

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City of Calistoga’s 6th Cycle Draft Housing Element Page 2 August 24, 2022
Local Knowledge and Data: The element should complement federal, state, and regional data with local data and knowledge where appropriate to capture emerging trends and issues, including utilizing knowledge from local and regional advocates, public comments, and service providers.

Sites Inventory: The element includes some analysis on the distribution of sites identified to meet the Regional Housing Needs Allocation (RHNA) regarding access to opportunity indicators (pp. 5-10-16). However, a full analysis should address the income categories of identified sites with respect to location, the number of sites and units by all income groups, and how that effects the existing patterns for all components of the assessment of fair housing (e.g., enforcement and outreach, segregation and integration, disproportionate housing needs including displacement). The element should also discuss whether the distribution of sites improves or exacerbates fair housing conditions and add or modify programs as appropriate.

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.

Goals, Priorities, Metrics, and Milestones: Goals and actions must significantly seek to overcome contributing factors to fair housing issues. Currently, the element identifies programs to encourage and promote affordable housing; however, most of these programs are limited to conducting outreach and do not appear to facilitate any meaningful change nor address affirmatively furthering fair housing requirements.

Furthermore, the element must include metrics and milestones for evaluating progress on programs, actions, and fair housing results. Given that most of the City is considered a low and moderate resource community, the element could focus on programs that center on place-based strategies for economic and community revitalization, protecting residents from disaster-driven and investment-driven displacement, and enhancing housing mobility to encourage the development of more housing choices and affordable housing.

Programs also should be based on identified contributing factors, be significant and meaningful. The element must add, and revise programs based on a complete analysis and listing and prioritization of contributing factors to fair housing issues. Furthermore, the element must include geographic targeting, metrics and milestones toward affirmatively furthering fair housing (AFFH) outcomes. For more information, please see HCD’s guidance at https://www.hcd.ca.gov/community-development/affh/index.shtml.

2. Include an analysis of population and employment trends and documentation of projections and a quantification of the locality's existing and projected needs for all income levels, including extremely low-income households. (Gov. Code, § 65583, subd. (a)(1).)
Extremely Low Income (ELI) Households: While the element included the total number of projected ELI households, it must quantify and analyze the number of existing ELI households by tenure.

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City of Calistoga’s 6th Cycle Draft Housing Element Page 3 August 24, 2022

3. 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).) Overpayment: While the element quantified the total number of households overpaying by tenure (p. 4-29), it must quantify the total number of lower-income households overpaying by tenure.

4. 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).)
Progress in Meeting the RHNA: The element is counting 128 units as progress towards the RHNA including 69 units affordable to lower-income households. First, to count these units as progress towards RHNA, the element must demonstrate the availability of these units within the planning period. To address this, the element could discuss project status, schedule for completion, outreach with developments, remaining steps for projects to receive final entitlements and any other relevant information. Additionally, the element must demonstrate the affordability for 1855 Lincoln Ave based on actual or projected sales prices, rent levels, or other mechanisms establishing affordability in the planning period. For additional information, see the Building Blocks at http://www.hcd.ca.gov/community-development/building-blocks/housingneeds/projected-housing-needs.shtml.

Sites Inventory: While the element lists sites by parcel number, parcel size, zoning, general plan designation, and describes existing uses for non-vacant sites (Appendix 5- 1), it must also identify the number of units that can be realistically accommodated on each site. For additional information and sample sites inventory, see the Building Blocks at http://www.hcd.ca.gov/community-development/building-blocks/site-inventoryanalysis/inventory-of-land-suitable.shtml.

Realistic Capacity: The element provides assumptions for buildout of sites in the inventory by multiplying the maximum allowable density by the size of a parcel.

However, the element must also provide support for these assumptions. For example, the element should demonstrate what specific trends, factors, and other evidence led to the assumptions. The estimate of the number of units for each site must be adjusted as necessary, based on the land use controls and site improvements, typical densities of existing or approved residential developments at a similar affordability level in that jurisdiction, and on the current or planned availability and accessibility of sufficient water, sewer, and dry utilities.

Additionally, for sites that have been identified in zones that allow for 100 percent nonresidential uses, the element must analyze the likelihood that residential will occur in nonresidential zones (e.g., community commercial and high density residential/office).

For example, while the element stated that residential densities are required and that multifamily is allowed excluding the ground floor, the element should address other criteria including whether these zones allow for 100 percent commercial projects.

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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].

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Item #8.2.

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 #8.2.

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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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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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 #8.2.

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
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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 #8.2.

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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 #8.2.

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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 #8.2.

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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 #8.2.

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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 #8.2.

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 #8.2.

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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 #8.2.

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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 #8.2.

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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 #8.2.

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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 #8.2.

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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 #8.2.

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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 #8.2.

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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 #8.2.