St. Helena City Council
May 9, 2023

City of St. Helena 2023-2031 Housing Element Update Public Hearing Draft, April 2023 A-16

3.2.1.1 Regional Trends
According to 2015-2019 ACS estimates, a total of 16,244 Napa County residents had one or more disabilities, which represents approximately 11.8 percent of the county’s total population. Figure 4 shows the percentage of the population living with one or more disabilities throughout Napa County. The western areas of the county, which includes the urban areas of the cities, have higher concentrations of persons living with one or more disabilities compared to the eastern areas of the county. The southeastern area of the City of Napa has the highest concentration of persons living with one or more disabilities in the county.

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Figure 1 Percent of Total Non-White Population (Napa County) Source: AFFH Viewer, 2022
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Figure 2 Percent of Total Non-White Population (St. Helena) Source: AFFH Viewer, 2022
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Figure 3 Predominant Populations (St. Helena)
Source: AFFH Viewer, 2022
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Figure 4 Percent of Population with a Disability (Napa County) Source: AFFH Viewer, 2022
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3.2.2 Local Trends
The 2015-2019 ACS estimated a total of 726 residents in St. Helena were living with one or more disabilities, which is approximately 11.9 percent of the total population. Of the 726 individuals living with a one or more disabilities, 466 (64.2 percent) are age 65 or older. The most common type of disability in St.

Helena is ambulatory difficulty, defined as those who have serious difficulty walking or climbing stairs, as shown in
Figure 5. Persons with ambulatory disability have specific housing needs and may require housing that is wheelchair accessible or lacks stairs or steps.

Figure 5 Disability by Type (St. Helena)
Source: U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B18102, Table B18103, Table B18104, Table B18105, Table B18106, Table B18107.

Figure 6 highlights the percentage of the population living with one or more disabilities in the city by census tract. The southeastern parts of the city, east of Spring Street and Pope Street, have higher concentrations of residents with one or more disabilities (between 10 and 20 percent living with at least one disability).

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Figure 6 Percentage of Population with One or More Disabilities (St. Helena) Source: AFFH Viewer, 2022
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3.3 Familial Status
Familial status refers to families with children under the age of 18, including those with legal custody of a child, pregnant persons, and those in the process of adopting or gaining legal custody. Families with children may face housing discrimination by landlords, including being denied housing due to the presence of children or being subject to special restrictions or fees. Differential treatments such as limiting the number of children in a complex or confining children to a specific location or unit are also fair housing concerns. In a 2016 housing discrimination study, researchers found that compared to households without children, households with children were shown slightly fewer units and were commonly told about units that were slightly larger, and as a result, slightly more expensive to rent.72 Additionally, female-headed households with children require special consideration and assistance because of generally greater needs for affordable housing and accessible day care, health care, and other supportive services.

3.3.1 Regional Trends
Most households in Napa County are family households, comprising approximately 68 percent of the total 48,705 households in the county. Households with children present comprise 28.1 percent (13,699 households) of the total households or 41.4 percent of all family households in the county. Married couples without children represent 46.9 percent of family households. The majority of family households with children are married couple households with fewer numbers of female and male single parent households.

Single-parent households are more often at risk for housing issues because they rely on a single income and may require access to affordable childcare. Table 4 shows a breakdown of household type by tenure (owned versus rented) and presence of children in Napa County. Single-parent households are more likely to rent than own, especially female, single-parent households. There are 1,008 single-parent households that own and 2,323 single-parent households that rent in Napa County.

Table 4 Household Type and Tenure (Napa County)
Household Type
OwnerOccupied
Percent of Total
OwnerOccupiedRenterOccupied
Percent of Total
RenterOccupied
Married Couple Family, with
Children Present 6,257 20.0% 4,036 23.2%
Single-Parent, Male Householder, no
Spouse Present 383 1.2% 577 3.3%
Single Parent, Female Householder,
No Spouse Present 700 2.2% 1,746 10.0%
Total Households with Children
Present 7,340 23.5% 6,359 36.5%
Total Households 31,276 100% 17,429 100%
Source: U.S. Bureau of the Census, American Community Survey (ACS), Table B25115 Tenure by Household Type (Including Living Alone) and Age of Householder, 2015-2019 Estimates. 72 HUD. 2016. https://www.huduser.gov/portal/sites/default/files/pdf/HDSFamiliesFinalReport.pdf.

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Figure 7 shows the percentage of children in married couple households in Napa County. The less urban areas of the county have higher concentrations of children residing in married couple households while the urban areas have a lower percentage of children residing in married couple households. In most areas of the county the majority of children live in married couple households, however the northern half of the county generally has a higher percentage of children living in married couple households compared to the southern half.

Figure 8 shows the estimated percentage of children in households with a female head of household with no spouse or partner. Urban areas of the county, especially areas of the City of Napa and Town of Yountville, have higher concentrations of children in female single-parent households with between 20 and 40 percent of family households headed by a single parent female. The southern area of the City of Napa has the highest concentration of children in households with a female head of household with no spouse or partner, with between 40 and 60 percent of families headed by a single parent female. Less urban areas of the county, outside of incorporated cities, have less than 20 percent of families headed by a single female.

Figure 9 shows the percentage of adults living with a spouse or partner in Napa County. In most areas of the county 40 to 60 percent of adults are living with a spouse/partner. In areas in the southeast portion of the county, and on the west side of the City of Napa, there is a higher concentration of adults living with a spouse/partner, consisting of approximately 60 to 80 percent of adults.

Figure 10 shows the percentage of adults living alone, with less than 20 percent adults living alone in most areas in Napa County. In several of the more urban areas, specifically portions of the City of Napa, Yountville, and St. Helena, there is a higher concentration of adults living alone (greater than 20 percent).

3.3.2 Local Trends
Approximately 58 percent of the total 2,702 households in St. Helena are family households, as shown in Table 5. The majority of families are married couple families with more renters than homeowners. However, more single-parent households own their home than rent. Table 6 shows the breakdown of families with children by tenure and household type.

Non-family households are the second most common household type; a total of 42 percent of households fall into this category. These are primarily individuals living alone. Female single parent families make up about 10 percent of both owner-occupied units and rented units. Compared to the entire county, St. Helena has a greater percentage of non-family households, especially those living alone.

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Table 5 Household Type and Tenure (St. Helena)
Source: U.S. Bureau of the Census, American Community Survey (ACS), Table S2501 Occupancy Characteristics, 2015-2019 Estimates.

Table 6 Tenure by Household Type and Presence of Children (St. Helena) Household Type
OwnerOccupied
Percent of Total
OwnerOccupiedRenterOccupied
Percent of Total
RenterOccupied
Married Couple Family, with
Children Present 164 10.3% 230 20.7%
Single-Parent, Male Householder, no
Spouse Present 17 1.1% 11 0.1%
Single Parent, Female Householder,
No Spouse Present 114 7.2% 50 4.5%
Total Households with Children
Present 295 18.6% 291 26.2%
Total Households 1,590 100% 1,112 100%
Source: U.S. Bureau of the Census, American Community Survey (ACS), Table B25115 Tenure by Household Type (Including Living Alone) and Age of Householder, 2015-2019 Estimates.

The majority of children in St. Helena live in married couple households; however this percentage is less than in rural areas of Napa County. Figure 11 shows the percentage of children in married couple households in St. Helena is between 60 and 80 percent, while more than 80 percent of children in the surrounding rural areas live in married couple households.

Figure 12 shows the percentage of children in female single-parent households in St. Helena. In the northwest areas of St. Helena, 20 to 40 percent of children live in female single-parent households. In the southeast areas of the city less than 20 percent of children live in female single-parent households.

Figure 13 provides estimates regarding the percent of the adult population living with a spouse in St.

Helena. Throughout the city, 40 to 60 percent of adults are living with a spouse. Figure 14 shows the Household Type Owner-Occupied
Percent of Total
Owner-Occupied
RenterOccupiedPercent of Total
Renter-Occupied
Family
Households 920 58 586 53
Married couple family 735 46 408 37
Male householder, no
spouse present 29 2 63 6
Female householder, no
spouse present 156 10 115 10
Non-family
households 670 42 526 47
Living Alone 644 41 395 36
Not Living Alone 26 2 131 12
Total Households 1,590 1,112
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percentage of the adult population living alone in St. Helena. In the western half of the city, 20 to 40 percent of adults live alone while in the eastern half of the city less than 20 percent of adults live alone.

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Figure 7 Children in Married-Couple Households (Napa County) Source: AFFH Viewer, 2022
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Figure 8 Female Headed Households with Children, No Spouse/Partner Present (Napa County) Source: AFFH Viewer, 2022
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Figure 9 Population of Adults Living with Spouse/Partner (Napa County) Source: AFFH Viewer, 2022
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Figure 10 Population of Adults Living Alone (Napa County) Source: AFFH Viewer, 2022
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Figure 11 Children in Married-Couple Households (St. Helena) Source: AFFH Viewer, 2022
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Figure 12 Female Headed Households with Children, No Spouse/Partner Present (St. Helena) Source: AFFH Viewer, 2022
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Figure 13 Population of Adults Living with Spouse/Partner (St. Helena) Source: AFFH Viewer, 2022
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Figure 14 Population of Adults Living Alone (St. Helena) Source: AFFH Viewer, 2022
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Overall, the northwest portion of the city has a higher proportion of children living in female single-parent households and a higher proportion of adults living alone compared to the southeast portion of the city.

The percentages of children living in married couple households and adults living in with a spouse/partner are high throughout the city.

3.4 Household Income
Household income is directly related to the ability to afford housing. Higher income households are more likely to own rather than rent housing. However, as household income decreases, households tend to pay a disproportionate amount of their income for housing and the number of persons occupying unsound and overcrowded housing increases. To achieve fair housing objectives, people in low-income households must have actual choice in housing opportunities – that is, they are able to locate units that are affordable and well maintained in all parts of a jurisdiction and region.

Identifying low or moderate income (LMI) geographies and individuals is important to overcome patterns of segregation. HUD defines a LMI area as a Census tract or block group where over 51 percent of the population is LMI (based on HUD income definition of up to 80 percent of the area median income).

3.4.1 Regional Trends
The median household income of Napa County is $88,596. LMI areas are concentrated in the more urbanized areas of the county, including the City of Napa, St. Helena, and Calistoga. Rural areas of the county tend to have higher income households. Figure 15 shows the median household income for cities within Napa County.

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Figure 15 Median Household Income (2015-2019)
Source: Bureau of the Census, American Community Survey American Community Survey, 2015-2019.

Figure 16 shows median household income by block group using 2015-2019 ACS estimates. Block groups with the lowest median income are the eastern area of St. Helena, the area south of Yountville, and areas within the City of Napa.

LMI populations by census tract for Napa County are displayed in Figure 17. Census tracts within Cities of Napa, St. Helena, and Calistoga have the highest percentages of populations with low to moderate income.

These areas are the same areas with the highest percentages of non-White population.

3.4.2 Local Trends
Household incomes in St. Helena tend to be higher than the region as a whole, with a median income of $90,031 compared to the median household income of Napa County ($88,596). St. Helena has a higher median income than many of the surrounding cities, including the cities of Napa, Yountville, and Calistoga, as shown in Figure 15.

Figure 18 provides an overview of median household income by block group in the city. The census blocks with the lowest median income are located on the northeast and east side of St. Helena with median incomes of $47,083 and $51,544, which is less than the state median income of $87,100. Community input identified that many of the property owners in this area are not lower income and are in fact very wealthy.

The low-medium income trends in this area of the city may partially be attributed to the three affordable housing developments (Stonebridge Apartments, Woodbridge Village Apartments, and Hunt’s Grove $-
$20,000
$40,000
$60,000
$80,000
$100,000
$120,000
American
Canyon
Angwin Calistoga Deer Park Moskowite
Corner
Napa Oakville Rutherford St. Helena Yountville
Median Household Income Average
$101,792
$72,625
$67,119
$89,500
$61,875
$88,596
$99,375
$90,031
$69,300
$84,043
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Apartments), Vineyard Valley Mobile Home Park, and a senior living community (Silverado Orchards Retirement Community) all located within these two census blocks. The census block with the highest median income is located in the downtown area in the center of the city with a median income of $158,500. The AFFH Data Viewer has no information on median income of the northwest area of St.

Helena.

The LMI populations in St. Helena are concentrated on the east side of the city, as shown in Figure 19.

According to HUD estimates, in the eastern area of the city 68 percent of the population are LMI populations. In contrast, on western side of city less than 20 percent of the population is LMI. This pattern closely corresponds with areas of the city that have a greater non-White population concentration, which is also greater on the eastern side of the city.

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Figure 16 Median Household Income (Napa County)
Source: AFFH Viewer, 2022
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Figure 17 Low and Moderate Income Population (Napa County) Source: AFFH Viewer, 2022
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Figure 18 Median Household Income (St. Helena)
Source: AFFH Viewer, 2022
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Figure 19 Low to Moderate Income Population (St. Helena) Source: AFFH Viewer, 2022
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3.5 Racially and Ethnically Concentrated Areas of Poverty To identify racially and ethnically concentrated areas of poverty (known as R/ECAPs), HUD developed thresholds based on racial and ethnic concentration and income level. The threshold for racial and ethnic concentration is a non-White population of 50 percent or more within metropolitan or micropolitan areas (in rural areas it is 20 percent). Areas of “extreme poverty” are defined using the poverty test as those with more than 40 percent of the population at or below the poverty line or a poverty rate or three times the average of the metropolitan area, whichever is less. Areas that meet both the racial/ethnic concentration threshold and the “extreme poverty” threshold are considered R/ECAPs.

3.5.1 Poverty and Segregation

3.5.1.1 Regional Trends
There are no R/ECAPs within Napa County, however there is a small area of in the southern portion of the City of Napa that would be considered an area of extreme poverty with more than 40 percent of the population below the poverty line. According to 2015-2019 ACS estimates, approximately 8 percent of the population of Napa County are below the poverty level. Several areas within county have 10 and 20 percent of the population below the poverty line, including areas in the southern region of the county, in and around the Cities of Napa, American Canyon, and St. Helena. Figure 20 shows the poverty status within Napa County.

3.5.1.2 Local Trends
St. Helena does not have any R/ECAPs. According to 2015-2019 ACS estimates, approximately 8 percent of the population of St. Helena are living below the poverty level, consistent with poverty rates of Napa County. The western half of the city has a greater percentage of the population below the poverty line, between 10 and 20 percent. This area also had a higher percentage of children in a female single parent household.

Figure 21 displays the percentage of the population whose income is below the poverty line in St. Helena.

The poverty rates in St. Helena have shifted over time. The 2010-2014 ACS estimated the eastern half of the city had a greater percentage of the population below the poverty line, opposite of the trend shown by the 2015-2019 ACS estimates.

Figure 22 shows neighborhood segregation in St. Helena using to data from UC Berkeley’s Urban Displacement Project (UDP). According to the UDP the predominant racial/ethnic composition in St. Helena is Latinx-White. ABAG’s Segregation Report also analyzed neighborhood segregation in St. Helena between 2010 and 2020 using the racial isolation index, racial dissimilarity index, and Thiel’s H-Index. The isolation index showed White residents are the most segregated racial group in the city, followed by Latinx residents. The dissimilarity index showed segregation is greatest between Asian/Pacific Islander and White residents, followed by Latinx and White residents. However, the dissimilarity index is an unreliable measure for Asian/Pacific Islander and Black/African populations in St. Helena because their populations are too Agenda Item #10.1.

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small for accurate calculation. Thiel’s H-index for neighborhood level segregation indicated racial segregation between all racial groups within the city is less than in the average Bay Area jurisdiction.

Compared to all Bay Area jurisdictions, St. Helena is less diverse, with a smaller percentage of the population consisting of people of color.

ABAG’s Segregation Report also analyzed neighborhood level income segregation between 2010 and 2015 in St. Helena using the income group isolation index, income group dissimilarity index, and Thiel’s H-index.

The isolation index showed above moderate income residents are the most segregated income group in the city followed by very low income residents. Among all income groups, segregation of the moderate income population has changed the most between 2010 and 2015, becoming less segregated. The dissimilarity index showed income segregation is greater in St. Helena than in the average Bay Area jurisdiction between lower income residents and non-lower income residents and between very low income residents and above moderate income residents. Overall, segregation between lower income residents and residents who are not lower income increased between 2010 and 2015. According to Thiel’s H-index for neighborhood level income segregation, income segregation in the city is less than the average Bay Area city and remained about the same between 2010 and 2015. Compared to all Bay Area jurisdictions, St.

Helena has a similar share of very low income residents, lower share of low and moderate income residents, and a higher share of above moderate income residents.

In summary, ABAG’s segregation report found White residents and above moderate income residents are the largest and most segregated racial and income groups in St. Helena.

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Figure 20 Areas of High Poverty (Napa County)
Source: AFFH Viewer, 2022
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Figure 21 Poverty Status (St. Helena)
Source: AFFH Viewer, 2022
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Figure 22 Neighborhood Segregation (St. Helena)
Source: AFFH Viewer, 2022
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3.5.2 Concentrated Areas of Affluence
While racially R/ECAPs have long been the focus of fair housing policies, racially concentrated areas of affluence (RCAAs) must also be analyzed. Racially concentrated areas of affluence (RCAAs) are affluent communities that are predominantly White.73 According to a policy paper published by HUD, White residents are the most racially segregated group in the United States and are typically more affluent than majority non-White communities. In addition to having a higher median income, areas of affluence experience less overcrowding, less housing cost burden on renters, and are generally less susceptible to displacement compared to LMI areas.

RCAAs have not been studied extensively, nor has a standard definition been published by HCD or HUD.

HCD has created a metric to identify RCAAs by analyzing the total White population for each census tract and comparing it to the average percentage of total White populations for all census tracts within a given Council of Government (COG) region. This compared value is referred to as the Location Quotient (LQ). For example, a census tract with an LQ of 1.5 has a percentage of total White population that is 1.5 times higher than the average percentage of total White population within the COG region. HCD identifies RCAAs as census tracts with an LQ of more than 1.25 and a median income 1.5 times higher than the COG AMI (or

1.5x the State AMI, whichever is lower).

3.5.3 Regional Trends
There are several RCAAs in Napa County, which are primarily located in more rural areas of the county.

Most of the RCAAs are concentrated along the western portion of the county with several RCAAs located within the northwest part of the City of Napa as well as in the rural areas northeast of the City of Napa. shows RCAAs in Napa County.

The population of Napa County is predominantly White, with the highest concentration of White residents residing in rural areas of the county. Figure 23 highlights the predominantly White census tracts in Napa County. Areas with a lower concentration of White residents are generally located within the valley where population density is higher. The more rural areas along the eastern boarder of Napa County have high concentrations of White populations, which corresponds with areas that have the highest median incomes in the county.

3.5.4 Local Trends
There are no RCAAs identified within St. Helena. However, similar to patterns of affluence throughout Napa County, areas of St. Helena with higher median incomes correspond to areas with higher proportions of White residents. The northwestern area of the city has a larger proportion of White residents and a higher median income, while the southeastern area has greater racial/ethnic diversity and a lower median income.

The northwestern area of the city has a predominant White population (over 50 percent) and the 73 Goatz, Damanio and Williams, “Racially Concentrated Areas of Affluence: A Preliminary Investigation” https://www.huduser.gov/portal/periodicals/cityscpe/vol21num1/ch4.pdf, (2019).

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southeastern area of the city has a large White population and large Hispanic population (approximately 48 percent each). Figure 26 shows the overlap of high median income and predominant White population in St. Helena.

In addition to having a higher median income, areas of affluence in St. Helena experience lower percentages of overpayment by homeowners, more positive economic outcomes, and more positive environmental outcomes compared to LMI areas.

3.6 Disparities in Access to Opportunities
According to HCD guidance, land use policies and planning often translate into the ability of residents to access neighborhoods of opportunity, with high-performing schools, greater availability of jobs that afford entry to the middle class, and convenient access to transit and services. The limits on housing choice and access experienced by people within protected classes, such as race, sexual orientation, or disability, have far-reaching impacts on access to job opportunity, quality education, and mental and physical health.74 Access to opportunity often means both improving the quality of life for residents of low-income communities, as well as supporting mobility and access to ‘high resource’ neighborhoods. This encompasses education, employment, economic development, safe and decent housing, low rates of violent crime, transportation, and other opportunities, including recreation, food, and healthy environment (air, water, safe neighborhood, safety from environmental hazards, social services, and cultural institutions).

The analysis of place-based characteristics linked to opportunity indicators, quality education, employment, transportation, and healthy environment, seeks to understand the disparity between communities in terms of access to real and potential economic benefits and quality of life.

3.6.1 Transit Access
Reliable access to public transit is crucial, especially for low-income residents and/or persons with disabilities, to provide connections to employment opportunities. Access to employment via public transit can reduce income burden and increase housing mobility, which enables residents to locate housing in more areas.75 The lack of a relationship between public transit, employment opportunities, and affordable housing may impede fair housing choice. Persons who depend on public transit may have limited choices regarding places to live.

3.6.2 Regional Trends
As Napa County is largely rural, residents mainly depend on their personal vehicles for commuting and traveling. Public transit options do exist in Napa County, primarily Vine Transit, a fixed route bus service 74 HCD. 2021. https://www.hcd.ca.gov/community-development/affh/docs/affh_document_final_4-27-2021.pdf 75 Ong, Paul and Evelyn Blumenberg, “Job Accessibility and Welfare Usage: Evidence from Los Angeles.” UCLA Department of Policy Studies, (1998).

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operated by the Napa Valley Transportation Authority. Vine Transit operates fixed bus route service throughout the county from American Canyon to Calistoga and provides connections to the Vallejo Ferry Terminal, and El Cerrito Del Norte BART station, SolTrans stations in Vallejo and Fairfield, and the Suisun/Fairfield Train Station. Lake Transit Authority connects southern areas of Lake County to northern Napa County, with bus stops in Calistoga, St. Helena, and Deer Park. Additionally, several low cost, on demand shuttle services are available to the public providing fixed route and door-to-door transit within the city limits of their operating city, including the Yountville Trolley, St. Helena Shuttle, Calistoga Shuttle, and American Canyon Transit. Residents and visitors with physical and/or cognitive disabilities may be eligible to participate in VineGo Paratransit Service, a shared ride service providing curb-to-curb transportation. VineGo offers rides within and between cities throughout the county as well as to Kaiser Vallejo Medical Center.

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Figure 23 Racially Concentrated Areas of Affluence (Napa County) Source: AFFH Viewer, 2022
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Figure 24 Racially Concentrated Areas of Affluence (St. Helena) Source: AFFH Viewer, 2022
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Figure 25 Predominant White Population (Napa County)
Source: AFFH Viewer, 2022
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Figure 26 Predominant Populations and Median Household Income (St. Helena) Source: AFFH Viewer, 2022
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The Commuter Bike Path (Vine Trail) runs parallel to the Napa Valley Railroad and provides an off-street route walking/biking path for recreation and commuting. Ultimately the Vine Trail will cover 47 miles from Vallejo to Calistoga. Currently 12.5 miles of the path has been completed from Kennedy Park in the City of Napa to Yountville. Sections of the Vine trail have also been completed in American Canyon and Calistoga.

AllTransit is an online database that provides details on transit opportunity throughout the United States, specifically looking at connectivity, access to jobs, and frequency of service. Napa County received an AllTransit performance score of 3.3 which equates to a low combination of trips per week and number of jobs accessible by transit.76 Approximately 1.5 percent of commuters use public transit in Napa County. The cities of Napa (4.6), Yountville (4.6), and Calistoga (4.0) have the highest scores with a slighter greater combination of number of trips per week, accessible jobs, and available transit routes.

3.6.3 Local Trends
The City of St. Helena has an AllTransit performance score of 2.4 with approximately 1.0 percent of workers who commute using public transit. This score is lower than the County score of 3.3. One Vine Transit bus route passes through St. Helena, providing connections to the City of Calistoga to the north and City of Napa to the south. Additionally, the St. Helena Shuttle Service provides both a fixed route and an ondemand, door-to-door transit service option within the city limits.

Walk Score is a tool that produces a walkability index by assigning a numerical walkability score to cities and neighborhoods. Walkability is measured by analyzing population density, distance to amenities, and road metrics such as block length and intersection density. St. Helena has a walk score of 83, which is considered very walkable, and most errands can be accomplished by foot77. St. Helena’s walkability score is most negatively affected by the limited number of parks within walking distance from different areas of the city.

The Environmental Protection Agency (EPA) also has a walkability index, which ranks block groups according to their relative walkability. The EPA walkability map, shown in Figure 27, shows that walkability varies across the city. The highest walkability scores are in downtown and along Main Street where most of the commercial areas are concentrated. Further from downtown and in the western and eastern parts of the city, walkability scores are below average.
76 https://alltransit.cnt.org/
77 https://www.walkscore.com/
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Figure 27 Walkability Index (St. Helena)
Source: National Walkability Index, 2022
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3.6.4 Access to Quality Education
Economics literature has consistently found about a 10 percent increase in wages/salary with each additional year of education.78 Educational attainment is directly linked to housing opportunities. TCAC education domain scores, which are used to identify areas of higher or lower education opportunities, incorporate a variety of indicators including math and reading proficiency scores, high school graduation rates and student poverty rates to assess educational outcomes at the census tract level.

3.6.5 Regional Trends
Napa County is served by five school districts: Napa Valley Unified School District, St. Helena Unified School District, Calistoga Joint Unified School District, Howell Mountain School District, and Pope Valley School District. An overview of education outcomes across the Napa County is illustrated in Figure 28 which shows the TCAC Opportunity Areas map. Education outcomes vary throughout the county. Areas in the western portion of the county and portions of the more urban areas have more positive education outcomes compared to eastern portions of the county and southern parts of the City of Napa.

3.6.6 Local Trends
The City of St. Helena is served by the St. Helena Unified School District which is comprised of four schools:
a primary school, elementary school, middle school, and high school. Altogether, approximately 1,243 students were enrolled in 2020 from the City St. Helena and the surrounding areas. Approximately 45 percent of students were White and 52 percent were Hispanic/Latino. St. Helena Unified School District reported a high school graduation rate of 92.9 percent in 2020, 90.1 percent in 2019, and 94.1 percent in 2018. The district reported all students who did not receive high school diplomas in 2019 were Long Term English Learners and socio-economically disadvantaged students.79 Figure 29Figure 28 shows TCAC scores for education outcomes for St. Helena at the census tract level. St.

Helena has better education outcomes than other areas of Napa County. At the city level, the southern and eastern areas of the city have better education outcomes than the western areas.

3.6.7 Economic Outcomes
Housing opportunities are directly related to economic opportunities. Access to high quality employment close to desired and affordable housing results in more housing opportunities and shorter commute times.

The analysis for economic opportunities uses TCAC economic indicators, employment participation data 78 The Rehabilitation Research and Training Center on Disability Statistics and Demographics. 2020. https://disabilitycompendium.org/annualreport
79 St. Helena Unified School District 2021-22 Local Control and Accountability Plan https://www.sthelenaunified.org/cms/lib/CA50000465/Centricity/Domain/36/LCAP%20Control%20Accountability%20Plan %202021%202022.pdf
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from the ACS, Metropolitan Transportation Commission (MTC) Equity Priority Communities (EPC), and the HUD Jobs Proximity Index.

TCAC economic opportunities are measured by census tract. They consider poverty, adult education, employment, job proximity, and median home values. A higher economic index score reflects more positive economic outcomes. The MTC EPC identifies concentrations of underserved populations in order to direct funding for housing and transportation equity. The HUD Jobs Proximity Index assesses the accessibility to job opportunities at the census block group level.

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Figure 28 TCAC Opportunity Areas – Education Outcomes (Napa County) Source: AFFH Viewer, 2022
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Figure 29 TCAC Opportunity Areas – Education Outcomes (St. Helena) Source: AFFH Viewer, 2022
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3.6.8 Regional Trends
According to the California Employment Development Department, the unemployment rate of Napa County was 3.9 percent in February 2022 (not seasonally adjusted). Top employers in the county include manufacturing (including large- and small-scale wine manufacturing), healthcare, and accommodation and food service. The 2015-2019 ACS estimates reported 74,549 workers in the County of Napa with a labor force participation rate of 65 percent of persons 16 years and older. Approximately 33.7 percent of workers commute 30 or more minutes to work with a countywide mean commute time of 25.6 minutes.

Figure 30 shows the TCAC Opportunity Areas map for economic outcomes across the county. Economic outcomes are varied with more positive outcomes generally located in the western areas of the county and less positive outcomes in the eastern areas of the county. This trend may be attributed to the high concentration of vineyards and wineries in the western and central areas of the county and low population density in eastern areas of the county.

3.6.9 Local Trends
According to the 2015-2019 American Community Survey (ACS), there are 3,159 persons in the labor force in St. Helena with a labor force participation rate of 61 percent. The California Employment Development Department reported the unemployment rate was 3.1 percent in December 2021 (not seasonally adjusted), slightly less than the county. Top industries in the city reflect county trends, with the highest number of workers in manufacturing, healthcare, and accommodation and food service.

Figure 31 shows the TCAC Opportunity Areas map for economic outcomes in St. Helena. Much like the county, economic outcomes are varied across the city. Western areas of the city have more positive economic outcomes and eastern areas have less positive economic outcomes. This pattern of lower economic outcomes in the eastern areas of the city reflects the lower median incomes and greater ethnic diversity that is also experienced in these areas. The eastern areas of the city contain affordable housing developments, a mobile home park, and senior living community which may be contributing to lower median incomes and lower median home values.

ACS 2015-2019 estimates show approximately 22.4 percent of workers commute 30 or more minutes to work and the mean commute time is 19.6 minutes. Figure 32 shows the job proximity index in St. Helena which assesses the accessibility of employment opportunities based on distance, a higher index score corresponds to closer job proximity. Job proximity throughout St. Helena is consistently high (closest proximity), especially when compared to the southern and eastern areas of the county.

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Figure 30 TCAC Opportunity Areas – Economic (Napa County) Source: AFFH Viewer, 2022
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Figure 31 TCAC Opportunity Areas – Economic (St. Helena) Source: AFFH Viewer, 2022
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Figure 32 Job Proximity Index (St. Helena)
Source: AFFH Viewer, 2022
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3.6.10 Healthy Environment
Access to a healthy environment is necessary for communities within a city to thrive. Healthy environment analysis considers patterns in the disparities found within individual neighborhoods and protected area groups. These disparities can vary in a number of categories, including air quality, water quality, safe neighborhood, environmental hazards, social services, and cultural institutions. Recent California laws, AB 1550, Senate Bill (SB) 535 and SB 1000 emphasize the importance of environmental justice as a fair housing issue. Environmental Justice, as defined by HUD, means ensuring the environment and human health are protected fairly for all people regardless of race, color, national origin, or income, and consideration the means by which federally assisted projects may have disproportionately adversely affect human health or the environmental on minority and low income populations.80 The California Office of Environmental Health Hazard Assessment developed the California Communities Environmental Health Screening Tool (CalEnviroScreen) a screening methodology to help identify California communities disproportionately burdened by multiple sources of pollution called. High scoring census tracts tend to be more burdened by pollution from multiple sources and are most vulnerable to its effects, taking into account their socioeconomic characteristics and underlying health status.

3.6.11 Regional Trends
The CalEnviroScreen map for Napa County identifies the degree to which communities are considered burdened by pollution. Figure 33 below shows the pollution burden for Napa County, representing the potential exposure to pollutants and resulting adverse environmental conditions. The more urban areas on the western side of the county have a higher pollution burden, especially within and to the south of the City of Napa. Figure 34 shows TCAC Opportunity Map for environmental outcomes in the county. Similar to the CalEnviroScreen map, the TCAC Opportunity Map shows that the western areas of the county have less positive environmental outcomes compared to the eastern areas of the county. This may be caused by the mountains flank the valley which block wind flow and trap pollution. Additionally, the western and central areas of the county have a higher concentration of people, traffic, and agriculture which produces greater levels of pollution and pesticides. Eastern areas of the county tend to be forested and are less populated

3.6.12 Local Trends
Pollution Burden in St. Helena is lower than many other areas in the county, as shown in Figure 35.

However, the eastern areas of the city have a slightly higher pollution burden (overall score of 40) compared to the rest of the city, with high burdens of pesticides, cleanups, and groundwater threats. The western areas have a slightly lower burden (overall score of 33) with high burdens of pesticides, cleanups, groundwater threats, and solid waste. Pesticide use is considered high throughout the city likely due to pesticide applications on nearby vineyards. There are two cleanup sites located within the city including one site with an active dry-cleaning business and one site with a manufactured gas plant that was dismantled in 1930. These two cleanup sites are also sources that pose groundwater threats to the city. A 80 HUD, 2021. https://www.hudexchange.info/programs/environmental-review/environmental-justice/ Agenda Item #10.1.

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third cleanup site is located outside the city limits, southeast of the city, with a food market that has detected high pesticides in the soil beneath the building. A solid waste facility is located in the eastern area of the city which may potentially expose neighboring communities to environmental burdens such as odor, pests, and truck traffic. The southern and eastern areas of the city have a higher pollution burden, which corresponds with areas with higher ethnic diversity, higher populations with a disability, and lower median incomes discussed in the previous sections.

Figure 36 shows the TCAC Opportunity map for environmental outcomes in the City of St. Helena. The southern and eastern areas of the city have less positive environmental outcomes compared to the western areas.

3.7 Disproportionate Housing Needs
Disproportionate housing needs generally refers to a condition in which there are significant disparities in the proportion of members of a protected class experiencing a category of housing need when compared to the proportion of members of any other relevant groups, or the total population experiencing that category of housing need in the applicable geographic area. For purposes of this definition, categories of housing need are based on such factors as cost burden and severe cost burden, overcrowding, homelessness, and substandard housing conditions

3.7.1 Housing Cost Burden
Housing cost burden is defined as the proportion of a household’s total gross income spent on housing costs. Households that spend at least 30 percent of their total gross income on housing costs (rent, mortgage, utilities, and other housing-related costs) are considered cost burdened, and households spending over 50 percent on housing costs are considered severely cost burdened. The higher the housing cost burden, the more likely residents are to live in overcrowded and substandard conditions and are less likely to afford to relocate. Low-income households and persons in protected classes disproportionately experience severe housing problems. Housing problems are households that has one or more of the following problems: lacks a complete kitchen facility, lacks complete plumbing facility, a household that is overcrowded, or a household that is cost burdened.

3.7.2 Regional Trends
Figure 37 shows areas of Napa County where renter households overpay for housing (spend more than 30 percent of household income on housing costs). Overpayment by renters is a widespread issue across the county, especially in the more urban areas of the county as well as the northeast and southeast areas of the county. Similar to overpayment by renters, overpayment by homeowners is common throughout the county, highlighting that the costs of housing are too high for both renters and homeowners. Figure 38 shows areas of the county where homeowners overpay for housing, which is most prevalent in the urban areas of the county as well as the northwest and southeast areas of the county.

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3.7.3 Local Trends
Housing cost burden among renters is widespread in St. Helena. Figure 39 shows that 40 to 60 percent of renters overpay for housing in all areas of the city. Additionally, data from HUD’s Comprehensive Housing Affordability Strategy (CHAS) indicates lower income households are disproportionately overpaying for housing.

Lower-income households experience higher cost burden than moderate income and above households in St. Helena. Approximately 41 percent of extremely low-income households (those earning 30 percent or less of the local area median income (AMI)) are considered severely cost burdened (spend 50 percent or more of their income on housing). Both renters and owners experience cost burden in St. Helena, with higher proportions of lower income households spending greater than 30 percent or 50 percent on housing.

Table 7 shows housing cost burden of lower income households in St. Helena. Generally, a higher percentage of renters than owners experience cost burden, however, more owners than renters experience severe cost burden.

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Figure 33 CalEnviroScreen 4.0 Percentile Scores (Napa County) Source: CalEnviroScreen 4.0, 2022
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Figure 34 TCAC Opportunity Areas – Environment (Napa County) Source: AFFH Viewer, 2022
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Figure 35 CalEnviroScreen 4.0 Percentile Scores (St. Helena) Source: CalEnviroScreen 4.0, 2022
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Figure 36 TCAC Opportunity Areas – Environment (St. Helena) Source: AFFH Viewer, 2022
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Figure 37 Overpayment By Renters (Napa County)
Source: AFFH Viewer, 2022
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Figure 38 Overpayment By Homeowners (Napa County)
Source: AFFH Viewer, 2022
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Figure 39 Overpayment By Renters (St. Helena)
Source: AFFH Viewer, 2022
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Table 7 Housing Cost Burden of Lower-Income Households (2014-2018) Household by Type,
Income, and Housing
Problem Renters Percent Owners Percent
Total
Households
Extremely Low-Income
(0-30 % AMI) 185 160 345
With Cost Burden >30% 100 54.1% 105 65.6% 205 59.4%
With Cost Burden >50% 50 27.0% 90 56.3% 140 40.6%
Very Low-Income
(0-30 % AMI) 240 105 345 %
With Cost Burden >30% 195 81.3% 70 66.7% 265 76.8%
With Cost Burden >50% 35 14.6% 40 38.1% 75 21.7%
Low-Income
(51-80 % AMI) 145 160 305 %
With Cost Burden >30% 100 69.0% 85 53.1% 185 60.7%
With Cost Burden >50% 40 27.6% 60 37.5% 100 32.8%
Moderate & Above
Income
(>80% AMI)
500 1,105 1,605 %
With Cost Burden >30% 133 26.6% 205 18.6% 338 21.1%
With Cost Burden >50% 8 1.6% 60 5.4% 68 4.2%
Total 1,070 41.2% 1,530 58.8% 2,600 %
Source: HUD Comprehensive Housing Affordability Strategy (CHAS), 2014-2018

3.7.4 Substandard Housing
HUD considers housing units to be “standard units” if they are in compliance with local building codes.

Substandard housing is housing that poses a risk to the health, safety, or wellbeing of its occupants or neighbors, includes housing that does not have operable indoor plumbing, electricity, or heat. Housing age can be an important indicator of housing condition in a community. Like any other tangible asset, housing is subject to gradual physical or technological deterioration over time. If not properly and regularly maintained, housing can deteriorate and discourage reinvestment, depress neighboring property values, and eventually impact the quality of life in a neighborhood. Typically, housing over 30 years old is more likely to have rehabilitation needs that may include new plumbing, roof repairs, foundation work, and other repairs. Some older housing units may have health risks such as lead paint and asbestos. Housing issues such as mold may elevate health conditions such as asthma.

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3.7.5 Regional Trends
In Napa County approximately 73 percent of all housing units were built before 1990. These older units potentially require minor repairs and modernization improvements. Figure 41 shows the approximate break down by age of housing units.

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Figure 40 Overpayment By Homeowners (St. Helena)
Source: AFFH Viewer, 2022
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Figure 41 Housing Stock Age (2015-2019)
Source: Bureau of the Census, American Community Survey, 2015-2019 The County of Napa has a total of 881 substandard housing units, approximately 2 percent of the total occupied units in the county. A housing unit is considered substandard if it lacks complete plumbing or kitchen facilities. Of the 881 substandard units, approximately 15 percent lacked complete plumbing facilities and 85 percent lacked complete kitchen facilities. Table 8 shows a breakdown of the number of substandard housing units in Napa County and St. Helena. In the past, lack of telephone service was also an indicator of housing conditions. Today, with the widespread availability of cell and internet phone services, many households have chosen not to install land line telephone services, and availability of telephone service is no longer considered an indicator of substandard housing conditions.

Table 8 Substandard Housing Units (2019)
Condition Napa County St. Helena
Lacking complete plumbing facilities 128 0.26% 0 0.00%
Lacking complete kitchen facilities 753 1.55% 83 3.07%
Total 48705 2702
Source: Bureau of the Census, American Community Survey, 2015-2019.

3.7.6 Local Trends
As shown above in Figure 41, approximately 79 percent of the city’s housing stock was built prior to 1990, potentially requiring minor repairs and modernization improvements.

Table 8 shows 83 units, about 3 percent of the St. Helena’s housing stock, are considered substandard. All identified substandard units lacked complete kitchen facilities. 2014 or
later
2010 to
2013
2000 to
2009
1990 to
1999
1980 to
1989
1970 to
1979
1960 to
1969
1950 to
1959
1940 to
1949
1939 or
earlier
Napa County 1.87% 1.30% 11.76% 12.20% 13.56% 17.76% 12.13% 16.28% 4.86% 8.28% St. Helena 1.34% 0.58% 7.67% 11.58% 11.55% 22.56% 14.64% 14.52% 5.29% 10.27%

0.00%

5.00%

10.00%

15.00%

20.00%

25.00%
Year Built
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3.7.7 Homelessness
“Homelessness,” as defined by HUD, describes an individual, who is not imprisoned or otherwise detained, who:
• Lacks a fixed, regular, and adequate nighttime residence; and • Has a primary nighttime residence that is:
– A supervised publicly or privately operated shelter designed to provide temporary living accommodations (including welfare hotels, congregate shelters, and transitional housing for the mentally ill);
– An institution that provides a temporary residence for individuals intended to be institutionalized; or
– A public or private place not designed for, or ordinarily used as, a regular sleeping accommodation for human beings.

Throughout Napa Country, homelessness has become an increasingly important issue. Factors that contribute to the rise in homelessness include a lack of housing affordable available for low- and moderateincome households, increases in the number of persons whose incomes fall below the poverty level, reductions in public subsidies, and lack of support for persons with extreme developmental, physical, and mental disabilities.

3.7.8 Regional Trends
Napa County’s 2020 Point-In-Time Count indicated there were 464 persons experiencing homelessness in the county on any given night; mostly in the City of Napa. This is an increase from 322 persons in the 2018 Point-In-Time Count.

3.7.9 Local Trends
The number of homeless persons in St. Helena is unknown as the 2020 Point-In-Time Count does not include a breakdown of the homeless population by jurisdiction. Based on St. Helena’s share of the countywide population, 3.9 percent, it is estimated the City’s homeless population is approximately 18 persons.

3.7.10 Overcrowding
Overcrowding is defined as housing units with more than one person per room (including dining and living rooms but excluding bathrooms and kitchen) and severe overcrowding refers to more than 1.5 persons per room. Large families generally have special housing needs due to lower per capita income, the need for affordable housing, or the need for larger units with three or more bedrooms, resulting in overcrowding.

Some households may not be able to accommodate high-cost burdens for housing and accept smaller housing or reside with other individuals or families in the same home. Potential fair housing issues emerge if non-traditional households are discouraged or denied housing due to a perception of overcrowding.

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Household overcrowding is reflective of various living situations such as a housing unit that is inadequately sized to meet a household’s needs, the necessity or desire to have extended family members reside in an existing household, or unrelated individuals or families share a single housing unit.

Not only is overcrowding a potential fair housing concern, but it can also potentially strain physical facilities and the delivery of public services, reduce the quality of the physical environment, contribute to a shortage of parking, and accelerate the deterioration of homes. As a result, some landlords or apartment managers may be more hesitant to rent to larger households, thus making access to adequate housing even more difficult. According to local fair housing service providers and property managers, addressing the issue of large households is complex as there are no set of guidelines for determining the maximum capacity for a unit. Fair housing issues may arise from policies aimed to limit overcrowding that have a disparate impact on specific racial or ethnic groups with higher proportion of overcrowding.

3.7.11 Regional Trends
In Napa County, approximately 6 percent of occupied housing units are overcrowded. As shown in Figure 42, overcrowded housing is most prevalent in the cities of Napa and Calistoga. The City of Napa has the highest percentage of overcrowded units. Certain areas within the city have between 14 and 36 percent of households that are overcrowded. Rural areas experience less overcrowding, and some rural areas have no overcrowded or severely overcrowded units.

Table 9 shows the percentage of housing units that are overcrowded. Renter-occupied households had a larger proportion of overcrowded households in the county.

Table 9 Overcrowding by Tenure
Jurisdiction
Overcrowded
(1+ occupants per room)
Severely Overcrowded
(1.5+ occupants per room)
Renter Owner Total Renter Owner Total
St. Helena 9.26% 1.57% 4.74% 1.44% 1.01% 1.18%
Napa County 11.92% 2.99% 6.18% 3.50% 0.64% 1.66%
Source: Table B25014 Tenure by Occupants Per Room 2015-2019 ACS. Bureau of the Census, American Community Survey, 2015-2019.

3.7.12 Local Trends
Based on 2015-2019 ACS estimates, approximately five percent of households in St. Helena are overcrowded, compared to 6 percent for the county as a whole. As shown in Table 9,a higher proportion of renter households are overcrowded than owned households in St. Helena. Figure 43 shows the percent of overcrowded households throughout the city, no concentrated areas overcrowding of households are shown. ACS estimates indicate overcrowding is a more common housing issue for Hispanic/Latino households than White households where approximately 20 percent Hispanic/Latino households in St.

Helena are overcrowded compared to three percent of White households.

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Figure 42 Overcrowded Households (Napa County)
Source: AFFH Viewer, 2022
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Figure 43 Overcrowded Households (St. Helena)
Source: AFFH Viewer, 2022
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3.7.13 Displacement
Displacement, as defined by HCD, is used to describe any involuntary household move caused by landlord action or market changes. Shifts in neighborhood composition are often framed and perpetuated by established patterns of racial inequity and segregation. Movement of people, public policies, and investments, such as capital improvements and planned transit stops, and flows of private capital can lead to displacement. Displacement is fueled by a combination of rising housing costs, rising income inequality, stagnant wages, and insufficient market-rate housing production. Decades of disinvestment in low-income communities, coupled with investor speculation, can result in a rent gap or a disparity between current rental income of the land, and potentially achievable rental income if the property is converted to its most profitable use. These processes can disproportionally impact people of color, as well as lower income households, persons with disabilities, large households, and persons at-risk or experiencing homelessness.81

3.7.14 Regional Trends
The Urban Displacement Project (UDP) is an initiative out of the University of California, Berkeley that conducts data-driven research to better understand gentrification and displacement in order to generate more equitable and inclusive cities. UDP provides data to identify “sensitive communities,” communities that are vulnerable to displacement caused by housing costs or with market-based displacement pressures within or near the community. As shown in Figure 44 below, portions of the cities of Napa and Calistoga are identified as sensitive communities by UDP. These communities are also more racially/ethnically diverse and have lower household median income compared to other areas of the county.

3.7.15 Local Trends
UDP did not identify any areas within St. Helena that are considered vulnerable to displacement, as shown in Figure 45. However, research from the University of California Berkeley indicates that 42.0 percent of households in St. Helena live in neighborhoods susceptible to or experiencing displacement. 81 HCD. 2021. https://www.hcd.ca.gov/community-development/affh/docs/affh_document_final_4-27-2021.pdf Agenda Item #10.1.

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Figure 44 Sensitive Communities (Napa County)
Source: AFFH Viewer, 2022
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Figure 45 Sensitive Communities (St. Helena)
Source: AFFH Data Viewer, 2022
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4. Local Area of Knowledge
The AFFH analysis identified the eastern portion of St. Helena as generally experiencing more fair housing issues than other areas of the city. Fair housing issues in this area include higher levels of minority populations, low and moderate median income, overpayment of housing, higher median rent, and lower economic and environmental outcomes. The predominant population in this area of the city is White, however it has the highest non-White population of all areas within the city. Additionally, this area has a higher proportion of persons living with a disability compared to other areas. Overall, the eastern portion of the city is a moderate resource area, the same as the rest of the city. Some factors that could play into the trends seen in the data could be the location of existing retirement and older adult living facilities. The population living within these communities are, many time, fixed income and more often single-headed households. In addition, most of the city’s high density land use and housing is located in this eastern portion of the city, which tends to be the housing type most affordable to lower income residents and single-parent households. As part of the Housing Element, the City is committing to improving the number of affordable units city-wide. In addition, with the recently adopted General Plan, the city envisions the redevelopment of Main Street within the eastern portion of the city with new, mixed-use development to increase economic opportunities and investments in this area.

4.1 Local Actions and Policy Efforts
In 2018, the City funded the 2018 St. Helena Housing Update Report, a housing analysis study that identified contributing factors to housing challenges in St. Helena. The report identified that residents believe new housing development primarily occurs east of Highway 29, however according to the report the majority of new construction was located west of Highway 29. In addition, the report also identified community opposition as a challenge to housing development in the city, leading to delays and increased project costs. Community members often desire to maintain the rural character of the city and are very concerned with how new development will impact surrounding neighborhoods.82 In October of 2020, the City Council adopted the Resolution 2020-105: Affirming that Discrimination and Systemic Racism Constitute A Public Health Crisis Causing Disparities in Mental Wellbeing, Language Access, Housing, Economic Development, Health, and Criminal Justice Experience, and Reaffirming Its Commitment to Advancing Justice, Equity, Diversity, and Inclusion in the City. This resolution commits the City to erasing barriers to opportunities to minority populations, including housing. The Staff Report to City Council for Resolution 2020-105 recommends actions to address racial equity and social justice in the community, including providing Spanish translation for City Council and Planning Commission meetings, provide all City communication in Spanish and reviewing adopted by other cities that promote inclusivity and access to affordable housing.
82 2018. St. Helena Housing and Community Report.
https://www.cityofsthelena.org/sites/default/files/fileattachments/planning_resources/page/3395/staff_rep ort-white_paper.pdf
Agenda Item #10.1.

City of St. Helena 2023-2031 Housing Element Update Public Hearing Draft, April 2023 A-100
The City also prepared a Diversity, Equity, and Inclusion Strategy to outline the City’s efforts towards diversity, equity and inclusion, and social justice. The strategy includes actions such as creating a Diversity, Equity and Inclusion Committee to discuss topics, including housing and racial justice, and offering live Spanish interpretation for regular and special City Council and Planning Commission meetings. The City continues to provide Spanish interpretation for City Council and Planning Commission meetings.

4.2 Stakeholder Input
The City held three housing workshops to receive feedback from the community on housing issues and the Housing Element Update (on September 16, 2021, January 20, 2022, and March 16, 2022). During these workshops, participants frequently brought up concerns regarding the lack of affordable housing for lower income households and the “missing middle” as well as the need to support affordable home ownership.

AFFH related concerns included the high cost of housing, transportation accessibility, ADU trends (specifically that ADUs tend to be utilized as vacation rentals and not housing).

4.2.1 Other Relevant Factors
Other factors to fair housing issues in St. Helena that have not been previously discussed in this analysis include lack of sufficient housing for farmworkers, availability of affordable units in a range of sizes, access to transportation, access to home ownership. These contributing factors limit the accumulation of wealth and access to housing resources in historically marginalized communities.

4.2.2 Farmworker Housing
An estimated between 6,000 and 9,000 farmworkers are employed Napa County. Sufficient affordable housing options are lacking for farmworkers who are often lower income and have special housing needs, such as seasonal housing. The number of farmworkers employed in St. Helena is unknown, however the city’s central location with regard to vineyards and wineries throughout the county would imply a number of farmworkers are employed in proximity to the city.

4.2.3 Access to Transportation
St. Helena’s public transportation system is operated by Vine Transit which operates one bus route (Route 10) in the city. Route 10 has four stops in the city, however all four stops are along the main road, State Route 29. Areas of the city located further north or south are more than 0.25 miles from a bus stop. This bus route connects the City of Napa and the City of Calistoga where connections to destinations further north or south can be made. Residents who live or work in St. Helena have limited options for traveling via public transit, potentially limiting their housing options.

4.2.4 Access to Home Ownership
Increasing housing costs has produced a barrier to home ownership for St. Helena residents. As of December 2020, Zillow reported typical home values in St. Helena were estimated at $1,665,790, much Agenda Item #10.1.

City of St. Helena 2023-2031 Housing Element Update Public Hearing Draft, April 2023 A-101
higher than the typical home value in Napa County, which is estimated at $768,410. Typical home values reflect the value of homes in the 35th to 65th percentile range. Home values have been consistently on the rise since 2000 (with the exception of the recession). This trend has made it more difficult for residents, especially lower income residents, to afford homes. Affordable housing projects in the city generally consist of rental units, which does not provide opportunities for lower income residents to own homes.

Mortgage application filing and acceptance data from 2018-2019 indicates there are racial/ethnic disparities among homeownership opportunities for residents in Napa County. As shown in Figure 46, 64 percent of White, Non-Hispanic applicants and 50 percent of Hispanic/Latinx had their loan originated, compared to 36 percent of Asian/ API applicants, 0 percent of Black/African American, and 0 percent of American Indian/Alaska Native applicants.

Figure 46 Mortgage Applications and Acceptance by Race
Source: Federal Financial Institutions Examination Council's (FFIEC) Home Mortgage Disclosure Act loan/application register (LAR) files

4.2.5 Opposition to New Development
According to the 2018 St. Helena Housing Update Report, city residents are “deeply concerned with maintaining the rural character of town” and therefore residents generally oppose housing projects that are perceived to changing neighborhood character. Many previous and ongoing multi-family housing projects 8% 6%
33%
9%
100%
17%
17% 16%
67%
18%
11%
17%
16%
36% 8%
6%
36%
64%
50%
57%
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
American
Indian or
Alaska Native,
Non-Hispanic
Asian / API,
Non-Hispanic
Black or
African
American,
Non-Hispanic
White, NonHispanicHispanic or
Latinx
Unknown
Loan Applications
Application approved but not accepted Application denied Application withdrawn by applicant File closed for incompleteness Loan originated
Agenda Item #10.1.

City of St. Helena 2023-2031 Housing Element Update Public Hearing Draft, April 2023 A-102
have been met with comments and concern from community members regarding environmental impacts, such as increases in water demand and increases in traffic as well as impacts to existing neighborhoods and community character.

4.2.6 Location of New Housing
Some residents of the city feel the city is segregated between east and west of Main Street, where the west side of the city consists of a greater percentage of White, affluent residents while the east side of the city has a greater percentage of non-White and low-income residents. In addition, residents have stated that the multi-family housing in the city is located in the eastern area. According to the 2018 St. Helena Housing Update Report, the majority of new construction over the last 10 years has been west of Highway 29.83 The Magnolia Oaks housing development consists of 44 multi-family housing units, 10 of which are affordable to low-income residents. While this project is located just west of Highway 29, other recently multi-family projects have been constructed on the east along McCorkle Avenue. The City is in the process of adopting a new Zoning Ordinance to be consistent with the 2040 General Plan, which would permit duplexes and triplexes within the MR District (see Program H-N). This would create additional housing choices and affordability levels in the MR Districts on the western side of the city. In addition, Programs H-BB, H-EE, and H-XXwould implement placemaking strategies to outreach and work with the more diverse and older populations living in the east due to the historic development patterns.

5.Sites Inventory Analysis

5.1 Opportunity Areas
HCD and TCAC opportunity maps identify areas throughout the state whose characteristics support positive economic (low poverty, high employment, high median household income), educational (reading and math proficiency, high school graduation rates, low student poverty rates), and environmental outcomes (low exposure to pollution). A census tract with a designation of high resource would indicate there are strong educational and economic opportunities, meaning opportunity for current and future residents.

According to the 2022 TCAC Opportunity Map, the entire city is considered an area of moderate resource.

However, the eastern portion of the city is has a higher percentage of non-White residents, lower household median income., higher percentage of cost burden among renters and owners, and less positive economic and environmental outcomes compared to the rest of the city. These demographic And socioeconomic patterns influenced the locations of potential lower income sites in the city. 83 Erica Skylar. 2018. St. Helena Housing Update Report. https://www.cityofsthelena.org/sites/default/files/fileattachments/planning_resources/page/3395/staff_rep ort-white_paper.pdf
Agenda Item #10.1.

City of St. Helena 2023-2031 Housing Element Update Public Hearing Draft, April 2023 A-103

5.2 Improved Conditions
According to the 2022 TCAC Opportunity Map, the entire city is considered an area of moderate resource.

Demographic and socio-economic spatial patterns show that census blocks with low- and moderate-income households, greater Hispanic/Latino populations, and higher rates of housing problems are located throughout the eastern half of the city. Sites that accommodate housing unit densities appropriate for lower-income units are scattered around the city. Sites that can accommodate most of the lower income units are located in the western and southern part of the city, which has a higher household median income and more positive economic and environmental outcomes. Approximately 38 percent of the total proposed units and 36 percent of the proposed lower-income units planned for in the sites inventory (Appendix B) are located in the eastern part of the city, which has a higher percentage of low- and moderate-income populations and non-White residents. .

Figure 47 shows the site inventory in relation to the TCAC Opportunity Map. Sites proposed within the eastern area of the city, are diverse with a mix of lower income and non-lower income sites. Lower income sites spread across the city. Site 7 (821 Pope Street) and Site 8 (882 and 886 College Avenue) have 50% lower income units and 50% moderate income units. The rest of the proposed lower income sites are 100% lower income units.

5.2.1 Exacerbated Conditions
The northern and eastern parts of the city contain block groups considered moderate resource with a higher concentration of Hispanic/Latino population, higher percent of renter occupied units, higher percentage of overpayment by residents, less positive economic outcomes, and higher pollution burden compared to the moderate and high resource areas of the city. According to California Housing Partnership data, all federal and State subsidized housing within St. Helena is in moderate resource areas in the northern and eastern portions of the city. The Sites Inventory does not exacerbate conditions in vulnerable areas of the city by identifying sites that can accommodate lower income units throughout the city. Additionally, one underutilized site was identified that could accommodate above moderate units in the eastern part of the city, which has a higher percentage of non-White residents and cost burden and lower economic and environmental outcomes.

5.2.2 Racially/Ethnically Concentrated Areas of Poverty and Affluence There are no racially/ethnically concentrated areas of poverty or affluence identified in St. Helena. However, eastern areas of the city have a larger population of Hispanic/Latino residents as well as LMI populations compared to other areas of the city. In contrast, western areas of the city have higher concentrations of White residents, higher median incomes, and lower concentration of LMI populations. Sites feasible for lower income housing were identified in these affluent areas.

Agenda Item #10.1.

City of St. Helena 2023-2031 Housing Element Update Public Hearing Draft, April 2023 A-104

5.2.3 Access to Opportunity
The city is categorized into 2 census tracts, both of which are considered moderate resource. Housing units in the sites inventory are not disproportionately concentrated in different resource areas, and the sites identified in the eastern areas are scattered on vacant and underutilized parcels to facilitate the development of lower- and above moderate-income units.

5.2.4 Disproportionate Housing Needs
The fair housing assessment found a need for affordable housing for people with disabilities and adequate low-income households. The City incentivizes the development of extremely low-, very low-, low-, and moderate-income housing by reducing development fees and relaxing development standards to incentivize housing development. The City may also assist in acquiring and assembling property, subsidizing on-site and off-site improvements, and assisting in relocation activities as well as clearing and demolition.

5.2.5 Subsidized Housing
In 2019, approximately 1,105 households received Housing Choice Vouchers in the County of Napa, with 10 households receiving rental assistance and 6 households on the wait list in St. Helena.84 The AFFH Data Viewer does not have data on Housing Choice Vouchers for St. Helena. 84 City of Napa Housing Authority’s Annual Report Housing Services Agreement, 2019, https://www.cityofsthelena.org/sites/default/files/fileattachments/planning_resources/page/3395/2018- 2019_housing_services_annual_report.pdf
Agenda Item #10.1.

City of St. Helena 2023-2031 Housing Element Update Public Hearing Draft, April 2023 A-105
Figure 47 Location of Sites Inventory in Relation to TCAC/HCD Opportunity Areas Source: AFFH Viewer, 2022
Figure 47 Location of Sites Inventory in Relation to TCAC/HCD Opportunity Areas Agenda Item #10.1.

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Agenda Item #10.1.

City of St. Helena 2023-2031 Housing Element Update Public Hearing Draft, April 2023 A-107

6.Contributing Factors
This assessment of fair housing issues identifies factors that contribute to fair housing issues in the City of St. Helena, as shown in Table 10.

Table 10 Factors that Contribute to Fair Housing Issues Identified Fair Housing Issue Contributing Factor Meaningful Action Fair housing enforcement and outreach · Lack of fair housing requirements and information provided to residents
· Outreach and communication of services
are limited to English
· Limited fair housing testing and
enforcement
· Participate in FHNV meetings, at least
once annually, to coordinate regional
responses to housing discrimination
issues (Program H-XX)
Lack of affordable housing and displacement of
residents
· Increasing rent and house/property costs
· Dominance of single family housing
· Land use and zoning laws
· Availability of affordable units in a range
of housing types
· Diversify and expand the housing stock
to accommodate the varied housing
needs of different groups (Programs H-E,

H-H, H-I, H-J, H-W, H-LL)
· Pursue down payment and mortgage
assistance resources through the
Housing Trust Fund or other resources
(such as CalHome) for local funding to
assist lower and moderate-income
residents (Program H-GG)
· Development of affordable housing on
City-owned sites (Program H-V)
· Provide by right approvals for multifamily housing projects that meet objective design and development
standards (Program H-V)
· At least once annually, provide an
information on accessory dwelling units
(ADUs) in the city, and target outreach
to residents in the high resource
Agenda Item #10.1.

City of St. Helena 2023-2031 Housing Element Update Public Hearing Draft, April 2023 A-108
southwest of Main Street and northeast
of Pratt Street (Program H-Q)
Concentration of lower income and minority
households in the southeastern areas of the
city
· Land use and zoning laws
· Location of existing affordable housing
· Prioritize affordable housing in high
resource areas southwest of Main Street
and northeast of Pratt Street (Program
H-V)
· Encourage construction and renting of
ADUs in high resource areas to increase
supply of variety of housing types in the
city (Programs H-I, H-R)
· Prioritize CIP in the eastern part of the
city (Program H-WW)
· Revise inclusionary housing ordinance
for more lower income units, realistic inlieu fees, workforce housing, and more on-site housing requirements (Program
H-F)
· Invest in public infrastructure projects in
low and moderate resource areas that
improve the quality of life for residents
(Program H-WW)
Limited resources for persons with
disabilities
· High cost of transportation for persons
with disabilities
· Lack of ADA compliant sidewalks
· Reduce ridership costs for VineGo
paratransit system (Program H-WW)
· Work with the County of Napa to carry
out the ADA self-Evaluation and
transition Plan to remove barriers for
persons with disabilities to facilities and
programs in Napa County (Program HWW)
Agenda Item #10.1.

City of St. Helena 2023-2031 Housing Element Update Public Hearing Draft, April 2023 B-1
Appendix B:

Comments on the Public Review Draft 2023-2031
Housing Element Update
The City received multiple comment letters on the Public Review Draft 2023-2031 Housing Element Update.

Comments on the Public Review Draft were received between June 29, 2022, and July 30, 2022. Key changes in response to public input include revisions to various programs and the addition of a new site in the sites inventory.

Response to Comments
In response to these comments, the City has made a number of revisions to the Public Review Draft Housing Element, including:
• 1: Policy Document – Program H-Y: Corrected spelling error and added Voorhees Circle (now program H-Z).
• 1: Policy Document – Policy HE 2.5: Revised language for clarity. • 1: Policy Document – Program H-C: Urban Limit Line: Deleted program. • 1: Policy Document – Program H-J: Updated funding sources to include State and Federal programs and grants (now program H-I).
• 1: Policy Document – Program H-M: Zoning to Facilitate Higher Density Housing: Revised for clarity (now program H-N).
• 1: Policy Document – Program H-R: Affordability Requirements for ADU Incentives: Updated text to specify that a regulatory agreement is required (now program H-S). • 5. Housing Conditions – Key Findings: Added source information for the data presented in the key finding related to Cost Burden
• 5. Housing Conditions – Physical Housing Conditions: Estimated the number of homes in need of rehabilitation.
• 6. Housing Market Conditions – Affordable Home Purchase Prices: Corrected broken references to Table 15.
• 6. Housing Market Conditions – For-Sale Housing: Revised note on Table 15 to clarify that 2021 data was used.

Agenda Item #10.1.

City of St. Helena 2023-2031 Housing Element Update Public Hearing Draft, April 2023 B-2
• 11. Housing Resources – Pending and Approved Projects: Revised Table 36 to identify the existing unit at 963 Pope Street as deed restricted.
• 11. Housing Resources – Remaining RHNA: Revised Table 37 to fix incorrect income categorization for 963 Pope Street.
• 11: Housing Resources – Residential Sites Inventory: Added 620 McCorkle (APN 009-502-003) to the available sites inventory.
• 11. Housing Resources – Pending and Approved Projects: Revised Table 36 to identify the existing unit at 963 Pope Street as deed restricted.
• 11. Housing Resources – Remaining RHNA: Revised Table 37 to fix incorrect income categorization for 963 Pope Street.
• 11: Housing Resources – Residential Sites Inventory: Added 620 McCorkle (APN 009-502-003) to the available sites inventory.

Agenda Item #10.1.

P.O. Box 94 St Helena, CA 94574
www.ourtownsthelena.org

July 26, 2022
TO: Members of the City Council and Planning Commission, City of St. Helena FROM: Jennifer La Liberte, Executive Director
SUBJECT: Housing Element Update, 2023-2031, Public Review Draft The Board of Directors of Our Town St Helena and I appreciate the opportunity to comment on the draft Housing Element Update (HEU).

General Comments
Pg 1-4 Potential Funding Sources – There does not appear to be consistency among the potential funding sources for the objectives. Some programs list specific potential sources (though the lists should be expanded) and some list only staff time. It appears this could be related to how current programs are funded. Federal, state, county, local, and private funding sources would seem appropriate for each objective that requires development and construction funding. Also, if detailed funding sources are to be included, then US Department of Agriculture Rural Development should be added.

Pg. 1-6 Throughout the document (beginning on page 1-6), much of the cited data is outdated and does not accurately reflect today’s market conditions. For example, the HEU states “typical contract rent for an apartment in St. Helena was $1,470 in 2019,” and to avoid being cost burdened, a renter would need to earn $59,160.

According to the Napa County 2021 Affordable Housing Needs Report (May 2021) produced by the California Housing Partnership, the average asking monthly rent in Napa County is $1,948 and renters need to earn $77,916 to avoid being cost burdened. Since St. Helena tends to be at the top of the market for Napa County, it’s safe to assume (and observe) that those figures are even higher. Marcus & Millchap publishes a quarterly Bay Area multi-family market report that identifies mean rents by county by unit type which would be more accurate even if not specific to St Helena. We know that a typical two-bedroom market rate unit in good condition is renting for $2,100-$2,650 plus utilities, and three-bedrooms in very good condition are at approximately $3,000 per month.

Pg.1-11 How were the specific quantified objectives derived under each of the programs and how do they relate to each other? There appears to be significant overlap in Agenda Item #10.1.

P.O. Box 94 St Helena, CA 94574
www.ourtownsthelena.org

these objectives. Example: farmworker housing and very low-income housing could be the same housing; senior housing could be incorporated into a lowincome project. The Quantified Objectives Summary Table on 1-40 page provides the totals but not the logic in how the quantities were broken out.

Pg. 1-17 “The City will explore possible incentives for building attached market rate housing units for rent and for sale” which is great, but it ought not take five years to explore incentives. And what action comes after exploration? Similarly, why will it take four years to study potential modifications to the Zoning Code to facilitate higher density housing, etc., when the City is already updating the Zoning Code and the HE and should be fairly versed in what changes are needed? Is it possible to make incremental changes? For example, an immediate step the City could take is to remove the conditional use permit requirement in multi-family zones to streamline the process for developers.

changed hands are also at-risk for conversion.

Pp. 2-23 Beginning on page 2-23, Joe is Joe McGrath, Jordan is Jordan Bentley, Mary Stevenson is Mary Stephenson, John is John Sales, Jennifer Le Liberte is Jennifer La Liberte, and Steve is Steve Goldfarb.

for Napa County, the comma is in the wrong place.

these units which comprise 17.4 percent of the housing stock. If the rental vacancy rate is 3.1 percent and ownership vacancy rate is 5.3 percent, what constitutes the delta (17.4 minus 3.1 minus 5.3)?

40 to 80 years old correlate with the City’s preservation goals?

which is providing listing prices, not value. Based on current listings in St. Helena, $1.6 million is at the lower end of the range. Local realtors could provide updated Agenda Item #10.1.

P.O. Box 94 St Helena, CA 94574
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MLS data which would be timelier and more accurate than Zillow. Also, within this section it is not clear whether existing deed-restricted units are included in totals of rent/homeownership units and monthly cost. It could be that these incomequalified units are affecting the total values. Could this be made more explicit?

sentence and middle of the second sentence that don’t make sense.

figures for 2022, so the footnote to the table should be adjusted accordingly.

a very low and low income; OTSH purchased in June 2021 and recorded 55-year deed restrictions. Also, Grayson Apartments were funded privately through the inclusionary requirements met by 632 McCorkle and references to tax credits, AHP, etc. should be removed. This is an important point because the housing crisis here will not be solved exclusively through non-profits.

restricted and should be noted.

should be moved to “lower” income.

Policies
HE 2.5 “Allow duplexes in all low-density residential zones” – please clarify whether this allowance is by right and not with a conditional use permit.

HE 4.8 “Give preference to projects providing workforce housing affordable to up to 140 percent of the AMI” – there doesn’t appear to be an implementation program associated with this policy. What preference would be given, and would it be at the expense of another affordability level?
Implementation Programs
H-A, H-NN “Concentration of sites for affordable housing” – OTSH supports the City’s efforts to ensure affordable housing sites are identified geographically throughout the city. But we caution that land is scarce, and large sites rarely become available that are suitable for multi-unit housing, and, most that do, tend to be located east of Main Street. We support incentivizing affordable housing wherever it can get Agenda Item #10.1.

P.O. Box 94 St Helena, CA 94574
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built, and don’t support the City prioritizing Affordable Housing Trust Fund dollars for affordable projects in the western portion of the city at the expense of projects in the eastern portion.

H-C OTSH believes we should be planning for a more sustainable and less cardependent future. We should be exploring opportunities to increase infill density and expand height limits and reduce parking requirements. Up and in should be the focus. The block of land from south of White Sulphur Spring Creek to Grayson and west of Highway 29 and east of Crane vineyard is one of the most poorly utilized sections of the City, and we believe a housing task force could explore how to unlock the potential here. Expanding the Urban Limit Line should be the last option as it runs a great risk of negatively impacting what makes this such a great and desirable place to live with vibrant wine and tourism industries.

H-D Water and sewer access should be prioritized for both affordable and missing middle housing. Also, please define “missing middle” in terms of Area Median Income. The water neutrality requirement should be eliminated for any attached affordable and missing middle housing. The City could consider requiring other trade-offs such as no-irrigation landscaping or rain capture systems.

H-J “ADU Workforce Housing Incentive Program” -- broaden the potential funding sources to include grants, state and federal programs. Also, consider working with the County Assessor to allow a property tax reduction on the larger property in exchange for 30-year a deed restriction on an ADU, with proper monitoring to ensure compliance.

H-M OTSH believe the City should immediately remove the Conditional Use Permit requirement on MDR Zoning. At a minimum, it should be removed for any parcel identified in the HE as a Housing Opportunity Site. Discretionary review is the toehold for opposition to these projects and makes developers wary of taking the significant financial risk that is required for this type of development. Also, consider allowing deed restrictions for missing middle projects (as defined by the City) and in exchange grant fee waivers and eliminate the housing impact fee requirement.

H-P We should not incentivize ADUs beyond existing state mandates unless they have a deed restriction and rental occupancy requirements in exchange. While this may be implied it isn’t clearly stated.

Agenda Item #10.1.

P.O. Box 94 St Helena, CA 94574
www.ourtownsthelena.org

H-R, H-DD “Affordability requirements for ADU incentives; reduced fees for affordable housing” – these should include a reference to the mechanism that will restrict affordability (i.e., affordable housing regulatory agreement).

H-S “Illegal housing units” – these types of policies or programs can be double edged as they often end up displacing households that cannot afford to live in legal units.

Consider a companion program that sees to support households displaced by this program.

H-U Under Objectives – “Support the development of 3 multi-unit housing projects….support the development of five infill projects….” What does “support” mean? As written it implies a maximum the City will “support” during the planning period.

H-?? Under Goal 3, Conservation of Existing Housing – consider adding an implementation program: “The City will work to obtain CDBG or other available funds to create an ‘Affordable Housing Conservation Fund’ so units can be acquired quickly when they hit the market and preserved at affordable levels.” H-Z “Vacation Rentals” – the City should consider prohibiting vacation rentals in certain zoning districts if it hasn’t already.

H-FF “Affordable Homeownership” – the City should work with the County’s Proximity Housing Program to provide down payment assistance to St. Helena first-time home buyers. If the County is amenable to working with the City to create a funding set-aside for St. Helena, the City could then market the program or work with others to do so.

H-II “Housing Coordinator” – this is an immediate need, and a specified time frame is encouraged rather than “ongoing”. It would be preferable to do this as a City of St Helena position, but a shared position is better than none. OTSH would prefer the City consider a Housing / Economic Development FTE rather than a lower level, part-time Housing Coordinator. Also, meeting with partner jurisdictions twice during the 13-year planning cycle does not appear to be sufficient.

Proposed Sites
Site maps It would be helpful to add a north arrow to the aerials.

Agenda Item #10.1.

P.O. Box 94 St Helena, CA 94574
www.ourtownsthelena.org

develop 36 to 50 units.”

Housing Opportunity Sites
Adams Street What is the rationale for the size and placement of the Opportunity Site on the Adams Street property?
709 McCorkle This site was recently purchased and is intended to function as an estate compound. It has a low to zero probability of being developed for affordable housing.
741 McCorkle This house was recently renovated with significant capital improvements and is unlikely to be further developed in the next HE cycle.
1637 Spring This site has recently been purchased for the intent of turning it into employee housing.

Proposed site We encourage the City to add 620 McCorkle Avenue (APN 009-502-003-000) as a “key housing site”. This 0.76-acre site is zoned MDR and is currently on the market. Including it as a key housing site would eliminate the requirement for a conditional use permit and be consistent with the goal to remove barriers to development of multi-unit housing.

Conclusion
OTSH commends the City for its work on this document. Realizing that the HEU is a mandated document that needs to follow strict guidelines, we hope the City will also create an implementation plan that identifies measures, cost analysis, staff and funding resources, and time frames for meeting the goals contained herein.

Agenda Item #10.1.

1 Aaron Hecock
From: LAURA KEIR <[email protected]>
Sent: Tuesday, July 19, 2022 11:09 AM
To: Aaron Hecock
Subject: [External] Land designation
Hi
It appears numerous parcels sent to the state to meet our quota fir homes are not currently available for sale? Are they going to be for sale? And we are not aware? Or, emanate domain enforcement would  be necessary? I firmly disagree with the high to med density development of Valley View Hudson vineyard property being developed as traffic on the road is already more than a residential area should have to handle between cut threw traffic to avoid Hwy 29 to the school traffic it’s impossible to safely get out of your driveway or even ride a bike! Spring Street is narrow and I notice in addition three sites are designated as possible development.

The government/ Bay Area need to either agree to continue our exempt status. Recognize us as a primary agricultural area or the Napa Vally will be destroyed!
Laura
Sent from my iPhone
Agenda Item #10.1.

As concerned St. Helena residents, we have read the Housing Element Update and plan to attend the public forum.

We support the city’s efforts to identify appropriate sites for potential development to provide additional housing that is badly needed. Yet af te
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reading about proposed rezoning and adding more density, we remain vigilant in pointing out situations where multi—unitprojects would negati vely impact neighborhoods.
e have shared with several City officials the situation we face after th e recent purchase of the parcels at 1521 and 1541 Elmhurst. The owner, Jennifer Mozzetti, and her friend John Bowman, a self-described devel oper from Napa, have disrupted this peaceful neighborhood with their allege d plans to develop the parcel at 1541 Elmhurst into a multi—unitsite with “cooperation of the City.” They initially claimed, as a result of their purc hase of the two parcels, they “owned” the Elmhurst Alley from the property 1 5 2
1 extending to the end of the alley.

The city, through correspondence from Eric Janzen on 5/17/22 and sev era
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other emails, assured us that the Elmhurst Alley was listed by the Coun ty Assessors as a public right of way and is not owned by Ms. Mozzetti.

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1 Aaron Hecock
From: Nancy Dervin <[email protected]>
Sent: Friday, July 1, 2022 3:13 PM
To: [email protected]
Cc: [email protected]; CityCouncil; Aaron Hecock Subject: Re: [External] Public Review Draft Housing Element Available Now! Dear HCD,
I am concerned about the City of St. Helena putting forth a Housing Element Draft that contains at least one property that the City has repeatedly been told is absolutely not available which is 601 Pope Street. There are other properties on the Draft that are also potentially not available but this one site is positively not available.

We have a huge housing shortage problem, like most communities. Knowingly including unavailable sites is unethical as well as contrary to the purpose of identifying housing opportunity sites.

What should be or can be done about this?
Sincerely,
Nancy Dervin
St. Helena, CA
From: St. Helena Housing Element <[email protected]> on behalf of St. Helena Housing Element <[email protected]>
Sent: Thursday, June 30, 2022 10:31 AM
To: [email protected] <[email protected]>
Subject: Public Review Draft Housing Element Available Now!

CITY OF ST. HELENA
Agenda Item #10.1.

1 Aaron Hecock
From: Mary Wilson <[email protected]>
Sent: Wednesday, July 13, 2022 12:54 PM
To: Aaron Hecock
Subject: [External] Housing sites
I wanted to comment on the list of potential sites for housing that was in the St Helena Star. I’ve taken the time to look at each of the addresses mentioned.    With the exception of one, I found all of them viable locations. My one exception is the vineyard location on Spring St.

One of the things that makes St Helena unique are the vineyards still scattered within the city. They are a part of our heritage, displaying the agriculture that has made this valley the world class jewel that it is.  Please allow this one to remain as it is.

Respectfully,     Mary Wilson
Sent from my iPad
Mary Wilson
1426 Kearney St.

St. Helena, Ca. 94574
707‐529‐4406
Agenda Item #10.1.

1 Aaron Hecock
From: Joe McGrath <[email protected]>
Sent: Thursday, July 14, 2022 12:12 PM
To: Aaron Hecock
Cc: Mary Stephenson; Maya DeRosa; Eric Hall; Lester Hardy; Jennifer La Liberte; Jordan Bentley; Joe Mcgrath
Subject: [External] Re: [External] A Potential New Opportunity Site Aaron:

Thanks.

Speaking as a private citizen and neighboring property owner (and concurring with Mary as an OTSH Board member), I would also advocate that this lot [620 McCorkle  ‐ APN 009‐502‐003‐000] be added to this HE cycle as a "Housing Opportunity Site".

In light of the recent multi‐family developments on that street I would recommend however that it remain MDR, otherwise it may cause too much opposition with residents on the south side of McCorkle.

The goal would be to eliminate conditional use requirements which become, as you know, major entanglements in entitlement.

However, as MDR it should be explicitly listed under 17.40.020 Permitted Uses (N):

N. Multiple-family dwellings, apartments, and dwelling groups at a density up to the maximum allowed by the medium density residential district shall be allowed as a permitted use on the following MR zoned parcels, which are identified as “Key Housing Sites” in Table 42 of the city’s 2015-2023 housing element, and are identified as follows by street address and assessor’s parcel number (APN): 567 Pope St. APN 009-070-002; 591 McCorkle Ave. APN 009-070-003; 1817 Spring St. APN 009-322-009; Sulphur Springs Ave. APN 009-362- 015; Spring St. APN 009-441-023 and 009-552-002; 576 Pope St. APN 009-552-003; 1105 Pope St. APN 009- 090-003. (Ord. 17-2 § 6 (part); Ord. 16-8 § 1; Ord. 15-2 § 7 (part): Ord. 12-2 § 6: Ord. 07-5 § 2 (part): Ord. 05-4 § 1 (part): Ord. 03-4 § 11: prior code § 27.51)
Please confirm that the above constitutes "public comment".

Thx,
Joe
On Thu, Jul 14, 2022 at 10:13 AM Aaron Hecock <[email protected]> wrote:

Hi Mary,
You can certainly make a public comment requesting that it be included as a housing opportunity site. We're holding a joint Planning Commission & City Council meeting on July 21st from 3‐5 pm to take public comment on the public review draft of the Housing Element Update and to receive direction on proceeding. You can comment in writing beforehand, verbally during the meeting, or both.

Kindly,
Aaron
Agenda Item #10.1.

1 Aaron Hecock
From: Joe McGrath <[email protected]>
Sent: Monday, July 18, 2022 4:41 PM
To: Aaron Hecock; Maya DeRosa
Subject: [External] HE Draft Input
Aaron/Maya:

Here are some additional comments/inputs re: Housing Element. Please do not take them as criticism of your hard work.

The Housing Element can be a valuable tool to accomplish our municipal housing objectives if we shape it correctly.

Thanks,
Joe
General Comments:
* Current planning meetings should be held in person with a zoom option. It should no longer be acceptable that public meetings are held entirely by Zoom. It also should not be acceptable that participants to Zoom meetings have no idea how many other participants are present, and, if  participants "opt‐in"  to identify themselves, are identified. * The document and the process are too long, too bureaucratic, and not specific enough with respect to immediate and effective actions and policy changes that will alter the climate in any meaningful way to have a real near‐term impact on affordable or missing middle  housing.
* The document itself is outdated with may reference to data as far back as  2019 representing "current" data. We lived in a far different world than in 2019.
* A major flaw in the Housing Element process for Above Moderate or Market Rate units. Our State Legislators did not comprehend second home or vacation communities.

So meeting the HE RHNA objective for Above Moderate by enabling, say, the Hunter Project is nonsensical if say 50% of the SFHs ultimately become vacation homes.

Having these types of development consume constrained water, sewer and other valuable resources can impinge on more critical housing needs.

Specific Section / Page Comments:

H‐C We should be planning for a more sustainable and less car‐dependent future. We should be exploring opportunities to increase infill density and explore expanding height limits, and reduce parking requirements. Up and In should be the focus. The block of land from south of White Sulphur Spring Creek to Grayson and West of Highway 29 and east of Crane vineyard  is one of the most poorly utilized sections of the City. We should unleash a task force to see if we can unlock Agenda Item #10.1.

2 potential here. Expanding the Urban Limit Line should be our last option, and runs great risk of negatively impacting what makes this such a great and desirable place to live with a vibrant wine industry and tourism economy.

H‐D. Water and sewer access should be prioritized for both affordable and missing middle. Also please define "missing middle" in terms of AMI %. 200%? Water Neutrality Requirement should also be eliminated for any attached affordable and missing middle. Mandate no‐irrigation landscaping instead. All new buildings in CA are highly water efficient by California Building Code. It is better that we have new stock than old stock re: environmental sustainability (similar to newer car fleet vs. older regarding emissions).

H‐M. It should not take 4 more years following 3 years working on the Housing Element to understand what Zoning Ordinances need to be changed to enable housing.
1) Start with removing the Conditional  Use Permit requirement in some manner on MDR Zoning.  At minimum, it should be reduced for any parcel identified in Housing Element as Housing Opportunity Site (not just Key Housing Opportunity Site") . It is imperative to reduce or eliminate "discretionary" review. Discretionary review is the toehold for opposition on these projects. It is also a toehold for CEQA opposition. 2) Define "Missing Middle" in terms of AMI.  200%?
3) Tradeoff off 2:1 (or some such ratio) of affordability requirements on private developers for below moderate units for moderate to missing middle (200%) cutoff units. Ie a developer can meet "affordable" designation if he/she builds (2) deed‐restricted moderate to missing middle (80‐200%AMI?) units for every (1) required < moderate unit (<80% AMI unit).
4) Eliminate Water Neutrality requirements for above. This is just one more hurdle. 5) Eliminate Housing Impact Fees for above. By very nature these projects are having a POSITIVE housing impact. 6) Reduce overall permit fee structure for above. (on page 2‐142 it calculates 12.3% of multi‐family costs on Permits & Fees. This is right after it the HE states that governmental constraints are not a factor? ) Pg 1‐15:

H‐J. What can we do to entice existing ADUs into a deed‐restricted affordable? How about a tradeoff on property tax relief on that unit for 30‐yr deed‐restriction and rental occupancy rate compliance?? Pg 1‐19:

H‐P. We should not further incent ADUS beyond existing state mandates unless they have deed‐restriction and rental occupancy requirements in exchange.

Pg 1‐29:

H‐II. What are the accountabilities of the Housing Coordinator? Why would we not do this under existing Departments? Pg 1‐34:

H‐UU. We should be considering "no‐irrigation" landscaping (at least after plants take hold).

We should eliminate the Water Neutrality Requirement on any deed‐restricted affordable < 200% AMI. This is a cumbersome and complex and expensive requirement to comply with. New attached buildings under CBC are highly water efficient and perform well below 65 GPD per capita. Nix the irrigated landscaping as a tradeoff.

Pg 2‐38:

HE1.B. This document indicates that because units have been built in last cycle that Growth management System was not an obstacle. This is untrue. 632 McCorkle was "lucky" in that we straddled two years and literally consumed (8) of the (9) available allocation. Had this been a 10 unit project, it is not clear what the City would have done. Had there Agenda Item #10.1.

3 been another similar project, it is unclear what the city would have done. Uncertainty is the enemy of Investment and the friend of Risk.

Pg 2‐103
Table 16 ‐ Grayson Apartment  2 units funding source were  not Tax Credits, nor AHP, nor RHCP, nor City funded. These two units were funded privately through inclusionary requirements on 632 McCorkle. This is an important point, because we will not solve the housing crisis here exclusively through non‐profits.

Pg 2‐125:

Saying that Building Codes and Zoning Ordinances are not a "governmental constraint" to development is an entirely untrue statement and somewhat offensive coming from a government agency.  While I would not argue that enhancements in the California Building Code are in most cases warranted, they have most definitely affected housing costs and housing production and have contributed to the shortage of affordable housing stock. Enhancements to CBC  in ADA, Seismic, Fire, and Environmental requirements have played a significant role in the increase in housing costs.   This must be acknowledged. As for Fire Code, nearly all of the costs in the building code are for suppression systems to extinguish a fire that starts inside the building. Most homes in  CA are destroyed by fire from outside the building.. The CBC however is very clear and the requirements do not have broad interpretation, so while costly to comply with, is not a great impediment.

Zoning Ordinances however and discretionary reviews are something entirely different. Developers do not like uncertainty. If a Zoning Ordinance can be interpreted differently by different people ‐ that is problematic. And if the outcome of a Design Review Meeting may be different based on the makeup of a Commission that is problematic.

Developers do not like uncertainty. This is why discretionary reviews are highly problematic. To bring a complete application to Design Review Submission ‐ let's say 8‐12 units ‐ could easily require an investment of $250K. Surveys, Civil Plans, Arch Plans, Elec Plans, Plumbing Plans, Mechanical Plans, etc. This all with the possibility of project Denial.

Lastly. CEQA is a major governmental constraint and should be acknowledged as such. CEQA should have no role in infill projects within ULL unless special circumstances warrant. 2‐132:

We should articulate what Design Review is "not". For projects that are entitled, Design Review has no function in determining whether a project can be built or not to its entitlement. It would be much preferable to establish objective design guidelines that should be followed for multi‐family rather than subject applications to a highly subjective process. 2‐138:

Parking requirements for 2 Bedrooms within the ULL should be reduced to 1.5 spaces for <200% AMI.

Housing Opportunity Sites Input
For the sites listed, the probability that any given site gets developed in the next HE cycle range between 0% and 95% (Phelps Site). Most sites identified have a low probability (< 10%?) chance of being developed. 709 McCorkle: This site has recently been purchased and is intended to function as an estate compound. 741 McCorkle: This house has been recently renovated with significant capital improvements, and is unlikely to be further developed in this HE cycle.
1637 Spring Street: This site has recently been purchased for the intent of turning it into employee housing. My understanding is that the current plan is to convert 1 BRs into 2 BRs through garage conversion.

Agenda Item #10.1.

4 620 McCorkle:  Per prior inputs, this site should be added to the Housing Opportunity Site and Key Housing Opportunity Site list.

Agenda Item #10.1.

Saint Helena Housing Coalition, Inc.

PO Box 988
Saint Helena, CA 94574
July 13, 2022
Mr. Aaron Hecock, AICP Senior Planner
City of Saint Helena
1572 Railroad Avenue
Saint Helena, Ca 94574
RE: 2023-2031 Housing Element Draft
VIA: Email
Dear Mr. Hecock:

First of all ,we would like to thank you for the this very through and professional work product. It is obvious that much research and attention to detail has been taken.

A question. Under the Water Section it is stated that “although the maximum amount of (Bell Canyon) water that is available to the City is 992 acre-feet”. Why? In Section 11. Housing Resources -Future Housing Needs we note the following:

The City must ensure the availability of residential sites at adequate densities and appropriate development standards to accommodate these units by income category.(Emphasis added).

Based upon our work in attempting to find suitable land for new “affordable” Essential worker housing our experience, in part, differs from the report’s conclusions:

Regarding the City owned Adams Street parcel considerable thought should be given to identifying the Eastern most portion of the parcel, not the Western end for “affordable” housing. SHHC submitted as preliminary site plan so indicating. Thus, leaving the West end for a potential city hall location or other civic functions. To us, it does not make sense to place any type of affordable” housing at the West end.

Site 4: 905 Main Street. When SHHC made inquiries, we were informed that the owner expressed that this for-sale price of this parcel would exceed $1,000,000. Given the suggested density of five units that would make the land cost per unit $200,000. For most “affordable” housing the land cost should be nearer to $50,000 per unit to qualify for the necessary grants and/or financing thus making this parcel financially unfeasible.

Site 7: 81 Pope Street. Zillow estimates that the current price for this property is approximately $2,000,000. Again, that would work out to a land cost of $100,000 per unit of the projected 20 “affordable Units (to say nothing of the cost of demolishing the existing structure). . For most “affordable” housing the land cost should be near to $50,000 per unit to qualify for the necessary grants and/or financing thus making this parcel financially unfeasible.

Agenda Item #10.1.

Site 9: 1447 and 1515 Spring Street. The Zillow estimated sales price for each of the existing residences at $1.6mm to $1.75mm, totally $3.35mm in value. For the estimated 24 units that works out to a land cost of $139,583.00 per unit. For most “affordable” housing the land cost should be near to $50,000 per unit to qualify for the necessary grants and/or financing thus making this parcel financially unfeasible.

Site 10: Spring Street between Hudson Avenue & Valley View. From my notes during the public comment portion, I believe it was Joe McGrath who said that this property had recently been sold and lease-back on a long-term basis. Based upon that it would appear this parcel is not currently available.

Site 11: 601 Pope Street. This property owner declined SHHC’s to acquire this parcel under a long-term lease. We offered $200,000 per year for a sixty-five-year lease and their response was “oh, we just like the way it looks”.

Site 12: 1637 Spring Street. As recently as this spring this property owner expressed No interest, and the direct quote was “let them try and develop it.” Therefore, Mr. Hecock, unless that City is prepared to use Eminent Domain as in Kelo v.

New London, it appears that the identified sites does not fulfill the “must” requirement of available sites to satisfy Saint Helena’s 2023-2031 RHNA requirements.

Respectfully submitted:

Rick Crebs
Rick Crebs, CEO
[email protected]
707-580-0418
Agenda Item #10.1.

Saint Helena Housing Coalition, Inc.

PO Box 988
Saint Helena, CA 94574
July 25, 2022
Mr. Aaron Hecock, AICP Senior Planner
City of Saint Helena
1572 Railroad Avenue
Saint Helena, Ca 94574
RE: 2023-2031 Housing Element Draft
VIA: Email
Dear Mr. Hecock:

Again, we would like to thank you for leading this sixth Housing Element 2023-2031 document incredibly rich document full of quite important and relevant data.

However, we have some considerable concerns over facts stated and conclusions reach:

Issue #1:

In this report you state “The Housing Element must also identify adequate residential sites available for a variety of housing types for all income levels; provide assistance in developing adequate housing to meet the needs of lowand moderate-income households; address governmental constraints on the maintenance, improvement, and development of housing; conserve and improve the condition of the existing stock of affordable housing; and promote housing opportunities for all persons”. (Aaron Hecock-Report to the City Council & Planning Commission Meeting -21 July 2022, page 4) (Emphasis added).

Response #1A:

Not being lawyers we referred to recognized authorities on the words contained in the above Issue #1.

Merriam-Webster Dictionary:

Ensure – “We define ensure as "to make sure, certain, or safe" and one sense of insure, "to make certain especially by taking necessary measures and precautions," is quite similar. But insure has the additional meaning "to provide or obtain insurance on or for," which is not shared by ensure.” Certain – Ascertained; precise; identified; definitive; clearly known; unambiguous; or in law, capable of being identified or made known, without liability or to mistake or ambiguity, from data already given.”
Realistic- means “based upon what is real rather than on what is wanted or hoped for” Real – means “having objective independent existence; not artificial, fraudulent, or illusory; being precisely what the name means; occurring or existing in actuality” Black’s Legal Dictionary:

Adequate means “Sufficient; proportionate; equally sufficient; equal to what is required; suitable to the case or occasion; satisfactory”
Availability Means “This phrase, among mercantile men, is a term well understood to be anything which can readily be converted into money; but it is not necessarily or primarily money.” Agenda Item #10.1.

Ready means “Prepared for what one is about to do or experience; equipped or supplied with what is needed for some act or event; prepared for immediate movement or action”(Emphasis added) Demonstrate means “to prove indubitably”
Indubitable Proof “Evidence of which is not only found creditable but is of such weight and directness as to make out the facts alleged beyond a doubt.” Must “This word, like the word ‘shall’ is primarily of mandatory effect.” Based upon the above definitions SHHC is perplexed as to how the Housing Element can, in good conscience, or on any legal basis include 601 Pope Street or 1837 Spring Street as both owners have stated that they are not interested.

I just spoke to the owner who has been a dear friend of our families for 37 years and she stated ,“No one contacted me and further had no interest in allowing their back acreage to be developed into ‘affordable’ housing.”? Response #1B:

During the public comment section of the July 21m, 2022 2023-31 Zoom Housing Element, Rick Crebs, from SHHC, raised the issue of financial feasibility of Sites #4, 905 Main Street is stating “When SHHC made inquiries, we were informed that the owner expressed that this for-sale price of this parcel would exceed $1,000,000. Given the suggested density of five units that would make the land cost per unit $200,000. For most “affordable” housing the land cost should be nearer to $50,000 per unit to qualify for the necessary grants and/or financing thus making this parcel financially unfeasible”.

Similar financial analysis was also offered on Site #7 821 Pope Street, (land costs of $100,000 per unit); Site #9 1447 & 1515 Spring Street, (land costs of $139,583 per unit).

Based upon that information provided during the Housing element Zoom meeting of Thursday, July 21, 2022, a question was directed by a city council member to the city’s staff relative to the property valuations statements raised by Rick Crebs of SHHC on valuations attributed to Zillow. The response was questioned of the authenticity of the Zillow valuations. This seems odd in that the Housing Element report refers to Zillow eight (8) times as the authority on real estate valuations.

It was further stated that grants or low interest loans would off set the high land costs.

Please allow SHHC to provide a current financial analysis as present in SHHC’s Offer to Develop 88 Units (using

2.3 acres at the East end of the Adams Street city owned parcel).

Use of Grants: Adams Street as an example:

Total Construction Costs $43,116,112 or average of $489,956 per unit (Leased, not sold land) Funding necessary to complete this project: (Projected) City/County $2,000,000 (4.4%)
Other Grants $32,337,084 (75.0%)*
Mortgage or Bond $ 7,054,364 (16.40%)
Total $43,116,112 100% (rounded)
*The largest grants that SHHC has been able to discover are from the California Department of Housing Affordable Housing Sustainable Communities (AHSC) grants which currently has a maximum grant amount of Agenda Item #10.1.

$35mm, so the Adams Street project comes close to it. This information is supplied to illustrate the extreme difficulty present in realistically financing the Saint Helena community to provide the “Must” in the RHNA requirement.

Issue #2:

In this report you state “The issue of owner consent to being included on the housing opportunity sites list has come up on several occasions. Being listed as a housing opportunity site in no way terminates or otherwise affects existing uses on-site. Furthermore, there are currently no legislative or other means to compel a private property owner in this process, meaning we cannot force or otherwise require that they build housing. That said, owner consent is not a requirement for inclusion in the housing opportunity sites inventory (Government Code 65583.2).

The inventory is to show that there are suitable sites to meet the City’s RHNA and the programs are there to help housing developers to make that happen. Designating sites as suitable for housing falls within the City's authority to regulate land uses. If the Housing Element were to designate an already developed site.” Response to #2:

Mr. Hecock, it is true that California government Code does not include language requiring “owners Consent”. but, by the same logic, it does not exclude requiring the “owners’ consent.” This, it would seem that your comment is non-responsive. Further, Code 65583.2 refers to Government code 65583 which, in part, states “(3) An inventory of land suitable and available for residential development, including vacant sites and sites having realistic and demonstrated potential for development during the planning period to meet the locality's housing need for a designated income level, and an analysis of the relationship of zoning and public facilities and services to these sites, and an analysis of the relationship of the sites identified in the land inventory to the jurisdiction’s duty to affirmatively further fair housing. (Emphasis added).

Further, in referring to the word definitions provided above, that the proposed Saint Helena Housing 2023-2031 Document on a factually basis fails to meet with any degree of accuracy of the meanings of the authenticated meaning of the words; Adequate, Available, Demonstratable, Ensure, and Must.

In closing, such vagueness in the prior Housing Element Reports may have been tolerated in the past. However, our town is critically deficient in sufficient “affordable” housing for all AMI’s. The fact that so many are required to commute to work in the Upper Valley each day clearly contributes to unnecessary Green Housing Gas (GHG) emissions to say nothing of the cost to commute which further contributes multiple well vetted studies that conclude that the majority of those renting are cost burdened. Many in the 50-60% of household income! Lastly, the lack of a strategy to affirmatively address Saint Helena’s housing crisis is to deny, or turn its back, on its pledge to work towards a policy of Diversity, Equity, and Inclusion.

Our town can no longer rely upon the old “Three Card Monty Trick” in addressing the statutory issues the Housing Element requires.

SHHC’s First Suggestion:

The city should consider removing Sites 4 (905 Mains Street, Ste 7 (821 Pope Street, Ste 9 1447 & b1515 Springs Street as being financially unrealistic due to associated land costs and instead revise the Adams Street parcel from 30 unit of Lower Income to the recommendations in the following graph:

Table 50 Summary of Housing Units (Extracted)

Lower
Income Moderate Income
Above
Moderate
Income Total
Agenda Item #10.1.

Pending Projects 0 4 88 92
ADU Trends 0 0 72 72
Recommended Changes Site Inventory
Site 3 (Adams Street) -22 9 76 63
Site 4 (905 Mains Street) 0 0 -5 -5
Site 7 (821 Pope Street -10 -10 0 -20
Site 9 (1447 & 1515 Spring Street) -24 0 -24 -48
Totals -56 -1 47 -10
Remaining Sites (Consolidated) Site Inventory
Sites 1, 2, 5, 6, 8, 10, 11,12 152 87 244 483
Color Code -Purple-Doubtful
Red - Subtractions
Green -Additions
The results reached is close to a net neutral on units for each category of AMI housing. And the inclusion of 88 units plus 50 for the OTSG/Phelps’s project equates to a realistic 54% of Saint Helena’s 2023-31 RHNA required allocation.

SHHC’s Second Suggestion:

While draconian, the only true solution SHHC sees to the significant challenges in achieving the forthcoming coming 2023-31 RHNA Site locations allocations is for the city to firmly state that it will undertake, if necessary, Eminent Domain proceeding as in the Kelvo v. New London U.S. Supreme Court Decision.

In closing, it is time to discard the Housing Element word games from the past and boldly put forth only those Opportunity Sites that are certain and available.

Respectfully submitted:

Rick Crebs
Rick Crebs, CEO
[email protected]
707-580-0418
Ccs: Anil Comelo, City Manager
Maya DeRosa, Director of Planning
Geoff Ellsworth, Mayor
Paul Dohring, Esq. Vice Mayor
Lester hardy, Esq., City Council Member
Eric Hall, City Council Member
Anna Chouteau, City Council Member
Agenda Item #10.1.

City of St. Helena 2023 General Plan Update
Addendum
prepared by
City of St. Helena
Maya DeRosa, Community Development Director
Department of Planning
1088 College Avenue
St. Helena, California 94574
prepared with the assistance of
Rincon Consultants, Inc.
449 15th Street, Suite 303
Oakland, California 94612
April 2023
Agenda Item #10.1.

City of St. Helena 2023 General Plan Update
Addendum
prepared by
City of St. Helena
Maya DeRosa, Community Development Director
Department of Planning
1088 College Avenue
St. Helena, California 94574
prepared with the assistance of
Rincon Consultants, Inc.
449 15th Street, Suite 303
Oakland, California 94612
April 2023
Agenda Item #10.1.

This report prepared on 50% recycled paper with 50% post-consumer content.

Agenda Item #10.1.

Table of Contents
Addendum i
Table of Contents
Acronyms and Abbreviations.................................................................................................................iii Executive Summary ................................................................................................................................1 Introduction....................................................................................................................................3

1.1 Project Title.........................................................................................................................3

1.2 Lead Agency Name and Address.........................................................................................3

1.3 Contact Person and Phone Number ...................................................................................3

1.4 Project Location ..................................................................................................................3

1.5 Project Description..............................................................................................................6

1.6 Environmental Review ........................................................................................................7

1.7 Discretionary Action............................................................................................................7

1.8 Prior Environmental Document(s) ......................................................................................8

1.9 Location of Prior Environmental Document(s) ...................................................................8 Project Context...............................................................................................................................9

2.1 St. Helena General Plan ......................................................................................................9

2.1.1 Housing Element...............................................................................................10

2.1.2 Public Health, Safety, and Noise Element ........................................................14

2.1.3 2040 General Plan EIR.......................................................................................15 Overview of CEQA Guidelines Section 15164...............................................................................17 Environmental Effects & Determination ......................................................................................19

4.1 Environmental Areas Determined to Have New or Substantially More Severe Significant Effects Compared to Those Identified in the Previous EIR ...............................................19

4.2 Determination...................................................................................................................19 Addendum Methodology..............................................................................................................21

5.1 2040 General Plan Consistency.........................................................................................21

5.2 Accommodation of the RHNA...........................................................................................21

5.3 Consistency with Horizon Year 2040 Projections .............................................................22

5.4 Preliminary Environmental Considerations......................................................................23 Addendum Evaluation ..................................................................................................................25

6.1 Aesthetics..........................................................................................................................25

6.2 Agricultural Resources......................................................................................................29

6.3 Air Quality .........................................................................................................................33

6.4 Biological Resources..........................................................................................................39

6.5 Cultural, Historic, and Tribal Cultural Resources..............................................................43

6.6 Energy, Greenhouse Gases, and Climate Change.............................................................47

6.7 Geology, Soils, and Seismicity...........................................................................................51

6.8 Hazards and Hazardous Materials ....................................................................................55

6.9 Hydrology and Water Quality ...........................................................................................59

6.10 Land Use, Population, and Housing ..................................................................................65

6.11 Noise .................................................................................................................................69

6.12 Public Services and Recreation .........................................................................................73

6.13 Transportation and Traffic ................................................................................................77 Agenda Item #10.1.

City of St. Helena
2023 General Plan Update
ii

6.14 Utilities and Service Systems ............................................................................................81 Summary of Findings ....................................................................................................................85 References....................................................................................................................................86 Bibliography..................................................................................................................................86 Tables
Table 1 City of St. Helena Regional Housing Needs Allocation......................................................12 Table 2 Summary of Areas of Potential Impact under the 2040 General Plan Update EIR...........15 Table 3 Housing Unit Yield per Site Category ................................................................................22 Figures
Figure 1 Regional Location................................................................................................................4 Figure 2 Project Area ........................................................................................................................5 Figure 3 Housing Element Sites Inventory Locations – Vacant and Underutilized (Nonvacant) Sites...................................................................................................................................13 Agenda Item #10.1.

Acronyms and Abbreviations
Addendum iii
Acronyms and Abbreviations
AB Assembly Bill
ABAG Association of Bay Area Governments
ADU Accessory dwelling unit
BAAQMD Bay Area Air Quality Management District
BMP Best management practices
CARB California Air Resources Board
CBC California Building Code
CEQA California Environmental Quality Act
DPM Diesel Particulate Matter
EIR Environmental impact report
GHG Greenhouse Gas
HRA Health risk assessment
NPDES National Pollutant Discharge Elimination System
PG&E Pacific Gas & Electric
PM Particulate matter
ROG Reactive organic gas
SB Senate Bill
SHMC Saint Helena Municipal Code
VMT Vehicle Miles Traveled
VOC Volatile organic compounds
Agenda Item #10.1.

City of St. Helena
2023 General Plan Update
iv
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Agenda Item #10.1.

Executive Summary
Addendum 1
Executive Summary
The proposed project consists of a comprehensive update to the Housing Element of the City of St.

Helena General Plan. State law requires that housing elements be updated every eight years (California Government Code Sections 65580 to 65589.8). The project would update the City of St.

Helena Housing Element as part of the 6
th cycle of updates. For St. Helena, the planning period runs from January 31, 2023 through January 31, 2031. The Housing Element update identifies residential sites adequate to accommodate a variety of housing types for all income levels and needs of special population groups, defined under state law (California Government Code Section 65583). It analyzes governmental constraints to housing maintenance, improvement, and development; addresses conservation and improvement of the condition of existing affordable housing stock; and outlines policies that promote housing opportunities for all persons. The proposed project also includes revisions to the Public Health, Safety, and Noise Elements to be consistent with California law regulating evacuation routes and climate change vulnerability.

The Housing Element update establishes objectives, policies, and programs to assist the City of St.

Helena in achieving state-mandated housing goals. The City’s implementation of these policies and programs includes amendments to the Public Health, Safety, and Noise Element of the General Plan and the rezoning of several sites in the inventory of potential sites for meeting the city’s Regional Housing Needs Allocation (RHNA) obligation. No formal land use changes or physical development is proposed at this time and future changes would require environmental evaluation as potential impacts are location-specific and cannot be assessed in a meaningful way until a project site and development proposal are identified.

Pursuant to Government Code section 65583(c)(1), these actions will be accomplished within three years of the City of St Helena’s adoption of the Housing Element update. As required by Government Code Section 65583(c)(8), the Housing Element update provides a timeline for processing each of the amendments to the General Plan, Zoning Ordinance and other land use documents which implement the Housing Element update.

In considering the potential environmental impacts of the Housing Element update, the City determined that the Final Environmental Impact Report (EIR) certified for the 2040 General Plan update (2040 General Plan update Final EIR, State Clearinghouse Number 2010042001) is of continuing informational value. The City also determined that the potential environmental impacts (both direct and indirect impacts) of the Housing Element update are within the scope of the previously certified Final EIR and that none of the conditions requiring subsequent or supplemental environmental review under California Environmental Quality Act (CEQA) Guidelines Section 15162 exist. Based on the information and analysis provided below, the City determined that only minor or technical changes to the previously certified Final EIR are necessary and that that preparation of an Addendum pursuant to CEQA Guidelines Section 15164 is appropriate.

Agenda Item #10.1.

City of St. Helena
2023 General Plan Update
2 This page intentionally left blank.

Agenda Item #10.1.

Introduction
Addendum 3
Introduction
This document is an Environmental Impact Report Addendum that analyzes the City of St. Helena’s (City’s) proposed Housing Element update and Public Health, Safety, and Noise Element update Project (hereafter also referred to as the “General Plan update,” “proposed project,” or “project”).

1.1 Project Title
City of St. Helena General Plan Update

1.2 Lead Agency Name and Address
City of St. Helena
Department of Planning
1088 College Avenue
St. Helena, California 94574

1.3 Contact Person and Phone Number
Maya DeRosa, Community Development Director
(707) 967-2783 x 530

1.4 Project Location
The Housing Element update planning boundaries (Plan Area) coincide with the St. Helena city limits. The area encompasses approximately 5 square miles of land in the western portion of Napa County. The city is located northwest of the City of Yountville and southeast of the City of Calistoga, surrounded by unincorporated areas of the County. State Route 29 and 121 provide regional access to the city from the north and south. Figure 1 shows the regional location of the Plan Area, and Figure 2 shows the Plan Area’s boundaries in its immediate location. In addition, the project identifies 11 vacant and underutilized sites within the city that can accommodate new housing or rezone. The vacant and underutilized sites to be studied for housing opportunities are shown broadly in Figure 3 and correspond to the list provided in the Housing Resources chapter of the needs assessment of the Housing Element update. Not all parcels have street addresses at this time.

With most of the City developed and preservation of open space a priority, all draft vacant and opportunity sites are on currently underdeveloped, underutilized, or vacant lots.

Agenda Item #10.1.

City of St. Helena
2023 General Plan Update
4 Figure 1 Regional Location
Agenda Item #10.1.

Introduction
Addendum 5
Figure 2 Project Area
Agenda Item #10.1.

City of St. Helena
2023 General Plan Update
6 1.5 Project Description
The project consists of a comprehensive update to the Housing Element of the St. Helena General Plan and update to the existing Public Health, Safety, and Noise Element of the General Plan. These elements are a part of the St. Helena General Plan, which is a long-term document with text and diagrams that express the goals, objectives, and policies necessary to guide the community toward achieving its vision over approximately 20 years (i.e., 2040). The General Plan was subject to a comprehensive update as well; it underwent extensive environmental review in the form of an EIR, which was certified in 2019. The EIR for the St. Helena 2040 General Plan includes discussion of alternatives and growth inducing impacts (direct and indirect impacts) associated with urban development in the city.

State law requires that housing elements be updated every eight years (California Government Code Sections 65580 to 65589.8). The Housing Element update identifies residential sites adequate to accommodate a variety of housing types for all income levels and needs of special population groups, defined under state law (California Government Code Section 65583). It analyzes governmental constraints to housing maintenance, improvement, and development; addresses conservation and improvement of the condition of existing affordable housing stock; and outlines policies that promote housing opportunities for all persons. The project would update the City of St.

Helena Housing Element as part of the 6
th cycle of updates. For St. Helena, the planning period runs from January 31, 2023 through January 31, 2031.

Additionally, the Housing Element update would bring it into compliance with state legislation passed since the adoption of the 2040 General Plan and 2015-2023 Housing Element. There are multiple main components of the Housing Element update that mirror those of the previous Housing Elements, but that have been updated to reflect current conditions, including:
▪ An introduction to review the requirements of the Housing Element, public participation process, and data sources
▪ A profile and analysis of the city’s demographics, housing characteristics, and existing and future housing needs
▪ An analysis of constraints on housing production and maintenance, including market, governmental, and environmental limitations to meeting the City’s identified needs ▪ A review of resources available and results of a housing sites inventory analysis conducted to demonstrate the City of St. Helena’s ability to satisfy its share of the region’s future housing need
▪ A review of the City’s housing programs and evaluation of accomplishments under the 2013- 2021 Housing Element
▪ A Housing Plan to address the city’s identified housing needs, which identifies the City’s housing goals, policies, and implementing programs
▪ An identification of the goals, policies, and programs and the city’s quantified objectives for the 2023-2031 planning period, by income group, based on growth estimates, past and anticipated development, and income data
The Housing Element update establishes objectives, policies, and programs to assist the City in achieving state-mandated housing goals. The city’s implementation of these policies and programs includes future amendments to other elements of the General Plan and the rezoning of several sites in the inventory of potential sites for meeting the city’s RHNA obligation. Pursuant to Government Agenda Item #10.1.

Introduction
Addendum 7
Code section 65583(c)(1), these actions will be accomplished within three years of the City of St.

Helena’s adoption of the Housing Element update. As required by Government Code Section 65583(c)(8), the Housing Element update provides a timeline for processing each of the amendments to the General Plan, Zoning Ordinance and other land use documents which implement the Housing Element update.

1.6 Environmental Review
In April 2019, the City of St. Helena certified the St. Helena 2040 General Plan update and Final EIR (City of St. Helena General Plan 2040, State Clearinghouse Number 2010042001) for an update to General Plan, including the Land Use Element. The certified Final EIR discussed the potential environmental impacts (both direct and indirect impacts) associated with future development allowed under the General Plan update and included a thorough analysis of the estimated build out of the City through the horizon year 2040. The EIR estimated new development for residential, commercial, office, industrial, hospital and hotel uses throughout the city and sphere of influence and evaluated the potential environmental impacts associated with an estimated total buildout of 400 new dwelling units. The EIR found that, with implementation of the policies and programs contained in the General Plan and recommended mitigation measures, all impacts (direct and indirect) associated with future development under the General Plan update would be less than significant, except impacts on agricultural resources, air quality, energy, greenhouse gas emissions, and climate change, and transportation and traffic which would be significant and unavoidable.

In considering the potential environmental impacts of the Housing Element update, the City determined that the EIR certified for the 2040 General Plan update is of continuing informational value. The City also determined that the potential environmental impacts (both direct and indirect impacts) of the Housing Element update are within the scope of the previously certified EIR and that none of the conditions requiring subsequent or supplemental environmental review under CEQA Guidelines Section 15162 exists. Based on the information and analysis provided below, the City determined that only minor or technical changes to the previously certified EIR are necessary and that that preparation of an Addendum pursuant to CEQA Guidelines Section 15164 is appropriate.

Like the 2040 General Plan update, the Housing Element update does not include any development proposal or approval and future development of any specific housing site would be subject to additional environmental review pursuant to CEQA Guidelines Section 15168(c).

1.7 Discretionary Action
Implementation of the Housing Element would require the following discretionary actions by the City of St. Helena City Council:
▪ Approval of an Addendum to the General Plan EIR
▪ Adoption of the updated Housing Element and Public Health, Safety, and Noise Element In addition to the above-mentioned actions, future amendments to the St. Helena Municipal Code (SHMC) consistent with the implementing programs of the updated Housing Element would also be adopted by the City Council.

The California Department of Housing and Community Development reviews the proposed Housing Element in accordance with California law. No other review by outside public agencies is required.

Agenda Item #10.1.

City of St. Helena
2023 General Plan Update
8 1.8 Prior Environmental Document(s)
The City of St. Helena General Plan 2040 Final EIR, State Clearinghouse Number 2010042001.

1.9 Location of Prior Environmental Document(s)
The location and custodian of the City of St. Helena General Plan 2040 EIR is the City of St. Helena Planning Department, 1088 College Avenue St. Helena, CA 94574. A copy of the EIR also is available online at the City of St. Helena website: https://www.cityofsthelena.org/planning/page/2040- general-plan-update
Agenda Item #10.1.

Project Context
Addendum 9
Project Context
The project consists of a comprehensive update to the Housing Element of the St. Helena General Plan and update to the existing Public Health, Safety, and Noise Element of the General Plan (collectively referred to as “project”). These elements are a part of the St. Helena General Plan, which is a long-term document with text and diagrams that express the goals, objectives, and policies necessary to guide the community toward achieving its vision over approximately 20 years (i.e., 2040).

2.1 St. Helena General Plan
California law requires that each city and county in California adopt “a comprehensive, long-term general plan,” the purpose of which is to plan for important community issues such as new growth, housing needs, and environmental protection. Furthermore, the General Plan is used to project future demand for services such as sewer, water, roadways, parks, and emergency services. A General Plan is only successful when it reflects the priorities and values of the community and is a key tool for influencing quality of life.

City of St. Helena decision-makers (e.g., City Council and Planning Commission), rely on the General Plan as the basis for making decisions on matters such as land use and the provision of public facilities (e.g., roads, parks, fire stations). It is also a policy document that guides decisions related to protecting, enhancing, and providing those things that the community values most, such as open space, habitat conservation, economic development, and protecting the character of the community.

California law requires that every general plan, at a minimum, address certain subject categories (called “elements”), which include land use, circulation, housing, conservation of natural resources, open space, noise, safety, and environmental justice. A general plan may also address other subjects that are of importance to the community‘s future, such as sustainability, community design, and public art. St. Helena’s adopted General Plan includes the following elements which address all state-mandated elements with additional policies and actions to address Environmental Justice issues:
▪ Land Use and Growth Management
▪ Economic Sustainability
▪ Public Facilities and services
▪ Circulation
▪ Historic Resources
▪ Open Space and Conservation
▪ Public Health, Safety, and Noise
▪ Climate Change
▪ Housing
▪ Parks and Recreation
▪ Arts, Culture, and Entertainment
Agenda Item #10.1.

City of St. Helena
2023 General Plan Update
10 2.1.1 Housing Element

2.1.1.1 Purpose of the Housing Element
The Housing Element of the General Plan is designed to provide the City of St. Helena with a coordinated and comprehensive strategy for promoting the production of safe, decent, and affordable housing within the community. A priority of both state and local governments, Government Code Section 65580 states that “the availability of housing is of vital statewide importance, and the early attainment of decent housing and a suitable living environment for every Californian, including farmworkers, is a priority of the highest order.” Pursuant to the state law, the Housing Element has two main purposes:

To provide an assessment of both current and future housing needs and constraints in meeting these needs
To provide a strategy that establishes housing goals, policies, and programs The Housing Element is one of the eight General Plan elements the state mandates in Government Code Section 65302. The Housing Element serves as an integrated part of the General Plan but is updated more frequently to ensure its relevancy and accuracy. The City of St. Helena’s current Housing Element, adopted in 2015, identifies strategies and programs that focus on:

Conserving and improving existing affordable housing
Maximizing housing opportunities throughout the community Assisting in the provision of affordable housing
Removing governmental and other constraints to housing investment Promoting fair and equal housing opportunities
The residential character of St. Helena is largely determined by the variety, location, and maintenance of its housing. The Housing Element is an official response to the need to provide housing for all economic segments of the population, establishing goals, policies, and programs that will guide the City of St. Helena decision making and set forth an action plan to implement these housing programs through an established planning period.

2.1.1.2 Updates to the Housing Element
State law requires that housing elements be updated every eight years (California Government Code Section 65588). The Housing Element must identify residential sites adequate to accommodate a variety of housing types for all income levels and to meet the needs of special population groups as defined under state law (California Government Code Section 65583). The Housing Element analyzes market and governmental constraints to housing maintenance, improvement, and development; addresses conservation and improvement of the condition of existing affordable housing stock; and outlines policies that promote housing opportunities for all persons.

The previous Housing Element covered an eight-year planning period (January 31, 2015 through January 31, 2023), Government Code Section 65588(e).

The City of St. Helena Housing Element is now being revised as part of the 6 th cycle of updates, the
period of which runs from January 31, 2023 through January 31, 2031. Therefore, this update is referred to as the “Housing Element update.”
Agenda Item #10.1.

Project Context
Addendum 11
The 2023-2031 Housing Element would bring the Element into compliance with California law enacted since the City’s adoption of the 2015-2023 Housing Element and with the current Association of Bay Area Governments’ (ABAG’s) RHNA. The 2023-2031 Housing Element includes the following components, as required by California law:
▪ An assessment of the City’s population, household, and housing stock characteristics, existing and future housing needs by household types, and special needs populations. ▪ An analysis of resources and constraints related to housing production and preservation, including governmental regulations, infrastructure requirements and market conditions such as land, construction, and labor costs as well as restricted financing availability. ▪ Identification of the City’s quantified objectives for the 2023-2031 RHNA and inventory of sites determined to be suitable for housing.
▪ Opportunities for Conservation in Residential Development: California law requires cities to identify opportunities for energy conservation in residential development. ▪ Review of the 2015-2023 Housing Element to identify progress and evaluate the effectiveness of previous policies and programs.
▪ A Housing Plan to address the City’s identified housing needs, including housing goals, policies, and programs to facilitate the 2023 Housing Element update (6 th Cycle).

2.1.1.3 Changes in California Law
The following items represent substantive changes to California law since the City’s last Housing Element was adopted and certified in 2015. The Housing Element update incorporated and addressed all pertinent housing law changes.
▪ Affordable Housing Streamlined Approval Process: Senate Bill (SB) 35 (2017) ▪ Additional Housing Element Sites Analysis Requirements: Assembly Bill (AB) 879 (2017) and AB 1397 (2017)
▪ Affirmatively Furthering Fair Housing: AB 686 (2017)
▪ No-Net-Loss Zoning: SB 166 (2017)
▪ Safety Element to Address Adaptation and Resiliency: SB 1035 (2018) ▪ By Right Transitional and Permanent Supportive Housing: AB 2162 (2018) and B 101 (2019) ▪ Accessory Dwelling Units: AB 2299 (2016), SB 1069 (2016), AB 494 (2017), SB 229 (2017), AB 68 (2019), AB 881 (2019), AB 587 (2019), SB 13 (2019), and AB 671 (2019) ▪ Density Bonus: AB 1763 (2019)
▪ Housing Crisis Act of 2019: SB 330
▪ Surplus Land Act Amendments: AB 1486 and AB 1255 (2019) ▪ Housing Impact Fee Data: AB 1483 (2019)
▪ Emergency and Transitional Housing Act of 2019: AB 139 (2019) ▪ Standardization of Sites Inventory Analysis and Reporting: SB 6 (2019) Agenda Item #10.1.

City of St. Helena
2023 General Plan Update
12 2.1.1.4 Regional Housing Needs Assessment and Required Buffer The Housing Element must address the City's fair share of the regional housing need (as determined by ABAG) and specific California statutory requirements. It must also reflect the vision and priorities of the local community. As of December 2021, ABAG determined a final RHNA Allocation of 256 units for the City of which 162 must be affordable to lower-income households, as shown in Table 1.

Table 1 City of St. Helena Regional Housing Needs Allocation Income Category (Percent of Napa County Area Median Income) Very Low
(<50%)
Low
(50-80%)
Moderate
(80-120%)
Above Moderate
(>120%)
Total
Housing Units
RHNA Housing units 104 59 26 67 256
RHNA + 20% Buffer 121 71 31 79 302
California law requires local jurisdictions to identify enough future housing sites inventory to not only cover the jurisdiction’s 6th Cycle RHNA, but to also provide for an additional buffer capacity above the RHNA. The buffer capacity is required to accommodate realistic production rates of affordable housing units. Additionally, the buffer can allow for instances when a smaller residential project must be considered for a given property or when existing units are demolished. The “No Net Loss” Law (Government Code Section 65863) requires maintenance of sufficient sites to meet the RHNA for all income levels throughout the planning period. With this required buffer, the number of housing units identified in the Housing Element is 307.

To meet the objectives of the RHNA and provide sufficient capacity for housing development, the Housing Element identifies sites for residential development. The Housing Element update identifies some sites for land use changes either to be consistent with the existing Land Use Element or to permit or increase residential uses on the sites. However, neither the Housing Element nor the City itself develops housing. Moreover, as described in further detail in Section 5, Addendum Methodology, below, the Housing Element update, in and of itself, does not itself implement land use changes, but puts forth goals and policies that support housing efforts. As described in the Housing Element update, the City’s RHNA can be accommodated in the following categories:
▪ Vacant or underutilized sites, where new residential units can be developed under current General Plan regulations;
▪ Sites to be rezoned to permit residential uses or permit them at a high density ▪ Planned or pending projects where no rezoning is required; and ▪ Current accessory dwelling units, also known as “granny flats” Figure 3 shows the locations of the vacant and underutilized sites identified in sites inventory in the Housing Element update. All sites in the housing sites inventory are within the City’s limits.

Agenda Item #10.1.

Project Context
Addendum 13
Figure 3 Housing Element Sites Inventory Locations – Vacant and Underutilized (Nonvacant) Sites Agenda Item #10.1.

City of St. Helena
2023 General Plan Update
14 2.1.1.5 Zoning and General Plan Amendments
The project would involve an amendment to the City’s Zoning Ordinance to rezone existing land use designations to Mixed-Use, Medium Density Residential, and High Density Residential. Some existing sites are designated as land uses other than a residential land use category and would be rezoned to mixed-use or residential land use categories. Select sites would be upzoned from existing residential land use categories to more dense residential land use categories. Most of these sites are located in the central areas of the City to reflect the intensity of existing nearby higher density parcels. Future development of those sites would require separate CEQA review and compliance with local development standards.

Due to the proposed zoning modifications on particular Draft Housing Element vacant and underutilized sites, a General Plan Amendment would be required to change the land use designations on those sites to be consistent with the zoning.

2.1.2 Public Health, Safety, and Noise Element
The Safety element is one of the eight General Plan elements the state mandates in Government Code Section 65302. The project includes revisions to the Public Health, Safety, and Noise Element which identifies forces of nature and events resulting from human action that have the potential to cause harm to life and property in the City. The goal of a Safety Element is to reduce the potential short and long-term risk of death, injuries, property damage, and economic and social dislocation resulting from fires, floods, droughts, earthquakes, landslides, climate change, and other hazards.

Identifying the source of such threats allows decision-makers to take preemptory action to minimize the damage, particularly as it relates to new development. The Public Health, Safety, and Noise Element also addresses noise, fire and police protection, hazardous materials, solid waste, and public utility systems. A climate change vulnerability assessment identifying potential impacts from climate change on vulnerable populations and natural and built assets in St. Helena was also conducted for the Public Health, Safety, and Noise Element update.

California law requires specific changes to a safety element when the municipality undergoes an update to the Housing Element. The Public Health, Safety, and Noise Element update includes revisions to be consistent with California law through the following actions:
▪ Identify and propose policies for residential developments in any hazard area identified in the safety element that do not have at least two emergency evacuation routes. ▪ Update information relating to flood and fire hazards and city assets at risk due to climate change vulnerability.
▪ Propose and strengthen policies related to risk reduction, emergency preparedness and evacuation, and community and facility resilience infrastructure and strategies. ▪ Propose additional policies to address climate change hazards, including extreme heat days, extended drought, increased precipitation, and worsening air quality such as investing in backup power sources, funding for weatherization of homes, and providing cooling centers.

2.1.2.1 Changes in State Law
The following represent bills passed by the California State Legislature and approved by the Governor that require substantive changes to a Safety Element when a municipality undergoes an update. The Safety and Community Services Element update has incorporated and addressed all pertinent safety element law changes.

Agenda Item #10.1.

Project Context
Addendum 15
▪ Residential Emergency Evacuation Routes: SB 99 (2019) ▪ Evacuation Routes: AB 747 (2019)
▪ General Plans: SB 1035 (2018)
▪ Climate Change Adaptation: SB 379 (2015)
▪ Integration of Local Hazard mitigation Plan: AB 2140 (2006) ▪ Seismic and Geologic Hazards: SB 926 (2004)
▪ Flood Mapping: AB 162 (2007)

2.1.3 2040 General Plan EIR
The 2040 General Plan update EIR addressed the potential environmental effects (direct and indirect) of the planned buildout of St. Helena through the year 2040 and concluded that implementation of the General Plan would result in levels of environmental impacts as detailed in Table 2.

Table 2 Summary of Areas of Potential Impact under the 2040 General Plan Update EIR Issue Area Highest Level of Impact Mitigation Proposed in the General Plan EIR Aesthetics Less than significant None
Agricultural Resources Significant and Unavoidable None Air Quality Significant and Unavoidable Mitigation Measures AQ-1, AQ-2, AQ-3, AQ-4, AQ-5, and AQ-6
Biological Resources Less than significant None
Cultural, Historic, and Tribal Cultural
Resources
Less than significant None
Energy, Greenhouse Gases, and Climate
Change
Significant and Unavoidable Mitigation Measure GHG-1
Geology, Soils, and Seismicity Less than significant None Hazards and Hazardous Materials Less than significant None Hydrology and Water Quality Less than significant HYDRO-1 Land Use, Population, and Housing Less than significant None Noise Significant and Unavoidable Mitigation Measure NO-1 Public Services and Recreation Less than significant None Transportation and Traffic Significant and Unavoidable Mitigation Measures TR-1, TR-2, TR-3, TR-4, TR-5, and TR-6
Utilities and Service Systems Less than significant None The General Plan has an approximate year 2040 horizon, but actual buildout of all planned land uses may occur earlier or later, as long-range demographic and economic trends are difficult to accurately predict. The designation within the proposed General Plan of a site for a certain use does not necessarily mean that the site will be developed or redeveloped with that use during the planning period, as most development will depend on property owner initiative and market conditions.

Agenda Item #10.1.

City of St. Helena
2023 General Plan Update
16 This page intentionally left blank.

Agenda Item #10.1.

Overview of CEQA Guidelines Section 15164
Addendum 17
Overview of CEQA Guidelines Section
15164
Public Resources Code Section 21166 and CEQA Guidelines Sections 15162 and 15164 set forth the criteria for determining the appropriate additional environmental documentation, if any, to be completed when changes are proposed to a project that has a previously certified EIR. When considering the need for additional environmental review, the fundamental determination a lead agency must make is whether the previously certified EIR retains some informational value or whether changes in the project or circumstances have rendered it wholly irrelevant. If the previously certified EIR has continuing informational value, the lead agency then must determine whether the proposed changes in the Project requires additional environmental review under Public Resources Code Section 21166 and CEQA Guidelines Section 15162.

CEQA Guidelines Section 15164 provides that a lead agency will prepare an addendum to a previously certified EIR if some changes or additions are necessary, but none of the conditions described in Section 15162 calling for preparation of a subsequent EIR have occurred. CEQA Guidelines section 15162(a) states that no Subsequent or Supplemental EIR may be prepared for a project with a certified EIR unless the lead agency determines, based on substantial evidence in the light of the whole record, one or more of the following:

Substantial changes are proposed in the project that will require major revisions of the previous EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects.

Substantial changes occur with respect to the circumstances under which the project is undertaken which will require major revisions of the previous EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects.

New information of substantial importance, which was not known and could not have been known with the exercise of reasonable diligence at the time the previous EIR was certified as complete, shows any of the following:

The project will have one or more significant effects not discussed in the previous EIR.

Significant effects previously examined will be substantially more severe than shown in the previous EIR.

Mitigation measures or alternatives previously found not to be feasible would in fact be feasible and would substantially reduce one or more significant effects of the project, but the project proponents decline to adopt the mitigation measure or alternative.

Mitigation measures or alternatives that are considerably different from those analyzed in the previous EIR would substantially reduce one or more significant effects on the environment, but the project proponents decline to adopt the mitigation measure or alternative.

The analysis pursuant to Section 15162 demonstrates whether the lead agency can approve the activity as being within the scope of the existing certified EIR, that an addendum to the existing EIR would be appropriate, and no new environmental document, such as a new EIR, would be required.

The addendum need not be circulated for public review but can be included in or attached to the Agenda Item #10.1.

City of St. Helena
2023 General Plan Update
18 final EIR, and the decision-making body shall consider the addendum with the final EIR prior to deciding on the project.

The City of St. Helena prepared this Addendum, pursuant to CEQA Guidelines Sections 15162 and 15164, to evaluate whether the project’s environmental impacts are covered by and within the scope of the General Plan Final EIR). The following Addendum details any changes in the project, changes in circumstances under which the project is undertaken, and/or "new information of substantial importance" that may cause one or more significant effects to environmental resources.

The responses herein substantiate and support the City of St. Helena’s determination that the potential environmental impacts of the Housing Element update and Public Health, Safety, and Noise Element update policies and programs are within the scope of the General Plan EIR, do not require subsequent or supplemental environmental review under CEQA Guidelines Section 15162 and, in conjunction with the EIR, preparation of an Addendum pursuant to CEQA Guidelines Section 15164 is appropriate.

Agenda Item #10.1.

Environmental Effects & Determination
Addendum 19
Environmental Effects & Determination

4.1 Environmental Areas Determined to Have New or
Substantially More Severe Significant Effects
Compared to Those Identified in the Previous EIR
The subject areas checked below were determined to be new significant environmental effects or to be previously identified effects that have a substantial increase in severity either due to a change in Project, change in circumstances, or new information of substantial importance, as indicated by the checklist and discussion on the following pages.
■ None
□ Aesthetics □ Agricultural Resources □ Air Quality
□ Biological Resources □ Cultural, Historic, and Tribal Cultural Resources
□ Energy, Greenhouse
Gases, and Climate
Change
□ Geology, Soils, and
Seismicity
□ Hazards & Hazardous
Materials
□ Hydrology and Water
Quality
□ Land Use, Population, and
Housing
□ Noise □ Public Services and
Recreation
□ Transportation and Traffic □ Utilities and Service Systems

4.2 Determination
Based on this analysis, the 2040 General Plan EIR has continuing informational value and:
□ Substantial changes are proposed in the project or there are substantial changes in the circumstances under which the project will be undertaken that will require major revisions to the previous EIR due to the involvement of significant new environmental effects or a substantial increase in the severity of previously identified significant effects. Or, there is "new information of substantial importance," as that term is used in CEQA Guidelines Section 15162(a)(3). Therefore, a SUBSEQUENT or SUPPLEMENTAL EIR is required.

Agenda Item #10.1.

Agenda Item #10.1.

Addendum Methodology
Addendum 21
Addendum Methodology

5.1 2040 General Plan Consistency
To promote a uniform and compatible vision for the development of the community, California law requires the General Plan be internally consistent in its goals and policies. The Housing Element and the Public Health, Safety, and Noise Element are components of the General Plan, and thus, the Housing Element update and Public Health, Safety, and Noise Element update must be consistent with the vision of the General Plan and supported by goals and policies of the other General Plan elements. General Plan elements and policies that affect housing are summarized below:

The Land Use and Growth Management Element directs the location, amount, and type of residential development in St. Helena. It presents the desirable pattern for the ultimate development of the city and reflects the community’s evolution and changing demographics over the General Plan horizon. The Land Use Plan details the location and the density of development allowed throughout the city.

The Community Design Element guides the form, character, and appearance of the community to preserve the city’s history and character in future commercial, industrial, and residential development.

The Circulation Element defines a safe, efficient, and adequate circulation system in St. Helena that responds to all circulation needs. Circulation means the actual physical circulation system consisting of freeways, streets, bicycle routes, sidewalks, and trails, as well as modes of transportation, including cars, buses, trucks, trains, bicycles, ridesharing, and walking.

The Open Space and Conservation Element and Parks and Recreation Element establish goals and polices to protect sensitive resources from development impacts; maintain and improve appropriate access to open space; and ensure park and recreation opportunities are sufficient to meet the needs of future residents.

The Economic Sustainability Element establishes goals and policies to guide city efforts to maintain an economically viable community, including providing a range of housing and employment opportunities that meet the needs of residents and workers alike, that attract families and businesses to create demand for planned land uses, and that establish and fund public service levels to preserve St. Helena’s quality of life.

The Climate Change Element directs the City’s response to and plans for climate change by addressing energy and water conservation, renewable energy production, transportation, sustainable business development, and reduction of climate change impacts in the city.

5.2 Accommodation of the RHNA
The City’s RHNA for the current planning period is 256 units, which includes 162 very low and lowincome housing units, 26 moderate income housing units, and 68 above moderate housing units.

The City must demonstrate the availability of sites with appropriate zoning and development standards that can facilitate and encourage the development of such units. As shown in Table 3, the City anticipates the development of 72 accessory dwelling units (ADUs) during the eight-year planning period and 93 units would be accommodated from planned and approved (pipeline) Agenda Item #10.1.

City of St. Helena
2023 General Plan Update
22 projects, which can count towards the RHNA. A total of 307 units were identified on vacant and nonvacant sites under the existing General Plan land uses, as well as on sites requiring rezoning under Program H-A.

Although the housing sites inventory has been identified for future planning purposes as part of the Housing Element update, the adoption of the Housing Element itself does not change the current zoning or General Plan designations of the properties. California Government Code Section 65583 (c)(1)(A) states that cities have up to three years from the start of the Housing Element planning period to rezone sites, including adoption of minimum density and development standards.

Therefore, the City’s rezoning program, which is identified as Program H-A of the Housing Element update, would be a separate project and evaluated in accordance with CEQA at the time of its review. Prior to the approval of any changes in land use, the City would evaluate the potential environmental impacts from the rezoning or change in land use.

Table 3 Housing Unit Yield per Site Category
Site Category/Approach Very Low/Low Moderate Above Moderate Total RHNA plus buffer 192 31 79 302
Vacant or underutilized parcels 203 69 35 307
Planned or Pending Projects, no rezone 4 1 88 93
Accessory Dwelling Units 0 0 72 72
Total 207 70 195 472
RHNA Surplus (15) (39) (116) (171)
As shown in Table 3, existing vacant or underutilized residentially zoned properties, planned, and pending projects that require no zone change, and accessory dwelling units would yield four very low and low income housing units under current conditions. Therefore, the City of St. Helena needs to account for the additional 188 very low and low income housing units through a combination of the remaining approaches. The 188 very low and low income housing units fall within the projected horizon year buildout and housing unit assumptions addressed in the General Plan and General Plan EIR.

5.3 Consistency with Horizon Year 2040 Projections
The General Plan EIR reports that in 2018 there were 2,735 existing housing units in St. Helena and predicts that by horizon year 2040, St. Helena will have 3,067 units (Chapter 2, Project Description), assuming an addition of 332 new housing units citywide between 2018 and horizon year 2040. As discussed above, the City of St. Helena’s RHNA for the current planning period is 256 units. In addition, the Housing Element includes a required buffer which plans for a total of approximately 302 units during the planning period. Including the pending and approved projects, ADU trends, and vacant and nonvacant sites, the Site Inventory would accommodate approximately 472 units as shown in Table 3 which would exceed the 332 units by an additional 140 units. Therefore, additional environmental analysis would be required prior to the implementation of the rezoning program identified as Program H-A in the Housing Element.

Agenda Item #10.1.

Addendum Methodology
Addendum 23

5.4 Preliminary Environmental Considerations
The Housing Element update, in and of itself, does not propose specific development projects, but rather puts forth goals, policies, and programs that support housing efforts in St. Helena. Each future housing development project and housing program adopted in the Housing Element would be subject to separate review to determine potential impacts on the environment related to each project as potential impacts are location-specific and cannot be assessed in a meaningful way until a project site and development proposal are identified. When a specific development proposal is considered for approval, that project would be subject to adopted development guidelines and standards and be required to incorporate applicable mitigation measures and alternatives developed in the 2040 General Plan EIR certified in 2019 (in accordance with CEQA Guidelines Section 15168(c)(3)). If a subsequent activity (in this case a specific development proposal) would have effects not identified in the program EIR (the 2040 General Plan EIR and this Addendum), the lead agency must prepare additional CEQA documentation.

Similarly, the goals, policies and programs in the updated Public Health, Safety, and Noise Element, in and of themselves, do not propose specific projects that result in a physical change to the environment. Should a project associated with implementation of the Public Health, Safety, and Noise Element have the potential to result in a physical change in the environment, it would be subject to separate review under CEQA.

This Addendum Evaluation, therefore, includes the analysis of the changes and potential impacts related to the adoption of Housing Element and Public Health, Safety, and Noise Element updates.

No physical development or changes in land use are addressed or evaluated. The City would analyze any future development or changes in land use separate from the adoption of the Housing Element.

This Addendum Evaluation is intended to demonstrate the project’s consistency with the existing St.

Helena 2040 General Plan update Final EIR to satisfy the requirements of CEQA. In particular, and pursuant to Public Resources Code Section 21083.3, this Addendum Evaluation assesses whether the updated Housing Element and Public Health, Safety, and Noise Element, as a policy and programs document, includes impacts not addressed or analyzed as significant effects in the St.

Helena 2040 General Plan update Final EIR.

Agenda Item #10.1.

City of St. Helena
2023 General Plan Update
24 This page intentionally left blank.

Agenda Item #10.1.

Addendum Evaluation
Aesthetics
Addendum 25
Addendum Evaluation

6.1 Aesthetics
EIR Evaluation Criteria
EIR
Significance
Conclusion
EIR
Mitigation
Measures
CEQA Guidelines Section 15162
Is a Subsequent EIR Needed?
Are Only Minor
Technical
Changes or
Additions
Necessary or Did
None of the
Conditions
Described in
§15162 Occur?
(§15164(a))
Project is
within the
Scope of
General Plan
EIR?
Do the Proposed
Changes Involve
a New or
Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Are There New
Circumstances
Involving a New
or Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Is There New
Information of
Substantial
Importance
Requiring New
Analysis or
Verification?
Would adoption of the General Plan update:
a. Have a substantial adverse effect on
a scenic vista?
Less than
Significant
None No No No Yes Yes
b. Substantially damage scenic
resources, including but not limited
to, trees, rock outcroppings, and
historic buildings within a state
scenic highway?
Less than
Significant
None No No No Yes Yes
c. In non-urbanized areas, substantially
degrade the existing visual character
or quality of public views of the site
and its surroundings? (Public views
are those that are experienced from
a publicly accessible vantage point).

If the project is in an urbanized area,
would the project conflict with
applicable zoning and other
regulations governing scenic quality?
Less Than
Significant
None No No No Yes Yes
Agenda Item #10.1.

City of St. Helena
2023 General Plan Update
26 EIR Evaluation Criteria
EIR
Significance
Conclusion
EIR
Mitigation
Measures
CEQA Guidelines Section 15162
Is a Subsequent EIR Needed?
Are Only Minor
Technical
Changes or
Additions
Necessary or Did
None of the
Conditions
Described in
§15162 Occur?
(§15164(a))
Project is
within the
Scope of
General Plan
EIR?
Do the Proposed
Changes Involve
a New or
Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Are There New
Circumstances
Involving a New
or Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Is There New
Information of
Substantial
Importance
Requiring New
Analysis or
Verification?
d. Create a new source of substantial
light or glare that would adversely
affect daytime or nighttime views in
the area?
Less Than
Significant
None No No No Yes Yes
Agenda Item #10.1.

Addendum Evaluation
Aesthetics
Addendum 27
2040 General Plan EIR Aesthetics Findings
The 2040 General Plan EIR determined that impacts to aesthetic resources would be less than significant for scenic vistas, scenic highways, visual quality, and light and glare (Section 3.1, Aesthetics). It further stated that individual development projects would be subject to projectspecific development and planning review, including adherence to goals and policies in the Land Use and Growth Management Element and Community Design Element related to urban design and visual quality. As such, all projects proposed under General Plan implementation would be required to conform to zoning, design standards, and other regulations concerning aesthetic resources such as those that address architectural design, lighting, landscaping, building setbacks, and visual compatibility.

Addendum Analysis
The Housing Element update is a policy document consistent with the General Plan. The Housing Element update identifies sites, shown in Figure 3, that could be developed to meet the City’s 6 th
cycle RHNA throughout St. Helena. Some of these sites could require land use changes that would bring the zoning into consistency with the Land Use Element, change the existing land use, or allow for increased density. As discussed in Section 5, Addendum Methodology, the City of St. Helena has sites that could undergo land use changes through Program H-A to facilitate development of housing units to meet the RHNA during the 6th cycle (2023-2031). Government Code Section 65583 (c)(1)(A) states that cities have up to three years from the time a Housing Element is adopted to rezone sites, including adoption of minimum density and development standards. The City would evaluate any proposed land use changes for potential environmental impacts prior to approval of the proposed land use change. Furthermore, future development proposals could be subject to further environmental analysis, pursuant to CEQA Guidelines Section 15168(c) and as required by state law, to evaluate potential impacts specific to that proposal.

Because it is a policy document, the Housing Element update would not, in and of itself, result in impacts to scenic vistas, scenic resources, or visual character, and would not create new sources of substantial light or glare which adversely affects views. The sites are located on vacant as well as non-vacant properties such as those with existing buildings or vineyards. However similar to the analysis within the 2040 General Plan EIR, any individual development projects consistent with the Housing Element would be subject to project-specific development and planning review, including adherence to goals and policies in the Land Use and Growth Management Element and Community Design Element related to urban design and visual quality. As such, all projects proposed under the Housing Element implementation would be required to conform to zoning, design standards, and other regulations concerning aesthetic resources such as those that address architectural design, lighting, landscaping, building setbacks, and visual compatibility.

The Public Health, Safety, and Noise Element update revised information on public and critical facilities, discussed safety impacts from climate change, and added implementation measures to create evacuation plans and educate residents and address climate vulnerability. None of the implementation items would cause impacts to scenic vistas or resources or directly develop new structures which would impact views and create substantial glare. Any potential updates to structures to mitigate potential risks to wildfire or other climate safety hazards would be subject to project-specific development and planning review, including adherence to goals and policies in the Land Use and Growth Management Element and Community Design Element related to urban Agenda Item #10.1.

City of St. Helena
2023 General Plan Update
28 design and visual quality. Therefore the Public Health, Safety, and Noise Element update would not result in significant adverse impacts related to aesthetics.

Conclusion
Based on the analysis above, the project would not result in new or more severe impacts (direct or indirect) than were analyzed in the 2040 General Plan EIR and no additional environmental assessment of aesthetics is required.

Agenda Item #10.1.

Addendum Evaluation
Agricultural Resources
Addendum 29

6.2 Agricultural Resources
EIR Evaluation Criteria
EIR
Significance
Conclusion
EIR
Mitigation
Measures
CEQA Guidelines Section 15162
Is a Subsequent EIR Needed?
Are Only Minor
Technical
Changes or
Additions
Necessary or Did
None of the
Conditions
Described in
§15162 Occur?
(§15164(a))
Project is
within the
Scope of
General Plan
EIR?
Do the Proposed
Changes Involve
a New or
Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Are There New
Circumstances
Involving a New
or Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Is There New
Information of
Substantial
Importance
Requiring New
Analysis or
Verification?
Would adoption of the General Plan update:
a. Convert Prime Farmland, Unique
Farmland, or Farmland of
Statewide Importance
(Farmland), as shown on maps
prepared pursuant to the
Farmland Mapping and
Monitoring Program of the
California Resources Agency, to
non-agricultural use?
Significant and
Unavoidable
None No No No Yes Yes
b. Conflict with existing zoning for
agricultural use or a Williamson Act
contract?
Less than
Significant
None No No No Yes Yes
c. Involve other changes in the
existing environment which, due to
their location or nature, could
result in conversion of Farmland to
non-agricultural use or conversion
of forest land to non-forest use?
Less than
Significant
None No No No Yes Yes
Agenda Item #10.1.

City of St. Helena
2023 General Plan Update
30 2040 General Plan EIR Agricultural Resources Findings The 2040 General Plan EIR determined that there would be significant and unavoidable impacts to agricultural resources (Section 3.2, Agricultural Resources). The EIR found that implementation of the 2040 General Plan could result in the loss of up to 118 acres of land identified as Important Farmland, including Prime Farmland, Farmland of Statewide Importance, Unique Farmland, and Farmland of Local Importance. The 2040 General Plan EIR found the loss of farmland is not directly mitigable, without preventing development altogether. No feasible mitigation measures were identified for agricultural land conversion that would fulfill the objectives of and implement the 2040 General Plan update. Therefore, and implementation of the plan would result in significant and unavoidable impacts to Important Farmlands.

Addendum Analysis
The Housing Element update is a policy document consistent with the General Plan. The Housing Element update identifies sites, shown in Figure 3, that could be developed to meet the City’s 6 th
cycle RHNA throughout St. Helena. Some of these sites could require land use changes that would bring the zoning into consistency with the Land Use Element, change the existing land use, or allow for increased density. As discussed in Section 5, Addendum Methodology, the City of St. Helena has sites that could undergo land use changes through Program H-A to facilitate development of housing units to meet the RHNA during the 6th cycle (2023-2031). Government Code Section 65583 (c)(1)(A) states that cities have up to three years from the time a Housing Element is adopted to rezone sites, including adoption of minimum density and development standards. .

The General Plan goals and policies support continued farming and restrict uses that would interfere with farming and open space uses in certain areas. Most of the sites identified within the Housing Element update are located on sites with existing development and on sites zoned for residential or commercial uses. The Housing Element update includes one site identified for housing which is located on prime farmland. However, the site has a land use designation of Public and Quasi-Public and housing development would not result in any more severe impacts to agricultural resources than were a public facility developed on the site as currently shown in the General Plan. In addition, the 2040 General Plan EIR determined that there would be significant and unavoidable impacts to farmland (Section 3.2, Agricultural Resources). Therefore, the Housing Element update would not result in new or more severe impacts than those identified in the General Plan EIR. .

There would also be no new impacts to Williamson Act contracts, as none of the identified sites in the sites inventory are under Williamson Act contract.

The Public Health, Safety, and Noise Element update revised information on public and critical facilities, discussed safety impacts from climate change, and added implementation measures to create evacuation plans and educate residents and address climate vulnerability. These updates would not convert existing farmland or forested land and would not impact any land under Williamson Act contract. Therefore, the Public Health, Safety, and Noise Element update would have no impact related to agricultural resources.

Conclusion
The Housing Element Update does not propose the development on housing on any areas of the City not already analyzed for development in the 2040 General Plan EIR. The Public Health, Safety, and Noise Element update would update information and goals, policies, and objectives to be consistent with the State legislation and would not change growth assumptions or buildout assessed Agenda Item #10.1.

Addendum Evaluation
Agricultural Resources
Addendum 31
in the 2040 General Plan EIR. Therefore, the project would not result in new or more severe impacts (direct or indirect) than were analyzed in the 2040 General Plan EIR and no additional environmental assessment of agricultural resources is required.

Agenda Item #10.1.

City of St. Helena
2023 General Plan Update
32 This page intentionally left blank.

Agenda Item #10.1.

Addendum Evaluation
Air Quality
Addendum 33

6.3 Air Quality
EIR Evaluation Criteria
EIR
Significance
Conclusion
EIR
Mitigation
Measures
CEQA Guidelines Section 15162
Is a Subsequent EIR Needed?
Are Only Minor
Technical
Changes or
Additions
Necessary or Did
None of the
Conditions
Described in
§15162 Occur?
(§15164(a))
Project is
within the
Scope of
General Plan
EIR?
Do the Proposed
Changes Involve
a New or
Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Are There New
Circumstances
Involving a New
or Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Is There New
Information of
Substantial
Importance
Requiring New
Analysis or
Verification?
Would adoption of the General Plan update:
a. Conflict with or obstruct
implementation of the applicable
air quality plan?
Less than
significant
None No No No Yes Yes
b. Violate air quality standards or
contribute substantially to an
existing or projected air quality
violation?
Significant and
Unavoidable
AQ-1, AQ-2,
and AQ-3
No No No Yes Yes
c. Result in a cumulatively
considerable net increase of any
criteria pollutant for which the
project region is non-attainment
under an applicable federal or
state ambient air quality standard?
Significant and
Unavoidable
AQ-1, AQ-2,
and AQ-3
No No No Yes Yes
d. Expose sensitive receptors to
substantial pollutant
concentrations?
Less than
significant
with
Mitigation
AQ-4, AQ-5,
and AQ-6
No No No Yes Yes
e. Create objectionable odors
affecting a substantial number of
people?
Less than
Significant
None No No No Yes Yes
Agenda Item #10.1.

City of St. Helena
2023 General Plan Update
34 2040 General Plan EIR Air Quality Findings
As discussed under in Section 3.3, Air Quality, of the 2040 General Plan EIR, impacts related to consistency with applicable air quality plans would be less than significant. The 2040 General Plan would support the goals of Bay Area Air Quality Management District’s (BAAQMD’s) 2017 Clean Air Plan, include all applicable control measures, and would not conflict with its implementation.

The 2040 General Plan EIR concluded that impacts related to criteria pollutants would be significant and unavoidable. Construction emissions associated with a potential level of annual development that is consistent the General Plan’s 2040 growth projections could result in reactive organic gas (ROG), NOx, CO, and particulate matter (PM) emissions construction activity that exceeds BAAQMDrecommended CEQA significance thresholds. All other potential construction emissions would be below BAAQMD-recommended CEQA significance thresholds. In addition, maximum daily operational emissions associated with potential 2040 growth under the General Plan would result in ROG and PM10 emissions that could exceed BAAQMD-recommended CEQA significance thresholds.

All other potential operational emissions would be below BAAQMD-recommended CEQA significance thresholds. To reduce impacts related to air quality emissions of criteria air pollutants, the 2040 General Plan EIR required implementation of Mitigation Measures AQ-1, AQ-2, and AQ-3 which would reduce ROGs from architectural coating, and PM from construction, as well require all development with the potential to create point-source air quality impacts to receive BAAQMD review prior to approval. In addition, any development under the 2040 General Plan would be required to comply with all applicable air quality plans, California Air Resources Board (CARB) and BAAQMD regulations, Title 24 energy efficiency standards, and policies within the 2040 General Plan aimed at reducing air pollution emissions. However, because the detail of future projects under the General Plan cannot be known, the 2040 General Plan EIR concluded impacts would be significant and unavoidable.

Mitigation Measure AQ-1: Require construction projects in the City of St. Helena to implement best management practices (BMPs) to reduce fugitive dust emissions. BMPs may include:
▪ Watering all exposed surfaces (e.g., parking areas, staging areas, soil piles, graded areas, and unpaved access roads) three times per day using recycled water. ▪ Covering all haul trucks transporting soil, sand, or other loose material. ▪ Removing all visible mud or dirt track-out onto adjacent public roads using wet power vacuum street sweepers at least once per day. The use of dry power sweeping is prohibited. ▪ Limiting all vehicle speeds on unpaved roads to 15 mph. ▪ Completing all roadways, driveways, and sidewalks to be paved as soon as possible. Laying building pads soon as possible after grading unless seeding or soil binders are used. ▪ Minimizing idling times either by shutting equipment off when not in use or reducing the maximum idling time to 5 minutes (as required by the California airborne toxics control measure Title 13, Section 2485 of California Code of Regulations). Clear signage shall be provided for construction workers at all access points. ▪ Maintaining and properly tuning all construction equipment in accordance with manufacturer’s specifications. All equipment shall be checked by a certified mechanic and determined to be running in proper working condition prior to operation. • Staging construction equipment as far as possible from existing sensitive receptors (away from the southeast property line and surrounding residences).

Agenda Item #10.1.

Addendum Evaluation
Air Quality
Addendum 35
▪ Posting a publicly visible sign with the telephone number and person to contact at the Lead Agency regarding dust complaints. This person shall respond and take corrective action within 48 hours. The Air District’s phone number shall also be visible to ensure compliance with applicable regulations.
▪ Where warranted, the project sponsors shall incorporate the following language into construction specifications if significant risk is anticipated based on design level construction schedule, duration and concurrent construction activities:
▪ Powering portable equipment by electricity if available or if electricity is not available, using propane or natural gas if feasible. Diesel engines shall only be used if electricity is not available and it is not feasible to use propane or natural gas. ▪ Ensuring that all mobile diesel-powered off-road equipment larger than 25 horsepower and operating on the site for more than two days continuously or 20 hours cumulative meets, at a minimum, U.S. EPA particulate matter emissions standards for Tier 2 engines or equivalent and be equipped with diesel particulate matter filters that meet CARB-certified Level 2 or 3 Diesel Particulate Filters. Alternatively-fueled equipment (i.e., non-diesel) would meet this requirement.

Mitigation Measure AQ-2: Require that applicants proposing development of projects within the City of St. Helena require contractors, as a condition of contract, to reduce constructionrelated fugitive ROG emissions by ensuring that low-volatile organic compounds (VOC) coatings that have a VOC content of 10 grams/liter (g/L) or less be used during construction. All project applicants shall submit evidence of the use of low-VOC coatings to BAAQMD prior to the start of construction.

Mitigation Measure AQ-3: Require all development applications with the potential to create point-source air quality impacts be referred to the Bay Area Air Quality Management District (BAAQMD) for review and comment to ensure compliance with BAAQMD requirements prior to approval of the project.

Mitigation Measure AQ-4: Require development projects to meet CARB setback recommendations from air contaminant sources for sensitive uses, or conduct specific air quality and health risk impact analyses and identify project specific mitigation measures.

Mitigation Measure AQ-5: To protect sensitive receptors require discretionary projects in proximity to Highway 29, Silverado Trail and the Rail Corridor to include an analysis of mobile source toxic air contaminant health risks. The analysis, if necessary, shall identify feasible mitigation measures to reduce health risks to acceptable levels.

Mitigation Measure AQ-6: All applicants proposing development of projects within 1,000 feet of existing sensitive receptors, as defined by BAAQMD, shall prepare a site-specific construction health risk assessment (HRA) taking into account both project-level and cumulative health risks (including existing toxic air contaminant sources). If the HRA demonstrates, to the satisfaction of the City, that the health risk exposures for adjacent receptors will be less than BAAQMD project level and cumulative thresholds (as appropriate), then additional mitigation would be unnecessary. However, if the HRA demonstrates that health risks would exceed BAAQMD project-level and/or cumulative thresholds (as appropriate), additional feasible on- and offsite mitigation shall be analyzed by the applicant to help reduce risks to the greatest extent practicable.

Agenda Item #10.1.

City of St. Helena
2023 General Plan Update
36 The 2040 General Plan EIR determined that impacts to sensitive receptors regarding pollutant concentrations by the General Plan would be less than significant. Although implementation of the General Plan could result in new sensitive residential receptors and new non-residential land uses that would potentially be emissions sources, permitted stationary sources in St. Helena are primarily located in commercial or semi-rural areas while most of the sensitive receptors, such as schools, residences, and retirement homes, are located in the downtown area of the city. In addition, individual development projects would be evaluated through the BAAQMD permit process and the CEQA process to identify and mitigate any significant exposures. Implementation of Mitigation Measures AQ-1 through AQ-6 would reduce potential impacts to sensitive receptors to less than significant.

Buildout under the General Plan would not cause or significantly contribute to CO concentrations that exceed State or federal ambient air quality standards for CO. Regulatory mechanisms, including asbestos National Emission Standards for Hazardous Air Pollutants regulations for demolition and renovation outlined in BAAQMD Regulation XI, Rule 11-2, would ensure impacts from asbestos containing materials present during demolition of existing structures would be less than significant.

Heath risks associated with receptor exposure to Diesel Particulate Matter (DPM) would be less than significant because the use of off-road heavy-duty diesel equipment would be temporary and would combine with the highly dispersive properties of DPM, additional reductions in exhaust emissions would occur in the future, and construction-related activities would be short-term, incremental through time, and would occur at scattered locations throughout the city such that an individual receptor location would not be exposed to DPM exposure for a prolonged period of time.

However, without specific details on the locations of building footprints or their construction schedules, a quantitative evaluation of potential health risk impacts is not possible. Mitigation Measures AQ-1, AQ-4, AQ-5, and AQ-6 would mitigate air quality impacts from construction to reduce health related impacts.

The 2040 General Plan EIR determined impacts related to objectionable odors affecting a substantial number of people would be less than significant.

Addendum Analysis
The Housing Element update is a policy document consistent with the General Plan. The Housing Element update identifies sites, shown in Figure 3, that could be developed to meet the City’s 6 th
cycle RHNA throughout St. Helena. Some of these sites could require land use changes that would bring the zoning into consistency with the Land Use Element, change the existing land use, or allow for increased density. As discussed in Section 5, Addendum Methodology, the City of St. Helena has sites that could undergo land use changes through Program H-A to facilitate development of housing units to meet the RHNA during the 6th cycle (2023-2031). Government Code Section 65583 (c)(1)(A) states that cities have up to three years from the time a Housing Element is adopted to rezone sites, including adoption of minimum density and development standards.

While potential air quality-related impacts of future projects cannot be assessed in a meaningful way until the project site and development design is known, including the number of units, potential number of residents, and potential vehicle miles traveled, operational impacts would be addressed by provisions in the General Plan, the Green Building Code, and other regulations and standards that govern air quality in St. Helena. Short-term air quality impacts resulting from construction of the sites, such as dust generated by clearing and grading activities, exhaust emissions from gas- and diesel-powered construction equipment, and vehicular emissions associated with the commuting of construction workers would be subject to BAAQMD rules and protocols Further General Plan goals Agenda Item #10.1.

Addendum Evaluation
Air Quality
Addendum 37
and policies support reduction of air quality impacts. Mitigation measures identified in the General Plan EIR will be implemented to help reduce impacts to the greatest extent possible. These measures would remain in practice with implementation of the Housing Element update.

Consistent with buildout under the 2040 General Plan, implementation of the proposed Housing Element update could contribute to impacts related to criteria pollutants. Annual development under the Housing Element update could increase construction emissions from indirect land use changes. Potential impacts caused by more development would be reduced through implementation of Mitigation Measures AQ-1 through AQ-6 identified in the General Plan EIR.

However, impacts would remain significant and unavoidable even with implementation of mitigation, the same as impacts identified in the General Plan EIR. Implementation of the proposed Housing Element update could impact sensitive receptors. However, the Housing Element update does not proposed new land use changes which would place new sensitive receptors in areas with emission sources.

The Public Health, Safety, and Noise Element update revised information on public and critical facilities, discussed safety impacts from climate change, and added implementation measures to create evacuation plans and educate residents and address climate vulnerability. The update would not directly result in development or activities that would generate air pollutants, cause an increase in VMT, or generate objectionable odors. Any potential updates to structures or development of climate resilient infrastructure designed to mitigate potential risk of climate safety hazards would not allow for more housing units or increase projected growth forecasts in the city. In addition, the updates would be subject to all applicable air quality plans, CARB and BAAQMD regulations, Title 24 energy efficiency standards, and policies within the 2040 General Plan aimed at reducing air pollution emissions. Therefore, the Public Health, Safety, and Noise Element update would have less than significant impacts related to air quality.

Conclusion
Based on the above, the Housing Element update as well as the Public Health, Safety and Noise Element Updates would not result in new or more severe impacts (direct or indirect) than were analyzed in the 2040 General Plan EIR.

Agenda Item #10.1.

City of St. Helena
2023 General Plan Update
38 This page intentionally left blank.

Agenda Item #10.1.

Addendum Evaluation
Biological Resources
Addendum 39

6.4 Biological Resources
EIR Evaluation Criteria
EIR
Significance
Conclusion
EIR
Mitigation
Measures
CEQA Guidelines Section 15162
Is a Subsequent EIR Needed?
Are Only Minor
Technical
Changes or
Additions
Necessary or Did
None of the
Conditions
Described in
§15162 Occur?
(§15164(a))
Project is
within the
Scope of
General Plan
EIR?
Do the Proposed
Changes Involve
a New or
Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Are There New
Circumstances
Involving a New
or Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Is There New
Information of
Substantial
Importance
Requiring New
Analysis or
Verification?
Would adoption of the Housing Element update:
a. Have a substantial adverse effect,
either directly or through habitat
modifications, on any species
identified as a candidate,
sensitive, or special status species
in local or regional plans, policies,
or regulations, or by the
California Department of Fish and
Wildlife or U.S. Fish and Wildlife
Service?
Less than
significant
None No No No Yes Yes
b. Have a substantial adverse effect
on any riparian habitat or other
sensitive natural community
identified in local or regional plans,
policies, or regulations, or by the
California Department of Fish and
Wildlife or U.S. Fish and Wildlife
Service?
Less than
significant
None No No No Yes Yes
Agenda Item #10.1.

City of St. Helena
2023 General Plan Update
40 EIR Evaluation Criteria
EIR
Significance
Conclusion
EIR
Mitigation
Measures
CEQA Guidelines Section 15162
Is a Subsequent EIR Needed?
Are Only Minor
Technical
Changes or
Additions
Necessary or Did
None of the
Conditions
Described in
§15162 Occur?
(§15164(a))
Project is
within the
Scope of
General Plan
EIR?
Do the Proposed
Changes Involve
a New or
Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Are There New
Circumstances
Involving a New
or Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Is There New
Information of
Substantial
Importance
Requiring New
Analysis or
Verification?
c. Have a substantial adverse effect
on state or federally protected
wetlands as defined by Section 404
of the Clean Water Act (including,
but not limited to, marsh, vernal
pool, coastal, etc.) through direct
removal, filling, hydrological
interruption, or other means?
Less than
significant
None No No No Yes Yes
d. Interfere substantially with the
movement of any native resident
or migratory fish or wildlife species
or with established native resident
or migratory wildlife corridors, or
impede the use of native wildlife
nursery sites?
Less than
significant
None No No No Yes Yes
e. Conflict with any local policies or
ordinances protecting biological
resources, such as a tree
preservation policy or ordinance?
Less than
significant
None No No No Yes Yes
f. Conflict with the provisions of an
adopted habitat conservation plan,
natural community conservation
plan, or other approved local,
regional, or state habitat
conservation plan?
No Impact None No No No Yes Yes
Agenda Item #10.1.

Addendum Evaluation
Biological Resources
Addendum 41
2040 General Plan EIR Biological Resources Findings
The 2040 General Plan EIR determined that impacts to biological resources would be less than significant for effects to listed species or their habitats, loss of significant populations of sensitive species, protected wetlands, wildlife migration or movement corridors, local policies or ordinances protecting biological resources, or conflicts with conservation plans and habitat management plans and habitat groups identified therein (Chapter 3.4 Biological Resources). Individual development projects would be subject to project-specific development and planning review. As such, all projects proposed under General Plan implementation would be required to conform to zoning, design standards, and other regulations concerning the protection of biological resources, including listed species, habitats, and all planning resources designed to protect and conserve these resources.

Furthermore, future development would be required to comply with State and federal law and policies within the Open Space Element of the General Plan that protect biological resources. The General Plan is consistent with the SHMC and Open Space and Conservation Element policies and standards for tree preservations. The General Plan does not include any policies that would interfere with the Pacific Gas & Electric (PG&E) Habitat Conservation Plan for PG&E facilities, rightsof way, buffer lands, owned lands and easements, access routes and mitigation areas.

Addendum Analysis
The Housing Element update is a policy document consistent with the General Plan that identifies sites, shown in Figure 3, that could be developed to meet the City’s 6 th cycle RHNA throughout St.

Helena. Some of these sites could require land use changes that would bring the zoning into consistency with the Land Use Element, change the existing land use, or allow for increased density.

As discussed in Section 5, Addendum Methodology, the City of St. Helena has several options for sites that could undergo land use changes through Program H-A to facilitate development of housing units to meet the RHNA during the 6th cycle (2023-2031).

Most sites identified in the sites inventory are located in previously developed areas with limited potential for disruption to undeveloped habitat areas, including sites that have previously been developed or infill sites in well developed areas. The sites inventory also includes vacant sites, although these sites have been previously disturbed and are in proximity to developed areas.

Consistent with the 2040 General Plan EIR, the project would not adversely affect biological resources, including special-status species, riparian habitats or wetlands, or migratory species and wildlife corridors, to a greater extent than buildout under the General Plan, and impacts would remain less than significant. Build out under the Housing Element update would be subject to all applicable requirements of the SHMC and Open Space and Conservation Element policies as well as the PG&E Habitat Conservation Plan for PG&E facilities, rights-of way, buffer lands, owned lands and easements, access routes and mitigation areas.

The Public Health, Safety, and Noise Element update revised information on public and critical facilities, discussed safety impacts from climate change, and added implementation measures to create evacuation plans and educate residents and address climate vulnerability. Policies contained within the update include vegetation management and maintenance and debris removal in stream channels that are designed to mitigate wildfire, erosion, and flood risk. These policies also stipulate that such activities must use best practices to protect wildlife and habitat. Any potential updates to structures or development of climate resilient infrastructure designed to mitigate potential risk of climate safety hazards would be subject to project-specific development and planning review, including zoning, design standards, and other regulations concerning the protection of biological Agenda Item #10.1.

City of St. Helena
2023 General Plan Update
42 resources, including listed species, habitats, and all planning resources designed to protect and conserve these resources. Therefore, the Public Health, Safety, and Noise Element update would not result in significant adverse impacts related to biological resources.

Conclusion
The Housing Element update as well as the Public Health, Safety and Noise Element Updates would not result in new or more severe impacts (direct or indirect) than were analyzed in the 2040 General Plan EIR.

Agenda Item #10.1.

Addendum Evaluation
Cultural, Historic, and Tribal Cultural Resources
Addendum 43

6.5 Cultural, Historic, and Tribal Cultural Resources
EIR Evaluation Criteria
EIR
Significance
Conclusion
EIR
Mitigation
Measures
CEQA Guidelines Section 15162
Is a Subsequent EIR Needed? Are Only Minor
Technical
Changes or
Additions
Necessary or Did
None of the
Conditions
Described in
§15162 Occur?
(§15164(a))
Project is
within the
Scope of
General Plan
EIR?
Do the Proposed
Changes Involve
a New or
Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Are There New
Circumstances
Involving a New
or Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Is There New
Information of
Substantial
Importance
Requiring New
Analysis or
Verification?
Would adoption of the Housing Element update:
a. Cause a substantial adverse change in
the significance of a historical resource
as defined in CEQA § 15064.5?
Less than
significant
None No No No Yes Yes
b. Cause a substantial adverse change in
the significance of an archaeological
resource pursuant to CEQA § 15064.5?
Less than
significant
None No No No Yes Yes
c. Directly or indirectly destroy a unique
paleontological resource or site or
unique geologic feature?
Less than
significant
None No No No Yes Yes
d. Disturb any human remains, including
those interred outside of formal
cemeteries?
Less than
significant
None No No No Yes Yes
Agenda Item #10.1.

City of St. Helena
2023 General Plan Update
44 EIR Evaluation Criteria
EIR
Significance
Conclusion
EIR
Mitigation
Measures
CEQA Guidelines Section 15162
Is a Subsequent EIR Needed? Are Only Minor
Technical
Changes or
Additions
Necessary or Did
None of the
Conditions
Described in
§15162 Occur?
(§15164(a))
Project is
within the
Scope of
General Plan
EIR?
Do the Proposed
Changes Involve
a New or
Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Are There New
Circumstances
Involving a New
or Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Is There New
Information of
Substantial
Importance
Requiring New
Analysis or
Verification?
e. Cause a substantial adverse change in
the significance of a tribal cultural
resource, defined in Public Resources
Code Section 21074 as either a site,
feature, place, cultural landscape,
sacred place, or object with cultural
value to a California Native Tribe and
that is:
▪ Listed or eligible for listing in the
California Register of Historical
Resources or in a local register of
historical resources as defined in
Public Resources Code Section
5020.1(k), or
▪ A resource determined by the lead
agency, in its discretion and
supported by substantial evidence,
to be significant pursuant to criteria
set forth in subdivision (c) of Public
Resources Code Section 5024.1. In
applying the criteria set forth in
subdivision (c) of Public Resource
Code Section 5024.1, the lead
agency shall consider the
significance of the resource to a
California Native American tribe.

Less than
significant
None No No No Yes Yes
Agenda Item #10.1.

Addendum Evaluation
Cultural, Historic, and Tribal Cultural Resources
Addendum 45
2040 General Plan EIR Cultural Resources Findings
As discussed under Impact CUL-1 in Section 3.4, Cultural, Historic, and Tribal Cultural Resources, of the 2040 General Plan EIR, impacts related to historic, cultural, and tribal cultural resources would be less than significant. Future development under the General Plan could result in demolition, deconstruction, relocation, or alteration of historic resources. The SHMC establishes procedures for archaeological surveys and mitigation measures for archaeological and paleontological resources and protections for significant architectural or historical buildings. Policies within the Historic Resources Element would further mitigate potential impacts on historic districts and buildings.

Implementation of the 2040 General Plan would be less than significant with implementation of existing regulations and the proposed policies and implementation actions within the Historic Resources Element.

Addendum Analysis
The Housing Element update is a policy document consistent with the General Plan. The Housing Element update identifies sites, shown in Figure 3, that could be developed to meet the City’s 6 th
cycle RHNA throughout St. Helena. Some of these sites could require land use changes that would bring the zoning into consistency with the Land Use Element, change the existing land use, or allow for increased density. As discussed in Section 5, Addendum Methodology, the City of St. Helena has several options for sites that could undergo land use changes through Program 1.1 to facilitate development of housing units to meet the RHNA during the 6th cycle (2023-2031).

Consistent with buildout under the 2040 General Plan, implementation of the proposed Housing Element update, including associated construction activities would result in less than significant impacts to historic, cultural, and tribal cultural resources within the Plan Area. Buildout under the Housing Element update would adhere to State and local development guidelines that govern historical, cultural, and tribal cultural resources, including AB 52 and SB 18 and policies in the City’s Historic Resources Element. Native American tribes requesting consultation will be notified of projects when project-specific environmental review begins, according to AB 52 and SB 18 (if applicable), and tribal representative requests will be included into project approval, including notification, monitoring, and consultations in accord with federal and state requirements. Any evidence of cultural resources that might be unearthed in the process of construction would be required to comply with SHMC which establishes mitigation measures for archaeological resources.

Compliance with existing regulations would ensure impacts related to archaeological resources and human remains would remain less than significant, the same as impacts identified in the 2040 General Plan EIR.

The Public Health, Safety, and Noise Element update revised information on public and critical facilities, discussed safety impacts from climate change, and added implementation measures to create evacuation plans and educate residents and address climate vulnerability. Any potential updates to structures or development of climate resilient infrastructure designed to mitigate potential risk of climate safety hazards would be subject to project-specific development and planning review and comply with relevant policies and standards within the General Plan Historic Resources Element and the SHMC previously adopted to protect archaeological and paleontological resources and significant architectural or historical buildings. Therefore, the Public Health, Safety, and Noise Element update would not result in significant adverse impacts related to cultural resources.

Agenda Item #10.1.

City of St. Helena
2023 General Plan Update
46 Conclusion
The 2040 Housing Element update as well as the Public Health, Safety and Noise Element Updates would not result in new or more severe impacts (direct or indirect) than were analyzed in the 2040 General Plan EIR.

Agenda Item #10.1.

Addendum Evaluation
Energy, Greenhouse Gases, and Climate Change
Addendum 47

6.6 Energy, Greenhouse Gases, and Climate Change
EIR Evaluation Criteria
EIR
Significance
Conclusion
EIR
Mitigation
Measures
CEQA Guidelines Section 15162
Is a Subsequent EIR Needed?
Are Only Minor
Technical
Changes or
Additions
Necessary or Did
None of the
Conditions
Described in
§15162 Occur?
(§15164(a))
Project is
within the
Scope of
General Plan
EIR?
Do the Proposed
Changes Involve
a New or
Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Are There New
Circumstances
Involving a New
or Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Is There New
Information of
Substantial
Importance
Requiring New
Analysis or
Verification?
Would adoption of the General Plan update:
a. Generate greenhouse gas
emissions, either directly or
indirectly, that may have a
significant impact on the
environment?
Significant and
Unavoidable
GHG-1 No No No Yes Yes
b. Conflict with an applicable plan,
policy or regulation adopted for
the purpose of reducing the
emissions of greenhouse gases?
Significant and
Unavoidable
GHG-1 No No No Yes Yes
c. Cause wasteful, inefficient, and
unnecessary consumption of
energy during project
construction, operation, and/or
maintenance?
Less than
Significant
None No No No Yes Yes
d. Conflict with the CBC Energy
Efficiency Standards, the CARB
passenger vehicle GHG emission
reduction targets for 2020 and
2035, or any other applicable
energy conservation regulations?
Less than
Significant
None No No No Yes Yes
Agenda Item #10.1.

City of St. Helena
2023 General Plan Update
48 2040 General Plan EIR Energy, Greenhous Gas Emissions, and Climate Change Findings
The 2040 General Plan EIR determined impacts related to greenhouse gas (GHG) emissions would be significant and unavoidable, Section 3.6, Energy, Greenhouse Gas Emissions, and Climate Change.

Buildout under the 2040 General Plan would result in a substantial increase in GHG emissions from baseline conditions by 2040 and would not make substantial progress towards meeting the State’s 2050 goal of 80 percent reduction from 1990 levels pursuant to Executive Order S-03-05. The primary source of GHG emissions under the General Plan would be from the transportation sector and the second largest source of emissions would be from the commercial/industrial sector. To reduce impacts related to greenhouse gas emissions, the 2040 General Plan EIR required Mitigation Measure GHG-1. However, even with implementation of the mitigation measure and policies within the 2040 General Plan aimed at reducing GHG emissions, the 2040 General Plan EIR concluded that impacts would remain significant and unavoidable.

Mitigation Measure GHG-1: The City of St. Helena shall adopt and begin to implement a Climate Action Plan within a goal of 18 months, but no later than 36 months, of adopting the Proposed Plan update to address the GHG reduction goals of Executive Order B‐30‐15 and Executive Order S‐ 03‐05 for GHG sectors that the City has direct or indirect jurisdictional control over. The Climate Action Plan shall include a community inventory of GHG emission sources, and quantifiable GHG emissions reduction targets for 2030 and 2050, and an interim target for the General Plan buildout year 2040, that are consistent with the statewide GHG reduction targets.

The City shall monitor progress toward its GHG emissions reduction goals and prepare reports every five years detailing that progress.

In addition, the 2040 General Plan EIR concluded that impacts related to consistency with applicable plans, policies, and regulation regarding GHG reductions would be significant and unavoidable.

Under buildout of the 2040 General Plan, per capita emissions would exceed the significance threshold of 2.3 metric tons of carbon dioxide equivalent per service population in 2040, which would conflict with CARB’s 2017 Scoping Plan, AB32, and Executive Order S-03-05, and BAAQMD’s CEQA Guidelines. Mitigation Measure GHG-1 would help reduce GHG emissions, however further action at the State and federal level would be necessary to achieve State reduction targets. At the time, there were no post‐2030 State or federal measures that would assist the city in achieving the efficiency target in 2040, even with implementation of Mitigation Measure GHG‐1. Therefore, the General Plan could potentially conflict with applicable plans, policies, or regulations adopted for the purpose of reducing the emissions of GHGs, meaning impacts would remain significant and unavoidable.

The 2040 General Plan EIR concluded that impacts related to energy resources would be less than significant for energy consumption and consistency with state or local plans for renewable energy or energy efficiency. The General Plan EIR determined that implementation of the General Plan would decrease net energy consumption and per service population energy consumption due to delivery of energy through Marin Clean Energy which has higher goals for renewable energy than PG&E and through an increase in fuel efficiency for vehicles. Furthermore, policies within the General Plan aim to reduce energy consumption of natural gas, electricity, and gasoline and diesel fuels by fostering an increase in energy efficiency and renewable energy, encouraging bicycle and pedestrian transit, and decreasing use of cars. All future development under the Proposed Plan would be required to comply with the latest California Building Code (CBC) requirements, including CBC Energy Efficiency Agenda Item #10.1.

Addendum Evaluation
Energy, Greenhouse Gases, and Climate Change
Addendum 49
Standards, as well as all federal, State, and local rules and regulations pertaining to energy consumption and conservation.

By decreasing demand for energy- and fuel-related energy resources both overall and on a per service population basis and complying with applicable federal, State, and local regulations, impacts to energy consumption and consistency with state or local plans for renewable energy or energy efficiency would be less than significant.

Addendum Analysis
The Housing Element update is a policy document consistent with the General Plan. The Housing Element update identifies sites evaluated previously for potential environmental impacts in the General Plan EIR. The Housing Element update identifies sites, shown in Figure 3, that could be developed to meet the City’s 6
th cycle RHNA throughout St. Helena. Some of these sites could require land use changes that would bring the zoning into consistency with the Land Use Element, change the existing land use, or allow for increased density. As discussed in Section 5, Addendum Methodology, the City of St. Helena has several options for sites that could undergo land use changes through Program H-A to facilitate development of housing units to meet the RHNA during the 6th cycle (2023-2031).

Implementation of the Housing Element update could increase the demand for electricity and natural gas. However, new development would be required to comply with statewide mandatory energy requirements outlined in CALGreen, which could decrease energy consumption in new and retrofitted structures. In addition, consistent with the General Plan, the Housing Element supports higher density that would reduce vehicle miles traveled (VMT) and fuel consumption compared to existing lower-density development. Therefore, energy consumption would not be wasteful, inefficient, or unnecessary, and the Housing Element update would not conflict with nor obstruct a State or local plan for increasing renewable energy or energy efficiency. Impacts would be less than significant, the same as those identified in the 2040 General Plan EIR.

Consistent with buildout under the 2040 General Plan, implementation of the proposed Housing Element update could increase the frequency and/or severity of GHG emissions or otherwise conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing greenhouse gases. Annual development under the Housing Element update could exceed the GHG significance threshold applied in the 2040 General Plan EIR and conflict with the 2017 Climate Change Scoping Plan. Potential impacts caused by development allowed under the Housing Element would be reduced through implementation of Mitigation Measure GHG-1, identified in the General Plan EIR. However, impacts would remain significant and unavoidable even with implementation of mitigation, the same as impacts identified in the General Plan EIR.

The Public Health, Safety, and Noise Element update revised information on public and critical facilities, discussed safety impacts from climate change, and added implementation measures to create evacuation plans and educate residents and address climate vulnerability. The update would not increase built out or population increases in the city and would not directly result in development or activities that would increase demand for energy or increase VMT. Policies within the update encourage use of renewable back-up power sources and storage that would support the City’s a more reliable and less wasteful source of energy for use during emergencies. In addition, any potential updates to structures or development of climate resilient infrastructure designed to mitigate potential risk from climate safety hazards would be subject to project-specific development and planning review and comply with the CBC Energy Efficiency Standards, policies within the General Plan aimed at reducing energy consumption of natural gas, electricity, and gasoline and Agenda Item #10.1.

City of St. Helena
2023 General Plan Update
50 diesel fuels, and all federal, State, and local rules and regulations pertaining to energy consumption and conservation. Therefore, the Public Health, Safety, and Noise Element update would have less than significant impacts related to GHG emissions, energy or climate change.

Conclusion
Based on the above, the Housing Element update as well as the Public Health, Safety and Noise Element Updates would not result in new or more severe impacts (direct or indirect) than were analyzed in the 2040 General Plan EIR.

Agenda Item #10.1.

Addendum Evaluation
Geology, Soils, and Seismicity
Addendum 51

6.7 Geology, Soils, and Seismicity
EIR Evaluation Criteria
EIR
Significance
Conclusion
EIR
Mitigation
Measures
CEQA Guidelines Section 15162
Is a Subsequent EIR Needed?
Are Only Minor
Technical
Changes or
Additions
Necessary or Did
None of the
Conditions
Described in
§15162 Occur?
(§15164(a))
Project is
within the
Scope of
General Plan
EIR?
Do the Proposed
Changes Involve
a New or
Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Are There New
Circumstances
Involving a New
or Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Is There New
Information of
Substantial
Importance
Requiring New
Analysis or
Verification?
Would adoption of the Housing Element update:
a. Expose people or structures to
potential substantial adverse
effects, including the risk of loss,
injury, or death involving:

No No No Yes Yes

1. Rupture of a known
earthquake fault, as
delineated on the most recent
Alquist-Priolo Earthquake
Fault Zoning Map or based on
other substantial evidence of
a known fault?
Less than
significant
None No No No Yes Yes

2. Strong seismic ground
shaking?
Less than
significant
None No No No Yes Yes

3. Seismic-related ground failure,
including liquefaction?
Less than
significant
None No No No Yes Yes

4. Landslides? Less than
significant
None No No No Yes Yes
Agenda Item #10.1.

City of St. Helena
2023 General Plan Update
52 EIR Evaluation Criteria
EIR
Significance
Conclusion
EIR
Mitigation
Measures
CEQA Guidelines Section 15162
Is a Subsequent EIR Needed?
Are Only Minor
Technical
Changes or
Additions
Necessary or Did
None of the
Conditions
Described in
§15162 Occur?
(§15164(a))
Project is
within the
Scope of
General Plan
EIR?
Do the Proposed
Changes Involve
a New or
Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Are There New
Circumstances
Involving a New
or Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Is There New
Information of
Substantial
Importance
Requiring New
Analysis or
Verification?
b. Result in substantial soil erosion
or topsoil loss?
Less than
significant
None No No No Yes Yes
c. Be located on a geologic unit or
soil that is unstable, or that would
become unstable as a result of
the project, and potentially result
in on- or off-site landslide, lateral
spreading, subsidence,
liquefaction or collapse?
Less than
significant
None No No No Yes Yes
d. Be located on expansive soil, as
defined in Section 1803.5.3,
Expansive Soil, of the California
Building Standards Code (2013),
creating substantial risks to life or
property?
Less than
significant
None No No No Yes Yes
e. Have soils incapable of
adequately supporting the use of
septic tanks or alternative
wastewater disposal systems
where sewers are not available
for the disposal of waste water?
Less than
significant
None No No No Yes Yes
Agenda Item #10.1.

Addendum Evaluation
Geology, Soils, and Seismicity
Addendum 53
2040 General Plan EIR Geology, Soils, and Seismicity Findings The 2040 General Plan EIR determined that impacts to geology, soils, and seismicity would be less than significant for adverse effects related to rupture of a known fault, strong ground shaking, seismic-related ground failure, or landslides; soil erosion; landslide, lateral spreading, subsidence, liquefaction, or collapse; locating development on expansive soils; and installing septic tanks and alternative waste water disposal systems in expansive soils, Section 3.7, Soils, Geology, and Seismicity. It further stated that individual development projects would be subject to projectspecific development and planning review, including adherence to standards for geology, soils, and seismicity impacts. Implementation of the 2040 General Plan would be less than significant in regard to impacts to geology, soils, and seismicity.

Addendum Analysis
The Housing Element update is a policy document consistent with the General Plan. The Housing Element update identifies sites evaluated previously for potential environmental impacts in the General Plan EIR. The Housing Element update identifies sites, shown in Figure 3, that could be developed to meet the City’s 6
th cycle RHNA throughout St. Helena. Some of these sites could require land use changes that would bring the zoning into consistency with the Land Use Element, change the existing land use, or allow for increased density. As discussed in Section 5, Addendum Methodology, the City of St. Helena has several options for sites that could undergo land use changes through Program H-A to facilitate development of housing units to meet the RHNA during the 6th cycle (2023-2031). Consistent with buildout under the 2040 General Plan, buildout under the Housing Element update could result in impacts related to geologic hazards, including seismic activity, faults, liquefaction, landslides, erosion, and unstable soils. However, new development would be required to comply with local and state codes and requirements related to geologic hazards, including the CBC, the National Pollutant Discharge Elimination System (NPDES) program, and applicable General Plan policies. Compliance with these requirements would ensure impacts would remain less than significant. In addition, consistent with buildout allowed under the General Plan, new development under the Housing Element update would connect to the existing sewer system and not include septic tanks or other alternative wastewater disposal systems. Therefore, impacts related to geology and soils would be less than significant, the same as those identified in the 2040 General Plan EIR.

The Public Health, Safety, and Noise Element update revised information on public and critical facilities, discussed safety impacts from climate change, and added implementation measures to create evacuation plans and educate residents and address climate vulnerability. The update contains policies and implementation actions that would mitigate potential impacts related to geology and soils by requiring soils and geology reports for new development, prohibiting development on instable slopes, and limiting development in hillside areas with potential for slope failure. None of the implementation items would directly result new structures that would be exposed to seismic activity, faults, liquefaction, landslides, erosion, or unstable soils or involve septic tanks. Any potential updates to structures or development of climate resilient infrastructure designed to mitigate potential risk of climate safety hazards would be subject to project-specific development and planning review and any impacts would be mitigated through compliance with all applicable General Plan policies, the CBC, the NPDES program, and all other applicable local and state codes and requirements. Therefore, the Public Health, Safety, and Noise Element update would not result in significant adverse impacts.

Agenda Item #10.1.

City of St. Helena
2023 General Plan Update
54 Conclusion
The Housing Element update as well as the Public Health, Safety and Noise Element Updates would not result in new or more severe impacts (direct or indirect) than were analyzed in the 2040 General Plan EIR.

Agenda Item #10.1.

Addendum Evaluation
Hazards and Hazardous Materials
Addendum 55

6.8 Hazards and Hazardous Materials
EIR Evaluation Criteria
EIR
Significance
Conclusion
EIR
Mitigation
Measures
CEQA Guidelines Section 15162
Is a Subsequent EIR Needed? Are Only Minor
Technical
Changes or
Additions
Necessary or Did
None of the
Conditions
Described in
§15162 Occur?
(§15164(a))
Project is
within the
Scope of
General Plan
EIR?
Do the Proposed
Changes Involve
a New or
Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Are There New
Circumstances
Involving a New
or Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Is There New
Information of
Substantial
Importance
Requiring New
Analysis or
Verification?
Would adoption of the General Plan update:
a. Create a significant hazard to the
public or the environment through
the routine transport, use, or
disposal of hazardous materials?
Less than
significant
None No No No Yes Yes
b. Create a significant hazard to the
public or the environment through
reasonably foreseeable upset and
accident conditions involving the
release of hazardous materials into
the environment?
Less than
significant
None No No No Yes Yes
c. Emit hazardous emissions or
handle hazardous or acutely
hazardous materials, substances,
or waste within one-quarter mile
of an existing or proposed school?
Less than
significant
None No No No Yes Yes
d. Be located on a site that is included
on a list of hazardous material sites
compiled pursuant to Government
Code Section 65962.5 and, as a
result, would it create a significant
hazard to the public or the
environment?
Less than
significant
None No No No Yes Yes
Agenda Item #10.1.

City of St. Helena
2023 General Plan Update
56 EIR Evaluation Criteria
EIR
Significance
Conclusion
EIR
Mitigation
Measures
CEQA Guidelines Section 15162
Is a Subsequent EIR Needed? Are Only Minor
Technical
Changes or
Additions
Necessary or Did
None of the
Conditions
Described in
§15162 Occur?
(§15164(a))
Project is
within the
Scope of
General Plan
EIR?
Do the Proposed
Changes Involve
a New or
Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Are There New
Circumstances
Involving a New
or Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Is There New
Information of
Substantial
Importance
Requiring New
Analysis or
Verification?
e. Impair implementation of or
physically interfere with an
adopted emergency response
plan or emergency evacuation
plan?
Less than
significant
None No No No Yes Yes
f. Expose people or structures to a
significant risk of loss, injury or
death involving wildland fires,
including where wildlands are
adjacent to urbanized areas or
where residences are intermixed
with wildlands?
Less than
significant
None No No No Yes Yes
g. For a project located within an
airport land use plan or, where
such a plan has not been adopted,
within two miles of a public
airport, public use airport, or
private airstrip, would the project
result in a safety hazard for people
residing or working in the Planning
Area?
Less than
significant
None No No No Yes Yes
Agenda Item #10.1.

Addendum Evaluation
Hazards and Hazardous Materials
Addendum 57
2040 General Plan EIR Hazards and Hazardous
The 2040 General Plan EIR determined that impacts for hazards and hazardous materials would be less than significant for transport, use, and disposal of hazardous materials; upset and accident conditions involving the release of hazardous materials into the environment; emissions or handling of hazardous materials within one-quarter mile of a school; location of development projects on hazardous materials sites such that the new use would create a hazard to the public or the environment; interference with an adopted emergency response or evacuation plan; and risk from wildland fire in lands adjacent to urbanized or residential areas, Section 3.8, Hazards and Hazardous Materials. It further stated that the Plan Area. The 2040 General Plan EIR described that individual development projects would be subject to project-specific development and planning review, including adherence to state, regional, and local regulations and standards related to hazards. There are no airport land use compatibility plans within the planning area or public airports, public use airports, or private airstrips within two miles of affecting any portion of the General Plan planning area.

Addendum Analysis
The Housing Element update is a policy document consistent with the General Plan. The Housing Element update identifies sites evaluated previously for potential environmental impacts in the General Plan EIR. The Housing Element update identifies sites, shown in Figure 3, that could be developed to meet the City’s 6
th cycle RHNA throughout St. Helena. Some of these sites could require land use changes that would bring the zoning into consistency with the Land Use Element, change the existing land use, or allow for increased density. As discussed in Section 5, Addendum Methodology, the City of St. Helena has several options for sites that could undergo land use changes through Program H-A to facilitate development of housing units to meet the RHNA during the 6th cycle (2023-2031). Consistent with buildout under the 2040 General Plan, construction and operation of the development allowed under the Housing Element update would be subject to existing regulations related to use, storage, handling, and disposal of hazardous materials.

Applicable regulations would include those set forth by the California Department of Toxic Substances Control, State Water Resources Control Board, Regional Water Quality Control Board, California Highway Patrol and California Department of Transportation, and BAAQMD. Compliance with these existing regulations would ensure impacts related hazardous materials would remain less than significant, consistent with the 2040 General Plan EIR. The proposed Housing Element update would not include circulation changes and is not located within the planning boundaries of any airports. Therefore, impacts would be less than significant, the same as those identified in the 2040 General Plan EIR.

The Public Health, Safety, and Noise Element update revised information on public and critical facilities, discussed safety impacts from climate change, and added implementation measures to create evacuation plans and educate residents and address climate vulnerability. The update contains policies and implementation actions to enhance emergency response and evacuation procedures through testing of response exercises and maintaining the City’s emergency response plan. In addition, policies and implementation actions address risk associated with the use, transport, and disposal of hazardous materials and wildfire prevention and response. The update is would not directly result in development that would have the potential to impact hazards or hazardous materials. Any potential updates to structures or development of climate resilient infrastructure designed to mitigate potential risk of climate safety hazards would be subject to project-specific development and planning review and would be required to comply with relevant Agenda Item #10.1.

City of St. Helena
2023 General Plan Update
58 policies within the General Plan California, as well as applicable standards from the Department of Toxic Substances Control, State Water Resources Control Board, Regional Water Quality Control Board, California Highway Patrol and California Department of Transportation, and BAAQMD.

Therefore, the Public Health, Safety, and Noise Element update would not result in significant adverse impacts.

Conclusion
The Housing Element update, as well as the Public Health, Safety, and Noise Element updates would not result in new or more severe impacts (direct or indirect) than were analyzed in the 2040 General Plan EIR.

Agenda Item #10.1.

Addendum Evaluation
Hydrology and Water Quality
Addendum 59

6.9 Hydrology and Water Quality
EIR Evaluation Criteria
EIR
Significance
Conclusion
EIR
Mitigation
Measures
CEQA Guidelines Section 15162
Is a Subsequent EIR Needed? Are Only Minor
Technical
Changes or
Additions
Necessary or Did
None of the
Conditions
Described in
§15162 Occur?
(§15164(a))
Project is
within the
Scope of
General Plan
EIR?
Do the Proposed
Changes Involve
a New or
Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Are There New
Circumstances
Involving a New
or Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Is There New
Information of
Substantial
Importance
Requiring New
Analysis or
Verification?
Would adoption of the General Plan update:
a. Violate any water quality
standards or waste discharge
requirements?
Less than
significant
None No No No Yes Yes
b. Substantially deplete groundwater
supplies or interfere substantially
with groundwater recharge such
that there would be a net deficit in
aquifer volume or a lowering of the
local groundwater table level (e.g.,
the production rate of pre-existing
nearby wells would drop to a level
which would not support existing
land uses or planned uses for
which permits have been granted)?
Less than
significant
None No No No Yes Yes
c. Substantially alter the existing
drainage pattern of the site or
area, including through the
alteration of the course of a stream
or river, in a manner which would
result in substantial erosion or
siltation on- or off-site?
Less than
Significant
None No No No Yes Yes
Agenda Item #10.1.

City of St. Helena
2023 General Plan Update
60 EIR Evaluation Criteria
EIR
Significance
Conclusion
EIR
Mitigation
Measures
CEQA Guidelines Section 15162
Is a Subsequent EIR Needed? Are Only Minor
Technical
Changes or
Additions
Necessary or Did
None of the
Conditions
Described in
§15162 Occur?
(§15164(a))
Project is
within the
Scope of
General Plan
EIR?
Do the Proposed
Changes Involve
a New or
Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Are There New
Circumstances
Involving a New
or Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Is There New
Information of
Substantial
Importance
Requiring New
Analysis or
Verification?
d. Create or contribute runoff water
which would exceed the capacity
of existing or planned stormwater
drainage systems or provide
substantial additional sources of
polluted runoff?
Less than
significant
None No No No Yes Yes
e. Otherwise substantially degrade
water quality?
Less than
significant
None No No No Yes Yes
f. Place housing within a 100-year
flood hazard area as mapped on a
federal Flood Hazard Boundary or
Flood Insurance Rate Map or
other flood hazard delineation
map?
Less than
significant
with
Mitigation
HYDRO-1 No No No Yes Yes
g. Place within a 100-year flood
hazard area structures which
would impede or redirect flood
flows?
Less than
significant
None No No No Yes Yes
h. Expose people or structures to a
significant risk of loss, injury or
death involving flooding, including
flooding as a result of the failure of
a levee or dam, or inundation by
seiche, tsunami, or mudflow?
Less than
significant
None No No No Yes Yes
Agenda Item #10.1.

Addendum Evaluation
Hydrology and Water Quality
Addendum 61
EIR Evaluation Criteria
EIR
Significance
Conclusion
EIR
Mitigation
Measures
CEQA Guidelines Section 15162
Is a Subsequent EIR Needed? Are Only Minor
Technical
Changes or
Additions
Necessary or Did
None of the
Conditions
Described in
§15162 Occur?
(§15164(a))
Project is
within the
Scope of
General Plan
EIR?
Do the Proposed
Changes Involve
a New or
Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Are There New
Circumstances
Involving a New
or Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Is There New
Information of
Substantial
Importance
Requiring New
Analysis or
Verification?
i. Create or contribute runoff water
which would exceed the capacity
of existing or planned stormwater
drainage systems or provide
substantial additional sources of
polluted runoff?
Less than
significant
None No No No Yes Yes
Agenda Item #10.1.

City of St. Helena
2023 General Plan Update
62 2040 General Plan EIR Hydrology and Water Quality Findings The 2040 General Plan EIR determined that impacts to hydrology and water quality would be less than significant for water quality standards and waste discharge requirements, depletion of ground water, drainage, runoff, erosion, and siltation. It further stated that new development under the General Plan would primarily result in redevelopment of previously developed sites with residential, commercial, and public uses, which would have a limited effect on local drainage or runoff characteristics. The 2040 General Plan EIR also concluded that on-going compliance with the NPDES requirements, including required implementation of BMPs to treat storm water runoff and protect water quality, the Bay Area Stormwater Management Agencies Association’s Manual design guidance for stormwater treatment, Title 16 of the SHMC, and General Plan policies would reduce potential impacts related to water quality, runoff, and flooding. Buildout of the General Plan would generate a small increase in impervious surfaces, although the planning area is already largely developed. However, it would not be anticipated that new development would contribute to a significant impact on water quality, groundwater recharge, or runoff.

The 2040 General Plan EIR determined that impacts related to placement of housing within a 100- year flood hazard area as mapped on a federal Flood Hazard Boundary or Flood Insurance Rate Map or other flood hazard delineation map would be less than significant with mitigation.

Implementation of the General Plan could result in development on sites partially or fully within the 100-year flood zone or construction of new housing within flood hazard zones. Policies within the General Plan and compliance with the SHMC regulate development in flood hazard areas, consistent with standards from the Federal Emergency Management Agency. To further reduce impacts related to development within flood zones, the 2040 General Plan EIR required Mitigation Measure HYDRO-1, which would reduce impacts to a less than significant level.

Mitigation Measure HYDRO-1: Any proposed development or redevelopment on land designated as regulatory floodway on current Federal Emergency Management Agency maps shall, prior to issuance of a construction permit, obtain and submit to the City a Letter of Map Revision from the Federal Emergency Management Agency, demonstrating that a hydrologic and hydraulic analysis showed that grading modifications were performed such that the proposed development would no longer be within the floodway. These modifications shall be completed without raising the base flood level or impacting other properties.

Addendum Analysis
The Housing Element update is a policy document consistent with the General Plan. The Housing Element update identifies sites evaluated previously for potential environmental impacts in the General Plan EIR. The Housing Element update identifies sites, shown in Figure 3, that could be developed to meet the City’s 6
th cycle RHNA throughout St. Helena. Some of these sites could require land use changes that would bring the zoning into consistency with the Land Use Element, change the existing land use, or allow for increased density. As discussed in Section 5, Addendum Methodology, the City of St. Helena has several options for sites that could undergo land use changes through Program H-A to facilitate development of housing units to meet the RHNA during the 6th cycle (2023-2031). Development allowed under the Housing Element update would be subject to existing regulations, including NPDES requirements, required BMPs, San Francisco Bay Area Stormwater Management Agencies Association ’s Manual design guidance for stormwater treatment, Title 16 of the SHMC, and General Plan policies related to water quality, runoff, and erosion, siltation, and flooding control. Compliance with these existing regulations would ensure Agenda Item #10.1.

Addendum Evaluation
Hydrology and Water Quality
Addendum 63
impacts related to water quality, drainage, erosion, siltation, runoff, and flooding would remain less than significant, the same as impacts identified in the 2040 General Plan EIR.

Consistent with buildout under the General Plan, implementation of the proposed Housing Element update, including associated construction activities could result in impacts to groundwater supply.

Individual projects allowed under the Housing Element update would be subject to Mitigation Measure HYDRO-1 identified in the General Plan EIR and project-level environmental review, which would identify potential impacts and reduce impacts to a less than significant level, the same as under the General Plan.

The Public Health, Safety, and Noise Element update revised information on public and critical facilities, discussed safety impacts from climate change, and added implementation measures to create evacuation plans and educate residents and address climate vulnerability. The update contains policies and implementation actions that reduce risk of floods and impacts related to flood hazards. None of the policies or implementation actions would impact hydrology or water quality or directly result in development that would alter existing drainage patterns, contribute to runoff, degrade water quality, impact groundwater supply and recharge, or expose people or structures to flood hazards. Any potential updates to structures or development of climate resilient infrastructure designed to mitigate potential risk of climate safety hazards would be subject to project-specific development and planning review and would be required to comply with NPDES requirements, including required implementation of BMPs to treat storm water runoff and protect water quality, the Bay Area Stormwater Management Agencies Association’s Manual design guidance for stormwater treatment, Title 16 of the SHMC, and applicable General Plan policies. Therefore, the Public Health, Safety, and Noise Element update would not have an adverse impact and hydrology and water quality.

Conclusion
The Housing Element update, as well as the Public Health, Safety, and Noise Element updates would not result in new or more severe impacts (direct or indirect) than were analyzed in the 2040 General Plan EIR.

Agenda Item #10.1.

City of St. Helena
2023 General Plan Update
64 This page intentionally left blank.

Agenda Item #10.1.

Addendum Evaluation
Land Use, Population, and Housing
Addendum 65

6.10 Land Use, Population, and Housing
EIR Evaluation Criteria
EIR
Significance
Conclusion
EIR
Mitigation
Measures
CEQA Guidelines Section 15162
Is a Subsequent EIR Needed?
Are Only Minor
Technical
Changes or
Additions
Necessary or Did
None of the
Conditions
Described in
§15162 Occur?
(§15164(a))
Project is
within the
Scope of
General Plan
EIR?
Do the Proposed
Changes Involve
a New or
Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Are There New
Circumstances
Involving a New
or Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Is There New
Information of
Substantial
Importance
Requiring New
Analysis or
Verification?
Would adoption of the General Plan update:
a. Physically divide an established
community?
No Impact None No No No Yes Yes
b. Conflict with any applicable land
use plan, policy, or regulation of an
agency with jurisdiction over the
project (including, but not limited
to the general plan, specific plan,
local coastal program, or zoning
ordinance) adopted for the
purpose of avoiding or mitigating
an environmental effect?
No Impact None No No No Yes Yes
c. Conflict with any applicable habitat
conservation plan or natural
community conservation plan?
No Impact None No No No Yes Yes
d. Induce substantial population
growth in an area, either directly
(for example, by proposing new
homes and businesses) or
indirectly (for example, through
extension of roads or other
infrastructure)?
Less than
significant
None No No No Yes Yes
Agenda Item #10.1.

City of St. Helena
2023 General Plan Update
66 EIR Evaluation Criteria
EIR
Significance
Conclusion
EIR
Mitigation
Measures
CEQA Guidelines Section 15162
Is a Subsequent EIR Needed?
Are Only Minor
Technical
Changes or
Additions
Necessary or Did
None of the
Conditions
Described in
§15162 Occur?
(§15164(a))
Project is
within the
Scope of
General Plan
EIR?
Do the Proposed
Changes Involve
a New or
Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Are There New
Circumstances
Involving a New
or Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Is There New
Information of
Substantial
Importance
Requiring New
Analysis or
Verification?
e. Displace substantial numbers of
existing housing or people,
necessitating the construction of
replacement housing elsewhere?
Less than
significant
None No No No Yes Yes
Agenda Item #10.1.

Addendum Evaluation
Land Use, Population, and Housing
Addendum 67
2040 General Plan EIR Land Use Planning, Housing, and Population Findings The 2040 General Plan EIR determined that impacts to land use and planning would be less than significant as they pertain to dividing established communities, conflicts with applicable land use plans, habitat conservation plan or natural community conservation plan, and displacing substantial numbers of existing housing or people, Section 3.10 Land Use, Population, and Housing. The 2040 General Plan EIR further found that General Plan implementation would not physically divide an established community and would beneficially increase connectivity throughout the city. The 2040 General Plan EIR further stated that individual development projects under the General Plan would be subject to project-specific development and planning review, which would ensure adherence to standards for land use planning, housing, and population.

Addendum Analysis
The Housing Element update identifies sites evaluated previously for potential environmental impacts in the General Plan EIR. The Housing Element update identifies a range of sites, shown in Figure 3, that could be developed to meet the City’s 6
th cycle RHNA throughout St. Helena. Some of
these sites may differ from those identified in the General Plan EIR. Some of these sites could require land use changes that would bring the zoning into consistency with the Land Use Element, change the existing land use, or allow for increased density. As discussed in Section 5, Addendum Methodology, the City of St. Helena has several options for sites that could undergo land use changes through Program H-A to facilitate development of housing units to meet the RHNA during the 6th cycle (2023-2031Consistent with development under the General Plan, the Housing Element update would not involve circulation changes to the Plan Area, and individual development projects would occur within private and City-owned property in already developed areas. In addition, projects under the Housing Element update would be subject to General Plan policies related to increased connectivity for pedestrians, bicycles, and drivers in the City. Therefore, development under the Housing Element update would not physically divide a community, and impacts would remain less than significant. Moreover, consistent with the General Plan, development under the Housing Element update would be subject to existing zoning and development regulations in the SHMC and policies in the General Plan. Compliance with these regulations and policies and required development and planning review would ensure individual projects would not conflict with applicable land use policies, plans, and regulations. Therefore, impacts would be less than significant, the same as those identified in the 2040 General Plan EIR.

The Public Health, Safety, and Noise Element update revised information on public and critical facilities, discussed safety impacts from climate change, and added implementation measures to create evacuation plans and educate residents and address climate vulnerability. None of the policies or implementation actions would result in new structures that would physically divide a community or change existing land uses. Any potential updates to structures or development of climate resilient infrastructure designed to mitigate potential risk of climate safety hazards would not displace people or housing or result in population growth. would not result in significant adverse impacts related to land use, population, and housing.

Conclusion
The Housing Element update, as well as the Public Health, Safety, and Noise Element updates would not result in new or more severe impacts (direct or indirect) than were analyzed in the 2040 General Plan EIR.

Agenda Item #10.1.

City of St. Helena
2023 General Plan Update
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Agenda Item #10.1.

Addendum Evaluation
Noise
Addendum 69

6.11 Noise
EIR Evaluation Criteria
EIR
Significance
Conclusion
EIR
Mitigation
Measures
CEQA Guidelines Section 15162
Is a Subsequent EIR Needed?
Are Only Minor
Technical
Changes or
Additions
Necessary or Did
None of the
Conditions
Described in
§15162 Occur?
(§15164(a))
Project is
within the
Scope of
General Plan
EIR?
Do the Proposed
Changes Involve
a New or
Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Are There New
Circumstances
Involving a New
or Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Is There New
Information of
Substantial
Importance
Requiring New
Analysis or
Verification?
Would adoption of the General Plan update:
a. Expose persons to or generate
noise levels in excess of standards
established in the proposed
General Plan Noise Element, or
applicable standards of other
agencies?
Less than
significant
None No No No Yes Yes
b. Expose persons to or generate
excessive groundborne vibration
or groundborne noise levels?
Less than
significant
with
mitigation
NO-1 No No No Yes Yes
c. Result in a substantial permanent
increase in ambient noise levels
in the vicinity of the Planning
Area above levels existing
without the project?
Significant and
unavoidable
None No No No Yes Yes
d. Result in a substantial temporary
or periodic increase in ambient
noise levels in the project vicinity
above levels existing without the
project
Less than
significant
None No No No Yes Yes
Agenda Item #10.1.

City of St. Helena
2023 General Plan Update
70 EIR Evaluation Criteria
EIR
Significance
Conclusion
EIR
Mitigation
Measures
CEQA Guidelines Section 15162
Is a Subsequent EIR Needed?
Are Only Minor
Technical
Changes or
Additions
Necessary or Did
None of the
Conditions
Described in
§15162 Occur?
(§15164(a))
Project is
within the
Scope of
General Plan
EIR?
Do the Proposed
Changes Involve
a New or
Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Are There New
Circumstances
Involving a New
or Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Is There New
Information of
Substantial
Importance
Requiring New
Analysis or
Verification?
e. For a project located within an
airport land use plan or, where
such a plan has not been
adopted, within two miles of a
public airport or public use
airport, expose people residing or
working in the Planning Area to
excessive noise levels?
No Impact None No No No Yes Yes
f. For a project within the vicinity of
a private airstrip, expose people
residing or working in the
Planning Area to excessive noise
levels?
No Impact None No No No Yes Yes
Agenda Item #10.1.