Agenda — St. Helena City Council, May 1, 2023 (part 24 of 26)

October 31, 2022

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In sum, while the project and its EIR focused on water neutrality for its municipal use, it failed to adequately evaluate onsite groundwater pumping, the GSP current basin conditions, pumping limitations and the resulting significant impact on the environment.

Very truly yours,

DICKENSON, PEATMAN & FOGARTY
Joshua S. Devore
JSD/sol
cc: Ethan Walsh, City Attorney, [email protected]
St. Helena Citizens for a Sustainable Future
Maria Villegas
Sandra McCorkle
Ben Alderman
Elizabeth Alderman
Martha Angus
Dyan Beito
Richard Beito
Linda Brown
Ron Brown
Bernerd Buckley
Cindy Ford
John Ford
Gale Greisen
Sherri Kelly
Marina Lavagnino
Katie Leinen
Sandra Lowry
Isobel Luria
John Milliken
Ann Nevero
Jan Oddy
Anne Offord
Becky Palmisano
Dave Palmisano
Laura Pohlen
Patrick Pohlen
Laurence Schlatter
Rene Schlatter
Dave Valentine
Dave Wilkinson
1500 FIRST STREET | STE 200 | NAPA, CA 94559 | T: 707.261.7000 DPF-LAW.COM Agenda Item #5.1.

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12 Agenda Item #5.9.

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JOSHUA S. DEVORE
[email protected]
1500 FIRST STREET | STE 200 | NAPA, CA 94559 | T: 707.261.7000 DPF-LAW.COM October 31, 2022
Via Email:

Commissioner John Ponte, Chair, [email protected] Commissioner Daniel Hale, Vice Chair, [email protected] Commissioner Autumn Anderson, [email protected] Commissioner Marika Rothfeld, [email protected] Commissioner Rosaura Segura, [email protected] Commissioner Christopher Warner, [email protected] City Manager Anil Comelo, [email protected]
Community Development Director Maya DeRosa, [email protected] RE: Hunter Subdivision Project Tentative Map No. 2022-001, File #PL10-040 Dear: Chair Ponte, Commissioners, City Manager Comelo, Community Development Director DeRosa:

We represent the Saint Helena Citizens for a Sustainable Future, a diverse group of City residents who are extremely concerned by the City’s actions with respect to the referenced project.

Numerous members of the Citizens group have individually commented on the project in the past. They write now collectively due to their concern with what appears to be an imminent basic failure of the City to follow its own law.

Before the Planning Commission is a request to certify the EIR and approve a Tentative Map for the Hunter Subdivision project. This letter addresses the latter, the requested approval of the Tentative Map.

The presented Tentative Map, Attachment 3 to the Staff Report (TM 2022-01), does not comply with either the City’s Subdivision Ordinance, Zoning Code nor the General Plan. It is important to note that the Planning Commission is not acting on any conceptual map that was presented in the EIR.

Rather, as far as consideration of the approval of the Tentative Map, TM 2022-001, Attachment 3 is the actual Map the Commission is to act upon.1
1 We also note that it appears from public records that the property was sold to White Fang Properties, LLC in June 2021, but such sale was not recorded until earlier this month. (Napa Recorder Doc. 2022-0018523, June 2, 2021 Grant Deed from Dennis R. Hunter to White Fang Properties, LLC, a South Dakota LLC, recorded October 10, 2022.) It is thus not clear who the proper applicant is, and whether the property owner is a party to the application. There is no reference to White Fang Properties anywhere in the nearly 3,000-page agenda packet. It appears at least that the Owner information on the proposed Map is incorrect.

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October 31, 2022

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1500 FIRST STREET | STE 200 | NAPA, CA 94559 | T: 707.261.7000 DPF-LAW.COM This Tentative Map is fatally defective and must be rejected.

Violation of Subdivision Ordinance Section 16.04.120
The Staff Report describes the project for consideration as follows:

The proposed project being considered by the Planning Commission at this time is a Tentative Subdivision Map to subdivide an approximately 17-acre parcel of land in the eastern area of the city, east of the existing terminus of Adams Street. The proposed subdivision would create lots for 51 single family homes, and a separate parcel (lot 52) on which multi-family attached housing units would be built. The proposed Tentative Subdivision Map is included as Attachment 3 to this report.

The applicant proposes to include Accessory Dwelling Units (ADUs) with 11 of the 51 single family homes. The Commission should note that the applicant has not yet filed an application for any specific development project; this would be done after the approval of the tentative map and recordation of the Final Map (following approval of an Affordable Housing Agreement and compliance with other relevant tentative map conditions). Approval of the tentative subdivision map would only provide for the subdividing of the property; future applications would define the exact development that would take place on the lots created by the subdivision. (Staff Report, p. 19, emphasis added).

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1500 FIRST STREET | STE 200 | NAPA, CA 94559 | T: 707.261.7000 DPF-LAW.COM This is expressly illegal.

Title 16 of the Saint Helena Municipal Code, the City’s Subdivision Ordinance, provides unambiguously that:

All applicants for tentative maps and tentative parcel maps shall concurrently submit applications for all other discretionary approvals, including but not limited to, conditional use permits, variances, rezonings, and general plan amendments. (Subdivision Ord., § 16.04.120 (emphasis added.))
The recognition by staff that “future applications” are required renders the submission incomplete, and directly contrary to Section 16.04.120’s mandate that the requests be made “concurrently.” Such a system makes perfect sense, as otherwise it is impossible to consider the whole of the project.

In short, Applicant’s proposal that ‘we will figure out the rest later’ is expressly counter to the City’s Subdivision Ordinance, and requires rejection.

Violation of Subdivision Ordinance Section 16.16.020
As a result of what appears to be a ‘get one foot in the door’ tactic, the submitted Map is objectively deficient, and fails to comply with the City’s Tentative Map requirements. Section 16.16.020 of the Subdivision Ordinance dictates the requirements for a Tentative Map. It requires that numerous specific “proposed design elements and improvements shall be shown on the tentative map or described on an attached written statement,2” including that:

The proposed use of each lot, lot layout and dimensions and area of each lot.

Engineering data shall show the approximate finished grading of each lot, the preliminary design of all grading, the elevation of proposed building pads, the top and toe of cut and fill slopes to scale and number of each lot. (Subdivision Ord., § 16.16.020 C.3.) However, the Map presented for approval shows nothing in Lot 52.

No usage of Lot 52 is shown (See Map Sheets TM1, TM3.) No finished grading of Lot 52 is shown. (See Map Sheet TM3.) No elevation of Lot 52 building pads is shown. (Id.) While these details are included for the remaining lots, Lot 52 is blank. As such, the Map does not comply with the Subdivision Ordinance’s requirements to detail each lot, unless Lot 52 is actually proposed to have no development.

Indeed, the presented Map Sheet TM2 shows the current use of Lot 52 as vineyard. As no changes to Lot 52 are proposed, assuming that the Map presented actually complied with Section

16.16.020, it would designate Lot 52 as open space. (Subdivision Ord. § 16.16.020 C.6.) Nothing on the Map, nor any attachments or plan notes that are actually presented for approval, designates any other usage, grading, elevation or other change to Lot 52.
2 There is no “attached written statement;” only a suggestion of a future submission detailing the actual development to be proposed.

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1500 FIRST STREET | STE 200 | NAPA, CA 94559 | T: 707.261.7000 DPF-LAW.COM While the Staff Report suggests that there may be a future specific description of 25 units of attached multi-family housing presented, no description has been provided for consideration or approval. To the extent different usage and grading of Lot 52 is proposed, it “shall” be included on the Tentative Map. Given the conflict between the Staff Report, Applicant’s apparent future plans, and the Map presented, it is plain that the Map presented for approval does not comply with Section 16.16.020 and must be rejected.

Violation of General Plan and Zoning Code
As such, the Map under consideration details a subdivision containing the required details only for 51 developed lots, and one open space lot. Those lots are proposed to consist of 51 Single Family Homes, and 11 Accessory Dwelling Units (ADUs). The Map under consideration thus provides plans for 62 units on the 16.92-acre parcel.

The parcel is zoned Medium Density Residential (MR) and designated as MDR in the General Plan. As correctly noted in the Staff Report:

The MDR designation provides for single-family detached and attached homes, secondary residential units, public and semi-public uses, and similar and compatible uses. Residential densities shall be in the range of 5.1 to 12.0 dwelling units per gross acre.
(Staff Report pp. 15-16.) The Map that is actually presented for consideration provides for a density of only 3.66 units per acre (62/16.92). It must be rejected as not complying with the Zoning Code or General Plan.

While Applicant appears intent to have the Planning Commission bless a future, unsubmitted project, that is not within the Commission’s power. The Planning Commission can act only on what is actually presented to it for consideration, and what has been presented does not comply with the Zoning Code or General Plan. Because the Planning Commission’s function is to evaluate the projects’ conformance with the Zoning Code and General Plan, it is required to reject the Map as presented.

There appears to be a suggestion that the Commission could provide Conditions that the Applicant must demonstrate by future actions that the project satisfies the General Plan. (Compare Proposed Condition of Approval (CoA) 14 (“The primary purpose of this review is for compliance with the General Plan and Zoning Ordinance.”) with CoA 27 (a future “Affordable Housing Agreement shall demonstrate how the project satisfies the minimum density requirement of the General Plan.”) (Staff Report pp. 143-144.)
But the Planning Commission is required to make a finding that “the proposed subdivision, together with the provisions for its design and improvement, is consistent with the general plan, any applicable specific plan, and other applicable provisions of this code.” (Subdivision Ordinance §

16.16.080 (emphasis added.)) At its most generous, the record suggests only that the subdivision could be compliant with the minimum density if future actions are taken.

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1500 FIRST STREET | STE 200 | NAPA, CA 94559 | T: 707.261.7000 DPF-LAW.COM Indeed, the very first element of the General Plan Consistency Analysis provides that “Conformance with the required General Plan density will be confirmed at the time an Affordable Housing Agreement and development plans are submitted for review and approval.” (Staff Report Attachment 4, p. 165 (emphasis added.)) That is not sufficient to make the finding required for approval that the project is compliant now.

Most concerningly, that same analysis element cryptically states that “If constructed with these types and numbers of units, the project would conform with the minimum density required by the General Plan. There are other alternative scenarios which would achieve the minimum density; the proposed subdivision map does not preclude achieving the minimum residential density required by the General Plan.” (Id. (emphasis added.)) That analysis is based on a hypothetical scenario of 51 single family homes, 11 ADUs, and 25 multi-family units. But as no multi-family development on Lot 52 is actually shown on the tentative map (but all of the other lots are described), the analysis apparently suggests that perhaps the applicant could instead build 51 single family homes with 36 ADUs using the proposed map. But there is no way to know, because the submission does not comply with City Subdivision Ordinance.

Certainly, a finding merely that the project is not precluded from meeting the General Plan is not what the City code envisions. The Commission must make a finding that the project is compliant. As the Map that is before the Commission does not, as currently presented, meet the General Plan or Zoning Code requirements, it must be rejected.

Conclusion
The Saint Helena Citizens for a Sustainable Future are not anti-growth. They are in favor of responsible City management, informed decision making, and adherence to law. They are concerned with the environment, and equity in development. The proposed project that has been presented is for large lots for single family homes. A number of those lots would have income-producing ADUs, for the single-family homeowners to profit by.

The members of the Citizens group are unable to fully consider the project however, as no actual proposal for low-income or multi-family housing units has been presented. But it appears the Applicant will relegate such development to a corner of the property, rather than fairly disperse them throughout a development that evenly complies with the General Plan and Zoning Code density requirements. The project’s proposal appears to destroy an existing vineyard with the (unspecified future) multifamily units to bulk up the unit count on a development that does not comply with the General Plan or Zoning Code density requirements.

This is directly contrast to 1993 General Plan Policy 4.3.5:

Require future residential development to conform to the pattern and density of older, neighboring areas of town in order to complement existing town character and ensure that densities are high enough to protect against unnecessary incursion into vineyard agricultural areas.

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1500 FIRST STREET | STE 200 | NAPA, CA 94559 | T: 707.261.7000 DPF-LAW.COM (1993 General Plan Policy, Staff Report p. 166 (emphasis added.)) Current General Plan Policy 3.1 is functionally identical. (“Require future development to conform to the pattern and density of the neighboring areas. In order to complement existing town character and protect against incursion into vineyard agricultural areas.” (Staff Report p. 180.))
Thus, the project – a large non-conforming subdivision with a potential future, dense multifamily parcel to compensate – should not simply be deferred for further consideration of the missing multi-family elements, but it should be rejected in its entirety.

Very truly yours,

DICKENSON, PEATMAN & FOGARTY
Joshua S. Devore
JSD/sol
cc: Ethan Walsh, City Attorney, [email protected]
Saint Helena Citizens for a Sustainable Future:

Maria Villegas
Sandra McCorkle
Ben Alderman
Elizabeth Alderman
Martha Angus
Dyan Beito
Richard Beito
Linda Brown
Ron Brown
Bernerd Buckley
Cindy Ford
John Ford
Gale Greisen
Sherri Kelly
Marina Lavagnino
Katie Leinen
Sandra Lowry
Isobel Luria
John Milliken
Ann Nevero
Jan Oddy
Anne Offord
Agenda Item #5.9.

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October 31, 2022

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1500 FIRST STREET | STE 200 | NAPA, CA 94559 | T: 707.261.7000 DPF-LAW.COM Becky Palmisano
Dave Palmisano
Laura Pohlen
Patrick Pohlen
Laurence Schlatter
Rene Schlatter
Dave Valentine
Dave Wilkinson

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Agenda Item #5.9.

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1 Attachment 17
Response to Comments on Draft EIR
DP&F Letter of Oct 31, 2022
On October 31, 2022, Joshua Devore sent a letter on behalf of Saint Helena Citizens for a Sustainable Future with comments on the Draft EIR for the proposed. The points raised in his letter are addressed below.

The letter is included as Attachment 17 to the February 7, 2023, Planning Commission staff report.

Response numbers below refer to paragraph numbers as shown in Attachment 16.

1. Analysis of Level of Service (LOS) is provided in this staff report.

2. As pointed out in this comment, Vehicle Miles Traveled (VMT) has, by state law, replaced LOS as a topic for analysis in an environmental impact report. An analysis of the project’s conformance with General Plan policies is provided in this staff report.

This comment also highlights an error in the traffic analysis (shown a change in the level of service at Pope/Silverado from LOS C to LOS E). This typographical error has been corrected (see Attachments 6l and 7 to this report) to show that, while a less than significant increase in delay at this intersection will occur, the LOS will remain at “C”.

3. The issue of conformance with the City’s water neutrality requirements is discussed in this staff report and in Master Response #2 to comments on the Draft EIR.

4. Please see Master Response #2 to comments on the Draft EIR. The onsite well will offset approximately 17 acre-feet of demand (reducing the use of City water by this amount).

The remaining 19.8 acre-foot offset is required by the conditions of approval to occur through the completion of one or more system improvements prior to issuance of building permits (see condition of approval #72).

5. City staff has carefully reviewed the issues associated with the use of the existing private well for onsite irrigation and outdoor uses, and has determined that the proposed use of the well is consistent with all applicable laws and programs, and that the proposed project is consistent with the Groundwater Sustainability Plan. The source for the conclusion regarding impacts to the groundwater basin, as discussed in the Draft EIR (page 3.9-40), is the “Napa County Groundwater Sustainability – Annual Report for Water Year 2020, (April 2021)” prepared by Luhdorff and Scalmanini Consulting Engineers for Napa County in April 2021, which determined that, “… the Subbasin was found to continue to exhibit stable groundwater levels, even despite a very dry 2020 water year, as it has historically, and has continued to be operated within the sustainable yield of the Subbasin (of between 17,000 and 20,000 AFY)” and “... Annual storage changes have commonly Agenda Item #5.9.

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2 fluctuated between positive and negative values dating back to 1988; however, the median change is a positive increase of 1,784 AF, indicating that groundwater demands are not resulting in depletion of the aquifer.”

6. The impact of the use of the existing well for onsite irrigation is addressed in detail in the Draft EIR and in Master Response #2, which addresses similar comments on the Draft EIR.

7. Please see the response to comment 5.

8. Please see the response to comment 5.

9. Please see the response to comment 5. Staff’s conclusion is that the existing well is not subject to the pumping limits discussed in this comment.

10. Please see the response to comment 9.

11. Please see the response to comment 5. Regarding impacts to the City’s Stonebridge wells, note that the capacity study performed on the existing well found no reduction in groundwater levels during sustained pumping, indicating that impacts to the City’s Stonebridge wells would result from the use of the well for onsite landscaping and outdoor uses.

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1 Attachment 18
Response to Comments on Tentative Subdivision Map
DP&F Letter of Oct 31, 2022
On October 31, 2022, Joshua Devore sent a letter on behalf of Saint Helena Citizens for a Sustainable Future with comments on the proposed tentative subdivision map. The points raised in the letter are addressed below.

Comment: The letter notes that the tentative map lists the property owner as Dennis R. Hunter, but the property that is the subject of the tentative map was recently conveyed to White Fang Properties, LLC.

Response: The tentative subdivision map and proposed resolutions have been updated to reference the new property owner.

Comment: The letter states that the tentative map must be denied because Municipal Code Section 16.04.120 states that applicants for tentative maps shall concurrently submit applications for all other discretionary approvals. In this case, the City is considering only the tentative subdivision map, and the applicant will need to apply for and secure additional discretionary approvals prior to the actual construction of the project.

Response: Staff disagrees that this section constitutes grounds for denying the tentative subdivision map. Section 16.04.120 sets forth a requirement that applies at the time of submission of the tentative map application, and at the most dictates that the Planning Director require concurrent submission of application for other discretionary approvals before the tentative map application was deemed complete. As staff has noted, the application for this map was accepted as complete on March 25, 2011. To the extent that City were to require compliance with this section, it should have done so at the time the tentative map was deemed complete rather than using it as ground for denial after fully processing the application. This is especially true given the restrictions that the State Legislature has placed on local agencies’ discretion to deny housing development projects. Government Code Section 65589.5(j)(2) provides a limited time for determine whether a housing development project is compliant with existing objective land use requirements. Specifically, Section 65589.5(j)(2) reads as follows:
(A) If the local agency considers a proposed housing development project to be inconsistent, not in compliance, or not in conformity with an applicable plan, program, policy, ordinance, standard, requirement, or other similar provision as specified in this subdivision, it shall provide the applicant with written documentation identifying the provision or provisions, and an explanation of the reason or reasons it considers the housing development to be inconsistent, not in compliance, or not in conformity as follows:
(i) Within 30 days of the date that the application for the housing development project is determined to be complete, if the housing development project contains 150 or fewer housing units.

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2 . . .
(B) If the local agency fails to provide the required documentation pursuant to subparagraph (A), the housing development project shall be deemed consistent, compliant, and in conformity with the applicable plan, program, policy, ordinance, standard, requirement, or other similar provision.

There is no record that staff notified the applicant that other discretionary applications must be submitted concurrently prior to or immediately after deeming the tentative map application complete. Based on the restrictions imposed by Government Code Section 65589.5(j)(2), staff does not believe that the City can deny the application based on a failure to comply with Section

16.04.120.

Comment: The letter asserts that the tentative map is not compliant with the City’s Subdivision Ordinance because the map does not show the use, approximate finished grading or elevation of proposed building pads for Lot 52.

Response: The tentative map has been updated to show the use, approximate finished grading and elevation of proposed building pads for Lot 52.

Comment: The letter asserts that the tentative map is not consistent with the General Plan and Zoning Code, arguing that the subdivision map provides for 62 units (the single family units and ADUs), and characterizing the 3.13 acre property where the multifamily housing development as “open space.” Based on this characterization, the letter argues that the density of the tentative map is only 3.66 units per acre.

Response: Staff does not agree with this characterization of the proposed density for this tentative map. In order to approve the tentative map, the City Council must find that the tentative map is consistent with the General Plan and the Zoning Code. In order to find that the map is consistent with the General Plan and Tentative Map, and confirm that when the project is developed, the map should demonstrate that it can meet the density requirements for this property as required by the General Plan and Zoning designations. The tentative map meets this requirement. The tentative map demonstrates that the map as currently configured allows for the development of the property at a density that that is within the allowed density for the MDR/MR land use and zoning designation. The applicant has indicated that they will develop a specific number of ADUs as part of the project, and intend to develop the 3.13 acre property as a multifamily development comprised of 25 units. The 3.13 acre parcel is not designated or zoned for open space, and should not be considered as such. Between the single family units, ADUs and multifamily development, the tentative map demonstrates how the required density can be achieved, and therefore demonstrates consistency with the General Plan Further, the conditions of approval assure that prior to approval of a final map, the applicant will demonstrate specifically how the General Plan and Zoning density will be met prior to approval of the final subdivision map (see Condition of Approval #24). The tentative map therefore ensures not only that the development of this property can meet the density requirements of the General Plan and Zoning Agenda Item #5.9.

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3 Code, but that it will do so. The tentative map therefore is consistent with the density requirements of the General Plan and Zoning Code.

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PO Box 5157 | Napa, CA 94581 | (707) 258-6318 | www.napabike.org November 1, 2022
City of St. Helena Planning Commission
Vintage Hall Board Room – Second Floor
465 Main Street
St. Helena, CA 94574
Public Comment Re: Item 5.1: Hunter Subdivision Project EIR Dear Chair Ponte and Commissioners,
The Napa County Bicycle Coalition (NCBC) represents over 2,000 members and supporters throughout Napa County in advocating to make riding a bicycle in our communities safe, convenient, and accessible for riders of all ages and abilities. For over 12 years, the Napa County Bicycle Coalition has worked with local organizations, businesses, elected officials, and the public to align our transportation infrastructure with the needs of cyclists and other active transportation users.

The proposed Hunter Subdivision development, located just a few blocks away from downtown St. Helena and community destinations would provide much-needed market rate and affordable housing. Residents would be well within reasonable walking (<1 mile) or biking (<5 miles) distance of grocery stores, pharmacies, parks, schools, as well as St. Helena City Hall and the St. Helena Public Library. With implementation of adopted Bicycle and Pedestrian Plans, this development could help accelerate the City’s progress toward the target active transportation mode share of 20% of trips by 2035 established in these active transportation plans.

The Hunter Subdivision Draft EIR states that the project will induce roughly 800 vehicle trips per day, a “potentially significant” increase in VMT, and claims that there are “no feasible mitigation measures,” making it a “significant and unavoidable” impact. The claim that there are no feasible actions to reduce this project’s VMT impact is untrue given the development’s close vicinity to several destinations that create regular travel (downtown, schools, grocery stores, etc.). One of the most powerful actions to reduce VMT is to provide bicycle and pedestrian facilities that are safe and comfortable for users of all ages and abilities in order to allow people to opt for walking or biking instead of driving – an option which is easy for developers to include, given that the developer has a clean slate to work with when creating new roads.

In order to address the VMT impact and to better align this significant development with City goals around climate, public health and safety, and active transportation, we urge Agenda Item #5.1.

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PO Box 5157 | Napa, CA 94581 | (707) 258-6318 | www.napabike.org the Planning Commission to recommend that the City direct the Hunter Subdivision developers to upgrade the planned active transportation facilities for Starr Avenue and Adams Street. While we appreciate that the City has included Class II bicycle lanes on Starr and Adams as a condition of approval, we believe that additional measures must be taken.

In addition to contributing towards City Goals 1, 5, and 6, NCBC's recommendations outlined below act as mitigation measures for the project’s significant projected VMT increase.

Adams Street
The City’s adopted 2019 Bike Plan proposes a Class I shared-use path on Adams Street east of SR 29, including along a future extension of Adams Street that connects to Starr Avenue. As Adams Street is one of the most significant east-west connections in the City of St. Helena, leading to St. Helena Public Library, Safeway, downtown St. Helena, and St. Helena Elementary School, it is crucial that all modes are provided adequate safety and access along this road. This section of Adams Street will also provide an important connection to the future Vine Trail shared-use path according to current proposed alignments.

We request that the project developers implement the planned Class I along the north side of the Adams Street extension and continue the Class I to at least Library Lane. This option is easily feasible with the 60 feet of Right of Way. We propose that the Class I be constructed by removing the parking lane from the north side of Adams Street, as the north side of Adams along this section (Library Lane to future Starr Avenue) is adjacent only to vineyards and is nonessential. Removing north side parking on Adams Street would free up 8 feet of space. We recommend that with this space, the south sidewalk be widened to at least 6 feet and the remaining space be used to contribute to a Class I on the north side.

The existing businesses on the south side of this corridor segment all have parking lots with adequate parking in addition to on-street parking on the south side. Since no proposed homes will be built on Adams Street, and all of the proposed housing has sufficient parking (3.5 spaces/unit in Lot 52 and two on-site spaces, covered guest parking, and street parking for the rest of the project), abundant parking is provided for residents in the areas around their homes. The proposed parking on the north side of Adams Street bordering the vineyard is superfluous, and the space would better serve the community and help reduce VMT by contributing towards an improved and connected active transportation network.

Agenda Item #5.1.

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PO Box 5157 | Napa, CA 94581 | (707) 258-6318 | www.napabike.org Starr Avenue
Although the City’s adopted 2019 Bike Plan proposes a Class I shared-use path along Starr Avenue, we support the City’s condition to install Class II bicycle lanes on Starr Avenue from Hunt Avenue to Adams Street. Class II bicycle lanes on the new segment will continue the existing Class II network on Starr to create a cohesive and understandable bike network along the corridor.

Additionally, we recommend that the sidewalks in the Starr extension be widened from four feet to at least five feet by narrowing the vegetation strips, in order to provide more valuable public space to pedestrians. Four-foot sidewalks are barely large enough to allow two able-bodied people to walk side-by-side. These simply do not provide sufficient space for families to walk together or for pedestrians in wheelchairs or with strollers to navigate other pedestrian traffic. This also reduces access to the social aspect of walking, a significant community health benefit the importance of which the Covid-19 pandemic has only emphasized.
-
Finally, on both Adams Street and Starr Avenue, the City should direct the project developers to implement appropriate traffic-calming measures to reduce vehicle speeding and improve road safety for all road users.

Speeding is already a significant traffic safety concern in St. Helena. As reported by resident comments listed in the DEIR Appendices, Starr Avenue is already used as a cutthrough street to avoid SR 29 and Silverado Trail traffic and experiences high volumes of speeding motorists. More broadly in St. Helena, a group of citizens concerned with speeding on existing City streets has already formed and began meeting with the City Police Department to identify actions to reduce speeding. The City approved a contract with GHD to address traffic safety on Madrona and Spring after citizen reports of unsafe motorist behaviors on those streets, namely speeding. Through our Safe Routes to School safety evaluation efforts and several separate conversations with community members, parents in St. Helena have expressed their fear of allowing their children to walk and bike to school due to motorist behaviors such as speeding.

As the street designs are presented in the DEIR, vehicle travel lanes will be 12 feet wide, the same width as the California standard for highways. These streets will be wide, long, and straight, with minimum traffic control and no traffic-calming – similar to Madrona and Spring. We know that such design facilitates motorist speeding and we urge the City Agenda Item #5.1.

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Agenda Item #5.9.

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PO Box 5157 | Napa, CA 94581 | (707) 258-6318 | www.napabike.org to be proactive on traffic safety by directing the developers to include appropriate traffic-calming on Starr and Adams.

We implore the Commission to recommend that the City ensures that the above recommendations are included in the Hunter Subdivision Project as it moves forward.

This project is early enough in the design stages to implement these reasonable changes that will help reduce the significant VMT impact and help St. Helena become more bikeable and walkable.

Should you have any questions about any of the above recommendations, please contact Carlotta Sainato at (707) 258-6317 or [email protected]. Thank you for your time and consideration.

Sincerely,
Carlotta Sainato
Program Manager
Napa County Bicycle Coalition
Agenda Item #5.1.

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Agenda Item #5.9.

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1 Attachment 20
Response to Napa County Bicycle Coalition
Letter of Nov 1, 2022
The following to be included in the Planning Commission staff report.

This letter suggests changes to the proposed subdivision to include additional off-street bicycle and pedestrian facilities as provided in the “City’s adopted 2019 Bike Plan,” including Class I (offstreet) shared-use paths along Adams Street and Starr Avenue.

However, staff notes that the “2019 Bike Plan” that the comment refers to is the “Napa Countywide Bicycle Plan,” adopted by the Napa Valley Transportation Authority in September 2019. Although the City was involved in the preparation of the Napa Countywide Bicycle Plan (which contains a chapter entitled “City of St Helena Bicycle Plan”), the Bicycle Plan was not adopted by the City of St Helena and is advisory only. Official City policy regarding future bicycle facilities is provided in the Circulation chapter of the St Helena General Plan, including Figure 5.5, “Bicycle Network.”
As discussed elsewhere in this report, conditions of approval are included to require that the proposed subdivision comply with Figure 5.5 of the St Helena General Plan, which designates Class II bicycle lanes (on-street) on both Adams Street and Starr Avenue.

Agenda Item #5.9.

Page 4041 of 4422 ends

Page 4042 of 4422 ends

-----Original Message-----
From: Judy Boyle <[email protected]>
Sent: Sunday, October 23, 2022 4:39 PM
To: Maya DeRosa <[email protected]>
Subject: [External] Extension
This is a request for an extension for the meeting scheduled for 11/1/22 to discuss the Hunter development. The document is over 2000 pages long. Judy Boyle Sent from my iPhone
Agenda Item #5.10.

Page 4043 of 4422 ends

From: Sherri Kelly <[email protected]>
Sent: Saturday, October 22, 2022 10:51 AM
To: Autumn Anderson <[email protected]>; Rosaura Segura <[email protected]>; Christopher Warner <[email protected]>; Marika Rothfeld <[email protected]>; John Ponte <[email protected]>; Maya DeRosa <[email protected]>
Cc: Geoff Ellsworth <[email protected]>; Paul Dohring <[email protected]>; Anna Chouteau <[email protected]>; Lester Hardy <[email protected]>; Eric Hall <[email protected]>
Subject: [External] Hunter Project DEIR responses - were they made public? Good morning,
I'm writing in response to item 5.1 on the Planning Commission agenda for November 1 regarding the Hunter Project.

There were many questions and concerns brought up in Fall 2021 during the public comment period on the Hunter Project DEIR. I don't recall seeing any responses from the City answering the myriad questions/concerns to the Hunter DEIR, and I thought that was required under CEQA before certification of the final EIR. Given the apparent lack of public response to questions and concerns regarding the Hunter DEIR, how can City staff now

1. "Recommend that the City Council adopt the attached Resolution recommending certification of the Final EIR, approval of the Mitigation Monitoring Program, Findings of Fact and Statement of Overriding Considerations; and

2. Recommend that the City Council adopt the attached Resolution recommending approval the requested Tentative Map No. 2022-001, File #PL10-040 for the Hunter Subdivision project."
Please let me know where and when questions and concerns about the Hunter DEIR will be formally addressed. For your reference, I have attached a letter that I submitted in Fall 2021 in response to the DEIR listing several concerns regarding threats to the health, safety and civil rights of existing and future St. Helena residents, should the Hunter Project be developed as proposed.

In a related issue, when I attempted to access the attachment to the Hunter item on the Planning Commission agenda, it appears to be password protected. It seems to me that the public is entitled to adequate time to access and review these important documents.

I look forward to your response, and thank you for your help on this matter.

Sherri Kelly
1192 Meadowcreek Circle
Agenda Item #5.10.

Page 4044 of 4422 ends

From: Isobel luria <[email protected]>
Sent: Sunday, October 23, 2022 12:09 PM
To: Maya DeRosa <[email protected]>
Subject: [External] Extension
Hi Maya,
I have pulled up the FEIR on the Proposed Hunter Project and there is no way I can possibly read the 2849 pages even cursorily by the November 1 meeting. As you know from the numerous comments submitted when the DEIR was made public, many residents of SH are really interested in this project. I am therefore respectfully requesting an extension to be able to fully digest the responses to our comments.

Thank you,
Isobel Luria
1173 Starr Avenue
--
Isobel Luria
[email protected]
Mobile: 707-480-3983
Sent from my iPad
Agenda Item #5.10.

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-----Original Message-----
From: Elisabeth Alderman <[email protected]>
Sent: Saturday, October 22, 2022 8:25 PM
To: Maya DeRosa <[email protected]>
Subject: [External] Hunter Project EIR
Hello,
I’m submitting my request to postpone the 11/1 hearing so that I have time to review the extremely lengthy report.

Thank you,
Liz Alderman
702 Hunt Ave
Agenda Item #5.10.

Page 4046 of 4422 ends

1 Xinia Gamero
From: Maya DeRosa
Sent: Monday, October 24, 2022 10:45 AM
To: Xinia Gamero
Cc: Eric Norris
Subject: FW: [External] Final EIR Hunter Project
Please see attached comment.

Please let me know if this is possible.

Thank you,
Maria
Sent from my iPhone
> On Oct 24, 2022, at 9:27 AM, Maya DeRosa <[email protected]> wrote:
>
> Hello Ms. Villegas, I do understand that on Saturday the link was not accessible to the Hunter staff report and files however that afternoon we resolved the privacy setting. I have been checking the link and it continues to work. I am copying it here below for your convenience.
>
>
https://sthelena.civicweb.net/document/68499/Request%20by%20Ben%20and%20Kelly%20Vanzutphen%20to%20subd ivid.pdf?handle=A2E3E5827C2F40B1BEB7F942C650D285
>
> Kind regards,
>
>
> MAYA DEROSA, AICP
> COMMUNITY DEVELOPMENT DIRECTOR
> City of St. Helena | Community Development Department > 1572 Railroad Avenue | St. Helena, CA 94574
Agenda Item #5.10.

Page 4047 of 4422 ends

2 > Direct: (707) 967‐2783 | [email protected] | http://cityofsthelena.org/planning >
>
> ‐‐‐‐‐Original Message‐‐‐‐‐
> From: MariaVillegas <[email protected]>
> Sent: Sunday, October 23, 2022 7:26 PM
> To: Maya DeRosa <[email protected]>
> Subject: [External] Final EIR Hunter Project
>
> Ms. DeRosa,
> The Planning Commissioners meeting scheduled for November 1, 2022 with the agenda item for the Vanzuhptens has a link which should allow the public to access the FEIR. When I clicked on the link it led me to a sign in page. I was unable to access the document. I have tried to access the document again today however, the link is no longer on the agenda item. For this reason I am asking for one, the link be provided in order to access the document and two, I’m requesting an extension in order to allow me to view and read the document. > Thank you,
> Maria Villegas
>
> Sent from my iPad
Agenda Item #5.10.

Page 4048 of 4422 ends

From: tom corkill <[email protected]>
Sent: Monday, October 24, 2022 9:32 AM
To: Maya DeRosa <[email protected]>
Subject: [External] Vanzutphen project
I am requesting that there be an extension on the above referenced hearing as there has been totally insufficient time to review the 2849 page report. I am a resident of Vineyard Valley. --
Tom Corkill
Agenda Item #5.10.

Page 4049 of 4422 ends

From: minna <[email protected]>
Sent: Monday, October 24, 2022 10:37 AM
To: Maya DeRosa <[email protected]>
Subject: [External] extention
we need extra time to read the proposed report submitted regarding the Hunter project Minna Williams, VV
Agenda Item #5.10.

Page 4050 of 4422 ends

From: Marina Lavagnino <[email protected]>
Date: October 24, 2022 at 5:56:18 PM PDT
To: Maya DeRosa <[email protected]>
Subject: [External] Hunter Project
Hello Maya.

I am one of the individuals who spoke at both comment zoom meetings last fall, and also turned in written comments. I only learned of the Final EIR yesterday, and was able to access the report late last night. I want time to review the document and consult with other neighbors and interested parties, to be prepared before the public meeting to vote on the project.

November 1st is way too soon for that vote.

In a brief look, I can quickly see responses to the issues that were raised that seem inaccurate.

If the reasoning in the final EIR is sound, then a delay to get give us a chance to understand the document should not be a problem.

Kind regardsMarina Lavagnino
15 Del Rio Ct.
508-612-8999
Agenda Item #5.10.

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1 Xinia Gamero
From: Elizabeth Green <[email protected]>
Sent: Tuesday, October 25, 2022 9:53 AM
To: Public Comment
Subject: [External] Hunter Project
We live in Vineyard Valley and we are very concerned about this housing development.

It is right behind
the end of our park. These are just a few of the concerns we have.

Major concerns:
*WATER: We don't have enough now for current residents.

*all the additional cars from new residents
*all the additional traffic
*evacuation issues: Vineyard Valley is supposed to use the road up on the levee as an additional
evacuation route, but this would be eliminated. And where would all the additional residents
living there use as an evacuate route? On Main St., south on 29? All of St. Helena will be using that ONE
and ONLY way out in the event of a wildfire.
*2+ years of dump trucks, lumber trucks, and all other types of construction trucks going up and
down Main St. and turning right on Adams. Dirt, noise, etc., due to ongoing construction.
*Major concerns about the safety of the levee and building on top of it. *A major flood in the future and the safety of Vineyard Valley.

PLEASE STOP THIS PROJECT FROM GOING FORWARD. IT HAS MAJOR RAMIFICATIONS FOR ALL OF ST. HELENA.

Respectively,
Rodney & Elizabeth Green
Agenda Item #5.10.

Page 4052 of 4422 ends

From: Sherri Kelly <[email protected]>
Sent: Tuesday, October 25, 2022 10:00 AM
To: Maya DeRosa <[email protected]>
Cc: Autumn Anderson <[email protected]>; John Ponte <[email protected]>; Christopher Warner <[email protected]>; Rosaura Segura <[email protected]>; Marika Rothfeld <[email protected]> Subject: [External] Request to continue PC item 5.1
Good morning Maya,
Thanks for your prompt assistance on making the attachment to item 5.1 for the upcoming 11/1/22 Planning Commission meeting accessible. I saw the password protection was removed and was able to open the link to access the file.

I now see that the document is 2849 pages long. I believe it is important for the public to have time to thoroughly read and process the information in order to submit well informed and timely responses during the public comment period prior to the 11/1 meeting. The Planning Commission meeting is a week away at this point. Please accept this message as my formal request for a continuance on agenda item 5.1 to allow members of the public to have adequate opportunity to read and respond to the information in the agenda attachment file number PL10-040 and TM 2022-001 and the Hunter Project Final EIR incorporated therein.

Thanks for your help on this.

Sherri Kelly
1192 Meadowcreek
Agenda Item #5.10.

Page 4053 of 4422 ends

1 Xinia Gamero
From: sherry powell <[email protected]>
Sent: Tuesday, October 25, 2022 1:42 PM
To: Public Comment
Subject: [External] Hunter project
To Whom it May Concern,
This project should NOT be considered for many reasons, but the primary reason is fire and evacuation concerns. There is a water shortage in St. Helena for residents without building more dwellings and the evacuation routes are already stretched with the residents and housing on Pope and adjoining streets.

Please do not allow this application process to go any further.

Thank you for your consideration.

Michael Powell
4 La Canada Ct.

St. Helena, CA 94574
Agenda Item #5.10.

Page 4054 of 4422 ends

1 Xinia Gamero
From: Maya DeRosa
Sent: Wednesday, October 26, 2022 1:11 PM
To: Xinia Gamero
Cc: Eric Norris
Subject: FW: [External] Request to postpone the meeting on November 1 Follow Up Flag: Follow up
Flag Status: Flagged
Please add to the public comment for Hunter.

MAYA DEROSA, AICP

COMMUNITY DEVELOPMENT DIRECTOR
City of St. Helena | Community Development Department
1572 Railroad Avenue | St. Helena, CA 94574
Direct: (707) 967-2783 | [email protected] | http://cityofsthelena.org/planning From: Mary Alice Stielau <[email protected]>
Sent: Wednesday, October 26, 2022 1:09 PM
To: Maya DeRosa <[email protected]>; Autumn Anderson <[email protected]>; John Ponte <[email protected]>; Christopher Warner <[email protected]>; Rosaura Segura <[email protected]>; Marika Rothfeld <[email protected]> Cc: Geoff Ellsworth <[email protected]>; Paul Dohring <[email protected]>; Anna Chouteau <[email protected]>; Lester Hardy <[email protected]>; Eric Hall <[email protected]> Subject: [External] Request to postpone the meeting on November 1 Please accept this message as my formal request for a continuance on agenda item 5.1 to allow myself and other members of the public to have adequate opportunity to read and respond to the information in the agenda attachment file number PL10‐040 and TM 2022‐001 and the Hunter Project Final EIR.

Thank you,
Mary Alice Stielau
18 Los Robles Ct, St Helena
Agenda Item #5.10.

Page 4055 of 4422 ends

1 Xinia Gamero
From: Maya DeRosa
Sent: Wednesday, October 26, 2022 9:22 PM
To: Xinia Gamero
Cc: Eric Norris
Subject: FW: [External] Hunt development EIR
Please see public comment below for 11/1 agenda.

MAYA DEROSA, AICP

Regards,
Ben
Ben Alderman
347‐461‐1594
Agenda Item #5.10.

Page 4056 of 4422 ends

1 Xinia Gamero
From: Maya DeRosa
Sent: Thursday, October 27, 2022 9:05 AM
To: Xinia Gamero
Cc: Eric Norris
Subject: FW: [External] Library Development - Review Extension Please see attached public comment for 11/1.

MAYA DEROSA, AICP

Regarding the proposed residential development in St Helena (east of the Library along the floodplain), I am formally requesting an extension from the City Clerk to provide more time to review the 3,000 page document.

Thank you in advance for your support.

Kind Regards,
William Odegard
William Odegard
Social Strategist
310 849 5078
Agenda Item #5.10.

Page 4057 of 4422 ends

1 Xinia Gamero
From: Maya DeRosa
Sent: Thursday, October 27, 2022 9:05 AM
To: Xinia Gamero
Cc: Eric Norris
Subject: FW: [External] Request for extension to review Hunter EIR Please see public comment for 11/1 hearing.

MAYA DEROSA, AICP
COMMUNITY DEVELOPMENT DIRECTOR
City of St. Helena | Community Development Department
1572 Railroad Avenue | St. Helena, CA 94574
Direct: (707) 967‐2783 | [email protected] | http://cityofsthelena.org/planning ‐‐‐‐‐Original Message‐‐‐‐‐
From: Nicole Garriott <[email protected]>
Sent: Wednesday, October 26, 2022 5:42 PM
To: Cindy Tzafopoulos <[email protected]> Cc: Maya DeRosa <[email protected]>
Subject: [External] Request for extension to review Hunter EIR To whom it may concern‐
May we kindly request an extended time to review the EIR and submit comment for the Hunter Subdivision project? We were disappointed to have only a little over a week’s notice from receiving the letter regarding the public hearing on Nov 1. As members of the local wine industry we are still in the height of busy season and will not be able to attend. Nor do we have enough time to review the EIR in the given timeframe.

Thank you for your consideration,
Nicole & Scott Dale
1326 Monte Vista Ave.

Agenda Item #5.10.

Page 4058 of 4422 ends

1 Xinia Gamero
From: Maya DeRosa
Sent: Thursday, October 27, 2022 9:05 AM
To: Xinia Gamero
Cc: Eric Norris
Subject: FW: [External] Hunter Project Report/ Timeline Please see public comment below for the 11/1 agenda.

MAYA DEROSA, AICP
COMMUNITY DEVELOPMENT DIRECTOR
City of St. Helena | Community Development Department
1572 Railroad Avenue | St. Helena, CA 94574
Direct: (707) 967‐2783 | [email protected] | http://cityofsthelena.org/planning ‐‐‐‐‐Original Message‐‐‐‐‐
From: Dawn Leininger <[email protected]>
Sent: Wednesday, October 26, 2022 3:47 PM
To: Maya DeRosa <[email protected]>
Subject: [External] Hunter Project Report/ Timeline
Ms. DeRosa,
I was dismayed to see the Hunter Project Reports length at 2849 pages was being decided next Tuesday. I urge you to move the meeting to a future date so that the community can read and evaluate the latest plan. It sounds like a large project with many implications to the west side of St. Helena.

Thank you,
Dawn Leininger
Sent from my iPad
Agenda Item #5.10.

Page 4059 of 4422 ends

1 Xinia Gamero
From: Maya DeRosa
Sent: Thursday, October 27, 2022 9:05 AM
To: Xinia Gamero
Cc: Eric Norris
Subject: FW: [External] EIR Review
Please see public comment below for the 11/1 agenda.

MAYA DEROSA, AICP
COMMUNITY DEVELOPMENT DIRECTOR
City of St. Helena | Community Development Department
1572 Railroad Avenue | St. Helena, CA 94574
Direct: (707) 967‐2783 | [email protected] | http://cityofsthelena.org/planning ‐‐‐‐‐Original Message‐‐‐‐‐
From: Joyce Armington <[email protected]>
Sent: Wednesday, October 26, 2022 4:10 PM
To: Maya DeRosa <[email protected]>
Cc: Elisabeth Alderman <[email protected]>; [email protected] Subject: [External] EIR Review
As residents of Vineyard Valley, we are directly affected by the proposed development. We request that you allow additional time for us to study the documents before hearings occur.

Thanks for your consideration.

Joyce Armington
6 Del Monte Court
Sent from my iPhone
Agenda Item #5.10.

Page 4060 of 4422 ends

1 Xinia Gamero
From: Maya DeRosa
Sent: Thursday, October 27, 2022 9:18 AM
To: Xinia Gamero
Cc: Eric Norris
Subject: FW: [External] Final EIR extension request.

Please see public comment below for the 11/1 agenda.

MAYA DEROSA, AICP

Kindly provide extension on the Final EIR due to the length of the document which exceeds 2000 pages so that the citizens have time to review.

Thanks for your consideration.

Chris Smith
Agenda Item #5.10.

Page 4061 of 4422 ends

1 Xinia Gamero
From: Maya DeRosa
Sent: Thursday, October 27, 2022 10:53 AM
To: Xinia Gamero
Cc: Eric Norris
Subject: FW: [External] Extension on 11/1 Hunter Project Hearing Please see comment below for the 11/1 agenda.

Sincerely,
Alyson Nelson
(1695 Sylvaner Ave)
Agenda Item #5.10.

Page 4062 of 4422 ends

1 Xinia Gamero
From: Maya DeRosa
Sent: Thursday, October 27, 2022 6:58 PM
To: Xinia Gamero
Cc: Eric Norris
Subject: FW: [External] Request an extension
Please see public comment below for the 11/1 agenda.

MAYA DEROSA, AICP

Thank you for your time.

Sherry Powell
4 La Canada Ct
St Helena
510-220-2621
Agenda Item #5.10.

Page 4063 of 4422 ends

1 Xinia Gamero
From: Maya DeRosa
Sent: Thursday, October 27, 2022 6:58 PM
To: Xinia Gamero
Cc: Cindy Tzafopoulos; Eric Norris
Subject: FW: [External] Hunter Subdivision
Please see public comment below for the 11/1 agenda.

MAYA DEROSA, AICP

Respectfully,
Vivian Robison
Kenneth Robison
35 Redondo Ct, St Helena CA
cell 707 337-9352
Sent from my iPhone
Agenda Item #5.10.

Page 4064 of 4422 ends

1 Xinia Gamero
From: Maya DeRosa
Sent: Thursday, October 27, 2022 7:05 PM
To: Xinia Gamero
Cc: Eric Norris
Subject: FW: [External] Request delay of Hunter review in PC Please see public comment below for the 11/1 agenda.

MAYA DEROSA, AICP

That includes trying to track down the maintenance records I’ve been asking for and reviewing those before the Planning Commission. All of this takes time and we have been given little of it to perform an adequate review of such an important decision.

Thanks,
Tim
Agenda Item #5.10.

Page 4065 of 4422 ends

1 Xinia Gamero
From: Maya DeRosa
Sent: Thursday, October 27, 2022 7:06 PM
To: Xinia Gamero
Cc: Eric Norris
Subject: FW: [External] Hunter Project
Please see public comment below for the 11/1 agenda.

MAYA DEROSA, AICP

Marianne Sylvia and James Wayson
8 Del Rio Ct. Saint Helena
Agenda Item #5.10.

Page 4066 of 4422 ends

From: Margaret Norton <[email protected]>
Sent: Thursday, October 27, 2022 2:29 PM
To: Maya DeRosa <[email protected]>
Subject: [External] extension of time to review the documents Final EIR (FEIR) Dear Maya,
I am a resident of St Helena . I am requesting an extension on time to review the 2800 plus pages of the final EIR. this matter requires all our involvement and we need a sufficient amount of time to review.
it would be helpful to also understand how we can add additional water requirements for the city when we already get surcharges and the front page of the ST Helena paper is indicating the current water infrastructure needs significant work.
regards,
Margaret Norton and Tom Nixon
Sent from my iPad
Agenda Item #5.10.

Page 4067 of 4422 ends

1 Xinia Gamero
From: Maya DeRosa
Sent: Thursday, October 27, 2022 7:12 PM
To: Xinia Gamero
Cc: Eric Norris
Subject: FW: [External] Hunter Subdivision
Please see public comment below for the 11/1 agenda.

MAYA DEROSA, AICP

COMMUNITY DEVELOPMENT DIRECTOR
City of St. Helena | Community Development Department
1572 Railroad Avenue | St. Helena, CA 94574
Direct: (707) 967-2783 | [email protected] | http://cityofsthelena.org/planning From: M Siobal <[email protected]>
Sent: Thursday, October 27, 2022 2:20 PM
To: Cindy Tzafopoulos <[email protected]>; Maya DeRosa <[email protected]> Subject: [External] Hunter Subdivision
Madams,
As a Vineyard Valley home owner I urgently request an extension of time to review the Final EIR for this proposed project. Recently released, this document which is over 2800 pages long, will require additional time to explore before the November 1st public hearing. The potential adverse impacts on the residents of Vineyard Valley and surrounding communities of Saint Helena need to be seriously considered.

Mark Siobal
20 Los Robles Ct
Saint Helena CA 94575
Agenda Item #5.10.

Page 4068 of 4422 ends

1 Xinia Gamero
From: Maya DeRosa
Sent: Thursday, October 27, 2022 7:16 PM
To: Xinia Gamero
Cc: Eric Norris
Subject: FW: Extend Review time for Final EIR
Please see public comment below for the 11/1 agenda.

MAYA DEROSA, AICP

Many thx,
Martha Angus
Sent from my iPhone
Martha Angus
415-728-4961
Agenda Item #5.10.

Page 4069 of 4422 ends

1 Xinia Gamero
From: Maya DeRosa
Sent: Thursday, October 27, 2022 7:16 PM
To: Xinia Gamero
Cc: Eric Norris
Subject: FW: [External] Hunter Project
Please see public comment below for the 11/1 agenda.

MAYA DEROSA, AICP

Thank you,
Audrey Ward
Vineyard Valley
510.508.3574
Sent from my iPhone
Agenda Item #5.10.

Page 4070 of 4422 ends

1 Xinia Gamero
From: Maya DeRosa
Sent: Thursday, October 27, 2022 7:17 PM
To: Xinia Gamero
Cc: Eric Norris
Subject: FW: [External] Hunter Subdivision FEIR
Please see public comment below for the 11/1 agenda.

MAYA DEROSA, AICP

I live at 5 Del Campo Ct. in Vineyard Valley and this project will have an important impact on my living conditions.

Thank you,
Gary Crosman
Agenda Item #5.10.

Page 4071 of 4422 ends

1 Xinia Gamero
From: Maya DeRosa
Sent: Thursday, October 27, 2022 7:18 PM
To: Xinia Gamero
Cc: Eric Norris
Subject: FW: [External] Extend the time period o review FEIR! Please see public comment below .

MAYA DEROSA, AICP

Thank you,
Madeline DeMarco
5 Del Campo Ct.

St. Helena, Ca.

Sent from Yahoo Mail for iPhone
Agenda Item #5.10.

Page 4072 of 4422 ends

1 Xinia Gamero
From: Maya DeRosa
Sent: Thursday, October 27, 2022 7:20 PM
To: Xinia Gamero
Cc: Eric Norris
Subject: FW: Hunter Subdivision Urgent Request
Please see comment below.

MAYA DEROSA, AICP

Dear Maya and Cindy,
We are formally requesting a time extension in order to review the final Hunter Subdivision EIR 2800 page report before the Nov.1st deadline to comment on the Hunter Subdivision.

My husband and I own a home in Vineyard Valley Senior mobile home park and are directly effected by the Hunter Subdivision development.

There is not enough time to review this 2800-page report by November 1, 2022 and, as such, that date is a ridiculously unattainable/unreachable reading goal not to mention time to process and organize our thoughts!
Thank you,
James and Nannette Heye
5 Laguna Seca Court
St Helena, Ca. 94574
(206) 909-5811
Agenda Item #5.10.

Page 4073 of 4422 ends

1 Xinia Gamero
From: Maya DeRosa
Sent: Friday, October 28, 2022 8:24 AM
To: Xinia Gamero
Cc: Eric Norris
Subject: FW: Extension
Please see public comment below for 11/1 agenda.

MAYA DEROSA, AICP

Page 4074 of 4422 ends

1 Xinia Gamero
From: Maya DeRosa
Sent: Friday, October 28, 2022 9:00 AM
To: Xinia Gamero
Cc: Eric Norris
Subject: FW: [External] Extension for FEIR
Please see comment below for the 11/1 agenda.

MAYA DEROSA, AICP

Request extension to review document.

Thank you
Chris Echols
11 Del Rio Court
Agenda Item #5.10.

Page 4075 of 4422 ends

1 Xinia Gamero
From: Maya DeRosa
Sent: Friday, October 28, 2022 9:07 AM
To: Xinia Gamero
Cc: Eric Norris
Subject: FW: [External] Hunter Project EIR and Staff report for November Planning Commission meeting
Please see public comment below for the 11/1 meeting.

MAYA DEROSA, AICP

COMMUNITY DEVELOPMENT DIRECTOR
City of St. Helena | Community Development Department
1572 Railroad Avenue | St. Helena, CA 94574
Direct: (707) 967-2783 | [email protected] | http://cityofsthelena.org/planning From: Pat Dell <[email protected]>
Sent: Thursday, October 27, 2022 12:37 PM
To: Maya DeRosa <[email protected]>
Subject: [External] Hunter Project EIR and Staff report for November Planning Commission meeting Dear Planning Director DeRosa, You have asked of the residents of the city of St. Helena an herculean effort in reading and understanding both the PC Staff report for November 1st and the Hunter project EIR. The City sent these documents out on Tuesday October 25th. That allows people barely 7 days to read and critique these voluminous documents. That is just simply not fair. I am asking for an extension of at least three weeks to allow people to read and intelligently comment on the EIR as well as read and understand the Staff report. Sincerely, Pat Dell.

Agenda Item #5.10.

Page 4076 of 4422 ends

1 Xinia Gamero
From: Maya DeRosa
Sent: Friday, October 28, 2022 9:08 AM
To: Xinia Gamero
Cc: Eric Norris
Subject: FW: [External] Hunter street
Please see public comment below for the 11/1 agenda.

MAYA DEROSA, AICP

Thank you.

Calie Candia
Vineyard Valley a resident.

Sent from my iPad
Agenda Item #5.10.

Page 4077 of 4422 ends

1 Xinia Gamero
From: Maya DeRosa
Sent: Friday, October 28, 2022 10:53 AM
To: Xinia Gamero
Cc: Eric Norris
Subject: FW: [External] Hunter Subdivision Tentative Map application and Final EIR will be considered by the Planning Commission at a public hearing on November 1, 2022 at 6 pm.

Please see public comment below for the 11/1 agenda.

MAYA DEROSA, AICP

Att: Maya DeRosa, Community Development Director and Cindy Tzafopoulos, City Clerk Dear Maya and Cindy.

I refer to the information submitted by the city a few days ago with regard to the above project.

The document is very long, with material repeated in some areas and is difficult to read in other areas.

I respectfully request that due to the significance of this project, the city grants an extension of time to allow everybody a reasonable amount of time to review the Final EIR (FEIR) Thank you for your assistance.

Best regards.

Wendy
Wendy Strachan
53 Laguna Seca Ct.

St Helena
CA 94574
Tel: 707 968-5140
Cell: 707 256-9854
Agenda Item #5.10.

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2 [email protected]
Agenda Item #5.10.

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1 Xinia Gamero
From: Maya DeRosa
Sent: Friday, October 28, 2022 10:54 AM
To: Xinia Gamero
Cc: Eric Norris
Subject: FW: [External] Hunter Subdivision Urgent Request Please see comment below for the 11/1 agenda item.

MAYA DEROSA, AICP

My husband and I live in Vineyard Valley Senior mobile home park and are directly effected by the development.

There is not enough time to review the report!
Thank you,
Mary and John West
3 Laguna Seca Court
St Helena, Ca. 94574
(707)227-7127
Sent from my iPhone
Agenda Item #5.10.

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1 Xinia Gamero
From: Maya DeRosa
Sent: Friday, October 28, 2022 10:57 AM
To: Xinia Gamero
Cc: Eric Norris
Subject: FW: [External] One week is not enough
Please see public comment below for the 11/1 meeting.

MAYA DEROSA, AICP

Thank you,
Mariam Hansen
5 San Lucas Ct
St. Helena
From: City of St Helena [mailto:[email protected]] Sent: Tuesday, October 25, 2022 11:00 AM
To: [email protected]
Subject: [St. Helena News Alerts] PRESS RELEASE | Hunter Subdivision Tentative Map application and Final EIR to be Considered bu Planning Commission November 1st
PRESS RELEASE | Hunter Subdivision Tentative Map application and Final EIR to be Considered bu Planning Commission November 1st

PRESS RELEASE
Agenda Item #5.10.

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2 TODAY’S DATE: October 24, 2022
RELEASE DATE: Immediate
TITLE: Hunter Subdivision Tentative Map application and Final EIR (Press Release 2022-36)
CONTACT: Maya DeRosa, Community Development Director
[email protected] (707) 967-2783
ST. HELENA, CA –
The City of St. Helena Community Development Department announces that the Hunter Subdivision Tentative Map application and Final EIR will be considered by the Planning Commission at a public hearing on November 1, 2022 at 6 pm. The public is welcome to attend the meeting at Vintage Hall (465 Main Street) or submit a public comment via email to [email protected]. To be considered at the Planning Commission meeting, written public comment should be submitted no later than 1 pm on November 1, 2022.

The agenda materials including the staff report and Final EIR may be viewed at the following link:
https://sthelena.civicweb.net/Portal/MeetingInformation.aspx?Org=Cal&Id=1010 A public viewing copy of the Final EIR may be found at City Hall (1572 Railroad Avenue) or the St. Helena Library starting on October 26th.

The original application to subdivide the 16.9 acre property located at the eastern terminus of Adams Avenue was filed in 2010 and over the years there has been public meetings to consider the residential subdivision project and Environmental Impact Report. Most recently, the updated Draft EIR that studied the impact of the 87 unit development at the minimum density of 5.1 dwelling units per acre was released for public review between September 23, 2021 and November 30, 2021 and the City conducted two public meetings to receive comments on the Draft EIR during that period. Responses have been prepared to all comment letters in the Final EIR.

The Planning Commission may only make a recommendation on the Tentative Map and Final EIR to the City Council. The City Council is the final decision-making body on the Tentative Map and Final EIR. At this point, a City Council date for action on this application has not been identified.

###

Please do not reply to this message. The email cannot accept inquires.

For more information about contacting the City of St. Helena, please visit our Contact Page: https://www.cityofsthelena.org/contact Unsubscribe
Agenda Item #5.10.

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3 Agenda Item #5.10.

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1 Xinia Gamero
From: Maya DeRosa
Sent: Friday, October 28, 2022 10:58 AM
To: Xinia Gamero
Cc: Eric Norris
Subject: FW: [External] Requesting more time!
Please see public comment below for the 11/1 meeting.

MAYA DEROSA, AICP

Life safety is my greatest concern. Where will the water that would fill the retention pond go once it is filled with houses?
Please consider giving use more time,
Thank you,
Kenneth A. Bergeron
19 San Lucas Ct
Sent from my iPhone.

Agenda Item #5.10.

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1 Xinia Gamero
From: Maya DeRosa
Sent: Friday, October 28, 2022 10:59 AM
To: Xinia Gamero
Cc: Eric Norris
Subject: FW: [External] Hunter Project EIR Report
Please see public comment below for the 11/1 agenda.

MAYA DEROSA, AICP

While not diametrically opposed to the Hunter Project, I have some concerns. As such, I am writing to request an extension of time to review the recently released Final EIR (FEIR) currently on the City website. This document which is over 2800 pages long, will require additional time for the Vineyard Valley leadership, and others, to explore.

I understand the Tentative Map application and Final EIR will be considered by the Planning Commission at a public hearing on November 1, 2022 at 6 pm. And that public comment is welcome at that time. In order to provide relevant and pertinent questions a thorough review must first be performed.

Your consideration is appreciated.

Thank you,
Denise Lloreda
Denise Lloreda
626-215-7466
Agenda Item #5.10.

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1 Xinia Gamero
From: Maya DeRosa
Sent: Friday, October 28, 2022 10:59 AM
To: Xinia Gamero
Cc: Eric Norris
Subject: FW: [External] EIR for Hunter Project
Please see public comment below on the 11/1 agenda.

MAYA DEROSA, AICP

COMMUNITY DEVELOPMENT DIRECTOR
City of St. Helena | Community Development Department
1572 Railroad Avenue | St. Helena, CA 94574
Direct: (707) 967-2783 | [email protected] | http://cityofsthelena.org/planning -----Original Message-----
From: Rhondda Grimm <[email protected]>
Sent: Thursday, October 27, 2022 11:57 AM
To: Maya DeRosa <[email protected]>
Cc: Tom Grimm <[email protected]>
Subject: [External] EIR for Hunter Project
Dear Ms. DeRosa,
My husband and I are requesting an extension of time in order to thoroughly review the 2800 page Final EIR document for the Hunter project. The project will have a huge impact on surrounding communities and St. Helena resources, so it needs more time than was given to us citizens to carefully assess the content.

Sincerely,
Tom and Rhondda Grimm
St. Helena
Sent from my iPhone
Agenda Item #5.10.

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1 Xinia Gamero
From: Maya DeRosa
Sent: Friday, October 28, 2022 11:07 AM
To: Xinia Gamero
Cc: Eric Norris
Subject: FW: [External] Hunter project
Please see public comment below for 11/1 agenda.

MAYA DEROSA, AICP

COMMUNITY DEVELOPMENT DIRECTOR
City of St. Helena | Community Development Department
1572 Railroad Avenue | St. Helena, CA 94574
Direct: (707) 967-2783 | [email protected] | http://cityofsthelena.org/planning From: [email protected] <[email protected]>
Sent: Thursday, October 27, 2022 11:56 AM
To: Maya DeRosa <[email protected]>
Cc: Cindy Tzafopoulos <[email protected]> Subject: [External] Hunter project
Hi Maya,
I would like to ask you to consider a continuance of the proposed Hunter project that is scheduled for review by the Planning Commission on November 1st. The public needs time to review the EIR and other documents including the 1993 and current General Plans. In view of the time required to review these documents I believe a continuance is definitely necessary.

Thank,
Grace D Kistne25
San Juan Court
St. Helena
Agenda Item #5.10.

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1 Xinia Gamero
From: Maya DeRosa
Sent: Friday, October 28, 2022 11:09 AM
To: Xinia Gamero
Cc: Joseph Leach; Eric Norris
Subject: FW: [External] Hunter Subdivision Tentative Map application and Final EIR Please see public comment below for the 11/1 agenda.

MAYA DEROSA, AICP

Resident of St Helena
John Galasso
Grove Ct
Agenda Item #5.10.

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1 Xinia Gamero
From: Cindy Tzafopoulos
Sent: Friday, October 28, 2022 2:53 PM
To: Xinia Gamero
Subject: FW: [External] The citizens of St Helena request and deserve an extension for the Hunter EIR
Public comment.

Thank you,
Cindy Tzafopoulos
City Clerk
City of St. Helena
*1572 Railroad Avenue – NEW ADDRESS!
St. Helena, CA 94574
Direct 707-968-2742 | Cell 707-312-1257
Fax 707-963-7748
[email protected]
www.cityofsthelena.org
*Please note that City Hall is closed to the public and will not answer calls from 12:00 to 1:00 pm for lunch. Please phone individual departments to make an appointment for service.

From: [email protected] <[email protected]>
Sent: Wednesday, October 26, 2022 1:32 PM
To: Cindy Tzafopoulos <[email protected]> Subject: [External] The citizens of St Helena request and deserve an extension for the Hunter EIR Hi Cindy,
Please forward my email to the Planning Director, City Manager, PC and CC. Thank you for your assistance as always.
------------------------------------------------------------------------------------------------------------------------- As a citizen of St Helena, I am requesting that an extension to review the extensive 2,000+ page FEIR report and Response to Comments (by St Helenans to the DRAFT EIR) be provided – a few reasons for this very fair and basic request are as follows:

Agenda Item #5.10.

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2 1) The Hunter FEIR document is over 2,000 pages in length. St Helenans are residents that work, have families and need more than a few days to review such a lengthy document.

The EIR authors had months and months to review our comments – are we not allowed to have the courtesy of more than a few days to review this extremely important document that will add 10% to our population and add significant risk behind our taxpayer-owned levee?
2) The City’s email of the PC Agenda had a broken link to the FEIR, and citizens were unable to access the FEIR. The Planning Director fixed the link this weekend after being notified by a citizen who was able to get through, but time to read the document was lost.
3) The document is now on the website, but it is Tuesday, which has again limited the time to review this document
4) There is no time to request public information that the FEIR refers to – for example, the EIR states that “the City has maintained the levee since the beginning”, but we know that is not true, because from a previous public records request, the City showed that they had indeed not maintained the levee, and still there are no records showing that on the website – please check for yourselves. We have requested access to the levee maintenance records since 2011 from the City Clerk but the link she provided has NO RECORDS ON THE PUBLIC WEBSITE SHOWING MAINTENANCE SINCE 2011 DESPITE THE CLAIM BY THE FEIR THAT RECORDS EXIST. How are citizens to verify this FEIR claim is true if we cannot access public information?
5) A general issue is in this request for this needed additional time is that Citizens have to be able to request proof of the FEIR claims when none has been provided, and cannot do that in a few days time, because the city cannot provide them. Citizens had no idea that the EIR would make claims this without demonstrating the validity, so the public has the right to request the documentation to support these unsupported claims.

Thank you for your attention to this matter and we hope the city of St Helena will ensure that citizens have sufficient time to review this document and time to get responses for records to verify FEIR claims, especially since St Helena city officials continue to stand on the principle of transparency in government. Many of us are also questioning why the name of the project that has been in place for over a decade “The Hunter Project” was not referenced in the city’s PC Agenda notice – people did not know it was this project, which as you know has been of great concern to many people. We certainly hope the Applicant did not request that it not be listed as such in an effort to make it unclear to the public, because it certainly did make it unclear to many. We appreciate your ongoing efforts to ensure transparency.

Agenda Item #5.10.

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3 Thank you City Council, Planning Commission and City Staff for your service to St Helena, Ann Nevero
Agenda Item #5.10.

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1 Xinia Gamero
From: Cindy Tzafopoulos
Sent: Friday, October 28, 2022 3:00 PM
To: Xinia Gamero
Subject: FW: [External] More Time to Review
Public comment
Thank you,
Cindy Tzafopoulos
City Clerk
City of St. Helena
*1572 Railroad Avenue – NEW ADDRESS!
St. Helena, CA 94574
Direct 707-968-2742 | Cell 707-312-1257
Fax 707-963-7748
[email protected]
www.cityofsthelena.org
*Please note that City Hall is closed to the public and will not answer calls from 12:00 to 1:00 pm for lunch. Please phone individual departments to make an appointment for service.

From: Gigi Batchelor <[email protected]>
Sent: Wednesday, October 26, 2022 4:11 PM
To: Cindy Tzafopoulos <[email protected]> Subject: [External] More Time to Review
Good afternoon Cindy!
As I resident of Vineyard Valley, I respectfully request more time to review the documents for the Hunter Project.

Thank you.

Gerilee (Gigi) Batchelor
11 Redondo Court
Saint Helena, Ca 94574
707/363-6343
Agenda Item #5.10.

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1 Xinia Gamero
From: Cindy Tzafopoulos
Sent: Friday, October 28, 2022 3:13 PM
To: Xinia Gamero
Subject: FW: Hunter Project EIR Review
Public comment
Thank you,

Cindy Tzafopoulos
City Clerk
City of St. Helena
*1572 Railroad Avenue – NEW ADDRESS!
St. Helena, CA 94574

Direct 707-968-2742 | Cell 707-312-1257
Fax 707-963-7748
[email protected]
www.cityofsthelena.org
*Please note that City Hall is closed to the public and will not answer calls from 12:00 to 1:00 pm for lunch. Please phone individual departments to make an appointment for service.

E-mail correspondence with the City of St. Helena (and attachments, if any) may be subject to the California Public Records Act, and as such may therefore be subject to public disclosure unless otherwise exempt under the Act. -----Original Message-----
From: David Armington <[email protected]>
Sent: Wednesday, October 26, 2022 4:46 PM
To: Cindy Tzafopoulos <[email protected]> Subject: [External] Hunter Project EIR Review
I am a resident of Vineyard Valley and I will be directly affected by the proposed development. Please allow additional time for me to study the documents before the hearings.

Respectfully,
Dave Armington
6 Del Monte Ct
St Helena
Sent from my iPad
Agenda Item #5.10.

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1 Xinia Gamero
From: Cindy Tzafopoulos
Sent: Friday, October 28, 2022 3:27 PM
To: Xinia Gamero
Subject: FW: [External] Request for continuance of Hunter Project - 11/1 Planning Comission Public comment
Thank you,
Cindy Tzafopoulos
City Clerk
City of St. Helena
*1572 Railroad Avenue – NEW ADDRESS!
St. Helena, CA 94574
Direct 707-968-2742 | Cell 707-312-1257
Fax 707-963-7748
[email protected]
www.cityofsthelena.org
*Please note that City Hall is closed to the public and will not answer calls from 12:00 to 1:00 pm for lunch. Please phone individual departments to make an appointment for service.

From: Megan Long <[email protected]>
Sent: Wednesday, October 26, 2022 6:22 PM
To: Cindy Tzafopoulos <[email protected]> Subject: [External] Request for continuance of Hunter Project - 11/1 Planning Comission Hi, I’m joining fellow residents to request a continuance of item 5.1 (Hunter Project) at the 11/1 Planning Commission in order to give citizens more time to review the complete 3,000-page EIR that was made publicly accessible over the past weekend. Thank you.

Best,
Megan Long
1337 Pine St
[email protected]
Agenda Item #5.10.

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1 Xinia Gamero
From: Cindy Tzafopoulos
Sent: Friday, October 28, 2022 3:31 PM
To: Xinia Gamero
Subject: FW: [External] Please extend our review time for the Hunter EIR Public comment
Thank you,

Cindy Tzafopoulos
City Clerk
City of St. Helena
*1572 Railroad Avenue – NEW ADDRESS!
St. Helena, CA 94574

E-mail correspondence with the City of St. Helena (and attachments, if any) may be subject to the California Public Records Act, and as such may therefore be subject to public disclosure unless otherwise exempt under the Act. -----Original Message-----
From: D and S Gmail <[email protected]>
Sent: Wednesday, October 26, 2022 7:02 PM
To: Cindy Tzafopoulos <[email protected]> Cc: Dave and Susanne Scott Gmail <[email protected]>
Subject: [External] Please extend our review time for the Hunter EIR It’s only fair and reasonable to enable those of us who bear financial responsibility for the safety of this proposed development to read, understand, and comment on its content.

Thank you for your consideration.

Sincerely,
Dave & Susanne Scott
Homeowners
843 Signorelli Circle
St Helena, CA
Sent from my iPhone
Agenda Item #5.10.

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1 Xinia Gamero
From: Cindy Tzafopoulos
Sent: Friday, October 28, 2022 3:32 PM
To: Xinia Gamero
Subject: FW: [External] Please delay Hunter hearing
Public comment
Thank you,

Cindy Tzafopoulos
City Clerk
City of St. Helena
*1572 Railroad Avenue – NEW ADDRESS!
St. Helena, CA 94574

E-mail correspondence with the City of St. Helena (and attachments, if any) may be subject to the California Public Records Act, and as such may therefore be subject to public disclosure unless otherwise exempt under the Act. -----Original Message-----
From: Susan McWilliams <[email protected]>
Sent: Wednesday, October 26, 2022 7:07 PM
To: Cindy Tzafopoulos <[email protected]> Subject: [External] Please delay Hunter hearing
This is an enormous project that demands input from all concerned citizens; access to the 3,000-page report and lots of time to read it. We have not been given nearly enough time.

Thank you.

Susan McWilliams
Sent from my iPhone
Agenda Item #5.10.

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1 Xinia Gamero
From: Cindy Tzafopoulos
Sent: Friday, October 28, 2022 3:34 PM
To: Xinia Gamero
Subject: FW: [External] Extension
Public comment
Thank you,

Cindy Tzafopoulos
City Clerk
City of St. Helena
*1572 Railroad Avenue – NEW ADDRESS!
St. Helena, CA 94574

E-mail correspondence with the City of St. Helena (and attachments, if any) may be subject to the California Public Records Act, and as such may therefore be subject to public disclosure unless otherwise exempt under the Act. -----Original Message-----
From: [email protected] <[email protected]> Sent: Wednesday, October 26, 2022 7:08 PM
To: Cindy Tzafopoulos <[email protected]> Subject: [External] Extension
Dear Cindy
It would be helpful i we could get an extension. I know the PC is anxious to bring this to closure yet the time to review the total document is quite limited.

Thank you for your consideration if this request.

Sandra 0. Archibald
Dean and Professor Emerita
Evans School of Public Policy & Governance University of Washington Box 353055 Seattle, WA 98195 Home address
Sandra Archibald McCorkle
1178 Meadowcreek Circle
St . Helena, CA 94574
Agenda Item #5.10.

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2 707.804.8263
Agenda Item #5.10.

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1 Xinia Gamero
From: Cindy Tzafopoulos
Sent: Friday, October 28, 2022 3:34 PM
To: Xinia Gamero
Subject: FW: [External] Hunter EIR
Public comment
Thank you,
Cindy Tzafopoulos
City Clerk
City of St. Helena
*1572 Railroad Avenue – NEW ADDRESS!
St. Helena, CA 94574
Direct 707-968-2742 | Cell 707-312-1257
Fax 707-963-7748
[email protected]
www.cityofsthelena.org
*Please note that City Hall is closed to the public and will not answer calls from 12:00 to 1:00 pm for lunch. Please phone individual departments to make an appointment for service.

From: Elaine de Man <[email protected]>
Sent: Wednesday, October 26, 2022 7:13 PM
To: Cindy Tzafopoulos <[email protected]> Subject: [External] Hunter EIR
Hi Cindy,
Please request that the Planning Commission postpone the review of the Hunter EIR for at least a month so that the community has an opportunity to review it.

Thank you,
Elaine de Man
Agenda Item #5.10.

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1 Xinia Gamero
From: Cindy Tzafopoulos
Sent: Friday, October 28, 2022 3:34 PM
To: Xinia Gamero
Subject: FW: [External] Hunter Project
Public comment.

From: Ester Akersloot <[email protected]>
Sent: Wednesday, October 26, 2022 7:41 PM
To: Cindy Tzafopoulos <[email protected]> Subject: [External] Hunter Project
Dear Cindy,
Please extend the Hunter EIR so citizens have a reasonable time to review this nearly 3,000 page document . Thank you.

Sincerely,
Ester Akersloot
St. Helena
Agenda Item #5.10.

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1 Xinia Gamero
From: Cindy Tzafopoulos
Sent: Friday, October 28, 2022 3:35 PM
To: Xinia Gamero
Subject: FW: [External] Hunter
Public comment
Thank you,

Cindy Tzafopoulos
City Clerk
City of St. Helena
*1572 Railroad Avenue – NEW ADDRESS!
St. Helena, CA 94574

E-mail correspondence with the City of St. Helena (and attachments, if any) may be subject to the California Public Records Act, and as such may therefore be subject to public disclosure unless otherwise exempt under the Act. -----Original Message-----
From: Bernerd Buckley <[email protected]>
Sent: Wednesday, October 26, 2022 8:23 PM
To: Cindy Tzafopoulos <[email protected]> Subject: [External] Hunter
I would like more time to review the documents on the Hunter project Sent from my iPhone
Agenda Item #5.10.

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1 Xinia Gamero
From: Cindy Tzafopoulos
Sent: Friday, October 28, 2022 3:36 PM
To: Xinia Gamero
Subject: FW: [External] Hunter EIR
Public comment
Thank you,

Cindy Tzafopoulos
City Clerk
City of St. Helena
*1572 Railroad Avenue – NEW ADDRESS!
St. Helena, CA 94574

E-mail correspondence with the City of St. Helena (and attachments, if any) may be subject to the California Public Records Act, and as such may therefore be subject to public disclosure unless otherwise exempt under the Act. -----Original Message-----
From: Henry Gundling <[email protected]>
Sent: Wednesday, October 26, 2022 9:09 PM
To: Cindy Tzafopoulos <[email protected]> Subject: [External] Hunter EIR
Please extend the review period for the Hunter EIR. Ten days for review of a roughly 3,000 page document is grossly inadequate.

Thank you,
Henry Gundling
Sent from my iPhone
Agenda Item #5.10.

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1 Xinia Gamero
From: Cindy Tzafopoulos
Sent: Friday, October 28, 2022 3:37 PM
To: Xinia Gamero
Subject: FW: [External] Hunter project review
Public comment
Thank you,

Cindy Tzafopoulos
City Clerk
City of St. Helena
*1572 Railroad Avenue – NEW ADDRESS!
St. Helena, CA 94574

E-mail correspondence with the City of St. Helena (and attachments, if any) may be subject to the California Public Records Act, and as such may therefore be subject to public disclosure unless otherwise exempt under the Act. -----Original Message-----
From: Larry Vermeulen <[email protected]>
Sent: Wednesday, October 26, 2022 9:57 PM
To: Cindy Tzafopoulos <[email protected]> Subject: [External] Hunter project review
Cindy,
The public review period for the Hunter project is entirely too short for a project of this magnitude. Please extend the review period for 30 days to allow for proper public review.

Thank you,
Larry Vermeulen
Sent from my iPhone
Agenda Item #5.10.

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1 Xinia Gamero
From: Cindy Tzafopoulos
Sent: Friday, October 28, 2022 3:37 PM
To: Xinia Gamero
Subject: FW: [External] Hunter Project
Public comment
Thank you,
Cindy Tzafopoulos
City Clerk
City of St. Helena
*1572 Railroad Avenue – NEW ADDRESS!
St. Helena, CA 94574
Direct 707-968-2742 | Cell 707-312-1257
Fax 707-963-7748
[email protected]
www.cityofsthelena.org
*Please note that City Hall is closed to the public and will not answer calls from 12:00 to 1:00 pm for lunch. Please phone individual departments to make an appointment for service.

From: Gayle Davies <[email protected]>
Sent: Wednesday, October 26, 2022 11:14 PM
To: Cindy Tzafopoulos <[email protected]> Subject: [External] Hunter Project
Due to the length of the EIR as well as the difficulty in reading the comments, I ask that we be granted an extension of time for proper review.

Thank you,
Gayle Davies
St Helena resident
Agenda Item #5.10.

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1 Xinia Gamero
From: Cindy Tzafopoulos
Sent: Friday, October 28, 2022 3:38 PM
To: Xinia Gamero
Subject: FW: [External] Hunter project
Public comment
Thank you,
Cindy Tzafopoulos
City Clerk
City of St. Helena
*1572 Railroad Avenue – NEW ADDRESS!
St. Helena, CA 94574
Direct 707-968-2742 | Cell 707-312-1257
Fax 707-963-7748
[email protected]
www.cityofsthelena.org
*Please note that City Hall is closed to the public and will not answer calls from 12:00 to 1:00 pm for lunch. Please phone individual departments to make an appointment for service.

From: Holly <[email protected]>
Sent: Wednesday, October 26, 2022 11:50 PM
To: Cindy Tzafopoulos <[email protected]> Subject: [External] Hunter project
I request an extension to the Hunter EIR so citizens have a reasonable time to review this nearly 3,000 page document.

Thank you,
Holly Rogers
Sent from the all new AOL app for Android
Agenda Item #5.10.

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1 Xinia Gamero
From: Cindy Tzafopoulos
Sent: Friday, October 28, 2022 3:39 PM
To: Xinia Gamero
Subject: FW: [External] Hunter EPA
Public comment
Thank you,
Cindy Tzafopoulos
City Clerk
City of St. Helena
*1572 Railroad Avenue – NEW ADDRESS!
St. Helena, CA 94574
Direct 707-968-2742 | Cell 707-312-1257
Fax 707-963-7748
[email protected]
www.cityofsthelena.org
*Please note that City Hall is closed to the public and will not answer calls from 12:00 to 1:00 pm for lunch. Please phone individual departments to make an appointment for service.

From: Peter McClory <[email protected]>
Sent: Thursday, October 27, 2022 6:55 AM
To: Cindy Tzafopoulos <[email protected]> Cc: Ann Nevero <[email protected]>; Holly Mason <[email protected]> Subject: [External] Hunter EPA
Please extend the time allotted for review of the Hunter EPA report. It is complicated and reviews multiple aspects of St Helena that could be adversely effected by the project.

Thank you,
Pete McClory
813 Signorelli Circle
SH 94574
Agenda Item #5.10.

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1 Xinia Gamero
From: Cindy Tzafopoulos
Sent: Friday, October 28, 2022 3:40 PM
To: Xinia Gamero
Subject: FW: [External] Extension request
Public comment
Thank you,
Cindy Tzafopoulos
City Clerk
City of St. Helena
*1572 Railroad Avenue – NEW ADDRESS!
St. Helena, CA 94574
Direct 707-968-2742 | Cell 707-312-1257
Fax 707-963-7748
[email protected]
www.cityofsthelena.org
*Please note that City Hall is closed to the public and will not answer calls from 12:00 to 1:00 pm for lunch. Please phone individual departments to make an appointment for service.

From: Lisa Pelosi <[email protected]>
Sent: Thursday, October 27, 2022 7:11 AM
To: Cindy Tzafopoulos <[email protected]> Subject: [External] Extension request
Hello,
Please, please please …I respectfully request an extension to the Hunter EIR so that citizens have reasonable time to review a 3000 PAGE document.

More time is necessary for full transparency of the issue before the community potentially is effected by this project.

Thank you.

Sincerely,
Lisa Pelosi
Honeydew Estate Mgmt
415-602-9176
Sent from my iPhone, pardon the typos
Agenda Item #5.10.

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1 Xinia Gamero
From: Cindy Tzafopoulos
Sent: Friday, October 28, 2022 3:40 PM
To: Xinia Gamero
Subject: FW: [External] Request of time extension for Hunter Project Document Review Public comment
Thank you,
Cindy Tzafopoulos
City Clerk
City of St. Helena
*1572 Railroad Avenue – NEW ADDRESS!
St. Helena, CA 94574
Direct 707-968-2742 | Cell 707-312-1257
Fax 707-963-7748
[email protected]
www.cityofsthelena.org
*Please note that City Hall is closed to the public and will not answer calls from 12:00 to 1:00 pm for lunch. Please phone individual departments to make an appointment for service.

From: Christopher Smith <[email protected]> Sent: Thursday, October 27, 2022 7:30 AM
To: Cindy Tzafopoulos <[email protected]> Subject: [External] Request of time extension for Hunter Project Document Review Greetings:

May you kindly extend the time frame for citizens of Saint Helena to read the related documents of the Hunters Project prior to meeting.

Thanks for your consideration.

Chris Smith
Agenda Item #5.10.

Page 4108 of 4422 ends

1 Xinia Gamero
From: Cindy Tzafopoulos
Sent: Friday, October 28, 2022 3:40 PM
To: Xinia Gamero
Subject: FW: [External] Hunter EIR
Public comment
Thank you,

Cindy Tzafopoulos
City Clerk
City of St. Helena
*1572 Railroad Avenue – NEW ADDRESS!
St. Helena, CA 94574

E-mail correspondence with the City of St. Helena (and attachments, if any) may be subject to the California Public Records Act, and as such may therefore be subject to public disclosure unless otherwise exempt under the Act. -----Original Message-----
From: Russell Gold <[email protected]>
Sent: Thursday, October 27, 2022 7:39 AM
To: Cindy Tzafopoulos <[email protected]> Subject: [External] Hunter EIR
Good Morning,
This is a request for an extension to the Hunter EIR. As you are well aware there have been numerous issues with access and readability of the document.

Thank you
Russell Gold
1192 Meadowcreek
Agenda Item #5.10.

Page 4109 of 4422 ends

1 Xinia Gamero
From: Cindy Tzafopoulos
Sent: Friday, October 28, 2022 3:41 PM
To: Xinia Gamero
Subject: FW: [External] Hunter Project
Public comment
Thank you,

Cindy Tzafopoulos
City Clerk
City of St. Helena
*1572 Railroad Avenue – NEW ADDRESS!
St. Helena, CA 94574

E-mail correspondence with the City of St. Helena (and attachments, if any) may be subject to the California Public Records Act, and as such may therefore be subject to public disclosure unless otherwise exempt under the Act. -----Original Message-----
From: Sandra Lowry <[email protected]>
Sent: Thursday, October 27, 2022 8:42 AM
To: Cindy Tzafopoulos <[email protected]> Subject: [External] Hunter Project
Dear Cindy,
The Hunter project document is nearly 3,000 pages. Nov. 1st will not give the public enough time to read the document. I respectfully request an extension of time. Thank you. Sandra Lowry, 1175 Starr Avenue.

Agenda Item #5.10.

Page 4110 of 4422 ends

1 Xinia Gamero
From: Cindy Tzafopoulos
Sent: Friday, October 28, 2022 3:42 PM
To: Xinia Gamero
Subject: FW: [External] please extend time to review St Helena housing project Public comment
Thank you,
Cindy Tzafopoulos
City Clerk
City of St. Helena
*1572 Railroad Avenue – NEW ADDRESS!
St. Helena, CA 94574
Direct 707-968-2742 | Cell 707-312-1257
Fax 707-963-7748
[email protected]
www.cityofsthelena.org
*Please note that City Hall is closed to the public and will not answer calls from 12:00 to 1:00 pm for lunch. Please phone individual departments to make an appointment for service.

From: Lisa Goldfarb <[email protected]>
Sent: Thursday, October 27, 2022 9:09 AM
To: Cindy Tzafopoulos <[email protected]> Subject: [External] please extend time to review St Helena housing project Hi there,
I don't know how quickly you ready, or if you have other obligations in your day to day life, but, for the majority of people, understanding dense text slows reading speed down to around 20 pages an hour.

Given this is a 3000 page document, and it needs careful attention to what is being proposed, an adequate amount of time to review it would be approximately 150 hours.

Seeing as people sleep, eat, and have other jobs or obligations throughout their day, asking someone to spend 4-5 solid hours/day reading this text seems doable. this would break down to around 33 days to just get through the text.

I would ask that we are given at least that much time to review this document. thank you,
Lisa Goldfarb
Agenda Item #5.10.

Page 4111 of 4422 ends

1 Xinia Gamero
From: Cindy Tzafopoulos
Sent: Friday, October 28, 2022 3:42 PM
To: Xinia Gamero
Subject: FW: [External] Hunter Project
Public comment
Thank you,
Cindy Tzafopoulos
City Clerk
City of St. Helena
*1572 Railroad Avenue – NEW ADDRESS!
St. Helena, CA 94574
Direct 707-968-2742 | Cell 707-312-1257
Fax 707-963-7748
[email protected]
www.cityofsthelena.org
*Please note that City Hall is closed to the public and will not answer calls from 12:00 to 1:00 pm for lunch. Please phone individual departments to make an appointment for service.

From: Dyan Beito <[email protected]>
Sent: Thursday, October 27, 2022 9:19 AM
To: Cindy Tzafopoulos <[email protected]> Subject: [External] Hunter Project
Dear City Clerk,
I'm a 20+ year resident of St Helena so I've follow this project form the beginning. With that in mine I would like the time to review the 3000 page document posted to the website. However one I wasn't able to get it downloaded and two you have not given enough time with the Nov 1 meeting, for a complete review.

Therefore I firmly believe an extension should be given to give all residents a chance to review this important document.

Respectfully,
Dyan Beito
707 Hunt Ave, St Helena, CA 94574
Agenda Item #5.10.

Page 4112 of 4422 ends

1 Xinia Gamero
From: Cindy Tzafopoulos
Sent: Friday, October 28, 2022 3:42 PM
To: Xinia Gamero
Subject: FW: [External] Hunter project
Public comment
Thank you,
Cindy Tzafopoulos
City Clerk
City of St. Helena
*1572 Railroad Avenue – NEW ADDRESS!
St. Helena, CA 94574
Direct 707-968-2742 | Cell 707-312-1257
Fax 707-963-7748
[email protected]
www.cityofsthelena.org
*Please note that City Hall is closed to the public and will not answer calls from 12:00 to 1:00 pm for lunch. Please phone individual departments to make an appointment for service.

From: Paula Goyins <[email protected]>
Sent: Thursday, October 27, 2022 9:53 AM
To: Cindy Tzafopoulos <[email protected]> Subject: [External] Hunter project
We need more time to read and understand the magnitude of this undertaking! Roger and Paula Goyins Sent from Yahoo Mail for iPad
Agenda Item #5.10.

Page 4113 of 4422 ends

1 Xinia Gamero
From: Cindy Tzafopoulos
Sent: Friday, October 28, 2022 3:43 PM
To: Xinia Gamero
Subject: FW: [External] Hunter Project
Public comment
Thank you,
Cindy Tzafopoulos
City Clerk
City of St. Helena
*1572 Railroad Avenue – NEW ADDRESS!
St. Helena, CA 94574
Direct 707-968-2742 | Cell 707-312-1257
Fax 707-963-7748
[email protected]
www.cityofsthelena.org
*Please note that City Hall is closed to the public and will not answer calls from 12:00 to 1:00 pm for lunch. Please phone individual departments to make an appointment for service.

From: Elizabeth Green <[email protected]>
Sent: Thursday, October 27, 2022 9:56 AM
To: Cindy Tzafopoulos <[email protected]> Subject: [External] Hunter Project
My husband and I live in Vineyard Valley. The ramifications of the Hunter Project are extremely concerning and even more concerning is the difficulty to access the final EIR which is over 2000 pages. We are asking for an extension in order to review this document.

Thank you.

Rodney & Elizabeth Green
Agenda Item #5.10.

Page 4114 of 4422 ends

1 Xinia Gamero
From: Cindy Tzafopoulos
Sent: Friday, October 28, 2022 4:52 PM
To: Xinia Gamero
Subject: FW: [External] Hunter Project/EIR
Public comment
Thank you,

Cindy Tzafopoulos
City Clerk
City of St. Helena
1572 Railroad Avenue
St. Helena, CA 94574

Direct 707-968-2742 | Cell 707-312-1257
Fax 707-963-7748
[email protected]
www.cityofsthelena.org
Office Hours:

Monday – Friday
9:00 a.m. – 4:00 p.m.

Closed for Lunch between 12:00 – 1:00 p.m.

E-mail correspondence with the City of St. Helena (and attachments, if any) may be subject to the California Public Records Act, and as such may therefore be subject to public disclosure unless otherwise exempt under the Act. -----Original Message-----
From: Diana L <[email protected]>
Sent: Thursday, October 27, 2022 10:19 AM
To: Cindy Tzafopoulos <[email protected]> Subject: [External] Hunter Project/EIR
Please give the community more time to study this report before pushing through approval - Thank you, Diana Lavagnino
Agenda Item #5.10.

Page 4115 of 4422 ends

1 Xinia Gamero
From: Cindy Tzafopoulos
Sent: Friday, October 28, 2022 4:53 PM
To: Xinia Gamero
Subject: FW: [External] Extension
Public comment
Thank you,
Cindy Tzafopoulos
City Clerk
City of St. Helena
1572 Railroad Avenue
St. Helena, CA 94574
Direct 707-968-2742 | Cell 707-312-1257
Fax 707-963-7748
[email protected]
www.cityofsthelena.org
Office Hours:

Monday – Friday
9:00 a.m. – 4:00 p.m.

Closed for Lunch between 12:00 – 1:00 p.m.

From: Mary Gundling <[email protected]>
Sent: Thursday, October 27, 2022 10:27 AM
To: Cindy Tzafopoulos <[email protected]> Subject: [External] Extension
Please grant an extension, so we have time to read the complete EIR.

Thank you.

Mary and Henry Gundling
1185 Meadowcreek Circle
St. Helena
Agenda Item #5.10.

Page 4116 of 4422 ends

1 Xinia Gamero
From: Cindy Tzafopoulos
Sent: Friday, October 28, 2022 4:53 PM
To: Xinia Gamero
Subject: FW: [External] Hunter Subdivision - Urgent Request Public comment
Thank you,
Cindy Tzafopoulos
City Clerk
City of St. Helena
1572 Railroad Avenue
St. Helena, CA 94574
Direct 707-968-2742 | Cell 707-312-1257
Fax 707-963-7748
[email protected]
www.cityofsthelena.org
Office Hours:

Monday – Friday
9:00 a.m. – 4:00 p.m.

Closed for Lunch between 12:00 – 1:00 p.m.

From: K'lyn Matthews <[email protected]>
Sent: Thursday, October 27, 2022 10:50 AM
To: Maya DeRosa <[email protected]>; Cindy Tzafopoulos <[email protected]> Subject: [External] Hunter Subdivision - Urgent Request I would like to request an extension of time to review the Final EIR (FEIR) currently on the City website.At over 2800 pages long, I require additional time to explore this important document.

Please provide a reasonable window for review of the Tentative Map application and Final EIR to be considered by the Planning Commission at a public hearing.

Thank you,
Kristi Lyn Matthews
14 Redondo Ct, St Helena, CA 94574
Agenda Item #5.10.

Page 4117 of 4422 ends

1 Xinia Gamero
From: Cindy Tzafopoulos
Sent: Friday, October 28, 2022 4:53 PM
To: Xinia Gamero
Subject: FW: [External] Hunter Project
Public comment
Thank you,
Cindy Tzafopoulos
City Clerk
City of St. Helena
1572 Railroad Avenue
St. Helena, CA 94574
Direct 707-968-2742 | Cell 707-312-1257
Fax 707-963-7748
[email protected]
www.cityofsthelena.org
Office Hours:

Monday – Friday
9:00 a.m. – 4:00 p.m.

Closed for Lunch between 12:00 – 1:00 p.m.

From: Bette Antor <[email protected]>
Sent: Thursday, October 27, 2022 10:53 AM
To: Cindy Tzafopoulos <[email protected]> Subject: [External] Hunter Project
In light of the Final EIR consisting of 2800 pages, please reschedule the November 1 meeting to a later date to ensure our ability to read the voluminous document.

It’s the right thing to do.

Bette Antor
Agenda Item #5.10.

Page 4118 of 4422 ends

1 Xinia Gamero
From: Cindy Tzafopoulos
Sent: Friday, October 28, 2022 4:53 PM
To: Xinia Gamero
Subject: FW: [External] Request for extension of time for review of EIR Public comment
Thank you,
Cindy Tzafopoulos
City Clerk
City of St. Helena
1572 Railroad Avenue
St. Helena, CA 94574
Direct 707-968-2742 | Cell 707-312-1257
Fax 707-963-7748
[email protected]
www.cityofsthelena.org
Office Hours:

Monday – Friday
9:00 a.m. – 4:00 p.m.

Closed for Lunch between 12:00 – 1:00 p.m.

From: ELLEN COTTEN <[email protected]>
Sent: Thursday, October 27, 2022 11:01 AM
To: Cindy Tzafopoulos <[email protected]> Subject: [External] Request for extension of time for review of EIR Due to the length of the most recent Hunter EIR I am requesting an extension of time to review the document.

Ellen Cotten
1 Del Rio Ct
Agenda Item #5.10.

Page 4119 of 4422 ends

1 Xinia Gamero
From: Cindy Tzafopoulos
Sent: Friday, October 28, 2022 4:55 PM
To: Xinia Gamero
Subject: FW: [External] FEIR
Public comment
Thank you,

Cindy Tzafopoulos
City Clerk
City of St. Helena
1572 Railroad Avenue
St. Helena, CA 94574

Direct 707-968-2742 | Cell 707-312-1257
Fax 707-963-7748
[email protected]
www.cityofsthelena.org
Office Hours:

Monday – Friday
9:00 a.m. – 4:00 p.m.

Closed for Lunch between 12:00 – 1:00 p.m.

E-mail correspondence with the City of St. Helena (and attachments, if any) may be subject to the California Public Records Act, and as such may therefore be subject to public disclosure unless otherwise exempt under the Act. -----Original Message-----
From: Dottie Gingerelli <[email protected]>
Sent: Thursday, October 27, 2022 11:33 AM
To: Cindy Tzafopoulos <[email protected]> Subject: [External] FEIR
Ms. Tzafopoulos,
I’m contacting you to request an extension of time to review the Final EIR (FEIR) currently on the City website.

Recently released, this document which is over 2800 pages long, will require additional time to explore.

Thank You,
Dottie Gingerelli
50 Laguna Seca Ct
St Helena, CA 94574
[email protected]
Sent from my iPhone
Agenda Item #5.10.

Page 4120 of 4422 ends

1 Xinia Gamero
From: Cindy Tzafopoulos
Sent: Friday, October 28, 2022 4:56 PM
To: Xinia Gamero
Subject: FW: We need a time extension!!!
Public comment
Thank you,
Cindy Tzafopoulos
City Clerk
City of St. Helena
1572 Railroad Avenue
St. Helena, CA 94574
Direct 707-968-2742 | Cell 707-312-1257
Fax 707-963-7748
[email protected]
www.cityofsthelena.org
Office Hours:

Monday – Friday
9:00 a.m. – 4:00 p.m.

Closed for Lunch between 12:00 – 1:00 p.m.

From: John West <[email protected]>
Sent: Thursday, October 27, 2022 11:58 AM
To: Cindy Tzafopoulos <[email protected]> Cc: John West <[email protected]>; Mary Thomas West <[email protected]> Subject: [External] We need a time extension!!!
I am a primary homeowner here in St. Helena. Giving the people of SH just 10 days to review this huge EIR for the Hunter Subdivision is RIDICULOUS. We all need more time. I request that the city grant at least a 60 day extension before the next hearing on this project.

John West l Senior Loan Officer l NMLS# 247892
First Class Lending, a division of
American Pacific Mortgage
MBA, Finance / Honors Graduate, Stanford Graduate School of Credit and Finance Direct: (949) 500-3424 or (707) 310-8535 Email: [email protected] Send me a file securely: Click Here
Agenda Item #5.10.

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2 Confidential: This electronic message and all contents contain information from American Pacific Mortgage Corporation which may be privileged or confidential. The information is intended for the individual or entity named above. If you are not the intended recipient, be aware that any disclosure, copying, distribution or use of the contents of this information is prohibited. If you have received this electronic message in error, please notify the sender by reply e-mail and destroy the original message and all copies.

Alert: For your protection and our customer's data security, we remind you that this is an unsecured email service that is not intended for sending confidential or sensitive information. Please do not include social security numbers, account numbers, or any other personal or financial information in the content of the email when you respond.

Agenda Item #5.10.

Page 4122 of 4422 ends

1 Xinia Gamero
From: Cindy Tzafopoulos
Sent: Friday, October 28, 2022 4:58 PM
To: Xinia Gamero
Subject: FW: [External] Hunter st.

Public comment
Thank you,

Cindy Tzafopoulos
City Clerk
City of St. Helena
1572 Railroad Avenue
St. Helena, CA 94574

Direct 707-968-2742 | Cell 707-312-1257
Fax 707-963-7748
[email protected]
www.cityofsthelena.org
Office Hours:

Monday – Friday
9:00 a.m. – 4:00 p.m.

Closed for Lunch between 12:00 – 1:00 p.m.

Please allow more time to review the EIR report on the hunter st. Project, as the impact of building on a flood plain may have serious impact on where I’m living. Thank you Calie Candia Vineyard Valley resident.

Sent from my iPad
Agenda Item #5.10.

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1 Xinia Gamero
From: Cindy Tzafopoulos
Sent: Friday, October 28, 2022 5:00 PM
To: Xinia Gamero
Subject: FW: [External] Extension To the Hunter EIR
Public comment
Thank you,
Cindy Tzafopoulos
City Clerk
City of St. Helena
1572 Railroad Avenue
St. Helena, CA 94574
Direct 707-968-2742 | Cell 707-312-1257
Fax 707-963-7748
[email protected]
www.cityofsthelena.org
Office Hours:

Monday – Friday
9:00 a.m. – 4:00 p.m.

Closed for Lunch between 12:00 – 1:00 p.m.

From: Andi Brown <[email protected]>
Sent: Thursday, October 27, 2022 1:48 PM
To: Cindy Tzafopoulos <[email protected]> Subject: [External] Extension To the Hunter EIR
I am writing as a concerned citizen of St. Helena to ask for an extension for the EIR document.

Sincerely,
Adrianna Didion-Brown
1174 Meadowcreek Circle
St. Helena, Ca 94574
Agenda Item #5.10.

Page 4124 of 4422 ends

1 Xinia Gamero
From: Cindy Tzafopoulos
Sent: Friday, October 28, 2022 5:06 PM
To: Xinia Gamero
Subject: FW: Extension
Public comment
Thank you,

Cindy Tzafopoulos
City Clerk
City of St. Helena
1572 Railroad Avenue
St. Helena, CA 94574

Direct 707-968-2742 | Cell 707-312-1257
Fax 707-963-7748
[email protected]
www.cityofsthelena.org
Office Hours:

Monday – Friday
9:00 a.m. – 4:00 p.m.

Closed for Lunch between 12:00 – 1:00 p.m.

E-mail correspondence with the City of St. Helena (and attachments, if any) may be subject to the California Public Records Act, and as such may therefore be subject to public disclosure unless otherwise exempt under the Act. -----Original Message-----
From: Joel Toller <[email protected]>
Sent: Thursday, October 27, 2022 2:37 PM
To: Cindy Tzafopoulos <[email protected]> Subject: [External] Extension
To whom in may concern. I would like to request that the city postpone making any decisions on the Hunter property until sufficient time has been provided to review the 3000 page document by the citizens of St Helena.

Thank you, Joel Toller
DRE#01259088
707-738-6860
[email protected]
Agenda Item #5.10.

Page 4125 of 4422 ends

1 Xinia Gamero
From: Cindy Tzafopoulos
Sent: Friday, October 28, 2022 5:13 PM
To: Xinia Gamero
Subject: FW: [External] Hunter Project Comment and Request for delay Public comment
Thank you,
Cindy Tzafopoulos
City Clerk
City of St. Helena
1572 Railroad Avenue
St. Helena, CA 94574
Direct 707-968-2742 | Cell 707-312-1257
Fax 707-963-7748
[email protected]
www.cityofsthelena.org
Office Hours:

Monday – Friday
9:00 a.m. – 4:00 p.m.

Closed for Lunch between 12:00 – 1:00 p.m.

From: Kelly Wheaton <[email protected]>
Sent: Thursday, October 27, 2022 3:37 PM
To: Cindy Tzafopoulos <[email protected]>; Geoff Ellsworth <[email protected]>; Paul Dohring <[email protected]>; Autumn Anderson <[email protected]>; Daniel Hale <[email protected]>; Aaron Hecock <[email protected]>; Rosaura Segura <[email protected]>; John Ponte <[email protected]>; Eric Hall <[email protected]>; Anna Chouteau <[email protected]>; Christopher Warner <[email protected]>; Lester Hardy <[email protected]>; Marika Rothfeld <[email protected]> Subject: [External] Hunter Project Comment and Request for delay Request for delay so that The EIR can be properly vetted.

Dear Staff, Mayor Ellsworth, Councilmembers, Planning Commissioners and Consultants, Aside from the fallacious water offsets to achieve miraculous water neutrality, it is obvious that no one has calculated the increased liability to the City of St Helena should the levee ever fail.

Please read this study by UC Davis before making any decisions. https://www.ucdavis.edu/news/behind-levee "People living behind levees on floodplains may not be as immune to flood damage as they think, according to results Agenda Item #5.10.

Page 4126 of 4422 ends

2 of a study led by the University of California, Davis. Levees often prevent costly flood damages and even loss of life. However, when those levees overtop or fail, and water spills onto the floodplain, the long-term damage can be far worse than if those levees were not there, the study found." Having a levee does not miraculously turn a floodplain into a safe building site. I am happy for Vineyard Valley residents that the levee has made them safer in the short term. However, putting more residences behind a levee increases St Helena's risk should there be a catastrophic failure. From what I have been able to read the EIR does not adequately address this from the standpoint of the City's risk.

Sincerely,
Kelly Wheaton
Inglewood
707-963-9609
Agenda Item #5.10.

Page 4127 of 4422 ends

1 Xinia Gamero
From: Cindy Tzafopoulos
Sent: Friday, October 28, 2022 5:14 PM
To: Xinia Gamero
Subject: FW: Hunter Project
Public comment
Thank you,
Cindy Tzafopoulos
City Clerk
City of St. Helena
1572 Railroad Avenue
St. Helena, CA 94574
Direct 707-968-2742 | Cell 707-312-1257
Fax 707-963-7748
[email protected]
www.cityofsthelena.org
Office Hours:

Monday – Friday
9:00 a.m. – 4:00 p.m.

Closed for Lunch between 12:00 – 1:00 p.m.

From: Schlatter, Laurence <[email protected]>
Sent: Thursday, October 27, 2022 3:47 PM
To: Cindy Tzafopoulos <[email protected]> Subject: [External] Hunter Project
Hello!
With this email, we would like to request an extension to the Hunter Project EIR in order to have a reasonable amount of time to review the nearly 3,000 page document.

As a resident of Starr Avenue, we are deeply concerned with the negative impact of such a massive development on a flood plain right next to our neighborhood.

Sincerely,
Laurence and Rene Schlatter
1183 Starr Avenue
Agenda Item #5.10.

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2 Agenda Item #5.10.

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1 Xinia Gamero
From: Maya DeRosa
Sent: Friday, October 28, 2022 5:18 PM
To: Xinia Gamero
Cc: Eric Norris
Subject: FW: [External] Hunter Subdivision
Please see comment below.

MAYA DEROSA, AICP

Thank You
Greg Nelson
Agenda Item #5.10.

Page 4130 of 4422 ends

1 Xinia Gamero
From: Cindy Tzafopoulos
Sent: Friday, October 28, 2022 5:27 PM
To: Xinia Gamero
Subject: FW: [External] request extension to the Hunter EIR Public comment
Thank you,
Cindy Tzafopoulos
City Clerk
City of St. Helena
1572 Railroad Avenue
St. Helena, CA 94574
Direct 707-968-2742 | Cell 707-312-1257
Fax 707-963-7748
[email protected]
www.cityofsthelena.org
Office Hours:

Monday – Friday
9:00 a.m. – 4:00 p.m.

Closed for Lunch between 12:00 – 1:00 p.m.

From: [email protected] <[email protected]>
Sent: Thursday, October 27, 2022 7:00 PM
To: Cindy Tzafopoulos <[email protected]> Subject: [External] request extension to the Hunter EIR Hello Cindy,
I’d like to Request an extension to the Hunter EIR.

This is a huge document and needs time to be digested by the community.

Thank you,
Valli Ferrell
780 Chiles Ave.

SH, CA
Agenda Item #5.10.

Page 4131 of 4422 ends

1 Xinia Gamero
From: Cindy Tzafopoulos
Sent: Friday, October 28, 2022 5:28 PM
To: Xinia Gamero
Subject: FW: [External] Final EIR
Public comment
Thank you,

Cindy Tzafopoulos
City Clerk
City of St. Helena
1572 Railroad Avenue
St. Helena, CA 94574

Direct 707-968-2742 | Cell 707-312-1257
Fax 707-963-7748
[email protected]
www.cityofsthelena.org
Office Hours:

Monday – Friday
9:00 a.m. – 4:00 p.m.

Closed for Lunch between 12:00 – 1:00 p.m.

E-mail correspondence with the City of St. Helena (and attachments, if any) may be subject to the California Public Records Act, and as such may therefore be subject to public disclosure unless otherwise exempt under the Act. -----Original Message-----
From: [email protected] <[email protected]>
Sent: Thursday, October 27, 2022 9:01 PM
To: Cindy Tzafopoulos <[email protected]> Subject: [External] Final EIR
Hello there,
I would like to request more time to review the Hunter Final EIR since it is around 3000 pages. I need time to read it on line which will take me longer than a week. I would appreciate a lot of extra time. It is a lot of papers to go through.

Thank you.

Sincerely,
Cathy Small
9 Del Monte
St Helena
Agenda Item #5.10.

Page 4132 of 4422 ends

1 Xinia Gamero
From: Cindy Tzafopoulos
Sent: Friday, October 28, 2022 5:28 PM
To: Xinia Gamero
Subject: FW: [External] Hunter project
Public comment
Thank you,

Cindy Tzafopoulos
City Clerk
City of St. Helena
1572 Railroad Avenue
St. Helena, CA 94574

Direct 707-968-2742 | Cell 707-312-1257
Fax 707-963-7748
[email protected]
www.cityofsthelena.org
Office Hours:

Monday – Friday
9:00 a.m. – 4:00 p.m.

Closed for Lunch between 12:00 – 1:00 p.m.

E-mail correspondence with the City of St. Helena (and attachments, if any) may be subject to the California Public Records Act, and as such may therefore be subject to public disclosure unless otherwise exempt under the Act. -----Original Message-----
From: Mehdi Eftekari <[email protected]>
Sent: Friday, October 28, 2022 6:45 AM
To: Cindy Tzafopoulos <[email protected]> Subject: [External] Hunter project
I’m writing to request for an extension to Hunter EIR, so we as citizens of city of St. Helena have reasonable chance to read and better understand the nearly 3000 page document regarding the Hunter project.

I feel that it is a risky project for the city to take, specially when the city and the taxpayers are fully liable for the levee and any damages to the homes proposed to be build behind it caused by levee failure.

I don’t believe giving 10 days window to read all nearly 3000 pages of documents with problems that encountered with the online tech issues is enough time to consider the liability for this very risky project.

Thank you for your attention to my request.

Mehdi Eftekari
1176 Starr Ave.

Agenda Item #5.10.

Page 4133 of 4422 ends

2 St Helena
Sent from my iPhone
Agenda Item #5.10.

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1 Xinia Gamero
From: Cindy Tzafopoulos
Sent: Friday, October 28, 2022 5:28 PM
To: Xinia Gamero
Subject: FW: [External] Planning Department Nov. 1 meeting Public comment
Thank you,

Cindy Tzafopoulos
City Clerk
City of St. Helena
1572 Railroad Avenue
St. Helena, CA 94574

Direct 707-968-2742 | Cell 707-312-1257
Fax 707-963-7748
[email protected]
www.cityofsthelena.org
Office Hours:

Monday – Friday
9:00 a.m. – 4:00 p.m.

Closed for Lunch between 12:00 – 1:00 p.m.

E-mail correspondence with the City of St. Helena (and attachments, if any) may be subject to the California Public Records Act, and as such may therefore be subject to public disclosure unless otherwise exempt under the Act. -----Original Message-----
From: Connie Wilson <[email protected]>
Sent: Friday, October 28, 2022 7:22 AM
To: Cindy Tzafopoulos <[email protected]> Subject: [External] Planning Department Nov. 1 meeting
Hello Cindy,
This letter is to request an extension for proper review of the 3000 page document of the “Hunter Project” on the November 1st Planning Commission agenda.

Thank you.

Connie Wilson
St. Helena
Agenda Item #5.10.

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1 Xinia Gamero
From: Maya DeRosa
Sent: Friday, October 28, 2022 5:45 PM
To: Xinia Gamero
Cc: Eric Norris
Subject: FW: [External] Hunter Project
Please see comment below.

MAYA DEROSA, AICP

Meanwhile, we could, God forbid if we had to, evacuate not only through the Pope Street exit, but also through the back of the Park at the Hunter Property.

Therefore, I would ask that you would delay the coming meetings to allow all involved to go over the hundreds of pages in the proposals in order to come up with a solution which would work for all parties concerned, thank you.

Sincerely,
Jean Martin
[email protected]
Agenda Item #5.10.

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1 Xinia Gamero
From: Maya DeRosa
Sent: Friday, October 28, 2022 5:46 PM
To: Xinia Gamero
Cc: Eric Norris
Subject: FW: [External] Hunter subdivision
Please see comment below.

Sent from my iPad
Agenda Item #5.10.

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1 Xinia Gamero
From: Maya DeRosa
Sent: Friday, October 28, 2022 5:47 PM
To: Xinia Gamero
Cc: Eric Norris
Subject: FW: [External] Hunter Project
Please see public comment below.

I respectfully ask for an extension of the FEIR of this project to give sufficient time to review.

Thank you in advance.

Robert Childs
2 La Canada Ct
SH
Sent from my iPhone
Agenda Item #5.10.

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1 Xinia Gamero
From: Maya DeRosa
Sent: Friday, October 28, 2022 6:00 PM
To: Xinia Gamero
Cc: Eric Norris
Subject: FW: [External] Request for time
Please see comment below.

MAYA DEROSA, AICP

Suzanne & Jurg Oggenfuss
Agenda Item #5.10.

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FROM RECENT HEADLINES
Drought Watch
St. Helena Star October 27, 2022
Bell Canyon Reservoir at 64.1%
Urgent need to save water-Pump failure reduces water supply St. Helena Star October 27, 2022
St. Helenans were notified Thursday of an urgent need to curtail water use after the failure of one of the City’s two groundwater wells.

Our water system continues to pose challenges,” Public Works Director Joe Leach said. “With significant deferred maintenance (emphasis added), we experienced a pump failure at one of our two wells and are currently operating at significantly reduced capacity……The pump failure is the latest in a string of mishaps that have highlighted the vulnerability of St Helena’s aging water system (emphasis added)…….. St Helena’s long neglected infrastructure-including water, sewer and storm drains (emphasis added) has dominated the current city council campaign.

AND THIS HAS BEEN THE CASE FOR YEARS
St. Helena tallies $58 million in infrastructure projects St. Helena Star Jun 7. 2021, updated July 19, 2021
"lt's a familiar story in St. Helena: Too many infrastructure projects, not enough money." City of St. Helena addresses complaints about water quality St. Helena Star Mar 2, 2021, updated April 28. 2021
"St. Helena's water system is drawing more water from the City of Napa...to conserve water in St.

Helena's Ball Canyon Reservoir, which is down to 40% capacity." City of St. Helena Fails Drinking Water Standard
Patch.com April 8, 2021
"The city did not meet treatment requirements while working to disinfect the Louis Water Treatment Plant after the Glass Fire."
St. Helena approves plans for $16.2 million sewer plant upgrade St. Helena Star Feb 23. 2021, updated Jun 9, 2021
"lt's a necessary move for the city....the plant isn't capable of complying..." Agenda Item #5.10.

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These headlines tell a story about the current state of critical infrastructure in the City of St. Helena. The consistent theme is that substantial investment in St. Helena’s critical infrastructure is needed for the current residential footprint and the City doesn't have enough money! The City is currently lacking adequate critical infrastructure including in particular the following:
• Water
• Sewer/Wastewater
• Storm drainage and flooding
• Roads
• Sidewalks
• Utilities
• Police
• Fire, and
• Schools
We believe approval of the proposed project which adds 51 single family homes, 25 multifamily units, and the corresponding increase in population would constitute gross negligence in that it would further strain and likely break our infrastructure.

Water Supply and Sewer/Wastewater. How could any proposal of this size not cause serious water and wastewater issues for the City? How could this project be water neutral? This project will literally require millions of gallons of water annually. Where is this water going to come from? Commissioners were recently quite skeptical (appropriately) of a report that a single-family home would be water neutral. One commissioner said it didn’t stand the commonsense test. It didn’t. So how can this project with 75 times the water requirements be water neutral. The project also proposes to activate abandoned wells for landscaping. How do we know that is going to work? And, if it does, is it done at the expense of well usage by current residents? Then there is the other side of water usage-wastewater.

Millions more gallons of wastewater per year to a sewer system that can’t handle today’s current needs.

Storm drainage and Flooding. The City’s current drainage system is inadequate. It is difficult to believe that building inside the levee on the floor of the basin is not going to add to these problems. We are also concerned that if the levee is compromised the drainage ditches that flow from Fulton Lane through our property will be overwhelmed and back up on our property and onto Fulton Lane. This already occurs with heavy rains. The ditches that handle this drainage are on our property and while apparently it is the City’s responsibility to maintain the ditches in the 6+ years we have owned our property the City has not once maintained the ditches. We were told that this was due to the lack of budget at the City. Again, how is it possible that this project doesn’t exacerbate the already existing problem.

Roads, sidewalks, traffic, parking. We believe the proposed project will cause the existing and already problematic traffic, congestion, and parking situation in St. Helena to become much worse. The roads (and sidewalks) in St. Helena are awful. Drive on Railroad from Fulton to Hunt. You think you are in a third world country. More traffic means more road repairs and apparently the City doesn’t have the money to repair the roads today. The congestion entering and exiting St. Helena via Highway 29 is brutal. People familiar with the area (or using apps such as Waze) find ways around this downtown traffic and congestion. The most common "detour" is using Silverado Trail and turning on Pope Street.

Agenda Item #5.10.

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Given the configuration of the Pope Street bridge and the location of the Pope Street and Silverado Trail intersection near the proposed project, traffic will most certainly back up on Pope Street and on Silverado Trail, which creates not just congestion but real risk of accidents. In addition to increased traffic the lack of adequate parking will cause further congestion.

Police, Fire, Schools, etc. The many other essential services that the City provides to its current residents will also be further strained as a result of the proposed project.

Quality of life for current residents. All of the above detracts from the quality of life of current St.

Helena residents. Open spaces and access to pedestrian walking paths enrich and enhance the lives of all current residents and particularly those most closely located near the proposed project. Taking land that is agricultural and has a rural feel and building more dense housing, particularly in this part of the City makes us all lose a part of the reason we want live in St. Helena. We watch all kinds of people (families, adults, children, and dogwalkers) enjoying the open space and vineyards on the walking path from town to the river. Often adults and children bike along the path. Families stop and picnics near the path. People walk their dogs enjoying the beautiful open space. Undeniably, the loss of open space and vineyards and safe access to the walking paths will negatively impact residents.

Construction. By the way has anyone looked at the disruption and impacts of construction on the City and its residents?
We are not anti-growth. ln fact, we favor thoughtful growth in the City of St. Helena. For example, we believe the City needs to consider development such as hotels which could provide revenue to make improvements in our current flawed infrastructure. However, the above headlines strongly suggest that City doesn't' have sufficient infrastructure for its current footprint let alone a project of the scope proposed. We believe that growth needs to be thoughtful and provide a means to improve (not cause further deterioration) of the City's financial condition and infrastructure.

We believe most St. Helena residents and nearly all those directly impacted because they live nearby are opposed to the proposed project. We are also aware of potential litigation. The City doesn’t need to spend money on lawyers when that money could go to improving critical infrastructure and the quality of life of its current residents.

We respectfully urge the Planning Commission to not proceed with the proposed project.

Patrick and Laura Pohlen
601 Fulton Lane
October 29, 2022
Agenda Item #5.10.

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P.O. Box 94, St Helena, CA 94574 (707) 302-5111 www.OurTownStHelena.org October 30, 2022
TO: City of St Helena Planning Commission
FROM: Our Town St. Helena Board of Directors
SUBJECT: Hunter Project: Proposed Subdivision Tentative Map Background
Our Town St Helena (OTSH) indicated in previous public testimony concerns related to the proposed Hunter Project. In summary: 1) the single-family lots are sized to support large homes that will likely sell in the $2.0-$3.0 million range in today’s market and will not be affordable for our community’s working people, young families and seniors; and 2) the parcel designated for “affordable housing” is segregated from the remainder of the homes, and, as such, is in direct conflict with the City’s inclusionary housing ordinance that requires integration of the affordable homes and similar bedroom/bathroom counts as the single-family homes. The subdivision as proposed misses the extremely rare opportunity to address St. Helena’s acute housing need.

Given the constraints on public comments for environmental impact reports and subdivision maps imposed by governing laws, OTSH will limit this additional testimony to the parameters described in the staff report related to the proposed tentative map, noting that our previous written comments are included with the Final EIR and provide context.

Proposed Tentative Map: Consistency with 1993 General Plan We thank staff for the evaluation of the proposed tentative map’s consistency with the 1993 and 2019 general plans. However, we take exception to the conclusion that the proposed development is consistent with the 1993 General Plan’s Guiding Policy 2.6.19 which states:
“Permit higher density housing in single family neighborhoods as long as the development character of the single family area is maintained (i.e., lot widths, orientation to street, building heights, etc.).”
Objectively, the proposed tentative map is inconsistent with 2.6.19 because the lot where higherdensity housing (25 units) would be developed is sized insufficiently to maintain the development character of the single-family homes in the manner the language describes.

Other guiding policies in the 1993 General Plan, while more difficult to evaluate objectively, also suggest the proposed subdivision falls short of fully complying with the General Plan:

Agenda Item #5.10.

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P.O. Box 94, St Helena, CA 94574 (707) 302-5111 www.OurTownStHelena.org

2.6.14 Encourage a mix of housing types and price ranges to allow choice for current and future generations of St. Helenans.

2.6.16 Encourage the development of higher density housing in areas near the center of town and close to recreation and services.

The policies are encouraging higher density, urban housing solutions near the city center, so current and future generations can walk or bicycle to town and afford to live close to where they work. The proposed subdivision achieves the lowest density allowed for the single-family lots within the zoning designation.
2019 General Plan Consistency
While the proposed subdivision’s consistency with the 2019 General Plan is not as relevant for the decisionmakers to determine whether to approve or deny the proposed tentative map, it is important for leaders and the general public to be cautious about the use of terms like “market rate” and “more affordable”.

Staff’s analysis concluded the proposed subdivision is consistent with the 2019 General Plan and more specifically policies LU2.1 and ES1.4 (below) because “The proposed project includes market-rate single family homes and two types of units intended to be more affordable: accessory dwelling units and multi-family units.”
Land Use (LU2.1): Promote a mix of housing types and price ranges that are consistent with the Housing Element RHNA categories of housing affordability.

Economic Sustainability (ES1.4): Encourage the creation of workforce housing to support the local employment base in keeping with small town smart growth.

The use of the term “market rate” to imply the single-family homes will somehow meet RHNA categories should be considered more closely. “Market rate” is simply what the market will support, where RHNA relies on Area Median Income (AMI) to establish categories of affordability for varying income levels and household sizes. Using today’s housing market data, the “market rate” for a single-family home with a similar lot size and configuration as what is being proposed is approximately $2 million, while a St. Helena moderate-income household earning $95,000- $143,000 can afford to buy a home in the $285,000-$420,000 range.

To truly encourage housing that would both serve our community and utilize the ‘highest and best use of the land, the subdivision should be made up of smaller lots to promote higher density and allow for homes the “missing middle” working professionals and younger families in our area will be able afford.

As has been stated in prior public meetings regarding the Housing Element update and the Hunter Subdivision, counting accessory dwelling units (ADUs) as “more affordable” only works if the ADUs are truly serving as housing at affordable prices. There is no way to guarantee this Agenda Item #5.10.

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P.O. Box 94, St Helena, CA 94574 (707) 302-5111 www.OurTownStHelena.org unless the City creates a policy / program to incentivize developers to regulate the ADUs. While this is not something that can be considered for the tentative map approval, it should be part of the future affordable housing agreement.

State Housing Law
The staff report cites Government Code Section 65589.5(j)(1) as limiting the City’s discretion to deny a proposed housing development, yet the citation is an excerpt of the greater law. The preambles in the code describe California’s severe and urgent affordable housing crisis and the intent of the law, which is to limit arbitrary or discretionary review to ensure affordable and higher density projects can get approved and not derailed by bureaucracy and NIMBYism.

Closing
In conclusion, Our Town St Helena submits the proposed tentative map is objectively inconsistent with the 1993 General Plan Guiding Policy 2. 6.19 and should not be recommended for approval by the Planning Commission to the City Council. Further, we encourage the developer and City to work together to create a plan that provides the vital housing our community needs right now and into the future to ensure St Helena is a sustainable, economically thriving city with smalltown character.

We understand this project has momentum and the developer has invested a significant amount of time and money into the proposal to date. OTSH would be supportive if the project had smaller lots and more units and would strongly encourage some portion of the units have affordability restrictions (e.g., up to 200% area median income) to ensure they remain affordable to the local workforce and first-time homebuyers. The proposed tentative map is supporting the minimum density allowed. OTSH recommends a supportable density would be around 128 (nowhere near the maximum allowed 270).

OTSH believes it is possible to attain this goal for our community while still giving the developer the support to complete a viable and profitable project. It is imperative that we support housing development that meets the realistic needs of our community. We see this as a positive opportunity for the city and the developer to harmoniously work together to achieve great mutual success. We ask the City to provide the leadership and the developer the cooperation to go beyond just meeting bare minimum code standards so that an innovative, inclusive neighborhood can be created. Our Town St. Helena stands ready to help make this happen in any way we can.

Agenda Item #5.10.

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1 Xinia Gamero
From: Maya DeRosa
Sent: Friday, October 28, 2022 5:51 PM
To: Xinia Gamero
Cc: Eric Norris
Subject: FW: [External] Extension request Hunter Subdivision Public comment below.

MAYA DEROSA, AICP

COMMUNITY DEVELOPMENT DIRECTOR
City of St. Helena | Community Development Department
1572 Railroad Avenue | St. Helena, CA 94574
Direct: (707) 967-2783 | [email protected] | http://cityofsthelena.org/planning From: [email protected] <[email protected]>
Sent: Thursday, October 27, 2022 11:14 AM
To: Maya DeRosa <[email protected]>
Subject: [External] Extension request Hunter Subdivision Good morning Miss Maya DeRosa,
Might I politely request an extension of time to review the Final EIR (FEIR) currently on the City website regarding the Hunter Subdivision? As this recently released document is over 2800 pages long, it will require additional time to explore. Might you consider providing a reasonable window for review of this important document? It would be greatly appreciated by me as well as others that will be greatly affected by the decisions about the proposed Hunter Subdivision.

Thank you for your consideration.

A concerned citizen of Saint Helena residing in Vibeyard Valley.

Kathleen McCreedy
Sent from my iPhone
Agenda Item #5.10.

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1 Xinia Gamero
From: Maya DeRosa
Sent: Friday, October 28, 2022 6:01 PM
To: Xinia Gamero
Cc: Eric Norris
Subject: FW: [External] Extension
Please see comment below.

Thank you,
Leanne & Thomas Corkill
20 Del Rio
Vineyard Valley Mobile Home Park
Sent from my iPhone
Agenda Item #5.10.

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1 Xinia Gamero
From: Maya DeRosa
Sent: Friday, October 28, 2022 6:02 PM
To: Xinia Gamero
Cc: Eric Norris
Subject: FW: [External] Hunter project eir
Please see comment below.

Denise Nelson
Agenda Item #5.10.

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1 Xinia Gamero
From: Maya DeRosa
Sent: Monday, October 31, 2022 8:53 AM
To: Xinia Gamero
Cc: Eric Norris
Subject: FW: [External] Hunter subdivision - hearing date Please see public comment below for the 11/1 agenda.

MAYA DEROSA, AICP

Thank you,
Michael Mills
______________
To: City of St. Helena Planning Commission
On Monday October 24 the City announced by press
release that the Final EIR and subdivision map are to be Agenda Item #5.10.

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2 considered by the Commission on Tuesday November 1,
just eight days after the announcement. The Staff Report is 2,849 single-spaced pages.

Responsible review of such a document in eight days is
obviously impossible. Therefore, on behalf of all residents who may wish to study this project—the largest single
development in the City's history, I believe—I ask that you defer the hearing for 90 days. (Less than 90 days will land in the middle of the holiday season.)
The applicant, consultant, and staff have had one full
year, since the Commission's meeting on November 2,
2021, to consider the comments submitted then and, one
assumes, all other relevant issues. At that time, public hearings were scheduled for Q1 2022.

Evidently, the applicant, consultant, and staff needed six months more than they had expected to prepare the Final EIR. Suddenly disclosing their work and demanding that
the community respond in eight days is, in effect, to deny an opportunity for informed comment.

Thank you,
Michael Mills
1380 Grove Court
917-885-1517
Agenda Item #5.10.

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1 Xinia Gamero
From: Dottie Gingerelli <[email protected]>
Sent: Monday, October 31, 2022 9:40 AM
To: Public Comment
Subject: [External] Hunter Subdivision
Planning Commission,
I live in Vineyard Valley as do many other seniors. The issues I see against Hunter Subdivision are scarcity of water, necessary emergency exits, and irreparable damage on open land and to downtown businesses already struggling to comeback from fires and COVID.

Living here with the severe climate change increased heat, everyone has received many messages from the City of St.

Helena regarding the dire water situation. The city being aware of future warming of the area, and less rainfall expected, puts building a large subdivision in direct conflict with the continuing climate change the area is experiencing.

Vineyard Valley VV has many aged and handicap occupants needing a safe and immediate area for evacuation. There are 2 escape routes for the already existing 200 + homes. Half exit onto Pope and the other half exit onto the area where the subdivision is being proposed. Using the one entrance area to VV for shared exiting is dangerous as Silverado Trail would be unavailable for use. The fire dept. and police hold emergency exit practices using the Adams space aware that evacuation at a single exit would create a backlog putting senior lives in danger.

The environmental impact to subdivide the area would cause irreparable repercussions for the city and for the people who live near it. Property value is high in St.Helena because of the open area and fulfills a smaller town need. Adding a subdivision in this remaining open area, depreciates the homes already here, and brings a city affect minimizing the desires of both citizens and tourists alike who often use it to access downtown shops.

Please contemplate the irreversible negative impact the Hunter Subdivision will create with severe climate change water unavailability, safety issues already in place for hundreds of seniors who have first hand knowledge of the fire danger, and the removal of an environmental area well used by locals and tourists with Adams being a direct path to businesses downtown.

Thank you,
Dottie Gingerelli
50 Laguna Seca Ct.

St. Helena, CA 94575
408‐348‐8475
[email protected]
Sent from my iPhone
Agenda Item #5.10.

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1 Xinia Gamero
From: Trudy Bouligny <[email protected]>
Sent: Monday, October 31, 2022 11:01 AM
To: Public Comment
Subject: [External] Hunter Project Hearing November 1 2022 To St Helena Planning Commission Hearing November 1st, 2022 Re Hunter Housing Project near eastern terminus of Adams St. St Helena Building 87 housing units of various configurations on the property behind the Napa River levee without serious consideration for traffic access does not make sense. Extending the street to Starr Avenue with traffic exiting on to Pope St will create further woes for the Pope St Bridge and turning north and south on Silverado Trail.

Unless serious consideration is give to a new bridge across the Napa River at the end of Adams St. with better visibility for turning on to the Trail, a project of this scale should be rejected.

There are many reasons for denying this planning application ‐ potential flooding issues (Vineyard Valley should never have been built in the flood plain for example), sewer plant upgrades and water shortages, infrastructure problems. We will just start with the traffic issue.

Earl and Trudy Bouligny
Earl and Trudy Bouligny
497 Silverado Trail S
St Helena CA 94574
707-963-0814
707-738-1230 [email protected]
Agenda Item #5.10.

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1 Xinia Gamero
From: Jenna Zabin <[email protected]>
Sent: Monday, October 31, 2022 11:05 AM
To: Public Comment
Subject: [External] Hunter Project concerns
Hello,
My name is Jenna Lavagnino and I live at 15 Del Rio Court in Saint Helena. I utilize and enjoy the levee and all aspects of the open space where the hunter project is proposed. I have so many concerns and have voiced them in prior discussions.
‐ WATER ‐ we are dangerously low on water now in the town. So much so that all of us at Vineyard Valley or on severe water rationing‘s. I don’t understand how we can be on severe water rationing‘s yet the city is contemplating the hunter project? I need someone to explain to me where the water will be coming from to house hundreds of more people.

What is the plan for the water?
‐ TRAFFIC ‐ what is the plan for the added traffic congestion? For every house that is built we are looking at at least two cars for every property. Everyone coming and going all day long. ‐ SEWER SYSTEM‐ i’ve been told our infrastructure and sewer system is extremely old and can barely accommodate current levels of usage. How are we going to accommodate 80+ homes? If the hunter project goes through as planned, I truly believe this will be a travesty and will be devastating! I could go on and on and on ‐ I will just say please please please reconsider! Sincerely,
Jenna Lavagnino
510‐292‐0181
Sent from my iPhone
Agenda Item #5.10.

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1 Xinia Gamero
From: Doris Mosler <[email protected]>
Sent: Monday, October 31, 2022 11:31 AM
To: Public Comment
Subject: [External] Hunter project
As a long time resident of Vineyard valley I’m strongly opposed to this development.

Why:
‐water usage
‐traffic
‐pressure on scant existing resources: police, fire ‐levee issues: flooding ‐noisy long term construction ‐unique quality of town as pleasant serene wine tourist destination would be compromised.

Please stop this project.

Doris Mosler
Sent from my iPhone
Agenda Item #5.10.

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1 Xinia Gamero
From: Maya DeRosa
Sent: Monday, October 31, 2022 2:42 PM
To: Xinia Gamero
Cc: Eric Norris
Subject: FW: [External] Current Hunter Project EIR
Please see public comment for 11/1 agenda.

MAYA DEROSA, AICP

There is not adequate time to review their voluminous responses and therefore request an extension of time prior to any further consideration given to it.

Respectfully submitted:

Rick Crebs
SHHC
707-580-0418
Agenda Item #5.10.

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October 31, 2022
City of St. Helena Planning Commission
Re: Hunter Subdivision and Application
Dear Members of the Commission:

We are writing in support of housing at the Hunter property. While there are many challenges in a proposal of this size, we believe it is time for St. Helena to address years of inadequate housing planning and development.

For a little perspective, the first decade we lived here, the plans for Harvest Inn and the Wine Train were under discussion and, of course, contention. As neighbors of one of these projects, we paid attention.

Change was hard then, and it still is.

A few years later, one of us joined the first Board of Directors of Stonebridge Apartments and served for 13 years. It’s an exemplary property; our children’s classmates lived there and it continues to serve the city well over 30 years later.

The Hunter project is needed not only to address our RHNA numbers but, more importantly, to address the urgent need to provide housing for wine industry staff, our city and school district employees, and hospitality and Main Street employees as well.

We would encourage the project to include a broader spectrum of housing types to attract residents from more income levels. In addition to single-family houses and affordable apartments, it’s important to include middle-price duplexes and condominiums. Those types of units should replace some planned single-family houses. Since they require less landscaping, water usage would lessen.

Agenda Item #5.10.

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Forty-four years ago the Ag Preserve was created to protect agriculture and wildlands in the unincorporated areas, both for Napa’s valuable wine industry and its environment. The concept then was that development would occur within the city limits, and it is still. (One of us spent his career in the wine industry and served on the Land Trust of Napa County board of directors, working to protect the countryside.) We both believe the human, economic and environmental reasons for providing more housing in St. Helena outweigh the desire we all have for nothing to change or for our town to be the way it was at whatever point in time we romanticize.

Thank you for your time and attention.

Loraine and Jack Stuart
St. Helena
Agenda Item #5.10.

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JOSHUA S. DEVORE
[email protected]
October 31, 2022
Via Email:

Commissioner John Ponte, Chair, [email protected] Commissioner Autumn Anderson, [email protected] Commissioner Marika Rothfeld, [email protected] Commissioner Rosaura Segura, [email protected] Commissioner Christopher Warner, [email protected] City Manager Anil Comelo, [email protected]
Community Development Director Maya DeRosa, [email protected] RE: Hunter Subdivision Project Environmental Impact Report, File #PL10-040 Dear Chair Ponte, Commissioners, City Manager Comelo, Community Development Director DeRosa:

We represent the Saint Helena Citizens for a Sustainable Future, a diverse group of City residents who are extremely concerned by the City’s actions with respect to the referenced project.

Numerous members of the Citizens group have individually commented on the project in the past. They write now collectively due to what appears to be an imminent failure of the City to recognize and adhere to recent groundwater requirements.

Before the Planning Commission is a request to certify the Final EIR and approve a Tentative Map for the Hunter Subdivision project. There have been extensive comments on the failures of the EIR to consider basic detrimental aspect of the project. The Final EIR responses have failed to provide a good-faith effort at full disclosure by ignoring, distorting, or giving short-shrift to those comments. As a reminder, this project was tabled nearly a decade ago, in part due to a determined need to improve the Pope Street/Silverado Trail intersection as a result of the project. Obviously, the applicant hopes that has simply been forgotten, or that the City will ignore its level of service (LOS) analysis.

Though VMT analysis is indeed the latest requirement, the project is reviewed under the 1993 General Plan. LOS must be considered per General Plan policies 5.4.1 and 5.4.2. And while there is also an analysis of some portions of the current general plan for comparison, some of the most relevant plan 1500 FIRST STREET | STE 200 | NAPA, CA 94559 | T: 707.261.7000 DPF-LAW.COM Agenda Item #5.10.

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October 31, 2022

Page 2 ends

policies are omitted, such as LU2.61 and CR1.42 The traffic study acknowledges the significant impact on traffic at Main and Pope Street, but ignores the worsening traffic at Pope/Silverado.3 That said, we will not restate all the issues with the EIR here, as they have been raised by more than 100 commenters and are too numerous to list. We do note now however one glaring problem in the proposed findings that requires, at the very least, additional analysis of a significant environmental issue facing all of California, sustainable groundwater management.

The project is for the subdivision of a 16.92 acre property. The EIR analyzed its proposed groundwater use of an on-site well of up to 17.16 acre-feet (AF) per year to provide for all on-site irrigation of public and private landscaping, as well as a small remnant of an existing vineyard. (DEIR 3.9-

40.) (The EIR also fancifully suggests that the remainder of the project will be water neutral, despite its demand for nearly 20 AFY beyond that produced by the onsite well. But that fantasy is not even the instant problem.)
The proposed finding regarding the project’s consistency with the Napa Valley Subbasin Groundwater Sustainability Plan (GSP) is contrary to the evidence. Proposed Hydrology and Water Quality finding I. 7. states:

The Project would not conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan. The County works with local jurisdictions, including the City, to sustainably manage the Napa Valley Groundwater Subbasin in compliance with SGMA. In its most recent assessment of conditions, the County, through its technical consultant, determined that the Subbasin is not exhibiting significant impacts with regard to the applicable sustainability indicators defined by SGMA, including lowering of groundwater levels, depletion of groundwater in storage, degradation of groundwater quality, and depletion of interconnected surface waters.
(Staff Report p. 50-51 (emphasis added.))
This is inconsistent with the Napa Valley Subbasin Groundwater Sustainability Plan’s (GSP) recent assessment, published in January 2022:

Groundwater levels reflect the amount [of] groundwater in storage and the movement of groundwater. Monitoring data exhibit generally stable long-term trends, although conditions are largely dependent on seasonal precipitation input.

Several wells located near the Napa Valley Subbasin margin in the northeastern Napa area, southwestern Yountville area, and southeastern St. Helena area show 1 “LU2.6 Allow residential density at the higher end of the permitted range for single family development within Medium and High Density Residential Land Use designations as long as the development character of the single family area is maintained, including lot widths, orientation to street, building heights, onsite parking, traffic, and noise, among other considerations.” (2019 General Plan.) 2 “CR1.4 Develop and use, in addition to intersection level of service standards, performance measures that consider all road users to determine transportation impacts of new development.” (2019 General Plan.) 3 DEIR Appendix K, p. 36 Table 7 (emphasizing worsening delay at Main Street/Pope Street - Mitchell Drive, but ignoring change in AM Peak LOS at Silverado Trail/Pope Street from LOS C to LOS E.) 1500 FIRST STREET | STE 200 | NAPA, CA 94559 | T: 707.261.7000 DPF-LAW.COM Agenda Item #5.10.

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periods of groundwater decline during times of drought. Continued monitoring of groundwater levels will be important to evaluate future hydrologic and climatic influences.
(Napa Valley Subbasin Groundwater Sustainability Plan Summary, Executive Summary (Jan. 2022) p. 2, available at https://www.countyofnapa.org/DocumentCenter/View/23549/GSP_Executive-SummaryAbstract?bidId=.) Indeed, while the GSP consists of a dozen separate sections, plus an Executive Summary and an Executive Summary Abstract, this critical contradictory information is found on the top of the second page of the Executive Summary Abstract –the simplest and first document of the GSP. (See https:// www.countyofnapa.org/3218/GSP-Sections.) It is indeed one of the most prominent findings of the GSP that wells in southeastern Saint Helena are showing evidence of groundwater decline during this ongoing drought.

Thus, the proposed contrary finding on this critical matter not only is not supported by substantial evidence, it is directly contrary to the most recent information.

As a result of these findings, Napa County has recently substantially revised downward the allocation of groundwater to subbasin, valley-floor properties. Although such properties were previously allocated 1 acre-foot of water per acre, per year, going forward all uses will be limited to 0.3 AF/acre/ year. This includes both existing and proposed wells. Any existing well usage above that level is prohibited to increase above its current net usage. (See Napa County Well Permit Standards FAQ, available at https://www.countyofnapa.org/DocumentCenter/View/25906/Well-Permit-StandardsFAQs---15-July-2022.) New domestic wells outside the subbasin may use 2 AF/year total (not per acre), and new public water supply wells may use their parcel specific recharge.4 But the well proposed to deliver the 17+ AF is not a new well.

Although the project is conditioned to require offsetting its Municipal water demand of 19.8 AF/year, no recognition of the GSP Subbasin limitations of groundwater use is made for the additional

17.16 AF/year to be pumped from the onsite well. The EIR does disclose that the well is currently inoperable meaning that the existing baseline for groundwater use is zero (DEIR 3.9-42 (Staff Report p. 594). As such the new water use proposed would be required to be limited to no greater than 0.3 AF/AC per year to comply with the GSP sustainable groundwater limitations.

However, there is no discussion of this GSP limitation and its potential impacts on rural residences and agriculture let alone any mitigation proposed or required. Instead, DEIR Appendix L, the September 9, 2021 Well Capacity Study Memorandum, referenced the prior 1 AF/AC allotment that has been reduced by 70%. Yet that memorandum emphasizes that “it is recommended that the annual groundwater use conform with County policy.” (DEIR Appx. L, p.1 (emphasis in original.) (No well interference analysis appears to have been conducted either, despite the well being within 1,500 feet of the Stonebridge wells.)
4 WAA Tier 1: Water Use for Napa County, available at
https://www.countyofnapa.org/DocumentCenter/View/25905/Well-Permit-Standards-Applicability-Tables---15- July-2022
1500 FIRST STREET | STE 200 | NAPA, CA 94559 | T: 707.261.7000 DPF-LAW.COM Agenda Item #5.10.

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Very truly yours,

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JOSHUA S. DEVORE
[email protected]
1500 FIRST STREET | STE 200 | NAPA, CA 94559 | T: 707.261.7000 DPF-LAW.COM October 31, 2022
Via Email:

We represent the Saint Helena Citizens for a Sustainable Future, a diverse group of City residents who are extremely concerned by the City’s actions with respect to the referenced project.

Agenda Item #5.10.

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1500 FIRST STREET | STE 200 | NAPA, CA 94559 | T: 707.261.7000 DPF-LAW.COM This Tentative Map is fatally defective and must be rejected.

Violation of Subdivision Ordinance Section 16.04.120
The Staff Report describes the project for consideration as follows:

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1500 FIRST STREET | STE 200 | NAPA, CA 94559 | T: 707.261.7000 DPF-LAW.COM This is expressly illegal.

Title 16 of the Saint Helena Municipal Code, the City’s Subdivision Ordinance, provides unambiguously that:

In short, Applicant’s proposal that ‘we will figure out the rest later’ is expressly counter to the City’s Subdivision Ordinance, and requires rejection.

The proposed use of each lot, lot layout and dimensions and area of each lot.

Indeed, the presented Map Sheet TM2 shows the current use of Lot 52 as vineyard. As no changes to Lot 52 are proposed, assuming that the Map presented actually complied with Section

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The parcel is zoned Medium Density Residential (MR) and designated as MDR in the General Plan. As correctly noted in the Staff Report:

16.16.080 (emphasis added.)) At its most generous, the record suggests only that the subdivision could be compliant with the minimum density if future actions are taken.

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This is directly contrast to 1993 General Plan Policy 4.3.5:

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Very truly yours,

DICKENSON, PEATMAN & FOGARTY
Joshua S. Devore
JSD/sol
cc: Ethan Walsh, City Attorney, [email protected]
Saint Helena Citizens for a Sustainable Future:

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1500 FIRST STREET | STE 200 | NAPA, CA 94559 | T: 707.261.7000 DPF-LAW.COM Becky Palmisano
Dave Palmisano
Laura Pohlen
Patrick Pohlen
Laurence Schlatter
Rene Schlatter
Dave Valentine
Dave Wilkinson
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Angela M. Zivkovic, PhD
1180 Starr Avenue
St. Helena, CA. 94574
City of St. Helena Planning Division
1572 Railroad Avenue
St. Helena, California 94574
(707) 967-2783
[email protected]
Dear Members of the City Planning Commission of St. Helena, I am writing regarding the Hunter Project Final Environmental Impact Report (FEIR). I am writing to express serious concerns about the findings of the report and, more importantly, all of the considerations that are missing from the report. In particular I am extremely concerned about the lack of consideration of the environmental impacts with regard to climate change.

Instead of taking into account the changing landscape of future impacts on such issues as water, infrastructure, and natural disasters, this EIR uses old data, outdated reports, and irrelevant projections based on assumptions about the climate staying the same as it always was, of water availability staying predictable, of flood risks fitting outdated “100-year flood plain” approaches that are no longer being used by the Federal Emergency Management Agency (FEMA), and sewage capacity and other reports based on outdated materials such as reports from as long ago as 2008 and 2011. I expressed my concerns about these issues one year ago when the draft EIR was being reviewed. The city has failed to address these concerns and greenlighted the process through to the Final EIR without consideration of the impact of these issues on our community.

I reiterate my concerns here and request that the city planning commission and city council address these issues forthwith as it appears to me that failure to address these concerns constitutes grounds for legal action. I would like to bring to the city’s attention recent advancements with regard to the legal liability of ignoring climate change in development projects and point the city council and planning commission members to a report prepared by the Conservation Law Foundation entitled “Climate Adaptation and Liability” https://www.clf.org/wp-content/uploads/2018/01/GRC_CLF_Report_R8.pdf. I urge the city council to carefully consider the consequences of ignoring and dismissing the issues that have been raised here with regard to the failure of the Hunter Project FEIR to take into account changing climate-related impacts on the city’s ability to provide adequate, safe water supplies, to ensure safe evacuation during wildfire events, especially on the East side of St. Helena, and to account for the financial liability that would occur if the levy should fail in a catastrophic flooding event.

I am aware that the city is obligated to comply with the Housing Accountability Act (Government Code Section 65589.5), which states that a housing development project that Agenda Item #5.10.

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complies with the objective standards of the General Plan and Zoning Ordinance must be approved by the City, unless the City is able to make written findings based on the preponderance of the evidence in the record that either: (1) the City has already met its Regional Housing Needs Assessment (RHNA) requirement; (2) there is an impact to the public health and safety and this impact cannot be mitigated; (3) the property is agricultural land; (4) approval of the project would violate State or Federal law and this violation cannot be mitigated; or (5) the project is inconsistent with the zoning and land use designation and not identified in the General Plan Housing Element RHNA inventory. I believe that it is clear given the concerns raised below that there is an impact to the public health and safety of the proposed development project that cannot be mitigated given the current city infrastructure limitations, and the increased and unaccounted for impacts of climate change.

Here I address several specific comments in response to the Planning Commission Report (file number PL10-040 and TM 2022-001) Section 1 “Findings regarding less than significant impacts not requiring mitigation.”
1) Regarding section H5: Emergency Access
a. The “less-than-significant impact” finding explanation does not address the actual concerns regarding emergency evacuation. The project would most definitely have an impact on the ability of all current residents of the East Side of St. Helena to evacuate in an emergency situation such as a catastrophic flood or wildland fire. The explanation that the city fire department will evaluate the width of the roads to be constructed inside the development has nothing to do with actual evacuation out of the city of St. Helena itself. The question is not whether the development would adequately provide access for the development residents out of the development area, but how the project will impact those residents once they leave the development, and the rest of the citizens of St.

Helena who all need to evacuate via the same limited routes out of the city and out of the valley. Once the hundreds of additional residents occupying hundreds of additional cars actually drive out of the development, they are going to have to funnel into the existing roadways, which are already impacted and cannot adequately handle evacuation in an emergency situation such as a quickly occurring wildland fires or catastrophic floods. They will all have to drive down Starr Avenue, make a left turn onto Pope Street, and then try to evacuate across the Pope Street Bridge, a historic bridge which is not capable of handling even the current number of cars that need to be able to evacuate out of the area. If they choose to turn right to try to evacuate out via Main Street, they will be competing with all of the West side traffic that is also trying to evacuate out of the city. An even worse scenario is what would happen if only one of those two routes was available for some reason. Additionally, the FEIR does not in any way address the increased urgency and frequency at which these types of catastrophic events are occurring and are going to be occurring with the increasing effects of climate change. The East side of town already houses the most vulnerable citizens in our city, encompassing multiple low-income housing Agenda Item #5.10.

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units and homes for the elderly. These are individuals who are not only at higher risk from injury but who are also less likely to be able to “evacuate early” as opposed to at the last minute once emergency shelters have been established, making the impact of urgent, las-minute evacuations even more important. b. Please also see additional text in points 8) and 9) below, highlighting that the estimated increase in number of residents due to the development is laughably unrealistic, and apparently assumes that only about 200 additional residents will result from a development containing 87 units, when a much more realistic calculation is that instead there will be >400 new residents. With more than 2 times higher impacts on the ability of St. Helena residents to safely evacuate in an emergency situation.
2) Regarding section H6: Wildland fires
a. The finding of “less-than-significant impact” explanation here is also missing the main point. As above, the question is not whether the construction or operation of the project will impact the ability of the development residents to egress out of the development itself, but how these residents will evacuate out of town once they have left the development itself, and how these additional numbers of individuals and cars will impact the ability of the rest of the citizens of St. Helena to evacuate in the case of a wildland fire emergency. Again, we have examples of recent wildland fires, which were all fast-moving, and which can occur in the middle of the night, for example, that raise concerns about the ability of hundreds of residents to evacuate out via our currently inadequate infrastructure. Again, this finding ignores the increasing risks of wildland fires due to climate change.
b. Please see additional text under section B below.
c. Please also see additional text in points 8) and 9) below, highlighting that the estimated increase in number of residents due to the development is laughably unrealistic, and apparently assumes that only about 200 additional residents will result from a development containing 87 units, when a much more realistic calculation is that instead there will be >400 new residents. With more than 2 times higher impacts on ability to safely evacuate during a wildland fire event. 3) Regarding section I2: Groundwater supplies
a. Again, the “less-than-significant impact” finding ignores the effects of climate change. Instead, the assessment relies on historical data and outdated processes of evaluation based on the past. Climate change is the present and the future.

We are currently in a water shortage, with water restrictions mandated by the city, due to our inadequate water infrastructure but also due to the simple fact that groundwater is running out everywhere in the state of California. b. Please see additional text under section C below, with particular attention to the impact of climate change on groundwater supplies throughout the state of California and the decreasing water supplies to replenish those groundwater supplies due to decreasing snowpack in the Sierras.
c. Please also see additional text in points 8) and 9) below, highlighting that the estimated increase in number of residents due to the development is laughably Agenda Item #5.10.

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unrealistic, and apparently assumes that only about 200 additional residents will result from a development containing 87 units, when a much more realistic calculation is that instead there will be >400 new residents. With more than 2 times higher impacts on groundwater supplies than estimated by the FEIR. 4) Regarding section I4: Surface runoff and flooding
a. Again, the FEIR ignores the impact of climate change. Please see text below under section A. Please note that the Federal Emergency Management Agency (FEMA) is no longer using the concept of “100-year flood zones” because climate change has rendered these calculations based on historical data meaningless.

The new Risk Rating 2.0 system has been in effect since October 2021. 5) Regarding section I5: Stormwater drainage system capacity and polluted runoff a. Again, the FEIR ignores the impact of climate change. Please see text below under section A. Please note that the Federal Emergency Management Agency (FEMA) is no longer using the concept of “10-year flood zones” because climate change has rendered these calculations based on historical data meaningless.

The new Risk Rating 2.0 system has been in effect since October 2021. 6) Regarding section I6: Flood flows
a. Again, the FEIR ignores the impact of climate change. Please see text below under section A. Please note that the Federal Emergency Management Agency (FEMA) is no longer using outdated maps and terminology regarding flood areas because climate change has rendered calculations based on historical data meaningless. The new Risk Rating 2.0 system has been in effect since October 2021. Moreover, recent flooding events around the country have raised awareness about the growing, unprecedented impacts of climate change. For example, in this article published in Scientific American:
https://www.scientificamerican.com/article/studies-sound-alarm-on-badly-outof-date-fema-flood-maps/ attention has been focused on the fact that FEMA maps are out of date and do not fully account for the dangers of flooding in the new era of climate change. Movements are under way around the country to curtail development in flood zones. It is irresponsible to use assessments based on historical data and rating systems which are no longer valid. 7) Regarding section I7: Conflict with water quality control plan or sustainable groundwater management plan
a. Again, the “less-than-significant impact” finding ignores the effects of climate change. Please see additional text under section C below, with particular attention to the impact of climate change on groundwater supplies throughout the state of California and the decreasing water supplies to replenish those groundwater supplies due to decreasing snowpack in the Sierras. b. Please also see additional text in points 8) and 9) below, highlighting that the estimated increase in number of residents due to the development is laughably unrealistic, and apparently assumes that only about 200 additional residents will result from a development containing 87 units, when a much more realistic calculation is that instead there will be >400 new residents. With more than 2 times higher impacts on groundwater supplies than estimated by the FEIR.

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8) Regarding section N3: Education
a. It is unclear how a project that will produce 87 housing units is supposedly only going to include 28 students. The calculation does not make sense and clearly assumes for unexplained reasons that only a third of the housing units will have any child in them, and those units that do have children will only have one child.

This is not realistic nor is there are rationale for why such low numbers of children are expected to be part of the housing development. Is the proposal for an adult community? A more realistic calculation is that 80% of the household will have children and that of those, there will be an average of 2 children per household, bringing the likely number of children that would need to be accommodated in the school district up to 140. In fact, given the high cost of living in the Napa Valley and in the city of St. Helena itself, families often live at much higher density than even this more realistic calculation. In fact, an even more realistic calculation is that closer to 90% of the households will have 5-6 people per house, with 3 of those being children, bringing the potential increase in students in the school district up to 234, 10 times more than suggested by the FEIR.
9) Regarding section N5: Other public facilities
a. Again, it is unclear how the estimate of 213 residents within the 87 housing units has been calculated. This very unrealistic, low number assumes that most of the households will be occupied by only 2 people, with only less than half (39) of the households having one child residing with the two other individuals. First of all, this calculation already demonstrates that the estimate of the number of children in section N3 of 28 is lower than expected, even by the extremely unrealistic calculations of a total of 213 residents across 87 units. A more realistic and still fairly conservative estimate is that 80% of the households will have 4 people in them, with the rest having 2-3 individuals, for a total of closer to >300 residents. An even more realistic calculation, as explained above under point 8) is that households will in fact be much more densely inhabited at occupancy rates of 5-6 individuals per household, bringing the total number of residents up to >400.
10) Regarding section O1: Existing facilities
a. Please see above under point 9): the estimate of 213 residents is unrealistic.

There are likely to be upwards of >400 new residents in the city due to the development.
11) Regarding section P1: Consistency with circulation performance plans a. The finding of “less-than-significant impact” is unsubstantiated by any kind of accounting for the actual increase in the number of residents and therefore also cars that would result from this development. Please see points 8) and 9) above, pointing out that the estimated number of approximately 200 new residents is laughably low and a more realistic number is >400 new residents, with as many as 300 new cars on the roads in the city of St. Helena. 12) Regarding section P2: Transportation hazards
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a. The finding of “less-than-significant impact” is unsubstantiated by any kind of accounting for the actual increase in the number of residents and therefore also cars that would result from this development. Please see points 8) and 9) above, pointing out that the estimated number of approximately 200 new residents is laughably low and a more realistic number is >400 new residents, with as many as 300 new cars on the roads in the city of St. Helena. b. Again, as discussed in point 1) above, the main concern is not simply whether the roads within the new housing development will be wide enough for the new residents to be able to safely drive out of during an emergency, but what happens to all those new additional people and cars once they get onto the current city streets, which can barely accommodate even the current number of cars driving on them, with potholes and street maintenance severely behind a normal maintenance schedule. Many of our streets, including Hunt Ave., are so severely rutted as to be like driving on a dirt road, with the unfortunate effect that cars must drive slowly to avoid damage, further complicating evacuation during an emergency situation, especially with as many as 300 additional cars needing to evacuate on already congested roadways.
c. One needs only look at the current street parking situation on the stretch of Starr Ave. between Pope St. and Hunt Ave. to realize that of course the parking situation with this new development will be a major problem. Again, the EIR assumes a laughably low number of additional residents and cars from this development. All one has to do is look at how many additional cars beyond what was planned for the Hunt’s Grove apartment complex are currently being parked on Starr Ave. A similarly much higher density of vehicles needing to overflow onto street parking would occur with this new development, increasing the risks and hazards of collision, and increasing impacts on current street and traffic flows. Again, the biggest concern is what happens under the increasing threat of catastrophic natural disasters and the ability of all St. Helena residents, current and future, to safely evacuate in an emergency.
13) Regarding section P3: Emergency access
a. As discussed previously under points 1), 2), 11) and 12) this “less-than-significant impact” finding ignores the effects of climate change on the increased likelihood, severity, and urgency of natural disasters and the ability to safely evacuate out of the city on currently inadequate road infrastructure which is not capable of accommodating even the current residents, and it also severely underestimates the number of new residents and cars that would result from the development.
14) Regarding section Q1: Utilities and infrastructure
a. Please see points 3)-7) above detailing the failure of the EIR to account for the effects of climate change on the calculations for effects on water supplies, as well as points 8) and 9) regarding the obvious micalculation of the realistic number of additional residents that would result from the housing development, and the potentially 2 times higher impact on water, wastewater, and other utilities and infrastructure.

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15) Regarding section Q2: Sufficient water supplies
a. The finding of “less-than-significant impact” on the water supplies, again, completely ignores the effects of climate change. All of the estimates put forth in the document simply state that there will be sufficient water supplies in the future to accommodate the new development, citing data from 2013 and 2016, which we all know are now completely meaningless and outdated. The city is currently in an emergency water shortage due to failing infrastructure. Beyond that, climate change is permanently and irreversibly changing the groundwater and reservoir supplies that we rely on. The calculations of water needs and Safe Yield are all based on outdated, historical information which does not account for actual decreases in water yields and replenishment of both reservors and groundwater due to climate change. Please see section C below detailing new information about the dwindling water supply from shrinking Sierra snowpack over the last several years and increased demand for water from growing populations.
b. In addition, please see points 8) and 9) above, highlighting the inadequacy of the calculations pertaining to the increase in the number of residents that would result from the new development. It is likely that instead of about 200 more residents there will in fact be more like 400 new residents, thereby increasing the water demand to double what was projected, since water demand is, rightly so, based on number of people per household rather than number of households.
16) Regarding section Q3: Wastewater treatment capacity a. Please see points 8)-9) above regarding the miscalculation of the real number of residents that would result from the development (i.e. double the estimate). The finding of “less-than-significant impact” does not account for this miscalculation in the actual increase in the number of residents that would occur with the development, and instead uses an extremely unlikely and very low estimate of the number of people per household that would result.
17) Regarding section R1: Impairment of adopted emergency response plan or emergency evacuation plan
a. Please see points 1), 2), 11), 12) and 13) above: the finding of “less-thansignificant impact” ignores the impacts of climate change and does not account for the current inadequacy of city infrastructure on the ability of both the new residents and current residents to safely evacuate out of the city during an emergency.
b. Please also see points 8) and 9) above: the “less-than-significant impact” relies on a flawed underestimate of the actual increase in number of residents that would result from the development.
18) Regarding section R3: Infrastructure-related wildfire risks a. Please see points 1), 2), 11), 12) and 13) above: the finding of “less-thansignificant impact” ignores the impacts of climate change and does not account for the current inadequacy of city infrastructure on the ability of both the new Agenda Item #5.10.

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residents and current residents to safely evacuate out of the city during an emergency.
b. Please also see points 8) and 9) above: the “less-than-significant impact” relies on a flawed underestimate of the actual increase in number of residents that would result from the development.
19) Regarding section 3A1: Air quality management plan consistency a. The finding that there will be an unavoidable impact on vehicle miles traveled (VMT) is still underestimating the full scope of that impact given the underestimate of the number of residents and vehicles that would actually result from the development, as pointed out in 8) and 9) above.

Climate change is happening. We all know it and have lived it and seen it over the last several years. Each fire season is worse than the last, each winter is warmer than the last, each year the weather patterns become more unpredictable. The recent conclusion from the United Nations Glasgow Climate Change Conference (COP26) meeting is that even if all countries that pledged to fully implement changes needed to meet agreed upon greenhouse gas reduction goals are actually able to meet those goals, we are still on a trajectory to see increases in the earth’s temperature of at least 1.8 degrees Celsius (https://www.washingtonpost.com/climateenvironment/2021/11/09/cop26-un-emissions-gap/). This means that the recently experienced natural disasters in our area including wildfires, flooding, mud slides, and droughts, are only going to be more frequent and exacerbated over the next 10-20 years and beyond.

What were once “100-year flood areas” will now effectively need to be renamed “it could flood any time” areas, highlighting the issue of the levy and the fact that the Hunter project is in a high-risk flood zone, which is inadequately addressed in the EIR. Furthermore, more frequent wildfires, as we have seen recently, will require more frequent evacuations, thus public safety and transportation during emergencies and natural disasters is another area that was not adequately addressed by the EIR. Finally, we are currently and in all likelihood will continue to experience droughts of unknown severity and duration and we barely have enough water for the current citizens of St. Helena, and this threat to our future water supply is inadequately addressed in the EIR. I have addressed each of these issues, as well as several additional issues in my comments below.

A. The Hunter Project is in a flood zone behind a levy that is NOT supported by federal funds, and when the levy fails and the homes within the project are flooded the residents of the city of St. Helena will be fully responsible for paying for repair of the levy and all the damage to the homes.

For the first time in 50 years the Federal Emergency Management Agency (FEMA) is changing its flood insurance program to better reflect the real risks associated with flooding in certain high-risk zones, and that take into account climate change. The entire idea of “100-year flood” zones is now outdated and no longer being used because it uses outdated projections about yearly percentage risk of flooding based on irrelevant, old information about weather patterns over the last 100 years. The new Risk Rating 2.0 is instead tailored to each individual property, and is designed to "adapt and re-adjust rates based on a changing, unpredictable climate,” Agenda Item #5.10.

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clearly highlighting the fact that the risk of catastrophic floods and failing levies in certain high-risk areas is so volatile as to be unpredictable
(https://www.houstonpublicmedia.org/articles/news/energyenvironment/2021/06/24/401402/femas-changing-its-flood-insurance-program-heres-how-itwill-impact-texans/). The new approach also takes into account more causes and types of flooding, including storm surge, river overflow and heavy rainfall, because climate change is increasingly and unpredictably leading to flooding due to heavier rain falls, sea-level rise, and stronger wind and storm weather patterns. The new risk rating policy is in effect starting October 1, 2021 for any new projects (https://www.fema.gov/flood-insurance/risk-rating). This is brand new information that is not in any way reflected in the EIR and in fact, all of the material in the EIR with regard to the fact that this project is in a high-risk flood zone, behind a levy that is city-managed and maintained rather than being maintained by the Army Corps of Engineers, is completely ignored by the EIR.

According to the official FEMA map of the city of St. Helena, the Hunter Subdivision project is clearly within a flood zone (https://map1.msc.fema.gov/firm?id=06055C0264E).

Although the city paid for consultants to try to mitigate this risk by providing independent evaluations that take into account the mitigation of the flood risk due to the existence of the levy, as I pointed out above, this all goes out the window with the current increased risks we are facing due to climate change. How does the city plan to provide and pay for the rescue of hundreds of additional citizens in this high-risk area, repair the failed levy and all the damaged homes WHEN (not if) there is a catastrophic flooding event, possibly as early as within the next 5-10 years? The unfortunate truth is that this parcel of land is in a flood zone. The entire parcel was purchased for a laughably low amount that currently cannot get you an average 2- bedroom, 1-bathroom home in this town. This parcel was sold cheap, because it should never be built on. A levy was constructed against the recommendation of the Federal government, which walked away from the project because it is not a good idea to build homes in a flood zone, and the city of St. Helena and its residents are entirely financially responsible for the maintenance, repair, and when needed, re-building of the levy when it fails. Where is the accounting on the financial implications of such an undertaking and the environmental impact of such a financial burden on the city and its citizens? Not to mention the financial toll on the people who will have bought these houses falsely deluded into thinking that they were “safe” behind the levy? The simple truth is that levies fail. Even a brand new, world-class levy built by the Army Corps of Engineers to protect the city of New Orleans failed a second time, after it was professionally rebuilt.

It was only last year, as we all remember so vividly, that we experienced an “atmospheric river.” Anyone who lives near the Napa River here and walked out to take a look over the bridge saw for themselves that the water rose well beyond the riverbed, and in some places flooded over the river banks. And this was, even in comparison to the atmospheric storm that we experienced last year, actually a fairly modest event. What will the next one look like? We simply do not know. But one thing is for sure: there will be a catastrophic weather event, and the levy will fail. The only question is when. The likely NEW answer, given the accelerating rate of climate change, is that it will be in significantly less than 100 years.

Agenda Item #5.10.

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B. Climate change is drastically and unpredictably altering weather patterns, and the incidence of wildfires and all of their consequences, both acute and long-term, is increasing to unprecedented rates that are surpassing all predictions based on historical data.

According to the National Interagency Fire Center the state of California faced over 8,000 fires that burned over 500,000 acres of land in 2002
(https://www.predictiveservices.nifc.gov/intelligence/2002_statssumm/fires_acres.pdf). In 2020 those numbers jumped to nearly 10,000 fires that burned over 4 million acres of land (https://www.predictiveservices.nifc.gov/intelligence/2020_statssumm/fires_acres20.pdf)! The state of California is facing unprecedented increases in wildfire incidences just in the last 20 years, at a time when the earth’s temperature has increased by less than 1 degree Celsius (https://www.climate.gov/news-features/understanding-climate/climate-change-globaltemperature), while the best-case scenario projections for temperature change, as pointed out above, are on the order of 1.8 degrees Celsius over the next 20 years, strongly suggesting that the incidence of wildfires is only going to increase. The current EIR does not account for these increases in risk due to wildfire. This is a problem in two specific ways: 1) more fires means more evacuations and more people that need to be able to leave in a short amount of time in a limited geographic area with limited evacuation routes, and 2) more fires also means more mud slides due to deforestation and loss of vegetation, which makes our beautiful hills more susceptible to slides when heavy rains hit.

The recent wildfires in Napa Valley and Sonoma Valley are a sobering reminder of what happens when wild, unpredictable winds coincide with extreme dry conditions and ignition sources. Sometimes those ignition sources are dry lightning, other times sparking generators, other times, devastatingly, even arson. Regardless of the ignition source, which in and of itself is growing in incidence (dry lightning storms in the Napa Valley in August?), the cold, hard truth is that due to climate change the “wildfire season” in California is increasing. More and more days out of more and more months of the year, from as early as April to as late as December, there are days when the combined conditions of extremely low humidity and high winds make this area ripe for fires to start (https://www.latimes.com/projects/wine-country-firescalifornia-sonoma-napa/). The fact is that there are only two ways out of town. Highway 29 and Silverado Trail. These are both narrow, 2-lane highways that can only move so many cars out per minute, and that is if all goes well and there are no accidents from people panicking and driving recklessly.

I remember very vividly driving in the middle of the night and listening to the radio with the announcer imploring people to please drive carefully so that our only arteries out of danger are not blocked by overturned vehicles, effectively trapping everyone trying to evacuate to safety. We have no right to endanger the people who already live in this town by building a large development that would add as much as 10% to our overall population in the city, with an even higher impact on the residents on the East side of town, where the population density is already higher and the population is already more vulnerable, with multiple apartment complexes and low-income housing areas housing our town’s low income residents and seniors, including Hunt’s Grove apartments, Stonebridge apartments, the Silverado Orchards Retirement apartments, and the Vineyard Valley Mobile Home Park 55+ community.

Agenda Item #5.10.

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This is not the part of town where half of the homes are second homes that sit unoccupied most of the year. The East side of St. Helena where the Hunter parcel is located is the part of town where there are more people per square mile that need to be able to evacuate in an emergency. The EIR already concedes that the one environmental impact that cannot simply “be mitigated” as has so conveniently been done with all of the other potential impacts, is the unavoidable impact on traffic. Phrasing it as a simple “traffic problem” makes it seem like just a minor nuisance. This is not about us having to wait a few extra minutes to make a left turn onto Pope Street when we are trying to get to work on a Monday morning. This could mean the difference between a family being able to evacuate to safety in time, or not being able to do so because they are stuck in traffic with 500 more people than should be living here all trying to leave their homes at the same time. And make no mistake this is also an equity issue: the very people who are the most likely to have to wait until the last minute to evacuate and thus be in danger when traffic is backed up and they cannot evacuate from fire, are those who do not have the funds to evacuate earlier than “necessary” because they cannot afford to simply pay for a hotel for days on end.

It is also critical to consider that the only way out, on one of only two roads out of town via the Silverado Trail for residents of the East side of town, is the Pope Street bridge. A historic, narrow, completely inadequate bridge that if even one car failed, crashed or overturned while trying to drive across, would completely cut off this evacuation route, and redirect all traffic from the East side of town onto Highway 29. It is difficult to envision how such an accident could even be remedied in a situation such as this, given that the bridge is barely wide enough for two vehicles to drive across, with no shoulder at all for emergency vehicles to be able to approach. It is easy to see how very quickly this very real danger of too many vehicles on the road all trying to go the same way out in a nightmare, yet very real, and recently experienced emergency wildfire evacuation scenario, becomes not just an East side problem, but also a problem for those trying to evacuate from the West side of town.

Just as the recent “atmospheric river” weather event increased our awareness of the high risk of flooding on the Hunter parcel, perhaps even more convincingly it reminded us of the extreme vulnerability of recent burn areas to heavy rainfall, the resulting mud slides, and the further impacts on our roads. I am sure that I do not need to remind anyone of the nightmare traffic that we experienced for nearly 3 weeks following the October 22 weather event that caused a mud slide that resulted in the closing of Silverado Trail (https://patch.com/california/napavalley/storm-takes-out-part-silverado-trail). Traffic on Highway 29, from vehicles being redirected from Silverado Trail north and south of town, was atrocious. Many residents who either needed to drive north or south out of town were dealing with traffic delays of up to 2 hours. On a normal day this is very frustrating and disruptive to work and school schedules. In an emergency situation where fast-moving wildfires necessitate immediate evacuations, a situation such as this is a devastating problem for a town that has only two roads out of town.

C. The severe drought and water shortages we are currently experiencing in the city of St. Helena are a harbinger of even worse times to come. We simply cannot support a large development which will drastically increase water demands on an already Agenda Item #5.10.

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strained and inadequate system that can barely supply enough water to our current residents.

Unfortunately, our water shortage problems here in St. Helena are happening all over the state.

Wells are running dry (https://calmatters.org/environment/2021/08/california-groundwaterdry/). Despite changes to California ground water laws in 2014 to enact sustainable practices that protect ground water, seven years later wells around the state continue to run dry. Current climate change projections, as outlined already above, are dire, and suggest that drought severity, intensity, and duration will only worsen over the coming decades. We simply cannot rely on old projections about water availability because we are in uncharted territory. Our ground water sources are not being normally replenished. The normal water cycles are not operating the way they used to. And it is not just wells that are running dry.

Snowpack in the Sierras normally “supplies about 30% of water statewide when the spring melt comes and water runs off to be captured in the state's system of reservoirs” (https://www.sfgate.com/bayarea/article/Sierra-snowpack-satellite-image-atmospheric-river16568005.php). But last year’s snowpack was only 59% of average, and even more disturbing and unexpected was the fact that 80% of the already lower than normal, predicted water runoff was simply soaked up or evaporated because the soils were so hot and dry, severely impacting water levels in reservoirs across the state. Even after the “atmospheric weather” event in October which brought heavy rains and a rise of over 20 feet to Lake Oroville, for example, according to the Department of Water Resources, this reservoir is at only 27% capacity. So it is not just our ground water and wells that are drying up, our Sierra snowpack, and thus reservoirs and rivers are also drying up. As mentioned earlier, climate change means that we are experiencing more and more warmer and warmer days, and this means that even if we do get big storms the snowpack does not stick around, and even when we do get runoff from the snowpack, the earth is so parched that the water simply disappears on its way to our reservoirs.

Our own reservoirs and water sources are not doing so well. Bothe last summer and currently, as I am sure we are all quite vividly aware of given the astronomical water bills, we entered severe drought restrictions (Phase II Water Regulations), with water use limited per household, and very unpopular and extreme fines being put in place in an attempt to mitigate the very real risk that we could run out of water before the reservoir was replenished by winter storms. We were lucky last year, since we did happen to get the big storm in October that saved us from imminent disaster, but next time we may not be so lucky. What is our city’s plan for dealing with these new, unexpected, unpredicted risks of severe and sustained drought conditions due to climate change? How do we plan to supply water to even the current residents, much less to 500 more residents if the Hunter parcel were to be developed? The current EIR does not adequately address these issues. Laughably simplistic solutions like the use of “low flow toilets” as a mitigation solution for our real water shortage issues that are only going to worsen over time, are so inadequate as to be insulting. We cannot rely on water supplies staying what they were even in the recent past, or being predictable based on what we used to know about how much water we might expect any given year based on old weather patterns. In fact, it is quite clear that this year’s severe drought and water shortages are likely to occur with much greater frequency in the coming years and decades, as our ground Agenda Item #5.10.

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water supplies, snowpack, river flows, and reservoir levels continue to be severely impacted by climate change. The EIR does not address these very real water issues in any real way.

I request that the city planning commission address the concerns related to climate change expressed above about the inadequacy of the EIR for the Hunter parcel, and the resulting threat to public health and safety of the development project.

Sincerely,
Angela M. Zivkovic
Agenda Item #5.10.

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1 Xinia Gamero
From: Katie Avery <[email protected]>
Sent: Tuesday, November 1, 2022 10:17 AM
To: Public Comment
Subject: [External] Hunter Subdivision FEIR
To Whom It May Concern,
We received a letter last week stating that the City Planning Commission would be considering the Final Environmental Impact Report today, November 1, 2022. We have not yet had enough time to read through the FEIR and this is a huge project that could change the city dramatically. The city has just asked its residents to conserve water as we lost a pump a few weeks ago. We cannot allow this to move forward until the residents of St Helena have had enough time to review the FEIR and comment on it. I don’t believe the potential effects of the proposed project have been reduced to less than significant levels. There is absolutely no way, without changing the plan entirely, for this to happen. The residents of St Helena need more time to read through this new report and were not given any time to do that. A massive 3,000 page document needs more than a few days to review.

Respectfully,
Jake & Katie Avery
Main St & Hunt Ave
Agenda Item #5.10.

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1 Xinia Gamero
From: [email protected]
Sent: Tuesday, November 1, 2022 11:47 AM
To: Public Comment
Cc: [email protected]
Subject: FW: [External] Request for a Continuance of Public Hearing Item 5.1 Beyond Tonight's Planning Commission Meeting
I would like to request that the Public Hearing for Item 5.1 be continued to a later date to be determined and that no Recommendations to the Council be made by the Planning Commission until after this continuance. This would allow the Public and the Planning Commissioners more time to evaluate the voluminous (2894 page) FEIR and respond with appropriate comments and recommendations.

The sudden release of the FEIR and rushed scheduling of the Public Hearing is not fair to the Public or the Commissioners who have a lot to absorb and respond appropriately. Also, the Commissioners will be presented with more information from the Public at the Hearing tonight that may better inform how they respond to Staff Recommendations. Community participation in the EIR process for this project is considerable as evidenced by the volume of comments to the DEIR and Public Comments submitted for this hearing.

And,..what is the hurry? This EIR has been going on for 12 years and what would be the harm in continuing this hearing until December or January allowing for a thorough and transparent review of the FEIR. I also think this would go a long way in restoring the public’s confidence in participating in the EIR process and that their comments are being fairly evaluated. As it stands now, the surprise release of the monster FEIR 11 months after DEIR comments were that submitted indicated that NOT ONE further significant impact was identified. I believe over 185 people commented on the DEIR and it is hard to believe that NONE of the comments elicited a change of even one thing in the FEIR from the DEIR. It is as if the DEIR was perfect and none of the 186 comments had merit. This combined with the rushed rollout of the FEIR is a bad look for the Saint Helena Planning Department.

Personally, I know that my comments were summarily dismissed without so much as a single “you may have a point there”. The public was also informed that if you want to challenge any of the City’s decisions on any of these matters in court, you may be limited to raising only those issues you raised at the public hearing described in this notice in written correspondence delivered to the City prior to the hearing. I very much disagree with the responses to my comments and will be re-submitting them to preserve my right to raise these issues in court. I would also like more time to comment on the responses to my comments.

Thank you for your attention in this matter.

John Milliken [email protected]
1256 Hudson Ave.

Saint Helena, CA 94574
Mobile/Text: 7074864266
Agenda Item #5.10.

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1 Xinia Gamero
From: [email protected]
Sent: Tuesday, November 1, 2022 11:54 AM
To: Public Comment
Cc: [email protected]
Subject: [External] Resubmittal of Comments on the DEIR for the Hunter Residential Subdivision Tentative Map Application to Preserve Legal Rights to Raise Issues for Agenda Item 5.1 Attachments: 02-20-2020_unresolved_issues_and_questions_hunter-final-c2.pdf; LeveeZoneEasementMap.pdf; VB Comments GP Update.pdf
John Milliken ([email protected])
Mobile/Text: 7074864266
1256 Hudson Ave., St. Helena, CA 94574
From: John Milliken <[email protected]>
Sent: Tuesday, November 30, 2021 11:59 AM
To: [email protected]
Subject: FW: Comments on the DEIR for the Hunter Residential Subdivision Tentative Map Application John Milliken
[email protected]
707-963-8134 (Office) 707-486-4266 (Mobile\Text)
1256 Hudson Ave.

St. Helena, CA 94574
From: John Milliken <[email protected]>
Sent: Tuesday, November 30, 2021 11:54 AM
To: '[email protected]' <[email protected]>; '[email protected]' <[email protected]>; '[email protected]' <[email protected]> Subject: FW: Comments on the DEIR for the Hunter Residential Subdivision Tentative Map Application November 30th, 2021
FR: John Milliken
1256 Hudson Ave, Saint Helena, CA 94574
Please include my comments and attachments concerning the DEIR for the Hunter Residential Subdivision Tentative Map Application (File no. PL 10-040).
1) Planning and Zoning Code Violations
Agenda Item #5.10.

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2 There is no mention in the DEIR of the project’s numerous violations of the St. Helena Zoning Ordinance. All land use decisions must be consistent with a city’s general plan and zoning ordinance. (Collier v. City and County of San Francisco (2007) 151 Cal. App. 4th 1326, 1333, citing Gov. Code 65860, subd. (a)(2); Napa Citizens for Honest Government v. Napa County Bd. of Supervisors (2001) 91 Cal.App.4th 342, 355. See also Land Management v. Contra Costa Bd. of Supervisors (1990) 222 Cal.App.3d 950,957-958 [“issuance of a permit inconsistent with zoning ordinances or the general plan may be set aside and invalidated as ultra vires”].) The proposed Tentative Subdivision Map and related residential construction violate the St. Helena Zoning Ordinance.

Most of the violations involve non-compliance with the City’s Inclusionary Housing Ordinance, Chapter 17.146, as documented by the attached Notification of Final Unresolved Issues and Questions prepared by the City’s Building and Planning Director on 2/27/2020. There were no responses from the applicant to this notification mentioned in the DEIR or listed on the Project’s Planning Archive. This notification was actually the fourth sent by the City Planning Department for this second attempt at a DEIR. All four document the same Chapter 17.146 violation issues. These same issues were also brought up at the initial Public Scoping Comments Meeting held in April of 2018. With the City and the Applicant well aware of the project’s violations of the Inclusionary Housing Ordinance since 2018, it is a mystery as to why these violations were not addressed in the DEIR. Also, per the section in the Municipal Code cited by Contract Planner, Eric Norris, in a letter to the applicant concerning other violations of the Municipal Code: “More on point is the requirement that a map must be denied if it does not comply with the General Plan and Zoning Code. Muni Code (section

16.16.080.D) states, A tentative map shall be denied if any of the following findings are made: 1. That the proposed map is not consistent with the general plan, applicable specific plans, or other applicable provisions of this code. Simply put, the map as presented to the Planning Commission for approval must meet all of the applicable standards of the Zoning Code. No mechanism is available to avoid this requirement.” 2) The DEIR Analysis is based upon an Affordable Housing Proposal that does NOT conform to the City’s Municipal Code and fails to account for potential California State Density Bonus and Development Concessions.

Because the applicant has featured “Affordable Housing” as a center piece of this project from day one, it is virtually impossible to prepare an EIR to CEQA standards without having a lawful Affordable Housing Agreement (AHA) in place that details the number, types and distribution of restricted units. As it stands now, the applicant is proposing that:

NONE of the 51 Market Rate 4 Bedroom Single Family Homes will be restricted; ALL of the 25 Duets of the restricted housing will be on one lot, and the 11 ADUs will be on 11 of the Market Rate lots (location to be determined). If the City were to accept this legally dubious proposal as is, the project would be eligible for a State Mandated Density Bonus that could trigger development concessions as well as allow for between 30 or 40 more units. So, a legally comprehensive EIR would have to take into account the impacts of these concessions and potentially greater number of units. And, there is also some controversy about whether or not the ADUs that are located on Single Family Lots would qualify for a designation of restricted housing and qualify as units that could be applied to the Density Bonus calculation.

Also, since the latest Project Description has an Affordable Component that is violation of the Municipal Code, there may have to be further changes made to the number, types and distribution of the restricted units to bring the project into conformance. All of this speaks to the difficulty of preparing an EIR to CEQA standards where the legality, number, types and distribution of restricted units are a moving target. The City should insist that a legally conforming AHA be formalized and a new DEIR analysis be appended based upon the details of the AHA. To not do so will send this second attempt at an EIR to the same fate as the failed first seven-year effort. The applicant has had 11 years to provide a lawful AHA and the majority of the delay in this EIR can be laid at the feet of the applicant’s inability or refusal to do so. 3) Environmental Diminishment of Taxpayer Funded Conservation Easements and a City Owned “Parklet” lot.

The DEIR makes no mention of how the extension of Adams and the intersection of Adams and Starr will be built upon a state taxpayer funded conservation easement. Additionally, there is a City owned parcel that will be paved over by the extension of Starr that is currently used as a non-motorized access point to the taxpayer funded river trail and levee hiking path. The conservation easements were agreed to by the City in exchange for funds from the Department of Water Resources to be used for the construction of the Flood Project in 2009. The City agreed that the conservation Agenda Item #5.10.

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3 easements were to exist in perpetuity. This would not be the case if a paved road(s), that would accommodate vehicles to access the residential housing proposed by the applicant, were built on the western portion of a conservation easement. This easement is clearly shown a map of the Levee Zone Easement (map attached) by recently prepared by the City to facilitate the transfer of deed to the Napa Valley Land Trust. Not only does this proposed road development on a conservation easement violate the spirit of the DWR agreement, it also threatens the funding from this organization if they find out that an easement has been violated. There is a precedent for having to return a public agency’s funding for the flood project. When it was found out the City had used FEMA funding improperly and also double billed FEMA for flood project activities, the City had to return $1.9 million in funds.

Attached are comments prepared in 2019 by a resident of St. Helena, Victoria Bradshaw, for the 2040 General Plan Update. These comments detail how the City never included plans for an extension of Adams in any of the funding agreements that provided funds to build the flood control project. None of this was reported in the DEIR. Also, in these comments is a report on the shocking lack of maintenance by the City of the levee (that continues to this day!) that was never built to accommodate a road. Once again, … none of this was mentioned or explored in the DEIR.

Environmental impacts that come with the diminishment of conservation easements were never addressed by the DEIR.

These include: having to walk/ride right next to a trafficked through road lined with parking and housing instead of what is currently open space/vineyard/wild life corridor. The path from the library to the river or atop the levee is an open space jewel that is enjoyed by many residents and visitors. The open space agricultural character of path(s) that are used to walk/exercise pets away from traffic, provided sweeping views of the surrounding mountains, and provide a muchappreciated tax payer funded venue for outdoor exercise and fresh air will literally be paved over. (Please see the attached photo documenting local Starr residents out walking their dog on Thanksgiving Day along the proposed route of the Starr extension.)
4) Traffic and Public Safety Impacts Not Mentioned in the DEIR.

Agenda Item #5.10.

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4 Although the DEIR claims to have studied the Traffic impacts of the project using the newer VMT standard (that only studies miles traveled by the project’s residents), there are quite a few Traffic Impacts that were ignored by the DEIR.

Also, the DEIR failed to study the impacts on Public Safety by ignoring the potential problems with evacuation routes created by the project, be it for flood or fire.

Other traffic impacts not mentioned in the DEIR include:
a) An increase in pass through traffic through surrounding residential neighborhoods by drivers looking to avoid congestion on Main Street (Highway 29) by crossing between the Silverado Trail and Main Street. Taking highway traffic off the highways and routing it through residential neighborhoods is insane. However, this is what will happen with the advent of apps like Waze or Google Maps, that will direct drivers to go through residential neighborhoods to save just a few minutes of driving time if new connector streets (Adams and Starr) are built. Once again, …none of this was studied or identified in the DEIR.
b) Residents of Hunt’s Grove and surrounding neighborhood will have to navigate and intersection with cross traffic (Hunt and Starr) to walk/drive to schools, shopping, etc. Simply put, there will be a lot more traffic on Starr if a connection is made to an Adams Street extension. Once again, …none of the impacts of this new intersection on the safety of residents was identified in the DEIR.
c) Overflow parking from Hunt’s Grove is already a problem on Starr and the surrounding neighborhood. These problems will be exacerbated by the new development from all the higher density development allowed on Lot 52. In addition, whoever develops Lot 52 can request a parking concession from the Density Bonus program that will allow fewer off-road parking spaces to be provided. Once again, …none of the impacts on increased demand for limited parking spaces was identified in the DEIR.
d) Evacuation routes from Vineyard Valley and the surrounding neighborhood could be impacted by the additional pressures from the proposed development. Not only will residents in Vineyard Valley be evacuated, all the residents of the project will be using the same evacuation routes. This could turn the evacuation into a Public Safety failure. Once again, …this was not studied or identified in the DEIR. 5) Public Safety Hazards Concerning the Lack of and Maintenance of the Flood Project and the Construction of the Levee
The aforementioned Comments prepared by Victoria Bradshaw in 2019 for the 2040 GP document the lack of maintenance of the Flood Project since its construction in 2010 and also how the levee was never intended to be used as a road bed. These two conditions result in a heightened degree of the chances for catastrophic levee/flood wall failure that could result in a loss of lives and property for residential development in a flood plain behind a compromised levee/flood wall. This is the opposite of risk management and it was never mentioned in the DEIR.

Here is a link to a cloud photo album that documents the construction and (lack of) maintenance from the time the levee/flood wall was started in 2009 to just last Thanksgiving Day:
https://photos.app.goo.gl/dDLvFW3nwMzxc7HP8
As you can see, the rodent damage over the years is quite extensive. The rodent damage is most extensive at the base of the VV flood wall as well as where the wall meets the levee. This is the area that would be most impacted by hydraulic forces in a major flood event. Perhaps even more disturbing are the levee inspection reports obtained from the City dating from 12/6/2019 – 7/7/2021. They state for Item 10 Animal Control, there is an Acceptable Rating (“Continuous animal burrow control program in place that includes the elimination of active burrowing and the filling in of existing burrows.”) Based on the photos, the rating should be Unacceptable (“Animal burrow control is not effective or is nonexistent. Significant maintenance is required to fill existing burrows, and the levee will not provide reliable flood protection until this maintenance is complete.”)
Agenda Item #5.10.

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5 Additionally, since the City could be liable for levee/flood wall failure, the impact to the finances of the City and its ability to provide services to the community could also be at risk.

Agenda Item #5.10.

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City of St. Helena
Planning Department
1480 Main Street
St. Helena, CA 94574
February 27, 2020
VIA Email [email protected]
Mr. Ben vanZutphen
237 Lorraine Ct.

Healdsburg, CA 95448
Re: NOTIFICATION OF FINAL UNRESOLVED ISSUES AND QUESTIONS – Hunter Residential Subdivision Tentative Map Application Re-Submittal (File no. PL 10- 040)
Mr. Hunter and Mr. vanZutphen:

The purpose of this letter is to summarize our current understanding of key aspects of the Hunter Subdivision and identify issues of concern to City Staff that have yet to be resolved.

Project Description:

The property contains 16.92 acres. The development proposed includes:
51 Market Rate For Sale detached single family residences with 11 Accessory Dwelling Units (“ADUs”) deed restricted for rental at Moderate Income Rents; 20 Rental Duets at Moderate Income Rents; and 5 Rental Duets (Two duets + One single) at Very Low Income rents. The total number of units proposed is 87 (including the ADUs).

The Applicants are proposing to enter into an “Affordable Housing Regulatory Agreement and Declaration of Restrictive Covenants” (hereinafter “Affordable Housing Agreement) in conjunction with the approval of a Tentative Subdivision Map.

The City’s issues of concern with the proposal are discussed below.

Affordable Housing Proposal:

The Affordable Housing Agreement that you have proposed to use will require significant additional editing to conform to this proposal. The Agreement is a form that would be used for a typical multi-family rental density bonus project. Your proposal, however, requests entitlements for a predominantly for-sale single family subdivision, with a clustered multi-family component and eleven ADUs intended to satisfy the City’s Agenda Item #5.10.

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2 inclusionary requirements. The Agreement requires edits so that it is consistent with the proposal, and to correct a number of inconsistencies within the document. The City can make edits to the Agreement, but before doing so City staff would like to highlight a number of substantive concerns raised by the Agreement and the affordable housing proposal.

1. Compliance with the City’s Inclusionary Housing Ordinance.

In a letter from RSA+ dated September 4, 2019, Mr. Sill asserts that the applicant does not intend to submit the project as an Alternative Equivalent Proposal under the City’s Inclusionary Housing Ordinance, because the project is consistent with the requirements of Chapter 17.146. Staff disagrees with Mr. Sill’s assertion for the reasons outlined below.

First, your proposal includes only rental affordable housing units. Under Section

17.146.050(g)(2), if “the developer is required to build four or more units of affordable housing, the number of affordable units which are required to be constructed in very low, low or moderate units shall be determined by the ration of units needed in each of those categories in order to satisfy the City’s fair share housing goals.” The City’s Regional Housing Needs Allocation currently requires the following number of units in each of the below market rate categories :

Very low income: _____13 units ____25%
Low income: ___ _ 9 units ____17%
Moderate income _____11 units ___ 21%
If you intend to provide rental units as part of this development, the units must be rented to very low, low and moderate income households based on the percentages set forth above. Your current proposal does not reflect those percentages, and therefore is not consistent with Section 17.146.050(G)(2).

Second, as we have discussed previously, City staff continues to have concerns with the fact that a portion of the affordable units will be provided as rental ADUs and the remainder of the affordable units clustered on a single parcel. Section 17.146.050(I) declares:

Affordable units shall be comparable in number of bedrooms, exterior appearance and overall quality of construction to market rate units in the same residential project. Subject to the approval of the planning commission, square footage of affordable units and interior features in affordable units need not be the same as or equivalent to those in market rate units in the same residential project, so long as they are of good quality and are consistent with contemporary standards for new housing. Affordable units shall be dispersed throughout the residential project, or, subject to the approval of the planning commission, may be clustered within the residential project when this furthers affordable housing opportunities.

Agenda Item #5.10.

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3 ADUs are significantly smaller units that are adjunct to the primary use of the single family dwellings located on each proposed lot. There is no indication that these ADUs or the duet units would have a comparable number of bedrooms to the market rate units, as required by Section 17.46.050(I).

Further, neither the ADUs nor the 25 duet units will be comparable in exterior appearance to the market rate units. This requirement is intended to ensure that the affordable units are indistinguishable from the market rate units, so that the affordable units are more fully integrated into the overall development. ADUs and duet units clustered onto a single lot unquestionably look different than single family homes, and therefore clearly have a different exterior appearance from single family homes. The proposal will not comply with this requirement of Section 17.46.050(I) either.

Additionally, while Section 17.146.050(I) indicates that the affordable units need not have the same square footage as the market rate units, that exception is “subject to the approval of the Planning Commission.” (Id.) In this proposal, where the affordable units all appear to be significantly smaller than the market rate units, Staff would not recommend that the Planning Commission make such an exception.

Finally, the affordable units are not dispersed throughout the project. Over two-thirds of the units are located on a single parcel, and an additional eleven ADUs will be located on a handful of the other 51 lots. The proposal does not meet the spirit nor the letter of the requirement that the units be dispersed throughout the project.

In summary, City staff does not believe this proposal is compliant with the City’s inclusionary housing requirements. As we have discussed previously, the Municipal Code does allow a developer to propose to meet the inclusionary requirements through an equivalent alternative action. We encourage you to provide a written narrative proposing how the affordable housing proposal will further affordable housing opportunities in the City to an equal or greater extent than compliance with the express requirements of Section 17.146.050(A), or the payment of an in-lieu fee. Based on the information that you have provided to this point, Staff cannot support your current proposal as compliant with the City’s inclusionary housing requirements.

2. References to Low Income Units and Households.

Throughout the Agreement, there are references indicating that the proposed development includes units that are restricted for rental to Low Income Households. (See, e.g., Recital C, Article 1, Definitions, Section 2.3, Increased Income of Tenants.) However, the proposed development includes only moderate and very low income restricted units. If there are no low income units to be included in the development, the references to low income households and low income units should be deleted.

However, as noted below, the City believes that you must also set aside low income units in order to comply with the City’s inclusionary housing requirements.

Agenda Item #5.10.

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4 3. References to Density Bonus..

Recital D of the Agreement stipulates: “As consideration for providing the Restricted Units, the Applicant reserves all rights under the State Density Bonus Law, as that term is defined in Article 1 below, with respect to incentives, concessions, waivers, and reductions.” Section 2.2 of the Agreement also states that you are providing the affordable units in exchange for incentives, concessions, waivers and reductions. Staff continues to question this proposal. There is no request for a Density Bonus on file. In fact, the overall project density is 5.1 units per acre, exactly at the minimum range established for the Medium Density Residential Designation in the City’s General Plan.

Not only are you not providing any additional units beyond the minimum allowed by the General Plan, you have not specified the nature and extent of any “… incentives, concessions, waivers, and reductions” in the Agreement. Further, this Agreement is to be entered into and recorded after entitlements are approved for the development. At that point, the City cannot provide incentives, concessions, waivers or reductions. If you are seeking a density bonus, incentives, concessions, waivers or reductions under the Density Bonus Law, please indicate what those are so the City can evaluate them as part of our review of your proposal.

4. Additional Comments Regarding the Affordable Housing Agreement:

If this affordable housing proposal is to move forward, there are a number of issues that will need to be addressed in the Affordable Housing Agreement, including the following:
a. The Agreement would have to require that the 25 duet units will be managed by a property management firm experienced in managing income restricted rental properties, as approved by the City. This is especially important in this instance, where the developer is proposing to sell the market rate units but rent the affordable units. The City would need assurance that the rental units would be competently operated, in order to ensure that the rental units remain part of the City’s affordable housing stock.
b. The Agreement would have to provide a mechanism to ensure, to the satisfaction of the City, that the ADUs would in fact be rented to households in the appropriate income categories. Individual homeowners frequently use ADUs as guest houses, offices, studios, and additional living space for the occupants of the primary residence. There would have to be some mechanism in place that would assure that did not occur with the restricted ADUs. Section 17.146.050(J)(4) requires that the resale restrictions for rental units must be acceptable to the housing director and city attorney, and this issue would need to be addressed in order to satisfy the City representatives.
c. In Section 2.2(b), the graphic indicates a mix of 23 two bedroom units and 13 three bedroom units. If there are no studio or one-bedroom units, those references should be deleted from the graphic. Additionally, Exhibit B indicates all of the duet units Agenda Item #5.10.

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5 are two bedroom units. That would mean there are at least 25 two bedroom units. That also suggests that all the ADUs are three bedroom units, which seems unlikely. d. One of the duet units should be described as a single unit, since there are 25 units on the clustered lot, and there cannot be an odd number of duet units. e. If there is to be a Homeowner’s Association or equivalent entity, the dues or costs associated with that entity should be addressed in the Affordable Housing Agreement and included in the rent calculation.
f. The Agreement should expressly require, per the City’s ordinance, that no certificate of occupancy shall be issued, final inspection approved or release of utilities authorized for any new dwelling unit in the project until the developer has completed onsite construction of all the required affordable units. (See Section 17.146.050(M).) If this affordable housing proposal moves forward, the City will provide additional edits to the proposed Affordable Housing Agreement, and the City reserves the right to recommend additional changes to the Agreement as it proceeds through the Planning Commission and City Council process.

Conformance with the St. Helena General Plan and Zoning Code:

Conditional Use Permit Required
With 16.92 acres and a total of 87 units, the overall project density is 5.14 units per acre. The site is located within the Medium Density Residential (MDR) General Plan designation with a density range of 5.1 to 16 units per acre. The site is in the MR Zoning District that permits single family residences and Accessory Dwelling Units. Residential condominium projects, attached duplex or triplex units are permitted in the MDR District subject to the Approval of a Conditional Use Permit in each case. Based on your current subdivision plan, you should concurrently submit a Conditional Use Permit application.

Grading Plan
In reviewing the grading plan dated January 31, 2019, it estimates there will be 10,202 cubic yards of cut and 24,350 cubic yards of fill. There is information in the files indicating that all earthwork on the site will be balanced and no material will be imported. Given the amount of anticipated over-excavation and re-compaction necessary to prepare the site for development, please confirm that there will be no importing or exporting of soil as a part of the grading and site preparation work.

Also, in order to address concerns raised by adjoining property owners, please provide a written description of any retaining walls proposed around the perimeter of the development site, including specific heights and locations and the site elevation differential between existing adjacent residential lots and the proposed lots in your project. It is also important for the neighbors to understand how the fencing between Agenda Item #5.10.

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6 their properties and yours will be addressed. Will you be providing new fencing on your property line, resulting in two fences? If so, will there be a space between the fences? Please provide the slope of the driveway into the multi-family parcel. There is an elevation provided for the extension of Adams but no grades for the multi-family parcel are provided or for the access drive.

Please address all of the above noted issues as soon as possible. We would appreciate responses no later than within 60 days of the date of this letter. Upon submittal of the requested information, please provide a letter indicating how each of the above noted items have been addressed and cite sheet numbers and/or supporting documentation as appropriate.

Completion of the CEQA Document:

Staff will be coordinating with Dudek to complete the E.I.R. as expeditiously as possible.

Staff will keep you informed of the progress as it moves forward.

Should you have any questions or need additional information, please contact me via email at [email protected] Respectfully submitted,
Maya DeRosa, AICP
Planning and Building Director
cc: Mark Prestwich, City Manager
Aaron Hecock, AICP, Senior Planner
Chris Gustin, Contract Case Planner
Agenda Item #5.10.

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Agenda Item #5.10.
1 Potential Issues Related to the Adams Street Extension to the Silverado Trail The Adams Street extension to the Silverado Trail could potentially create problems for the City’s largest-ever public project, namely the St Helena Comprehensive Flood Control Project. While that street extension appears in the 1993 General Plan and the 2040 General Plan Update, it did not appear as part of any of the county, state or federal funding agreements, which were the funding sources for nearly all of the money used to build the flood control project. Nor did the street extension appear as part of permit applications or approvals required to build the levee or flood wall. While the original design of the Flood Control Project, which was done right after Measure A passed, showed a discretionary extension of the Adams Street to the Silverado Trail, it was not part of the project by the time the EIR was finalized, the RFP was let for the flood control project and all permitting, funding and approvals were done after 2006. There is, unfortunately, a common misconception in St Helena that the extension of Adams Street to the Silverado Trail was somehow approved as part of the Flood Control Project and because it appears in the 2040 GPU. There are, however, a number of other important issues related to this particular project.

1. There were at least six different funding sources for the Flood Control Project, almost all of which had specific requirements in order to obtain funding and some of those requirements extend into perpetuity. Two of the funding sources were federal, two were from the state, one was from the county and the last was from the City’s own general fund. With the exception of the funds from the City’s general fund, none of the five other funding sources considered the extension of the Adams Street to the Silverado Trail and its impact on the Flood Control Project in their approval of their funds for the levee and floodwall project.

For example, the “Maintenance and Property Improved” section of one of the state funding sources states:
“Grantee agrees to use, manage and maintain the property developed, rehabilitated or restored with the grant funds provided in this Agreement consistent with the purposes of the program and is required to continue into perpetuity or until deemed no longer necessary by the State.” Agenda Item #5.10.

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2 At the very least it appears the City would need to get the state’s approval to build the extension of Adams Street, since the road extension was not considered when the project was approved and funded and, therefore, would not be considered “consistent with the purpose of the program,” which was entirely a flood control project and not in any way a road project.

In seeking the State’s approval, however, the issue of whether or not the levee and flood wall have been maintained according to the Army Corp of Engineers standards (which is required by the Flood Control Project’s operational and maintenance manual) will likely be examined. From documentation about the maintenance of the levee for the first five years from its completion through 2015, it is absolutely clear it had not been maintained according to the Army Corp of Engineer standards and, in fact, has had barely any maintenance. The documentation of the maintenance of the Flood Control Project from 2016 to the present has not been available, but it is clear from the hundreds of gopher holes appearing every year in both the levee and foundation of the flood wall, no other conclusion could be reached other than the maintenance of our largest project has not been robust, let alone up to acceptable standards. Residents have been taking pictures of the gopher holes appearing each year in the levee and flood wall, just in case it ever becomes an issue. According to Dr. Nicholas Pinter, a national levee expert currently at UCD, who has spent time examining the St Helena levee and the issues related to it, has said that burrowing animals on any levee is one of the signs that a levee is not being maintained appropriately. Keeping burrowing animals away from the levee is one of the first issues raised in the Flood Control Project’s own operation and maintenance manual.

2. There were also at least eight state and federal permits or approvals required in order to build the levee, flood wall, terraces, etc. Many of these permits involved specific requirements and were issued without any consideration of the extension of Adams Street. While the 1993 General Plan Circulation Element showed Adams Street as a potential street extension to the Silverado Trail, it was not a factor considered in any decision to either issue required permits or in providing funding for the Flood Control Project. To now attempt to extend Adams Street to the Trail may jeopardize some of those permits and approvals. Examples of some of the unique permits and approvals required include:

California Endangered Species Act Incidental Take Permit; Agenda Item #5.10.

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3 California Fish and Game Streambed Alteration Agreement; US Army Corp of Engineers 404 Permit;
State Water Resources Control Board Section 401Water Quality Certification;
State Historic Preservation Office;
Bay Area Regional Water Quality Control Board National Pollution Discharge Elimination System permit; and
US Fish and Wildlife Service and Atmospheric Administration Fisheries Section 7 approval.

As an example, according to the staff report to the City Council dated May 24, 2016, the California Endangered Species Act Incidental Take Permit (ITP) No. 2081-2009-004-03 through the California Department of Fish and Wildlife (DFW) required, as a mitigation measure, that a deed restriction into perpetuity be placed over a portion of the city-owned land consisting of two parcels totaling approximately 10 acres. In addition to this requirement, the funding from the Department of Water Resources (DWR) required the creation of a conservation easement deeded into perpetuity over the same area of city-owned land. This staff report goes onto explain that in 2016 the City worked with the state to develop a specific deed restriction acceptable to the state, which was discussed at that City Council meeting. The state approved the Land Trust of Napa County (Land Trust) as the third-party easement holder. To avoid a duplication of efforts, both DWR and DFW mutually agreed upon a single conservation easement and the Land Trust as the conservation easement holder.

According to the staff report, during an on-site meeting with the Land Trust staff in 2016, the subject of the extension of Adams Street extension was discussed. The conservation easement would only permit the maintenance of existing infrastructure, flood control measures and habitat. It would prohibit the construction of a street, pedestrian path or bicycle lane on that portion of the City-owned property. The staff report concluded that Adams Street could not be extended to the Silverado Trail.

To ensure that there were no other alternatives available at that time (in 2016), City staff reached out to both DWR and DFW about the conflict between the 1993 General Plan (and the proposed GPU) regarding the extension of Adams St. DWR told the City staff that it would not approve a change to the conservation easement area or possible alternative mitigation to satisfy the requirements for the grant funds. This grant was scored and Agenda Item #5.10.

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St. Helena City CouncilMay 1, 2023

St. Helena City Council
May 1, 2023