Agenda, regular meeting — St. Helena City Council, May 9, 2023 (part 5 of 12)

Addendum Evaluation
Noise
Addendum 71
2040 General Plan EIR Noise Findings
As discussed under in Section 3.11, Noise, of the 2040 General Plan EIR, impacts related to construction, traffic, railway, and stationary noise sources would be less than significant. Policies within the Public Health, Safety, and Noise Element address construction operation noise, noise compatibility along the rail line, traffic noise impacts, and stationary noise sources. Impacts from to traffic-related vibration and rail vibration was determined to be less than significant with mitigation.

The 2040 General Plan EIR concluded that impacts related to vibration during construction would be less than significant with mitigation. Impacts related to traffic vibration and rail vibration were less than significant. Construction of new development under the 2040 General Plan could result in use of heavy duty equipment that could produce vibration that may be felt by adjacent uses.

Construction equipment operating within 25 feet of sensitive land uses could generate distinctly perceptible vibration, non-pile driving construction activities occurring within 25 feet of sensitive uses could result in significant vibration impacts. In addition, pile driving occurring within approximately 175 feet or 300 feet of sensitive uses for vibratory/sonic pile drivers and impact pile drivers, respectively, could also result in significant vibration impacts. As the specific future projects to be developed under the General Plan are not known at this time, and as the level of construction activity that would occur at various locations for future projects is also not known, it is possible the future construction activities could result in significant vibration impacts in portions of the Planning Area near historic structures and sensitive receptors such as schools and residences. To reduce construction related vibration impacts, the General Plan EIR required Mitigation Measure NO-1 which would reduce impacts to less than significant.

Mitigation Measure NO-1: Where vibration impacts have the potential to cause structural damage or distinctly perceptible human response (reference Tables 3.11-12 to 3.11-14, or more recent sources), require a vibration study, prepared by a qualified vibration consultant. The study should include a site-specific engineering assessment of potential vibration impacts to structures and sensitive receptors from construction activities and specify a mitigation plan to minimize the impacts using all reasonable and feasible means available. The mitigation plan should include a procedure for establishing threshold and limiting vibration values for potentially affected structures, based on an assessment of each structure’s ability to withstand the loads and displacements due to construction vibrations and a commitment to develop a vibration monitoring plan during the engineering phase and to implement a compliance monitoring program during construction.

The 2040 General Plan EIR reported there would be no noise impacts related to exposure of people residing or working in the Planning Area to excessive noise levels related to use of a public airport or private airstrip since the Planning Area is not in proximity to either a public airport or private airstrip. The nearest public airport to St. Helena is Angwin-Parrett Field located 4 miles northeast of the Planning Area and the nearest private airstrip is the Pope Valley Airport located 7 miles northeast of the Planning Area.

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City of St. Helena
2023 General Plan Update
72 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 General Plan, construction of individual projects under the proposed Housing Element update could increase the frequency and/or severity of noise levels within the city. Individual projects allowed under the Housing Element update would be subject to Mitigation Measure NO-1, which would reduce construction vibration impacts to a less than significant level. Operation of individual projects under the proposed Housing Element update could increase the frequency and/or severity of traffic-related noise levels within the city but they would be less than significant. Individual projects allowed under the Housing Element update would be subject to policies identified in the Public Health, Safety, and Noise Element and standards within the SHMC related to noise. Compliance with these requirements would ensure impacts related to increases in noise levels from construction, traffic, rail, and stationary sources would remain less than significant. Consistent with development allowed under the General Plan, the proposed project would not be located within the vicinity of a private air strip or an airport land use plan and would not expose people residing or working in the area to excessive airport-related noise levels. Therefore, impacts would be less than significant, the same as those identified in the 2040 General Plan EIR.

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.

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Addendum Evaluation
Public Services and Recreation
Addendum 73

6.12 Public Services and Recreation
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. Implementation of the Proposed Plan
would not result in substantial
adverse physical impacts associated
with the provision of new or physically
altered governmental facilities, need
for new or physically altered
governmental facilities, the
construction of which could cause
significant environmental impacts, in
order to maintain acceptable service
ratios, response times or other
performance objectives for fire
protection, police protection, schools,
parks, or other public facilities?
Less than
significant
None No No No Yes Yes
b. Implementation of the Proposed Plan
would not increase the use of existing
neighborhood and regional parks or
other recreational facilities such that
substantial physical deterioration of
the facility would occur or be
accelerated?
Less than
significant
None No No No Yes Yes
Agenda Item #10.1.

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City of St. Helena
2023 General Plan Update
74 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. Implementation of the Proposed Plan
would not include recreational
facilities or require the construction or
expansion of recreational facilities
which might have an adverse physical
effect on the environment?
Less than
significant
None No No No Yes Yes
Agenda Item #10.1.

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Addendum Evaluation
Public Services and Recreation
Addendum 75
2040 General Plan EIR Public Services and Recreation Findings As discussed in Section 3.12, Public Services, of the 2040 General Plan EIR, buildout under the 2040 General Plan would not result in significant impacts to local fire and police agencies or other public facilities within the City of St. Helena. Projected new development under the 2040 General Plan could result in population and employment increase but would not result in substantial increase demand for fire services, police services, schools, parks, recreation, and library facilities. The increase in service population would not require construction of new or expansion of existing facilities for fire service, police service, schools, parks or other public facilities. Policies within the General Plan monitor the need for additional public facilities, pursue sites for future facilities, require Fire Department and Police department review of individual development projects, and implement public safety impact fees. In addition, potential new or expanded public service facilities would be subject to additional CEQA review. Therefore, impacts were found to 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). Consistent with buildout under the General Plan and analyzed in the 2040 General Plan EIR, buildout under the Housing Element update could increase the demand for fire, police, schools, parks, and library services within the city but is not anticipated to generate a need for the construction of new facilities or expansion of existing ones. Most sites are urban infill sites where development already exists and public services are already being provided. New development would be required to pay safety impact fees and subject to review by the Fire Department and Police Department. Additionally, General Plan policies governing public services would remain in effect for the Housing Element update and future development projects.

Compliance with General Plan goals and policies regarding public services and recreation would ensure that new housing would not result in a substantial demand to public services. These goals and policies would continue to apply to projects implemented under the Housing Element update.

Therefore, potential impacts to public services associated with implementation of the updated Housing Element are within the scope of impacts analyzed 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 would not result in development that would increase demand for public services or governmental or recreational facilities. The update includes policies and implementation actions that would ensure adequate provisions of public services, including fire and police protection, and protect of City facilities from potential natural and made-made hazards which would improve response times and safety. Any potential updates to structures or development of climate resilient infrastructure designed to mitigate potential risk of climate safety hazards would increase service ratios, response times, and other performance objectives for public services and facilities. Potential development Agenda Item #10.1.

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City of St. Helena
2023 General Plan Update
76 would be subject to project-specific development and planning review and comply with General Plan goals and policies regarding public services and recreation. Therefore, the Public Health, Safety, and Noise Element update would have no impact related to public services or recreation.

Agenda Item #10.1.

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Addendum Evaluation
Transportation and Traffic
Addendum 77

6.13 Transportation and Traffic
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 an applicable plan,
ordinance, or policy establishing
measures of effectiveness for the
performance of the circulation
system, taking into account all
modes of transportation including
mass transit and non-motorized
travel and relevant components
of the circulation system,
including but not limited to
intersections, streets, highways,
and freeways, pedestrian and
bicycle paths, and mass transit?
Significant and
unavoidable
None No No No Yes Yes
b. Conflict with an applicable
congestion management
program, including, but not
limited to level of service
standards and travel demand
measures, or other standards
established by the county
congestion management agency
for designated roads or
highways?
Not discussed None No No No Yes Yes
Agenda Item #10.1.

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City of St. Helena
2023 General Plan Update
78 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. Result in a change in air traffic
patterns, including either an
increase in traffic levels or a
change in location that results in
substantial safety risks?
Less than
significant
None No No No Yes Yes
d. Substantially increase hazards due
to a design feature (e.g., sharp
curves or dangerous intersections)
or incompatible uses (e.g., farm
equipment)?
Less than
significant
None No No No Yes Yes
e. Result in inadequate emergency
access?
f. Conflict with adopted policies,
plans, or programs regarding public
transit, bicycle, or pedestrian
facilities, or otherwise decrease
the performance or safety of such
facilities?
Agenda Item #10.1.

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Addendum Evaluation
Transportation and Traffic
Addendum 79
2040 General Plan EIR Transportation Findings
The 2040 General Plan EIR concluded that impacts related to transportation would be significant and unavoidable regarding consistency with policies and regulations related to roadway, transit, pedestrian, and bicycle facilities, Section 3.13, Transportation. The 2040 General Plan EIR determined 7 out of 27 analyzed intersections would have significant impacts. Policies and actions within the General Plan aim to reduce single occupancy vehicle trips, improve circulation throughout the city, and promote options for alternate forms of transportation. To reduce impacts to intersections, the 2040 General Plan EIR required Mitigation Measures TR-1, TR-2, TR-3, TR-4, TR5, and TR-6. However, even with implementation of the mitigation measures, the 2040 General Plan EIR concluded that impacts would remain significant and unavoidable. Main Street is a State highway (State Route 29), therefore mitigation measures along Main Street are subject to Caltrans approval and cannot be guaranteed by the City. In addition, improvements to accommodate future traffic volumes may not be implemented due to lack of funds. Therefore, because the City cannot guarantee that needed improvements would be implemented, impacts to intersection traffic operations are significant and unavoidable.

The 2040 General Plan EIR determined that other transportation impacts would be less than significant, including potential to conflict with applicable congestion management programs, change in air traffic patterns, increase in hazards due to a design feature or incompatible uses, emergency access, and potential to conflict with adopted policies, plans or programs regarding public transit, bicycle, or pedestrian facilities.

Pursuant to CEQA Guidelines Section 5064.3, subdivision(b), a project’s transportation impact is now based on VMT instead of an level of service analysis as conducted under the 2040 General Plan EIR. Under the updated State requirements, VMT are derived based on location and the amount and distance of vehicle travel attributable to a project, including induced automobile travel. Significance criteria used to determine VMT impact include questions as to whether the project would cause substantial additional VMT, or substantially induce additional automobile travel by increasing physical roadway capacity in congested areas (e.g., by adding new mixed flow travel lanes) or by adding new roadways to the network.

The Housing Element update would facilitate development of 307 units to meet the City of St.

Helena’s RHNA for the current planning period. The proposed housing sites in the Housing Element update would concentrate housing development in the City, which would reduce overall VMT.

Furthermore, the policies within the General Plan encourage the use of transit, bicycling and pedestrian routes and work to reduce VMT. Buildout under the Housing Element update would be subject to comply with these policies. Therefore, potential transportation impacts associated with Agenda Item #10.1.

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City of St. Helena
2023 General Plan Update
80 implementation of the updated Housing Element are within the scope of impacts analyzed 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 includes policies and implementation actions to alleviate evacuation constraints for residential developments with less than two emergency evacuation routes and would strengthen emergency preparedness and evacuation procedures. None of the policies or implementation actions would impact congestion management programs, change air traffic patterns, increase hazards due to a design feature or incompatible use, impair emergency access, or conflict with adopted policies, plans or programs regarding public transit, bicycle, or pedestrian facilities. 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 applicable policies in the General Plan aimed at reducing VMT and transportation impacts. Therefore, the Public Health, Safety, and Noise Element update would have no adverse impacts related to transportation.

Agenda Item #10.1.

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Addendum Evaluation
Utilities and Service Systems
Addendum 81

6.14 Utilities and Service Systems
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. Exceed wastewater treatment
requirements of the applicable
Regional Water Quality Control
Board?
Less Than
Significant
None No No No Yes Yes
b. Require or result in the
construction of new water or
wastewater treatment facilities or
expansion of existing facilities, the
construction of which could cause
significant environmental effects?
Less than
Significant
with
Mitigation
UTS-1 No No No Yes Yes
c. Require or result in the
construction of new stormwater
drainage facilities or expansion of
existing facilities, the construction
of which could cause significant
environmental effects?
Less than
significant
None No No No Yes Yes
d. Have insufficient water supplies
available to serve the project from
existing entitlements and
resources such that new or
expanded entitlements needed?
Less than
Significant
None No No No Yes Yes
Agenda Item #10.1.

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City of St. Helena
2023 General Plan Update
82 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. Result in a determination by the
wastewater treatment provider
which serves or may serve the
project that it has inadequate
capacity to serve the project’s
projected demand in addition to
the provider’s existing
commitments?
Less than
Significant
None No No No Yes Yes
f. Be served by a landfill with
insufficient permitted capacity to
accommodate the project’s solid
waste disposal needs?
Less than
Significant
None No No No Yes Yes
g. Not comply with federal, State, and
local statutes and regulations
related to solid waste?
Less than
Significant
None No No No Yes Yes
Agenda Item #10.1.

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Addendum Evaluation
Utilities and Service Systems
Addendum 83
2040 General Plan EIR Utilities and Service Systems Findings The 2040 General Plan EIR concluded that impacts related to wastewater, water supply, and solid waste would be less than significant provided that proposed projects would comply with federal, State, and local statutes and regulations and the policies and actions within the General Plan addressing wastewater capacity, stormwater runoff, water conservation, waste management, recycling, and composting. The City plans to increase the wastewater treatment plant permitted capacity from 0.5 million gallons per day to 0.65 million gallons per day by 2030, which would have sufficient capacity to accommodate buildout under the General Plan. Any new stormwater facilities would comply with all applicable environmental regulations, including project-level environmental review and NPDES permits regulations. The City’s Water Neutral Policy for Development would ensure future water demand does not exceed current demand by requiring any new water demand be offset by water conservation retrofits or in-lieu payments for the City to conduct retrofits.

Buildout under the General Plan would not require exceed the capacity of the Clover Flat Landfill which has significant remaining capacity. Therefore, the General Plan EIR determined there would be no significant impacts to the city’s utilities or service systems.

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, evaluated previously for potential environmental impacts in the General Plan EIR 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. Many of these sites have existing connections to utility and service systems as they are infill sites or already developed. 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). .

All future development accommodated under the Housing Element update would be required to adhere to the General Plan, adopted master plans, and other regulatory requirements concerning water, wastewater, storm drains, solid waste, and other infrastructure; water supply; and wastewater treatment systems.

Consistent with buildout under the General Plan, implementation of the proposed Housing Element update could increase population such that new or expanded wastewater facilities would be required to provide utilities and service systems to new development. In addition, future development for new or expanded facilities would be subject to further environmental analysis, pursuant to CEQA Guidelines section 15168(c) and as required by state law, to evaluate potential impacts.

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 includes policies and implementation actions that aim to enhance and protect the City’s utilities and service system, such as improving efficiency of stormwater drainage systems and ensuring adequate water supply. Any potential updates to structures or development of climate resilient infrastructure designed to mitigate potential risk of climate safety hazards would work to address these goals and would be subject to project-specific development and planning review and comply with applicable policies in the General Plan, NPDES permits regulations, and the City’s Water Neutral Policy for Agenda Item #10.1.

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City of St. Helena
2023 General Plan Update
84 Development. Therefore, the Public Health, Safety, and Noise Element update would have no adverse impacts related to utilities and service systems.

Agenda Item #10.1.

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Summary of Findings
Utilities and Service Systems
Addendum 85
Summary of Findings
The Housing Element update is part of the City’s General Plan, and like other elements within the General Plan, includes goals and policies that the City should meet when it comes to the planning of housing. The Housing Element is unique from the other elements within the General Plan in that it is required to be periodically updated to align with the State’s allocation of the RHNA. Also, the Housing Element includes Housing Programs that are required to be implemented within the planning period established for the Housing Element. These programs are usually implemented over time as a separate project after the Housing Element is adopted. The Housing Element update does not involve site-specific projects but does include identified sites that could undergo land use changes through Program H-A to facilitate development of RHNA housing units during the 6th cycle.

The sites inventory (provided in the Housing Resources chapter of the Housing Element update) yields housing units that exceed the number needed to meet the RHNA requirements, as demonstrated in Table 3.

The General Plan Program EIR is accompanied the City’s 2040 General Plan update. Future development and zoning changes associated with the Housing Element’s Housing Programs will be subject to applicable development standards and reviews established by City ordinances.

The Public Health, Safety, and Noise Element update does not involve site-specific projects but proposes policies and implementation actions that are aimed at enhancing emergency response and evacuation procedures and minimizing impacts to people and structures from natural and manmade disasters. Any potential updates to structures or development of climate resilient infrastructure would be designed to mitigate potential impacts associated with climate safety hazards. Potential updates and development would not generate population growth or additional VMT or result in an increase in demand for services or facilities.

This analysis demonstrates that adoption of the Housing Element and Public Health, Safety, and Noise Element update would not result in impacts beyond those addressed or analyzed in the General Plan EIR, nor does the General Plan update present new information that shows impacts would be more significant than those described in the General Plan EIR. Therefore, the General Plan EIR applies to the General Plan update and no additional environmental assessment is required.

This analysis was performed pursuant to CEQA Guidelines Sections 15162 and 15164 and is intended to determine if additional environmental review is required or if the changes proposed by the project are within the scope of the previously certified 2040 General Plan EIR. This analysis determined that the 2040 General Plan EIR is of continuing informational value, the proposed changes in the General Plan update are within the scope of that previously certified EIR, and none of the conditions requiring the preparation of subsequent or supplemental environmental review under CEQA Guidelines section 15162 exists. Therefore, the City of St. Helena, as lead agency, has determined that this Addendum to the EIR is sufficient to meet the requirements of CEQA and no additional environmental review is required. Pursuant to CEQA Guidelines section 15164, this Addendum does not need to be circulated for public review and can be included in or attached to the final EIR. The decision-making body shall consider the Addendum with the Final EIR prior to deciding upon the Project.

Agenda Item #10.1.

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City of St. Helena
2023 General Plan Update
86 References
Bibliography
St. Helena, City of. 2018. St. Helena General Plan Update 2040 Draft Environmental Impact Report SCH#2010042001. St. Helena, CA. October, 2018.

St. Helena, City of. 2019. General Plan Update 2040. St. Helena, CA. April, 2019.

List of Preparers
Rincon, Consultants, Inc. prepared this Addendum under contract to the City of St. Helena. Persons involved in data gathering analysis, project management, and quality control are listed below.

RINCON CONSULTANTS, INC.

Darcy Kremin, AICP, Director
Ryan Russell, Project Manager
Leeza Segal, Associate Planner
Agenda Item #10.1.

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

DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT

DIVISION OF HOUSING POLICY DEVELOPMENT
2020 W. El Camino Avenue, Suite 500
Sacramento, CA 95833
(916) 263-2911 / FAX (916) 263-7453
www.hcd.ca.gov
December 6, 2022
Maya DeRosa, Planning & Building Director
Planning Department
City of St. Helena
1572 Railroad Avenue
St. Helena, CA 94574
Dear Maya DeRosa:

RE: City of St. Helena’s 6th Cycle (2023-2031) Draft Housing Element Thank you for submitting the City of St. Helena’s (City) draft housing element received for review on October 5, 2022. Pursuant to Government Code section 65585, subdivision (b), the California Department of Housing and Community Development (HCD) is reporting the results of its review. In addition, HCD considered comments from Holland & Knight, Generation Housing, and Nancy Dervin pursuant to Government Code section 65585, subdivision (c).

The draft element addresses many statutory requirements; however, revisions will be necessary to comply with State Housing Element Law (Article 10.6 of the Gov. Code).

The enclosed Appendix describes the revisions needed to comply with State Housing Element Law.

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

Public participation in the development, adoption and implementation of the housing element is essential to effective housing planning. Throughout the housing element process, the City should continue to engage the community, including organizations that represent lower-income and special needs households, by making information regularly Agenda Item #10.1.

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Maya DeRosa, Planning & Building Director

Page 2 ends

available and considering and incorporating comments where appropriate. Please be aware, any revisions to the element must be posted on the local government’s website and to email a link to all individuals and organizations that have previously requested notices relating to the local government’s housing element at least seven days before submitting to HCD.

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

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

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

Sincerely,
Paul McDougall
Senior Program Manager
Enclosure
Agenda Item #10.1.

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

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

A. Review and Revision
Review the previous element to evaluate the appropriateness, effectiveness, and progress in implementation, and reflect the results of this review in the revised element. (Gov. Code, § 65588 (a) and (b).)
As part of the evaluation of programs in the past cycle, the element must provide an explanation of the effectiveness of goals, policies, and related actions in meeting the housing needs of special needs populations (e.g., elderly, persons with disabilities, large households, female-headed households, farmworkers, and persons experiencing homelessness).

B. Housing Needs, Resources, and Constraints

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

Concentration of Fair Housing Issues: The assessment of fair housing (AFH) demonstrated that there is a concentration of several fair housing issues within the east and southeast quadrant of the City. For example, this area has the highest concentrations of lower-income households, highest percentage of single-headed households, greatest percentage living below the poverty line, high exposure to environmental burdens, and is considered the only low-resourced area in the City. As a result, the analysis should address trends, past and current policy efforts, and their effectiveness, neighborhood investment or disinvestment, local data and knowledge, and other relevant factors, particularly relative to equitable quality of life, resources, and strategies to address any inequities in quality of life.

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2. Include an analysis and documentation of household characteristics, including level of payment compared to ability to pay, housing characteristics, including overcrowding, and housing stock condition. (Gov. Code, § 65583, subd. (a)(2).) Housing Costs (For Sale and Rental Prices): While the element includes estimated rents and for sale housing costs for residents, it utilizes American Community Survey (ACS) data. The element should supplement census data with other sources (e.g., local knowledge) to better reflect current market conditions.

3. An inventory of land suitable and available for residential development, including vacant sites and sites having realistic and demonstrated potential for redevelopment during the planning period to meet the locality’s housing need for a designated income level, and an analysis of the relationship of zoning and public facilities and services to these sites. (Gov.

Code, § 65583, subd. (a)(3).)
Progress towards Regional Housing Needs Allocation (RHNA): The element is crediting 87 above moderate-income units from the Hunter Subdivision Project towards the RHNA. However, HCD has received public comment indicating that the Hunter Subdivision project has been pending since 2010 and there are concerns about the City’s ability to process and approve this project during the planning period. The element should provide an analysis demonstrating the likelihood of these units being built during the planning period.

Nonvacant Sites: The element must include an analysis demonstrating the potential for redevelopment of nonvacant sites. In addition, the element could analyze the extent that existing uses may impede additional residential development. The element included a siteby-site description along with some general information about the characteristics for each site. While the element included an analysis of some sites existing uses, it did not provide an analysis for all sites. For example, Sites 1, 2, 3, 11, and 13 included information on the existing use but provided no analysis on the likelihood for redevelopment. For example, Site 1 and 2 stated that development will occur upon the removal of the existing uses and structures. However, the element did not include any information on the likelihood that this will occur during the planning period. Additionally, Site 6 includes two parcels with separate owners and states that one of the owners is interested in developing pursuant to Senate Bill 9, however provides no description or analysis about the likelihood that the second parcel will redevelop. Sites 7 and 9 do not include any analysis of the existing uses or information about the likelihood for redevelopment. Lastly, Sites 5, 6, 10, and 12 analysis is entirely dependent on property owner interest. The element should either provide additional information on these sites such as the nature of meetings with property owners, the likelihood that the owner will redevelop during the planning period or additional information that indicates the likelihood for redevelopment.

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sites identified. The element could also consider indicators such as age and condition of the existing structure expressed developer interest, low improvement to land value ratio, and other factors. Based on a complete analysis, the element may need to add or modify programs to further encourage and incentivize redevelopment of sites.

Realistic Capacity: The element is generally assuming 75-80 percent of maximum allowable densities on most sites. However, while the element provides assumptions of buildout for sites included in the inventory, it must also provide support for these assumptions. For example, the element mentions realistic capacity assumptions were taken into account for sites selection but should demonstrate what specific criteria, trends, factors, and other evidence led to the assumptions. The estimate of the number of units for each site must be adjusted as necessary, based on the land use controls and site improvements, typical densities of existing or approved residential developments at a similar affordability level in that jurisdiction, and on the current or planned availability and accessibility of sufficient water, sewer, and dry utilities.

The element also assumes that Site 5 will be developed for 50 lower-income units.

However, this site allows a maximum allowable density of 26 units per acre and the site size is 1.8 acres equating to a total capacity of 46 units. While the site may have owner interest to develop beyond the maximum allowable densities, the element must either revise the capacity assumptions within the allowable densities or include a program to increase the sites allowable density.

The element also should analyze the likelihood that the identified units will be developed as noted in the inventory in zones that allow 100 percent nonresidential uses. This analysis should consider the likelihood of nonresidential development, performance standards, and development trends supporting residential development. For additional information, see the Building Blocks at https://www.hcd.ca.gov/analysis-of-sites-andzoning.

Publicly-Owned Sites: The element must include additional discussion on each of the Cityowned sites identified to accommodate the RHNA. Specifically, the analysis should provide support for residential capacity assumptions, existing uses and any known conditions that preclude development in the planning period and the potential schedule for development. If zoning does not currently allow residential uses at appropriate densities, then the element must include programs to rezone sites pursuant to Government Code section 65583.2, subdivisions (h) and (i). In addition, the housing element must include a description of whether there are any plans to sell the property during the planning period and how the jurisdiction will comply with the Surplus Land Act Article 8 (commencing with Section 54220) of Chapter 5 of Part 1 of Division 2 of Title 5.

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Replacement Housing Requirements: If the sites inventory identifies sites with existing residential uses, it must include a program to provide for replacement. Absent a replacement housing program, these sites are not adequate sites to accommodate lowerincome households. The replacement housing program has the same requirements as set forth in Gov. Code section. 65915, subdivision (c)(3).

Infrastructure Availability: The element included a capacity analysis for water, sewer and dry utilities. The analysis noted that there are some deficiencies in the current infrastructure system and additional upgrades will be needed to meet current demand such was the water distribution system, wastewater collection system, and storm drainage system. The element must include a program committing to actions and a timeline to make sufficient infrastructure available to accommodate the RHNA. Additionally, while the element included an analysis of infrastructure capacity, the element must specifically indicate if total infrastructure capacity (existing and planned) is available to accommodate the RHNA.

Environmental Constraints: The element describes a few environmental conditions within the City and indicates that the City certified a FEIR with the 2040 General Plan Update that described environmental constraints and mitigation measures. However, the element must specifically describe any known environmental constraints or any other conditions that preclude development on identified sites within the planning period.

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

Zoning for a Variety of Housing Types:
• Emergency Shelters – The element states that emergency shelters are required to provide sufficient parking for employees and one space per two beds pursuant to AB 139 (Statutes of 2019). However, pursuant to Government Code section 65583, subdivision a)(4)(A), parking for emergency shelters should only be the number of spaces necessary for staff working in the shelter and no more than other uses in the same zones. The element should discuss compliance with this requirement or include a program, if necessary. Additionally, the element should describe any siting or spacing requirements imposed on emergency shelters.

Lastly, the element must include an analysis of the suitability and capacity of the zone(s) identified to accommodate emergency shelters. Specifically, the analysis should demonstrate whether the I and SC zone have sufficient capacity to accommodate the identified housing need for emergency shelters. For example, identifying the number of parcels, typical parcels sizes, whether the sites are nonvacant, and the potential capacity for adaptive reuse. Lastly, in analyzing the Agenda Item #10.1.

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suitability of these zones, the element should address proximity to transportation and services and any conditions inappropriate for human habitability. • Transitional and Supportive Housing - While the element indicates that the City permits supportive housing by-right in all residential zones, the element must specifically demonstrate compliance with AB 2162 (Statutes of 2018). Specifically, supportive housing shall be a use by-right in zones where multifamily and mixed uses are permitted, including nonresidential zones permitting multifamily uses pursuant to Government Code section 65651. The element must demonstrate compliance with this requirement and include programs, if necessary. • Accessory Dwelling Unit (ADU) – The element notes that ADUs are allowed in most residential zones. However, ADUs must be permitted in all zones that allow for residential uses including the AP Zone, mixed-use and commercial zones. The element should analyze consistency with this requirement and include a program, if appropriate. Additionally, after a cursory review of the City’s ordinance, HCD discovered several areas which were not consistent with State ADU Law. This includes, but is not limited to, the definition of a cooking facility, definition of an efficiency kitchen, allowing both an ADU and JADU for conversions on a lot with an existing or proposed single-family dwelling, separate conveyance of an ADU or JADU, and restricting bedroom count. The element must include a program to update the City’s ADU ordinance in compliance with state law.

4. An analysis of potential and actual governmental constraints upon the maintenance, improvement, or development of housing for all income levels, including the types of housing identified in paragraph (1) of subdivision (c), and for persons with disabilities as identified in the analysis pursuant to paragraph (7), including land use controls, building codes and their enforcement, site improvements, fees and other exactions required of developers, and local processing and permit procedures... (Gov. Code, § 65583, subd. (a)(5).)
Land-Use Controls: The element must identify and analyze all relevant land use controls impacts as potential constraints on a variety of housing types (e.g., multifamily rental housing, mobilehomes, transitional housing), as follows:
• Zoning – The element must include an analysis of all residential zones, especially those identified to accommodate a variety of housing types and the regional housing needs allocation (RHNA) i.e., mixed-use, central business, overlay zones, etc., As part of the analysis, the element should identify all applicable land use controls including development standards, allowable densities, zoning, and any other relevant requirements. The analysis should evaluate these requirements for impacts on achieving maximum densities, cost, feasibility and supply (number of units) of housing. Lastly, the element should identify and analyze any minimum unit size requirements.
• Parking – The element notes that mobile home units are required to provide two spaces per mobile home unit in addition to centralized parking and multifamily housing is required to provide 1.5 – 2 parking spaces per unit. The element should Agenda Item #10.1.

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analyze these requirements and their impacts on cost, supply, housing choice and affordability and include programs to address identified constraints.

Local Processing and Permit Procedures: The element briefly discusses the required permits for a typical single family, subdivision, and multifamily project. This is not a complete analysis and does not address the requirements. The element must describe and analyze the City’s permit processing and approval procedures by zone and housing type (e.g., multifamily rental housing, mobilehomes, housing for agricultural employees, supportive housing. The analysis should consider processing and approval procedures and time for typical single-family and multifamily developments, including type of permit, level of review, approval findings and any discretionary approval procedures. The analysis must evaluate the processing and permit procedures’ impacts as potential constraints on approval certainty, feasibility, and housing supply and affordability. For additional information and sample analysis, see the Building Blocks at https://www.hcd.ca.gov/processing-permitting-procedures.

Additionally, the element indicates that multifamily requires a conditional use permit (CUP) and design review, however the element also states that multifamily is allowed by right and subject only to “routine approvals” and design review. The element must clearly detail the approval process for multifamily housing by zone. For your information, subjecting multifamily housing to an exception process such as a CUP in zones where multifamily housing is already allowed is generally considered a constraint. As noted above, the element must clarify what type of discretionary process and identify and evaluate any approval findings or decision-making criteria for this requirement. The analysis should address impacts on housing cost, supply, timing and approval certainty. Based on a complete analysis, the element should include programs to address or remove the identified constraints.

Design Review: The element’s analysis of the design review process states that every development including an individual single-family home and multifamily housing must go through design review and approvals from planning commission which can take an average of three months processing time. In addition, the various approval criteria include subjective language related to the compatibility of design with the neighborhood and surrounding areas, compatibility with historical character, and designs that promote harmonious transitions. Design review processes that have little to no guidance or clarity and requiring findings related to character are generally considered a constraint. The element must analyze this process and the approval criteria for potential constraints on approval certainty, feasibility, supply and affordability. Based on a complete analysis, the element may need to include or modify a program to address and remove or mitigate any identified constraints.

Local Ordinances: While the element included a discussion of the City’s inclusionary requirement, it must specifically identify and analyze any other locally adopted ordinances such as short-term rental ordinances that directly impact the cost and supply of residential development.

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On/Off-Site Improvements: While the element indicates on and off-site improvements are listed in St. Helena’s municipal code, it must specifically identify subdivision level improvement requirements, such as minimum street widths (e.g., 40-foot minimum street width) and analyze their impact as potential constraints on housing supply and cost. For additional information and a sample analysis, see the Building Blocks at http://www.hcd.ca.gov/community-development/building-blocks/constraints/codes-andenforcement-on-offsite-improvement-standards.shtml.

Fees: The element includes a hypothetical example of fees for single family and a multifamily project that focuses on detailing impact fees for each project type. However, a complete analysis should identify all fees and costs including permit processing and planning fees, development fees, exactions, and any other applicable fees and analyze as potential constraints on housing supply and affordability. For more information, please visit: https://www.hcd.ca.gov/planning-and-community-development/housingelements/building-blocks/fees-and-exactions.

Building Codes and Enforcement: While the element states that the City has authority to deem any structure unsafe, it should specifically discuss the City’s code enforcement process (e.g., whether code enforcement activities are compliant-based or proactive).

Constraints on Housing for Persons with Disabilities:
• Reasonable Accommodation – The element identifies approval findings for granting a reasonable accommodation including finding related to impacts on surrounding uses – essentially a CUP finding. However, reasonable accommodation should be a unique exception process from a CUP, especially given its importance in addressing barriers to housing for persons with disabilities. The element should include a program to amend the Reasonable Accommodation Ordinance and remove constraints, namely the “potential impact on surrounding uses” approval finding. Additionally, the element should also indicate whether the City charges any fees to applicants filing reasonable accommodation requests. • Other Requirements – The element must also include an analysis of zoning, development standards, building codes, and process and permit procedures as potential constraints on housing for persons with disabilities. Specifically, the analysis must describe any zoning code definitions of family and any spacing or concentration requirements for housing for persons with disabilities. • Residential Care Facilities of Seven or More – The element states that these uses are permitted with a CUP in high-density residential zones. For your information, excluding these uses from residential zones and/or subjecting the uses to a CUP is generally considered a constraint and programs should be modified as appropriate with specific commitment to allow the use in residential zones with objectivity and certainty.
• Residential Care Facilities of Six or Fewer – The element indicates that group homes of six or fewer are excluded from some residential zones. For your Agenda Item #10.1.

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information, these uses must be allowed in any area zoned for residential use. The element should include or modify a program to address this requirement committing to allowing these uses in any zone that permits residential uses.

5. An analysis of potential and actual nongovernmental constraints upon the maintenance, improvement, or development of housing for all income levels, including… …the length of time between receiving approval for a housing development and submittal of an application for building permits for that housing development that hinder the construction of a locality’s share of the regional housing need in accordance with Government Code section 65584... (Gov. Code, § 65583, subd. (a)(6).)
Permit Times: The element must include an analysis of the length of time between receiving approval for a housing development and submittal of an application for building permits that potentially hinder the construction of a locality’s share of the regional housing need.

6. Analyze any special housing needs such as elderly; persons with disabilities, including a developmental disability; large families; farmworkers; families with female heads of households; and families and persons in need of emergency shelter. (Gov. Code, § 65583, subd. (a)(7).)
Special Needs Households: While the element includes data and a general discussion of housing challenges faced by special needs households, it still must provide an analysis of the existing needs and resources for each special needs group including extremely lowincome households, persons with disabilities including developmental disabilities, female headed households, and farmworkers. For example, the element should discuss the existing resources to meet housing needs (availability of shelter beds, number of large units, number of deed restricted units, etc.), an assessment of any gaps in resources, and proposed policies, programs, and funding to help address those gaps.

C. Housing Programs

1. Include a program which sets forth a schedule of actions during the planning period, each with a timeline for implementation, which may recognize that certain programs are ongoing, such that there will be beneficial impacts of the programs within the planning period, that the local government is undertaking or intends to undertake to implement the policies and achieve the goals and objectives of the Housing Element... (Gov. Code, § 65583, subd. (c).)
To address the program requirements of Government Code section 65583, subdivision (c)(1-6), and to facilitate implementation, programs should include: (1) a description of the City’s specific role in implementation; (2) definitive implementation timelines; (3) objectives, quantified where appropriate; and (4) identification of responsible agencies and officials. Programs to be revised include the following:
• Ongoing Programs: Numerous programs continue to indicate an “ongoing” implementation status. While this may be appropriate for some programs, programs Agenda Item #10.1.

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with quantified objectives or specific implementation actions must include completion or initiation dates resulting in beneficial impacts within the planning period. This includes but is not limited to Programs H-U, H-X, H-KK and H-P. • Timelines: The element includes two programs with timelines for implementation towards the end of the planning period (Programs H-S and H-I). Given the importance of these programs and to achieve beneficial impact throughout the planning period, the element should revise these programs to be implemented earlier in the planning period.

2. Identify actions that will be taken to make sites available during the planning period with appropriate zoning and development standards and with services and facilities to accommodate that portion of the city’s or county’s share of the regional housing need for each income level that could not be accommodated on sites identified in the inventory completed pursuant to paragraph (3) of subdivision (a) without rezoning, and to comply with the requirements of Government Code section 65584.09. Sites shall be identified as needed to facilitate and encourage the development of a variety of types of housing for all income levels, including multifamily rental housing, factory-built housing, mobilehomes, housing for agricultural employees, supportive housing, single-room occupancy units, emergency shelters, and transitional housing. (Gov. Code, § 65583, subd. (c)(1).) As noted in Finding B3, the element does not include a complete site analysis, therefore, the adequacy of sites and zoning were not established. Based on the results of a complete sites inventory and analysis, the City may need to add or revise programs to address a shortfall of sites or zoning available to encourage a variety of housing types. In addition, the element should be revised as follows:

Shortfall of Sites (Program H-A): The element notes that several sites do not currently permit residential uses or have appropriate densities and will need to be rezoned to accommodate the RHNA. While the element included Program H-A to rezone sites, the program should identify acreage, allowable densities, and anticipated units to be rezoned and must specifically commit to meet all requirements pursuant to Government Code section 65583.2, subdivisions (h) and (i). For example, the program must commit to permit owner-occupied and rental multifamily uses by-right for developments in which 20 percent or more of the units are affordable to lower-income households. By-right means local government review must not require a CUP, planned unit development permit, or other discretionary review or approval.

Replacement Housing Requirements: The housing element must include a program to provide replacement housing. Absent a replacement housing program, these sites are not adequate sites to accommodate lower-income households. The replacement housing program must adhere to the same requirements as set forth in Government Code section 65915, subdivision (c)(3).

Sites Identified in Multiple Planning Periods: While the element includes Program H-A to maintain an inventory to comply with Government code section 65583.2 (c), this program must commit to zone and allow for the following:

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• sites must meet the density requirements for housing for lower income households, and
• allow by-right approval for housing developments that include 20 percent or more of its units affordable to lower income households (Gov. Code, § 65583.2, subd. (c).).

Nonvacant Sites Reliance to Accommodate RHNA: As the element relies upon nonvacant sites to accommodate the regional housing need for lower-income households, it should include a program(s) to promote residential development of those sites. The program could commit to provide financial assistance, regulatory concessions, or incentives to encourage and facilitate new, or more intense, residential development on the sites.

Examples of incentives include identifying and targeting specific financial resources and reducing appropriate development standards. For additional information, see the Building Blocks at https://www.hcd.ca.gov/identify-adequate-sites.

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

Senate Bill 9 Implementation: The element relies on the implementation and usage of Senate Bill 9 to accommodate a portion of the RHNA, promote a variety of housing types and choices, and implement affirmatively furthering fair housing requirements. While the element included program H-T to support lot splits, the element must include specific actions to implement and incentive the usage of SB 9. This includes but is not limited to establishing a compliant ordinance, development standards, incentives, and marketing and outreach to developers and property owners.

Program H-C – Water Sewer Priority: For your information, water and sewer service providers must establish specific procedures to grant priority water and sewer service to developments with units affordable to lower-income households. (Gov. Code, § 65589.7.) While the element commits to granting priority water and sewer to developments with units affordable to lower income households, local governments are also required to immediately deliver the housing element to water and sewer service providers. HCD recommends including a program, policy, or commitment to deliver the adopted housing element to water and sewer providers and include a cover memo describing the City’s housing element, including the City’s housing needs and regional housing need. For additional information and sample cover memo, see the Building Blocks at https://www.hcd.ca.gov/priority-for-water-and-sewer.

3. Address and, where appropriate and legally possible, remove governmental and nongovernmental constraints to the maintenance, improvement, and development of housing, including housing for all income levels and housing for persons with disabilities.

The program shall remove constraints to, and provide reasonable accommodations for housing designed for, intended for occupancy by, or with supportive services for, persons with disabilities. (Gov. Code, § 65583, subd. (c)(3).)
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As noted in Findings B4 and B5, the element requires a complete analysis of potential governmental and non-governmental constraints. Depending upon the results of that analysis, the City may need to revise or add programs and address and remove or mitigate any identified constraints. In addition, the element should be revised as follows:

Program H-B (Growth Management System): The element notes that the City implemented a growth management system which likely violates SB 330 (Housing Crisis Act, 2019, Gov. Code, § 66300). The element included a program to remove the growth management system, however included the timeline has “ongoing.” The element should include a specific implementation timeline for when this system will be removed and implementation should happen earlier in the planning period (e.g., one year).

4. Promote and affirmatively further fair housing opportunities and promote housing throughout the community or communities for all persons regardless of race, religion, sex, marital status, ancestry, national origin, color, familial status, or disability, and other characteristics... (Gov. Code, § 65583, subd. (c)(5).)
As noted in Finding B1, the element requires a complete AFFH analysis. Depending upon the results of that analysis, the City may need to revise or add programs. Additionally, while the element did include programs to address fair housing issues and contributing factors, several programs will need to be revised with increased metrics, geographic targeting for place-based strategies, and implementation steps to facilitate meaningful change. Additionally, while the element included some programs for place-based strategies, these programs must include geographic targeting for the Southeast quadrant of the City, include actions that improve one’s quality of life related to housing, transportation, safety, education, recreation, infrastructure, etc., and quantified metrics that target beneficial impacts for people, households and neighborhoods ( e.g., number of people or households assisted, number of housing units built, number of parks or infrastructure projects completed). HCD will follow-up under a separate cover with additional information.

D. Public Participation
Local governments shall make a diligent effort to achieve public participation of all economic segments of the community in the development of the Housing Element, and the element shall describe this effort. (Gov. Code, § 65583, subd.(c)(9).) While the element described various efforts to achieve public participation in the preparation of the housing element update, it should also describe how comments were considered and incorporated into the element.

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City of St. Helena 2023-2031 Housing Element Update
Responses to HCD’s 90-day Comment Letter
January 31, 2023 | 1
Section HCD Comment Revision
A As part of the evaluation of programs in the past cycle, the element must provide an explanation of the
effectiveness of goals, policies, and related actions in meeting the housing needs of special needs populations
(e.g., elderly, persons with disabilities, large households, female-headed households, farmworkers, and persons
experiencing homelessness).

We have added the required
evaluation under the new
heading “Effectiveness in
Meeting the Needs of Special
Needs Populations” to page 2-39
of the track changed version.

B Enforcement: While the element includes analysis of fair housing complaints, it must describe the City’s
compliance with existing fair housing laws and
regulations.

We have added a paragraph
under the heading Local
Resources on page A-12.

B Concentration of Fair Housing Issues: The assessment of fair housing (AFH) demonstrated that there is a
concentration of several fair housing issues within the east and southeast quadrant of the City. For example, this area has the highest concentrations of lower-income
households, highest percentage of single-headed
households, greatest percentage living below the poverty line, high exposure to environmental burdens, and is
considered the only low-resourced area in the City. As a result, the analysis should address trends, past and
current policy efforts, and their effectiveness,
neighborhood investment or disinvestment, local data
and knowledge, and other relevant factors, particularly relative to equitable quality of life, resources, and
strategies to address any inequities in quality of life.

We have expanded the analysis
under the heading 4. Local Area
of Knowledge on page A-101 of
the track change version.

We have also expanded the
analysis under heading “5. Sites
Inventory Analysis,” on pages A103 to A-105 of the track changed version.

B 2. Housing Costs (For Sale and Rental Prices): While the element includes estimated rents and for sale housing
costs for residents, it utilizes American Community Survey (ACS) data. The element should supplement census data
with other sources (e.g., local knowledge) to better reflect current market conditions.

We have expanded the analysis
of for sale housing under the new
heading “Current Market Rate
For-Sale Housing” on page 2-101
of the track changed version; and
“Current Market Rate Rental
Housing” on page 2-107 of the
track-changed version.

B Progress towards Regional Housing Needs Allocation
(RHNA): The element is crediting 87 above moderateincome units from the Hunter Subdivision Project towards the RHNA. However, HCD has received public comment
indicating that the Hunter Subdivision project has been pending since 2010 and there are concerns about the
City’s ability to process and approve this project during the planning period. The element should provide an
analysis demonstrating the likelihood of these units being built during the planning period.

We have clarified the analysis
under the heading Pending or
Approved/Entitled Projects on
pages 2-194 and 2-195 of the
track change version.

B Nonvacant Sites: The element must include an analysis demonstrating the potential for redevelopment of
We have added an analysis of
nonvacant sites under the new
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City of St. Helena 2023-2031 Housing Element Update
Responses to HCD’s 90-day Comment Letter
January 31, 2023 | 2
nonvacant sites. In addition, the element could analyze the extent that existing uses may impede additional
residential development. The element included a site-bysite description along with some general information about the characteristics for each site. While the element included an analysis of some sites existing uses, it did not provide an analysis for all sites. For example, Sites 1, 2, 3, 11, and 13 included information on the existing use but provided no analysis on the likelihood for redevelopment.

For example, Site 1 and 2 stated that development will
occur upon the removal of the existing uses and
structures. However, the element did not include any
information on the likelihood that this will occur during the planning period. Additionally, Site 6 includes two
parcels with separate owners and states that one of the owners is interested in developing pursuant to Senate Bill 9, however provides no description or analysis about the likelihood that the second parcel will redevelop. Sites 7 and 9 do not include any analysis of the existing uses or information about the likelihood for redevelopment.

Lastly, Sites 5, 6, 10, and 12 analysis is entirely dependent on property owner interest. The element should either
provide additional information on these sites such as the nature of meetings with property owners, the likelihood that the owner will redevelop during the planning period or additional information that indicates the likelihood for redevelopment.

To facilitate a complete analysis, the element can
summarize past experiences converting existing uses to
higher density residential development, include current market demand for the existing use, provide analysis of existing leases or contracts that would perpetuate the
existing use or prevent additional residential
development and include current information on
development trends and market conditions in the City
and relate those trends to the sites identified. The
element could also consider indicators such as age and
condition of the existing structure expressed developer interest, low improvement to land value ratio, and other factors. Based on a complete analysis, the element may
need to add or modify programs to further encourage and incentivize redevelopment of sites.

Lastly, HCD received a number of comments concerning
sites identified in the inventory that have a low likelihood of redevelopment due to existing buildings in commercial districts and on privately-owned property. As noted
above, the element should provide additional analysis and heading “Suitability of Nonvacant
Sites” beginning on page 2-201 of
the track change version. The
nonvacant site analysis was
included in Site 7, 9, 10, and 12
Sites 1-3 are City-owned sites and
the existing uses would not
impede redevelopment as the
City has authority over its uses.

Added timeline for City goals for
these sites on page 2-196 and in
Program H-L.

Removed one parcel on Site 6 to
only include parcel with owner
interest (page 2-205) and
removed Site 11 based on public
comment (page 2-213)
Clarified on Site 5 that there is
on-going discussions and plans
being prepared for affordable
housing (page 2-204)
Agenda Item #10.1.

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information demonstrating the likelihood of
redevelopment on these sites.

B Realistic Capacity: The element is generally assuming 75- 80 percent of maximum allowable densities on most sites.

However, while the element provides assumptions of
buildout for sites included in the inventory, it must also provide support for these assumptions. For example, the element mentions realistic capacity assumptions were
taken into account for sites selection but should
demonstrate what specific criteria, trends, factors, and other evidence led to the assumptions. The estimate of
the number of units for each site must be adjusted as
necessary, based on the land use controls and site
improvements, typical densities of existing or approved residential developments at a similar affordability level in that jurisdiction, and on the current or planned
availability and accessibility of sufficient water, sewer, and dry utilities.

The element also assumes that Site 5 will be developed
for 50 lower-income units. However, this site allows a
maximum allowable density of 26 units per acre and the
site size is 1.8 acres equating to a total capacity of 46 units. While the site may have owner interest to develop beyond the maximum allowable densities, the element
must either revise the capacity assumptions within the
allowable densities or include a program to increase the sites allowable density.

The element also should analyze the likelihood that the identified units will be developed as noted in the
inventory in zones that allow 100 percent nonresidential uses. This analysis should consider the likelihood of
nonresidential development, performance standards, and
development trends supporting residential development.

We have expanded the analysis
under sites 4-12 beginning on
page 2-203 of the track change
version.

We have adjusted the capacity
assumptions for Site 5 to 46
units.

B Publicly-Owned Sites: The element must include
additional discussion on each of the City-owned sites
identified to accommodate the RHNA. Specifically, the
analysis should provide support for residential capacity assumptions, existing uses and any known conditions that preclude development in the planning period and the
potential schedule for development. If zoning does not
currently allow residential uses at appropriate densities, then the element must include programs to rezone sites
pursuant to Government Code section 65583.2,
subdivisions (h) and (i). In addition, the housing element must include a description of whether there are any plans to sell the property during the planning period and how the jurisdiction will comply with the Surplus Land Act
We have expanded their analysis
under the heading City-Owned
Sites on page 2-196 of the track
change version, as well as in the
Site 1 summary on page 2-197.

New Program H-L has been
added to address City’ Owned
Sites. – Rezone requirements
have been added.

Agenda Item #10.1.

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Article 8 (commencing with Section 54220) of Chapter 5
of Part 1 of Division 2 of Title 5.

B Replacement Housing Requirements: If the sites inventory identifies sites with existing residential uses, it must include a program to provide for replacement. Absent a
replacement housing program, these sites are not
adequate sites to accommodate lower-income
households. The replacement housing program has the
same requirements as set forth in Gov. Code section.
65915, subdivision (c)(3).

The sites inventory does not
assume demolition or
replacement of any units that
meet the State criteria, including
any parcel that:
• currently has residential uses
or within the past five years
has had residential uses that
have been vacated or
demolished, and
• was subject to a recorded
covenant, ordinance, or law
that restricts rents to levels
affordable to persons and
families of low or very lowincome, or
• subject to any other form of
rent or price control through
a public entity’s valid exercise
of its police power, or
• occupied by low or very lowincome households
B Infrastructure Availability: The element included a
capacity analysis for water, sewer and dry utilities. The analysis noted that there are some deficiencies in the
current infrastructure system and additional upgrades will be needed to meet current demand such was the water
distribution system, wastewater collection system, and
storm drainage system. The element must include a
program committing to actions and a timeline to make
sufficient infrastructure available to accommodate the
RHNA. Additionally, while the element included an
analysis of infrastructure capacity, the element must
specifically indicate if total infrastructure capacity
(existing and planned) is available to accommodate the
RHNA.

We have expanded the analysis
under the heading Available of
Infrastructure and Services on
page 2-221 of the track change
version.

B Environmental Constraints: The element describes a few environmental conditions within the City and indicates
that the City certified a FEIR with the 2040 General Plan Update that described environmental constraints and
mitigation measures. However, the element must
specifically describe any known environmental constraints or any other conditions that preclude development on
identified sites within the planning period.

We have expanded the analysis
under the heading Environmental
Constraints, beginning on page 2-
223 of the track change version.

B Sites Inventory Electronic Form: Please note, pursuant to We will provide an updated sites Agenda Item #10.1.

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Government Code section 65583.3, subdivision (b), the
City must utilize standards, forms, and definitions
adopted by HCD when preparing the sites inventory.
inventory form at the time of
submission.

B Emergency Shelters – The element states that emergency shelters are required to provide sufficient parking for employees and one space per two beds pursuant to AB
139 (Statutes of 2019). However, pursuant to
Government Code section 65583, subdivision a)(4)(A),
parking for emergency shelters should only be the
number of spaces necessary for staff working in the
shelter and no more than other uses in the same zones.

The element should discuss compliance with this
requirement or include a program, if necessary.

Additionally, the element should describe any siting or spacing requirements imposed on emergency shelters.

Lastly, the element must include an analysis of the
suitability and capacity of the zone(s) identified to
accommodate emergency shelters. Specifically, the
analysis should demonstrate whether the I and SC zone
have sufficient capacity to accommodate the identified
housing need for emergency shelters. For example,
identifying the number of parcels, typical parcels sizes, whether the sites are nonvacant, and the potential
capacity for adaptive reuse. Lastly, in analyzing the
suitability of these zones, the element should address
proximity to transportation and services and any
conditions inappropriate for human habitability.

We have added an action for
compliance with AB 139 in the
municipal code update program
(HE-F).

We have added the required
capacity analysis to pages 2-127
and 2-182 of the track changed
version.

B Transitional and Supportive Housing - While the element indicates that the City permits supportive housing by-right in all residential zones, the element must specifically demonstrate compliance with AB 2162 (Statutes of 2018).

Specifically, supportive housing shall be a use by-right in zones where multifamily and mixed uses are permitted,
including nonresidential zones permitting multifamily
uses pursuant to Government Code section 65651. The
element must demonstrate compliance with this
requirement and include programs, if necessary.

As required, the City allows
transitional and supportive
housing in all residential,
commercial, and mixed use
districts, subject only to the
requirements of residential uses.

We have updated pages 2-10, 2-
13, 2-129, and 2-190 of the track
changed version.

B Accessory Dwelling Unit (ADU) – The element notes that ADUs are allowed in most residential zones. However,
ADUs must be permitted in all zones that allow for
residential uses including the AP Zone, mixed-use and
commercial zones. The element should analyze
consistency with this requirement and include a program, if appropriate. Additionally, after a cursory review of the City’s ordinance, HCD discovered several areas which
were not consistent with State ADU Law. This includes,
but is not limited to, the definition of a cooking facility, We have revised the analysis on
page 2-10, 2-192, and 2-193 to
reflect the needed revisions to
the code, as identified here.

We have added the necessary
actions to the municipal code
update program (HE-F).

Agenda Item #10.1.

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definition of an efficiency kitchen, allowing both an ADU and JADU for conversions on a lot with an existing or
proposed single-family dwelling, separate conveyance of an ADU or JADU, and restricting bedroom count. The
element must include a program to update the City’s ADU ordinance in compliance with state law.

B Zoning – The element must include an analysis of all
residential zones, especially those identified to
accommodate a variety of housing types and the regional housing needs allocation (RHNA) i.e., mixed-use, central business, overlay zones, etc., As part of the analysis, the element should identify all applicable land use controls including development standards, allowable densities,
zoning, and any other relevant requirements. The analysis should evaluate these requirements for impacts on
achieving maximum densities, cost, feasibility and supply (number of units) of housing. Lastly, the element should identify and analyze any minimum unit size requirements.

We have expanded our analysis
within the governmental
constraints section to include
analysis of density and
development standards in the CB,
SC, and BPO zones, the HP, MHP,
PD, RR, and SP overlay zones, the
new Mixed-Use zone (currently
part of the Draft Zoning Code
Update, October 2022). We have
also expanded our analysis to
include discussion of minimum
unit size requirements, which are
only regulated for commercial
parcels. Please see the heading
“Zoning Code” in the
“Governmental Constraints”
section beginning on page 2-136
of the track changed version.

B Parking – The element notes that mobile home units are required to provide two spaces per mobile home unit in
addition to centralized parking and multifamily housing is required to provide 1.5 – 2 parking spaces per unit. The element should analyze these requirements and their
impacts on cost, supply, housing choice and affordability and include programs to address identified constraints.

We have expanded our analysis
of parking requirements on pages
2-152 through 2-154 of the track
changed version.

We could not provide a direct
cost analysis, but have provided a
comparison to neighboring
jurisdictions and an evaluation of
how these requirements would
impact a site in the inventory.

B Local Processing and Permit Procedures: The element
briefly discusses the required permits for a typical single family, subdivision, and multifamily project. This is not a complete analysis and does not address the
requirements. The element must describe and analyze the City’s permit processing and approval procedures by zone and housing type (e.g., multifamily rental housing,
mobilehomes, housing for agricultural employees,
supportive housing. The analysis should consider
processing and approval procedures and time for typical single-family and multifamily developments, including
We have completely overhauled
the Governmental Constraints
section to respond to these
comments. Please see the new
headings “Processing and Permit
Procedures,” “Procedures for
Selected Housing Types,” and
beginning on page 2-160 of the
track changed version.

Agenda Item #10.1.

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type of permit, level of review, approval findings and any discretionary approval procedures. The analysis must
evaluate the processing and permit procedures’ impacts
as potential constraints on approval certainty, feasibility, and housing supply and affordability.

B Design Review: The element’s analysis of the design
review process states that every development including
an individual single-family home and multifamily housing must go through design review and approvals from
planning commission which can take an average of three
months processing time. In addition, the various approval criteria include subjective language related to the
compatibility of design with the neighborhood and
surrounding areas, compatibility with historical character, and designs that promote harmonious transitions. Design review processes that have little to no guidance or clarity and requiring findings related to character are generally considered a constraint. The element must analyze this
process and the approval criteria for potential constraints on approval certainty, feasibility, supply and affordability.

Based on a complete analysis, the element may need to
include or modify a program to address and remove or
mitigate any identified constraints.

We have revised the document
under the heading “Design
Review” beginning on page 2-163
of the track changed version.

We have updated program H-F to
include actions related to
codifying objective design
standards, as well as a by-right
ministerial review process for
affordable housing developments
meeting state affordability
thresholds, in compliance with SB
35 and SB 330.

B Local Ordinances: While the element included a
discussion of the City’s inclusionary requirement, it must specifically identify and analyze any other locally adopted ordinances such as short-term rental ordinances that
directly impact the cost and supply of residential
development.

We have revised the
Governmental Constraints
section to include analysis of
additional locally adopted
ordinances (17.132, 17.134,

17.138, 17.144, and 17.146)
associated with residential
development or commercial uses
in residential zones. Please see
the analysis under the heading
“Locally Adopted Ordinances”
beginning on page 2-174 of the
track changed version.

B On/Off-Site Improvements: While the element indicates on and off-site improvements are listed in St. Helena’s municipal code, it must specifically identify subdivision level improvement requirements, such as minimum street
widths (e.g., 40-foot minimum street width) and analyze their impact as potential constraints on housing supply and cost.

We have expanded our analyses.

Please see the changes to the
On/Offsite Improvement
Standards section beginning on
page 2-148 of the track changed
version.

B Fees: The element includes a hypothetical example of
fees for single family and a multifamily project that
focuses on detailing impact fees for each project type.

However, a complete analysis should identify all fees and We have updated our analysis
accordingly. Please see the
revised information under the
heading “Fees and Exactions”
Agenda Item #10.1.

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costs including permit processing and planning fees,
development fees, exactions, and any other applicable
fees and analyze as potential constraints on housing
supply and affordability.
beginning on page 2-156.

B Building Codes and Enforcement: While the element
states that the City has authority to deem any structure unsafe, it should specifically discuss the City’s code
enforcement process (e.g., whether code enforcement
activities are compliant-based or proactive).

We have updated our analysis
accordingly. Please see the
revised information under the
heading “Building Codes and
Enforcement” beginning on page
2-147 of the track-changed
version.

B Reasonable Accommodation – The element identifies
approval findings for granting a reasonable
accommodation including finding related to impacts on
surrounding uses – essentially a CUP finding. However,
reasonable accommodation should be a unique exception
process from a CUP, especially given its importance in
addressing barriers to housing for persons with
disabilities. The element should include a program to
amend the Reasonable Accommodation Ordinance and
remove constraints, namely the “potential impact on
surrounding uses” approval finding. Additionally, the
element should also indicate whether the City charges
any fees to applicants filing reasonable accommodation
requests.

We have revised the analysis
accordingly. Please see
information under the heading
“Reasonable Accommodation”
beginning on page 2-170 of the
track changed version.

We have also added an action to
the Municipal Code Update
program (H-F) committing the
City to update Chapter 173.200
(Reasonable Accommodation) to
remove discretionary finding
requirements that constrain
development, including finding
#5, which considers impacts to
surrounding properties or uses.

B Other Requirements – The element must also include an analysis of zoning, development standards, building
codes, and process and permit procedures as potential
constraints on housing for persons with disabilities.

Specifically, the analysis must describe any zoning code definitions of family and any spacing or concentration
requirements for housing for persons with disabilities.

We have expanded our analysis
of constraints to housing for
persons with disabilities to
include subsections for “Zoning
and Land Use,” “Permits and
Processing,” “Building Codes,”
and “Definition of family,”
beginning on page 2-170 of the
track changed version.

B Residential Care Facilities of Seven or More – The element states that these uses are permitted with a CUP in highdensity residential zones. For your information, excluding these uses from residential zones and/or subjecting the uses to a CUP is generally considered a constraint and
programs should be modified as appropriate with specific commitment to allow the use in residential zones with
objectivity and certainty.

We have revised the analysis of
small and large residential care
facilities in the chapter on
“Zoning for a Variety of Housing
Types,” beginning on page 2-188.

We have also made associated
revisions in the section
“Constraints to Housing for
Persons with Disabilities” under
the headings, “Zoning and Land
Agenda Item #10.1.

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Use” and “Permits and
Processing” beginning on page 2-
170 of the track changed version.

We have updated the Municipal
Code Update program (H-F) to
commit the City to “allow
residential care homes facilities
of six or fewer in zones allowing
single-family uses, subject only to
the requirements of single-family
uses, in compliance with State
law (HSC § 1568.0831); and
facilities with seven or more beds
in zones allowing multifamily
uses, subject only to the
requirements multifamily uses.”
B Residential Care Facilities of Six or Fewer – The element indicates that group homes of six or fewer are excluded from some residential zones. For your information, these uses must be allowed in any area zoned for residential
use. The element should include or modify a program to
address this requirement committing to allowing these
uses in any zone that permits residential uses.

We have revised the analysis of
small and large residential care
facilities in the chapter on
“Zoning for a Variety of Housing
Types,” beginning on page 2-188.

We have updated the Municipal
Code Update program (H-F) to
commit the City to “allow
residential care homes facilities
of six or fewer in zones allowing
single-family uses, subject only to
the requirements of single-family
uses, in compliance with State
law (HSC § 1568.0831); and
facilities with seven or more beds
in zones allowing multifamily
uses, subject only to the
requirements multifamily uses.”
We have also made associated
revisions in the section
“Constraints to Housing for
Persons with Disabilities” under
the headings, “Zoning and Land
Use” and “Permits and
Processing” beginning on page 2-
170 of the track changed version.

B Permit Times: The element must include an analysis of the length of time between receiving approval for a
housing development and submittal of an application for We have updated the section
“Processing and Permit
Procedures” with an analysis of
Agenda Item #10.1.

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building permits that potentially hinder the construction of a locality’s share of the regional housing need.
the length of time between
receiving approval for a housing
development and submittal of an
application for building permits.

Please see the subheading
“Actual Project Times” beginning
on page 2-162 of the track
changed version.

B Special Needs Households: While the element includes
data and a general discussion of housing challenges faced by special needs households, it still must provide an
analysis of the existing needs and resources for each
special needs group including extremely low-income
households, persons with disabilities including
developmental disabilities, female headed households,
and farmworkers. For example, the element should
discuss the existing resources to meet housing needs
(availability of shelter beds, number of large units,
number of deed restricted units, etc.), an assessment of any gaps in resources, and proposed policies, programs, and funding to help address those gaps.

We have updated Chapter 7:

Special Housing Needs
extensively, including a new
subsection on Extremely LowIncome Households. We have
added analyses of existing
resources as well as gaps in
resources and actions items to all
subsections. Please Chapter 7:

Special Housing Needs, beginning
on page 2-109 of the track
changed version.

C Ongoing Programs: Numerous programs continue to
indicate an “ongoing” implementation status. While this may be appropriate for some programs, programs with
quantified objectives or specific implementation actions must include completion or initiation dates resulting in beneficial impacts within the planning period. This
includes but is not limited to Programs H-U, H-X, H-KK and H-P.

We have updated the timeframe
of all programs previously
marked “ongoing.”
C Timelines: The element includes two programs with
timelines for implementation towards the end of the
planning period (Programs H-S and H-I). Given the
importance of these programs and to achieve beneficial
impact throughout the planning period, the element
should revise these programs to be implemented earlier
in the planning period.

We have updated these programs
to be implemented earlier in the
planning period.

C Shortfall of Sites (Program H-A): The element notes that several sites do not currently permit residential uses or have appropriate densities and will need to be rezoned to accommodate the RHNA. While the element included
Program H-A to rezone sites, the program should identify acreage, allowable densities, and anticipated units to be rezoned and must specifically commit to meet all
requirements pursuant to Government Code section
65583.2, subdivisions (h) and (i). For example, the
program must commit to permit owner-occupied and
rental multifamily uses by-right for developments in
I’ve updated the Program H-A
with program text provided by
HCD in the Sites Inventory
Guidelines.

Agenda Item #10.1.

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which 20 percent or more of the units are affordable to lower-income households. By-right means local
government review must not require a CUP, planned unit
development permit, or other discretionary review or
approval.

C Replacement Housing Requirements: The housing
element must include a program to provide replacement
housing. Absent a replacement housing program, these
sites are not adequate sites to accommodate lowerincome households. The replacement housing program must adhere to the same requirements as set forth in
Government Code section 65915, subdivision (c)(3).

The sites inventory does not
include any sites that currently
have residential uses, or within
the past five years have had
residential uses that have been
vacated or demolished, and:
• Were subject to a
recorded covenant,
ordinance, or law that
restricts rents to levels
affordable to persons and
families of low or very
low-income, or
• Subject to any other form
of rent or price control
through a public entity’s
valid exercise of its police
power, or
• Occupied by low or very
low-income households
C Sites Identified in Multiple Planning Periods: While the element includes Program H-A to maintain an inventory
to comply with Government code section 65583.2 (c), this program must commit to zone and allow for the
following:
• sites must meet the density requirements for
housing for lower income households, and
• allow by-right approval for housing developments
that include 20 percent or more of its units
affordable to lower income households (Gov.

Code, § 65583.2, subd. (c).).

We have updated Program H-A to
commit to these requirements.

C Nonvacant Sites Reliance to Accommodate RHNA: As the
element relies upon nonvacant sites to accommodate the
regional housing need for lower-income households, it
should include a program(s) to promote residential
development of those sites. The program could commit to provide financial assistance, regulatory concessions, or incentives to encourage and facilitate new, or more
intense, residential development on the sites. Examples of incentives include identifying and targeting specific financial resources and reducing appropriate
development standards.

We have added a new program,
which appears as H-K, related
non-vacant sites. The program
commits to adopting incentives
to encourage new or more
intense development on nonvacant lower-income sites.

Agenda Item #10.1.

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

We have added a new program,
which appears as H-L, related to
publicly owned sites. The
program commits to engaging
local affordable housing
developers, conducting studies of
the sites, and implementing an
action, all by 2025. Rezone
requirements have also been
included in the program, based
on HCD’s previous comment.

C Senate Bill 9 Implementation: The element relies on the implementation and usage of Senate Bill 9 to
accommodate a portion of the RHNA, promote a variety
of housing types and choices, and implement
affirmatively furthering fair housing requirements. While the element included program H-T to support lot splits, the element must include specific actions to implement
and incentive the usage of SB 9. This includes but is not limited to establishing a compliant ordinance,
development standards, incentives, and marketing and
outreach to developers and property owners.

We have updated program H-U
(formerly H-S) to include
incentives and outreach related
to SB 9 development generally.

Program H-V (formerly H-U)
includes an additional layer by
further incentivizing affordable
multi-unit developments in high
resource areas specifically. We
have committed the City to
adoption these additional
incentives by 2026 (as part of the
current zoning code update)
C Program H-C – Water Sewer Priority: For your
information, water and sewer service providers must
establish specific procedures to grant priority water and sewer service to developments with units affordable to
lower-income households. (Gov. Code, § 65589.7.) While
the element commits to granting priority water and sewer to developments with units affordable to lower income
households, local governments are also required to
immediately deliver the housing element to water and
sewer service providers. HCD recommends including a
program, policy, or commitment to deliver the adopted
housing element to water and sewer providers and
include a cover memo describing the City’s housing
element, including the City’s housing needs and regional housing need.

We have updated Program H-C
accordingly.

C Program H-B (Growth Management System): The element
notes that the City implemented a growth management
system which likely violates SB 330 (Housing Crisis Act, 2019, Gov. Code, § 66300). The element included a
program to remove the growth management system,
however included the timeline has “ongoing.” The
element should include a specific implementation
timeline for when this system will be removed and
We have updated Program H-B to
commit the City to implement
these changes immediately and
to update the revised zoning
code prior to the sunset of SB 330
in 2025.

Agenda Item #10.1.

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implementation should happen earlier in the planning
period (e.g., one year).

D While the element described various efforts to achieve public participation in the preparation of the housing
element update, it should also describe how comments
were considered and incorporated into the element.

We have expanded our analysis,
to include this info under
Workshop #1, each of the Focus
Group Meetings, and the Joint
Study Sessions.

For other events and efforts, this
information is already included in
the Draft. Please note that
Workshops #2 and #3 include
information related to the city
response to each commentor.

Additionally, each subheading
under Other Outreach Activities
identifies how input was
incorporated. Finally, in Appendix
B, the City has outlined the
changes that were made to the
Housing Element based on the
public comments on the Public
Review Draft (which are also
included in the Appendix),
including changes to programs,
corrected data, and the addition
of a new site (620 McCorkle).

Agenda Item #10.1.

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

DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT

DIVISION OF HOUSING POLICY DEVELOPMENT
2020 W. El Camino Avenue, Suite 500
Sacramento, CA 95833
(916) 263-2911 / FAX (916) 263-7453
www.hcd.ca.gov
April 7, 2023
Maya DeRosa, Planning & Building Director
Planning Department
City of St. Helena
1572 Railroad Avenue
St. Helena, CA 94574
Dear Maya DeRosa:

RE: City of St. Helena’s 6th Cycle (2023-2031) Revised Draft Housing Element Thank you for submitting the City of St. Helena’s (City) revised draft housing element that was received for review on February 7, 2023. Pursuant to Government Code section 65585, subdivision (b), the California Department of Housing and Community Development (HCD) is reporting the results of its review. HCD considered comments from Holland and Knight; David Kellogg and Generation Housing; pursuant to Government Code section 65585, subdivision (c).

The revised draft element addresses many statutory requirements described in HCD’s December 6, 2022 review; however, revisions will be necessary to comply with State Housing Element Law (Article 10.6 of the Gov. Code). The enclosed Appendix describes the revisions needed to comply with State Housing Element Law.

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

Agenda Item #10.1.

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Maya DeRosa, Planning & Building Director

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Otherwise, the local government’s housing element will no longer comply with State Housing Element Law, and HCD may revoke its finding of substantial compliance pursuant to Government Code section 65585, subdivision (i). Please be aware, if the City fails to adopt a compliant housing element within one year from the statutory deadline, the element cannot be found in substantial compliance until these rezones are completed.

Please be aware Chapter 654, Statues of 2022 (AB 2339), adds specificity on how cities and counties plan for emergency shelters and ensure sufficient and suitable capacity.

Future submittals of the housing element may need to address these statutory requirements. For additional information and timing requirements, please see HCD’s memo at https://www.hcd.ca.gov/sites/default/files/docs/planning-andcommunity/ab2339-notice.pdf.

Sincerely,
Paul McDougall
Senior Program Manager
Agenda Item #10.1.

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

A. Housing Needs, Resources, and Constraints

1. Affirmatively further[ing] fair housing in accordance with Chapter 15 (commencing with Section 8899.50) of Division 1 of Title 2…shall include an assessment of fair housing in the jurisdiction. (Gov. Code, § 65583, subd. (c)(10)(A).) Enforcement: While the element discussed compliance with existing fair housing laws, it must also address any past or current findings, lawsuits, enforcement actions, settlements or judgements related to fair housing or civil rights. For additional information, please see HCD’s prior review and pages 28-30 on HCD’s Affirmatively Furthering Fair Housing (AFFH) Guidance Memo at https://www.hcd.ca.gov/communitydevelopment/affh/index.shtml.

Concentration of Fair Housing Issues: The element was revised to briefly indicate that the east side of the City’s fair housing conditions are attributed to types of uses and zoning. However, to better formulate appropriate policies and programs, the element must still analyze trends, past and current policy efforts, and their effectiveness, neighborhood investment or disinvestment, local data and knowledge, and other relevant factors, particularly relative to equitable quality of life, resources, and strategies to address any inequities in quality of life. Please see HCD’s prior review for more information.

2. An inventory of land suitable and available for residential development, including vacant sites and sites having realistic and demonstrated potential for redevelopment during the planning period to meet the locality’s housing need for a designated income level, and an analysis of the relationship of zoning and public facilities and services to these sites. (Gov. Code, § 65583, subd. (a)(3).)
Agenda Item #10.1.

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Progress towards the Regional Housing Needs Allocation (RHNA): The element is crediting 87 units from the Hunter Subdivision Project towards the RHNA. HCD’s prior review found that the City must analyze the likelihood that this project will be built and units will be available during the planning period. Additionally, the prior review found that HCD has received public comments regarding the City’s ability to process and approve this project in a timely manner. Further, this analysis is particularly important given that the project has been pending since the 4th cycle planning period and the project will help the City provide housing and build a portion of their RHNA. The element was revised to state that the project will receive “planning approvals in the near future” and the next planning commission hearing is in February. This does not address HCD’s prior review. The element should clearly indicate timelines and remaining steps to fully entitle this project and demonstrate the likelihood these units will become available during the planning period. Lastly, the revised element is now crediting these units towards the City’s above moderate-income RHNA. However, HCD received public comments from the applicant indicating that 20 percent of the project will be affordable via deed restrictions in line with the City’s inclusionary requirements. The element could be revised to credit a portion of these units towards the City’s lower-income RHNA.

Based on the outcomes of a complete analysis, the element should include a program to monitor the progress of the project and take alternative action if the project is not entitled and permit are not issued in a timely manner.

Realistic Capacity: The element was revised to state that sites are assumed to develop at an average of 80 percent of maximum allowable densities and noted three projects that have developed between 50-100 percent of maximum allowable densities. First, while the element states that most sites were assumed to develop at 80 percent of maximum allowable densities, Sites 2, 4 and 5 have higher build out assumptions (e.g., 85-100 percent). The element should either adjust calculations in the inventory based on the analysis or provide a specific analysis supporting the higher assumptions.

Second, the analysis indicates that realistic capacity was based on past trends and notes three projects. However, the element should include all recent residential or multifamily projects to analyze all development activity by zone, size, allowable density, built density and affordability.

The element was revised to indicate that sites in the mixed-use zone do allow 100 percent commercial and that the City will implement Program H-P to incentivize residential development. However, to account for the likelihood of 100 percent nonresidential development, the analysis should discuss recent trends for development in the pertinent zone, including how often 100 percent nonresidential uses occur, then, adjust residential capacity assumptions and add or modify programs, if appropriate.

Nonvacant Sites: The element was revised with additional site characteristics, including owner interest and referenced past projects that redeveloped to residential development with similar existing uses. However, in addition to property owner interest and development trends, the analysis should consider additional factors that are indicative of redevelopment potential. For example, several sites seem to have low underutilization e.g., existing densities vs. allowable densities, floor area ratio (FAR), low lot coverage, Agenda Item #10.1.

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City of St. Helena’s 6th Cycle Revised Draft Housing Element Page 3 April 7, 2023
etc., The element could quantify this factor for applicable sites and include additional local or regional examples supporting the trend that underutilized sites will redevelop at the densities and uses identified in the inventory.

Lot Consolidation: The revised element now indicates that Sites 8 and 9 are made up of several parcels. The element should include an analysis evaluating whether these sites will need be consolidated to develop at the densities that were identified in the inventory. Based on a complete analysis, the element may need to add or modify programs with a commitment to facilitate and incentivize lot consolidation.

City-Owned Sites: HCD’s prior review found that the element must include an analysis supporting residential capacity assumptions, existing uses and any known conditions that would preclude development. The element was not revised to address this finding.

The element did reference that the City conducted feasibility studies for these sites.

Where appropriate, the analysis should incorporate more information regarding the outcomes of these feasibility studies to support the likelihood of development on these sites. Please see HCD’s prior review for additional information.

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

Infrastructure: The element was revised to state that adequate infrastructure is available contingent upon the implementation of infrastructure improvements identified in the City’s Integrated Utility master plan. However, the element must still include a program committing to actions and a timeline to make sufficient infrastructure and implement the necessary improvements to accommodate the RHNA. Please see HCD’s prior review for additional information.

3. An analysis of potential and actual governmental constraints upon the maintenance, improvement, or development of housing for all income levels, including the types of housing identified in paragraph (1) of subdivision (c), and for persons with disabilities as identified in the analysis pursuant to paragraph (7), including land use controls, building codes and their enforcement, site improvements, fees and other exactions required of developers, and local processing and permit procedures.. (Gov. Code, § 65583, subd. (a)(5).)
Land Use Controls: While the element was revised to include a list of all development standards by zone, it must evaluate lot coverage requirements and heights for impacts on achieving maximum densities, cost, feasibility and supply (number of units) of housing.

Agenda Item #10.1.

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Parking: The element was revised with an analysis evaluating the 1.5 parking space requirement for smaller bedroom types (i.e., studio and one-bedrooms). While the analysis found that these requirements are not a constraint on development due to the lack of available public transportation, requiring 1.5 parking spaces for a studio apartment is generally considered a constraint and can impact a project’s cost, supply (number of units), feasibility and ability to achieve maximum densities. The element should be revised with a program committing to reducing parking requirements.

Local Permit and Processing Procedures: HCD’s prior review found that multifamily housing is subject to a conditional use permit (CUP) and it is considered a constraint.

Additionally, HCD’s certification of the 5th cycle housing element on May 29, 2015 explicitly stated that for the City to remain in compliance, it must complete Program HE1.D which committed to eliminating use permit requirements for multifamily projects in the medium density residential district. Further, HCD’s records indicate that the City utilized state funding to remove or lessen discretionary review for multifamily housing (SB2 Planning Grants) and removing the use permit requirements for multifamily housing in certain zones (LEAP Planning Grants).

However, the element provides conflicting information. For example, the element’s review and revise section indicates that the City removed the CUP requirement for multifamily housing. Additionally, page 2-162 indicates that a CUP is a required permit, while page 2-160 notes that multifamily is only subject to design review. The element must reconcile this information and clearly indicate if multifamily housing is subject to CUP requirements and whether this constraint has been removed. If this constraint has not been fully addressed, the element must include a program committing to removing this constraint early in the planning period (e.g., one year).

Fees and Exactions: While the element now includes a listing of fees for a typical single family and multifamily development, the element should specifically evaluate impact fees e.g., parks and public safety for impacts on housing cost, supply, and feasibility.

Constraints on Housing For Persons with Disabilities: While the element now includes Program H-F committing to allowing group homes for seven or more persons similarly to multifamily uses, it must also commit to 1) allowing group homes of seven or more in all zones allowing residential uses and 2) permit these uses with objectivity and certainty similar to other residential uses of the same form.

Agenda Item #10.1.

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B. Housing Programs

1. Identify actions that will be taken to make sites available during the planning period with appropriate zoning and development standards and with services and facilities to accommodate that portion of the city’s or county’s share of the regional housing need for each income level that could not be accommodated on sites identified in the inventory completed pursuant to paragraph (3) of subdivision (a) without rezoning, and to comply with the requirements of Government Code section 65584.09. Sites shall be identified as needed to facilitate and encourage the development of a variety of types of housing for all income levels, including multifamily rental housing, factory-built housing, mobilehomes, housing for agricultural employees, supportive housing, single-room occupancy units, emergency shelters, and transitional housing. (Gov. Code, § 65583, subd. (c)(1).)
As noted in Finding A2, the element does not include a complete site analysis, therefore, the adequacy of sites and zoning were not established. Based on the results of a complete sites inventory and analysis, the City may need to add or revise programs to address a shortfall of sites or zoning available to encourage a variety of housing types. In addition, the element should be revised, as follows:

City-Owned Sites: While the element includes Program H-L (City-Owned Sites), the Program should be revised based on the outcomes of a complete analysis as noted in Finding A2. In addition, the Program should include steps and milestones beyond a request for proposal, including complying with the Surplus Land Act, facilitating all necessary entitlements, assisting with funding, issuing permits and alternative actions to identify other sites within a specified time if development does not proceed as anticipated. Finally, the program should include numeric objectives, including affordability, consistent with the assumptions in the sites inventory.

Permanent Supportive Housing: The element now includes Program H-F (Municipal Code Updates) to incorporate objective design standards for ministerial design review of multifamily uses. However, the Program should clarify permanent supportive housing pursuant to Government Code section 65651 will also be permitted without discretionary action.

2. Address and, where appropriate and legally possible, remove governmental and nongovernmental constraints to the maintenance, improvement, and development of housing, including housing for all income levels and housing for persons with disabilities. The program shall remove constraints to, and provide reasonable Agenda Item #10.1.

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accommodations for housing designed for, intended for occupancy by, or with supportive services for, persons with disabilities. (Gov. Code, § 65583, subd. (c)(3).) As noted in Finding A3 the element requires a complete analysis of potential governmental and nongovernmental constraints. Depending upon the results of that analysis, the City may need to revise or add programs and address and remove or mitigate any identified constraints.

3. Promote and affirmatively further fair housing opportunities and promote housing throughout the community or communities for all persons regardless of race, religion, sex, marital status, ancestry, national origin, color, familial status, or disability, and other characteristics... (Gov. Code, § 65583, subd. (c)(5).)
As noted in Finding A1, the element requires a complete AFFH analysis. Depending upon the results of that analysis, the City will need to add or revise programs. Goals and actions must specifically respond to the analysis and to the identified and prioritized contributing factors to fair housing issues and must be significant and meaningful enough to overcome identified patterns and trends.

Additionally, as found in HCD’s prior review, programs still should be revised with increased metrics and significant and meaningful actions (beyond the RHNA) to promote housing mobility (more choices and affordability across geographies) and new housing choices and affordability in higher opportunity and relatively higher income areas (e.g., missing middle housing types). Further, as found in HCD’s prior review, the element still must include significant and meaningful place-based strategies for community revitalization with actions targeting the southeast quadrant of the City to improve quality of life related to housing, transportation, safety, education, recreation, infrastructure, etc., and quantified metrics that target beneficial impacts for people, households and neighborhoods ( e.g., number of people or households assisted, number of housing units built, number of parks or infrastructure projects completed).

HCD will follow-up under a separate cover with additional information.

Agenda Item #10.1.

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Responses to HCD’s 60-day Comment Letter
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Comment
Section
Comment Revision
A-1 Enforcement: While the element
discussed compliance with existing fair
housing laws, it must also address any
past or current findings, lawsuits,
enforcement actions, settlements or
judgements related to fair housing or
civil rights. For additional information,
please see HCD’s prior review and
pages 28-30 on HCD’s Affirmatively
Furthering Fair Housing (AFFH)
Guidance Memo at
https://www.hcd.ca.gov/communitydevelopment/affh/index.shtml.

We have added information on a previous
settlement between the City and Esvin
Calderon in 2021 [page A-13] and claim filed in
the city in 2016 [page A-13] both based on fair
housing concerns.

A-1 Concentration of Fair Housing Issues:

The element was revised to briefly
indicate that the east side of the City’s
fair housing conditions are attributed
to types of uses and zoning. However,
to better formulate appropriate
policies and programs, the element
must still analyze trends, past and
current policy efforts, and their
effectiveness, neighborhood
investment or disinvestment, local
data and knowledge, and other
relevant factors, particularly relative to
equitable quality of life, resources, and
strategies to address any inequities in
quality of life. Please see HCD’s prior
review for more information.

We have added information on City efforts to
address fair housing concerns, including the
2018 St. Helena Housing Update Report [page
A-100] and Diversity, Equity, and Inclusion
Strategy [page A-101]., as well as additional
information under headings 4.2.5 and 4.2.6 on
page A-103.

A-2 Progress towards the Regional
Housing Needs Allocation (RHNA):

The element is crediting 87 units
from the Hunter Subdivision Project
towards the RHNA. HCD’s prior
review found that the City must
analyze the likelihood that this
project will be built and units will be
available during the planning period.

Additionally, the prior review found
that HCD has received public
comments regarding the City’s ability
to process and approve this project
in a timely manner. Further, this
analysis is particularly important
given that the project has been
pending since the 4th cycle planning
period and the project will help the
City provide housing and build a
portion of their RHNA. The element
We have included additional information on
progress and timelines for the Hunter
Subdivision Project [page 2-197]. We have also
added an objective to Program H-A, which
commits the City to supporting the timely
completion of the Hunter Subdivision Project
and alternative actions.

Agenda Item #10.1.

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Responses to HCD’s 60-day Comment Letter
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was revised to state that the project
will receive “planning approvals in
the near future” and the next
planning commission hearing is in
February. This does not address
HCD’s prior review. The element
should clearly indicate timelines and
remaining steps to fully entitle this
project and demonstrate the
likelihood these units will become
available during the planning period.

Lastly, the revised element is now
crediting these units towards the
City’s above moderate-income RHNA.

However, HCD received public
comments from the applicant
indicating that 20 percent of the
project will be affordable via deed
restrictions in line with the City’s
inclusionary requirements. The
element could be revised to credit a
portion of these units towards the
City’s lower-income RHNA. Based on
the outcomes of a complete analysis,
the element should include a
program to monitor the progress of
the project and take alternative
action if the project is not entitled
and permit are not issued in a timely
manner.

A-2 Realistic Capacity: The element was
revised to state that sites are
assumed to develop at an average of
80 percent of maximum allowable
densities and noted three projects
that have developed between 50-100
percent of maximum allowable
densities. First, while the element
states that most sites were assumed
to develop at 80 percent of
maximum allowable densities, Sites
2, 4 and 5 have higher build out
assumptions (e.g., 85-100 percent).

The element should either adjust
calculations in the inventory based
on the analysis or provide a specific
analysis supporting the higher
assumptions. Second, the analysis
indicates that realistic capacity was
based on past trends and notes three
projects. However, the element
should include all recent residential
We have added the following information:

Site 2 [page 2-201]: Added details regarding
the 2015 site feasibility and capacity analysis
which found the site can accommodate the
proposed number of housing units on the
site.

Site 4 [page 2-207]: Revised to propose a
total of four housing units on the site,
equaling 80 percent of the maximum allowed
density.

Site 5 [page 2-209]: Added details regarding
non-profit ownership’s plans to develop an
affordable housing development on the site
that is equal to greater than 100 percent of
the maximum allowed density of the site,
including referencing the allowed density
bonus for a 100 percent affordable housing
project and the feasibility analysis conducted
by the non-profit.

Agenda Item #10.1.

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Responses to HCD’s 60-day Comment Letter
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or multifamily projects to analyze all
development activity by zone, size,
allowable density, built density and
affordability.

The element was revised to indicate
that sites in the mixed-use zone do
allow 100 percent commercial and
that the City will implement Program
H-P to incentivize residential
development. However, to account
for the likelihood of 100 percent
nonresidential development, the
analysis should discuss recent trends
for development in the pertinent
zone, including how often 100
percent nonresidential uses occur,
then, adjust residential capacity
assumptions and add or modify
programs, if appropriate.

A-2 Nonvacant Sites: The element was
revised with additional site
characteristics, including owner
interest and referenced past projects
that redeveloped to residential
development with similar existing
uses. However, in addition to
property owner interest and
development trends, the analysis
should consider additional factors
that are indicative of redevelopment
potential. For example, several sites
seem to have low underutilization
e.g., existing densities vs. allowable
densities, floor area ratio (FAR), low
lot coverage, etc., The element could
quantify this factor for applicable
sites and include additional local or
regional examples supporting the
trend that underutilized sites will
redevelop at the densities and uses
identified in the inventory.

We have added additional regional examples of
redevelopment of nonvacant sites for current
projects in the cities of Calistoga and Napa
[page 2-205]. We have also, added additional
statements of other underutilized factors for
each of the non-vacant sites [page 2-211 to
2-223]
A-2 Lot Consolidation: The revised
element now indicates that Sites 8
and 9 are made up of several parcels.

The element should include an
analysis evaluating whether these
sites will need be consolidated to
develop at the densities that were
identified in the inventory. Based on
a complete analysis, the element
may need to add or modify programs
We have added a statement clarifying that the
parcels making up Site 8 and Site 9 are under
single ownership and development would not
be dependent upon lot consolidation [pages 2-
215 and 2-217].

We have added program H-ZZ as follows:

H-ZZ Lot Consolidation
To expand opportunities for additional
Agenda Item #10.1.

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Responses to HCD’s 60-day Comment Letter
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with a commitment to facilitate and
incentivize lot consolidation.
affordable housing, the City will encourage the
consolidation of small parcels to accommodate
larger-scale and higher density developments
that are compatible with existing
neighborhoods. The sites inventory includes
five parcels equating to 39 lower- and 39
moderate-income RHNA units. These sites were
identified based on common ownership and
contiguous lots. While all five parcels are within
moderate resource areas, two of these parcels
(site 9) are located on the western portion of
the city, an area with fewer fair housing issues,
and adjacent to Spring Street in proximity to
high-quality transit opportunities.

While these parcels will be processed by-right
pursuant to Gov. Code section 65583(c)), the
City will also implement other efforts to
facilitate and encourage lot consolidation.

Objectives:

Post the sites on the City’s website by October
2023 and provide list to interested developers
when requested, and review annually for
accuracy
Develop and implement incentives for lot
consolidation by January 2024 such as fee
waivers, reduced development fees, expedited
permit processing, greater density bonus
incentives, and modifications to parking, height,
or setback standards
Facilitate lot consolidation for high density
residential developments by providing
appropriate assistance to developers to
encourage negotiations between property
owners
Encourage the development of 39 lower- and
39 moderate income units during the planning
period.

To increase housing mobility and opportunities
in areas where fair housing issues are less
concentrated, encourage the development of
15 lower- and 15 moderate-income units on the
western portion of the City
A-2 City-Owned Sites: HCD’s prior review
found that the element must include
an analysis supporting residential
capacity assumptions, existing uses
and any known conditions that would
preclude development. The element
We have added details of the 2015 site
feasibility and capacity analysis which
evaluated site capacity for all three of the
proposed City-owned sites. We have also
Incorporated information for each of the three
sites on total housing unit capacity, lot
Agenda Item #10.1.

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Responses to HCD’s 60-day Comment Letter
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was not revised to address this
finding. The element did reference
that the City conducted feasibility
studies for these sites. Where
appropriate, the analysis should
incorporate more information
regarding the outcomes of these
feasibility studies to support the
likelihood of development on these
sites. Please see HCD’s prior review
for additional information.
coverage, parking, environmental sensitives on
site, and service connection obstacles from the
2015 analysis [pages 2-199 to 2-204].

A-2 Sites Inventory Electronic Form:

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

Noted
A-2 Infrastructure: The element was
revised to state that adequate
infrastructure is available contingent
upon the implementation of
infrastructure improvements
identified in the City’s Integrated
Utility master plan. However, the
element must still include a program
committing to actions and a timeline
to make sufficient infrastructure and
implement the necessary
improvements to accommodate the
RHNA. Please see HCD’s prior review
for additional information.

We have clarified that the RHNA allocation is
within buildout of the Master Plan and that all
improvements would not impede housing
construction and would be constructed on the
adopted CIP schedule. [2-227 to 2-230]
A-3 Land Use Controls: While the
element was revised to include a list
of all development standards by
zone, it must evaluate lot coverage
requirements and heights for impacts
on achieving maximum densities,
We have revised our analysis to include an
analysis of height and lot coverage [beginning
on page 2-137 just before the development
standards table], as well as new program
actions in Program H-N.

Agenda Item #10.1.

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New Text, page 2-137 to 2-138
Development standards related to maximum
lot coverage and height pose potential
constraints to multifamily affordable housing
development. Currently the City allows 45
percent lot coverage and a maximum height of
30 feet in the MR and HR zones. Due to the
potential to constraint affordable housing
development, the City has included actions in
Program H-N: Zoning to Facilitate Higher
Density Housing that commit the City to
increasing lot coverage to 55 percent and
maximum height to 42’ (three stories) in the HR
zone and on multifamily sites in the MR zone.

Please note that the MR zone is a single-family
zone, but the zoning code has been updated to
allow multifamily uses on housing opportunity
sites identified in the 5th Cycle Housing
Element Update. Additionally, the program
commits the City to allowing minor
modifications to these standards that can be
approved by the Community Development
Director without a public hearing. Minor
modifications should include up to 10 percent
modification to maximum lot coverage and up
to five percent (or two feet, whichever is
greater) modification in maximum height.

New Actions: Program H-N: Zoning to
Facilitate Higher Density Housing
The City shall revise maximum lot coverage to
55 percent and maximum height to 42 feet in
the HR zone and on multifamily sites in the MR
zone.

The City shall revise the zoning code to allow
minor modifications of up to 10 percent
increase in lot coverage standards and 5
percent (or two feet, whichever is greater) in
maximum height. Minor modifications shall be
approved by the Community Development
Director without a public hearing.

A-3 Parking: The element was revised
with an analysis evaluating the 1.5
parking space requirement for
smaller bedroom types (i.e., studio
and one-bedrooms). While the
analysis found that these
requirements are not a constraint on
development due to the lack of
available public transportation,
We have revised our analysis to identify
parking for multifamily developments with
small unit sizes as a constraint. The revisions
are shown in track changes below. We have
also included a new program action related to
parking standards in Program H-N.

Revised text, page 2-153, above Table 35
The City of St. Helena’s parking standards do
Agenda Item #10.1.

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requiring 1.5 parking spaces for a
studio apartment is generally
considered a constraint and can
impact a project’s cost, supply
(number of units), feasibility and
ability to achieve maximum densities.

The element should be revised with a
program committing to reducing
parking requirements.
not impose undue constraints to development
of multifamily uses with two or more
bedrooms. As shown in Error! Reference
source not found.Table 35, when compared to
other nearby jurisdictions, St. Helena’s housing
requirements are not only less restrictive, but
much less complex. Additionally, the City is
currently reevaluating its parking requirements
for residential uses as part of the ongoing
Comprehensive Zoning Code Update. However,
parking standards for multifamily uses with
three or more studio or one-bedroom units
require 1.5 parking spaces per unit. This
requirement is a constraint to development of
smaller unit multifamily uses. Program H-N
commits the City to limiting parking
requirements for these uses to one space per
unit.

Program H-N: Zoning to Facilitate Higher
Density Housing [new action]
The City shall reduce parking requirements for
multifamily uses with three or more units to
require one parking space for studio or onebedroom units.

A-3 Local Permit and Processing
Procedures: HCD’s prior review
found that multifamily housing is
subject to a conditional use permit
(CUP) and it is considered a
constraint. Additionally, HCD’s
certification of the 5th cycle housing
element on May 29, 2015, explicitly
stated that for the City to remain in
compliance, it must complete
Program HE1.D which committed to
eliminating use permit requirements
for multifamily projects in the
medium density residential district.

Further, HCD’s records indicate that
the City utilized state funding to
remove or lessen discretionary
review for multifamily housing (SB2
Planning Grants) and removing the
use permit requirements for
multifamily housing in certain zones
(LEAP Planning Grants).

However, the element provides
conflicting information. For example,
the element’s review and revise
section indicates that the City removed
We have revised our analysis to summarize
allowed uses in the MR zone, and to clear up
confusion related to implementation of the 5th
cycle program discussed (see below). We have
also included a new program action committing
the City to allowing duplexes and triplexes, as
well as density ranges from 5.1 to 16 du/ac in
the MR zone without a CUP.

We have added information that the City is in
the process of adopting a new Zoning
Ordinance (hearings in Fall 2023) 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, several
programs, including H-BB, H-EE, and H-XX
would implement place-based strategies to
engage and work with the more diverse and
older populations in the eastern portion of the
city due to the historic development patterns.

New text page 2-166 to 2-167:

Currently (2023) the MR zone does not allow
for multifamily uses without a conditional use
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the CUP requirement for multifamily
housing. Additionally, page 2-162
indicates that a CUP is a required
permit, while page 2-160 notes that
multifamily is only subject to design
review. The element must reconcile
this information and clearly indicate if
multifamily housing is subject to CUP
requirements and whether this
constraint has been removed. If this
constraint has not been fully
addressed, the element must include a
program committing to removing this
constraint early in the planning period
(e.g., one year).

Additionally, the element should
address public comments on this
revised draft submittal and discuss
compliance with the Permit
Streamlining Act and intersections with
CEQA and timing requirements,
including streamlining determinations
and add or modify programs as
appropriate.
permit (CUP), with the exception of 5th Cycle
Housing Element opportunity sites. Although
the MR zone is primarily a single-family zone,
the requirement for a CUP in this zone
constrains the development of smaller
multifamily uses. Program H-N commits the
City to allowing duplexes and triplexes and a
density range of 5.1 to 16 dwelling units per
acre in the MR zone without a CUP.

Please note: the City implemented 5th Cycle
Housing Element program HE1.D which
committed the City to eliminating use permit
requirement for multifamily projects on
Housing Opportunity sites (Key Housing Sites)
in the medium density residential zone. Section

17.40.020 was amended to permit the
following:

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)
Further, The City has received SB 2 and LEAP
grants from the State of California to assist with
encouraging and streamlining affordable
housing development in the city. The City has
applied these funds to the Comprehensive
Zoning Code Update currently underway. The
Draft Update works to overcome constraints
and encourage development by incorporating
objective design standards for residential
development and removing CUP requirements
for duplexes and triplexes and densities of 5.1
to 16 du/ac in the MR zone, among other
efforts.

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In an effort to implement this Goal, the City has
removed the Use Permit requirement for multifamily housing in the High Density Residential (HR) land use designationzone and all of the
Housing Opportunity Sites (Key Housing Sites,
see Section 17.40.020(N)) located within the
Medium Density Residential (MR) zoneother
designations and has established a streamlined
approval process consistent with SB35 and
SB330. Further, as mentioned above,
affordable housing units are not subject to the
GMS Ordinance limitations.

Program H-N: Zoning to Facilitate Higher
Density Housing [new action]
The City shall revise Section 17.40.020 to allow
duplexes and triplexes and densities of 5.1 to
16 dwelling units per acres in the MR zone
without a conditional use permit.

We have also added program H-AAA to address
compliance with the Permit Streamlining Act as
follows:

H-AAA Permit Streamlining Act
The City shall amend the Municipal Code to
specify who is responsible for making CEQA
determinations and within the timeframes of
PRC 21080.1 and PRC 21080.2; and
determination of when the PSA is triggered per
Government Code 65950(a)(5) the Permit
Streamlining Act (PSA).

Objective:

Amend the municipal code for compliance with
State law within 18 months of adoption of the
Housing Element
Timeframe:

Within 18 months of adoption of the 2023-
2031 Housing Element
A-3 Fees and Exactions: While the
element now includes a listing of fees
for a typical single family and
multifamily development, the
element should specifically evaluate
impact fees e.g., parks and public
safety for impacts on housing cost,
supply, and feasibility.

We have revised the summary of fees and
exactions to include the following analysis
immediately following Table 36 on page 2-159.

New Text, page 2-159
City impact fees are included in Table 36 above.

Among these, the costliest fee is the Parks fee
of $7.16 per square foot. These funds are used
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to develop and maintain City parks, a critical
resource in the community. The City’s
wastewater impact fee ($0.45 per square foot),
drainage system fee ($0.73 per square foot)
and public safety fee ($1.04 per square foot)
are particularly low. Further, the City’s civic
facilities and transportation fees are both
under $2 per square foot. Importantly, City
impact fees for multifamily listed in Table 36
are based on an eight-unit development, as
explained previously, and have a lower per unit
cost than City impact fees shown for a typical
single-family use. These impact fees are based
on the City’s actual costs and are reevaluated
and revised each year. The City’s impact fees
do not impose undue impacts to housing cost,
supply, and feasibility, and are not a constraint
to the development of housing.

A-3 Constraints on Housing For Persons
with Disabilities: While the element
now includes Program H-F
committing to allowing group homes
for seven or more persons similarly
to multifamily uses, it must also
commit to 1) allowing group homes
of seven or more in all zones allowing
residential uses and 2) permit these
uses with objectivity and certainty
similar to other residential uses of
the same form.

We have revised the relevant action in Program
H-F to include this specific language. Revisions
are shown in track changes below.

Revised Action, Program H-F
Define and aAllow for residential care homes
facilities of six or fewer in zones allowing
single-family uses, subject only to the
requirements of single-family uses, in
compliance with State law (HSC § 1568.0831);
California Government Code Section 65583and
permit facilities with seven or more beds in
zones allowingall multifamilyresidential
useszones , with objectivity and certainty
similar to other residential uses of the same
formsubject only to the requirements
multifamily uses.

B-1 Replacement Housing
Requirements: The housing element
must include a program to provide
replacement housing. Absent a
replacement housing program, these
sites are not adequate sites to
accommodate lower-income
households. The replacement
housing program must adhere to the
same requirements as set forth in
Government Code section 65915,
subdivision (c)(3).

We have added a new program, H-YY, as
follows:

Replacement Unit Program
The City will adopt a policy and will require
replacement housing units subject to the
requirements of Government Code section
65915, subdivision (c)(3) on sites identified in
the site inventory when any new development
(residential, mixed-use or nonresidential)
occurs on a site that is identified in the
inventory meeting the following conditions:
• currently has residential uses or within
the past five years has had residential
uses that have been vacated or
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demolished, and
• was subject to a recorded covenant,
ordinance, or law that restricts rents to
levels affordable to persons and
families of low or very low-income, or
• subject to any other form of rent or
price control through a public entity’s
valid exercise of its police power, or
• occupied by low or very low-income
households
Objectives:

In order to mitigate the loss of affordable
housing units, require new housing
developments to replace all affordable housing
units lost due to new development.

Implements policies:

HE3.1
HE6.1
Who is responsible:

Planning Department
Funding: General Fund
Timeframe:

Implement: immediately
Adopt policy:
by January 31, 2024
B-1 City-Owned Sites: While the element
includes Program H-L (City-Owned
Sites), the Program should be revised
based on the outcomes of a
complete analysis as noted in Finding
A2. In addition, the Program should
include steps and milestones beyond
a request for proposal, including
complying with the Surplus Land Act,
facilitating all necessary
entitlements, assisting with funding,
issuing permits and alternative
actions to identify other sites within
a specified time if development does
not proceed as anticipated. Finally,
the program should include numeric
objectives, including affordability,
consistent with the assumptions in
the sites inventory.

We have revised program H-L as follows:

H-L City- Oowned Sites
The City will maintain compliance with the
Surplus Land Act throughout the 2023-2031
Housing Element planning period. The City will
assess the appropriateness of and consider
implementing the following: outreach
opportunities with housing developers,
requests for proposals, development incentives,
fee waivers, priority processing, and financial
assistance (when available) to facilitate and
incentivize developers to develop housing units
on City-owned sites.

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studies of City owned sites included in the sites
inventor to determine the most efficient use for
housing. These include sites 1, 2, and 3.

Through this process, the City shall engage local
affordable housing developers to determine
site constraints and potential policies to
meaningfulmeaningfully incentivize affordable
housing development on these sites. The City
shall proceed with the findings for housing
development by 20252026. The City anticipates
two-and-a-half years to enter into an Exclusive
Negotiation Agreement (Fall 2026), and oneand-a-half additional years for land use entitlements and development agreements
(Spring 2028).

City owned sites included in the inventory (sites
1-3) shall be rezoned incompliance with Govt.

Code Section 65583.2(h) and (i) within three
years of the adoption deadline (by January 31,
2026.

Objectives:

Engage local affordable housing developers
immediately
Study city owned sites to determine the most
efficient use for affordable housing
development within the first year following
adoption
By 2026, implement an action plan to sell, or
release an RFP to develop, City owned land for
affordable housing development based on the
findings of the conducted studies. Through the
action plan, establish and implement a variety
of incentives to facilitation housing
development.

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walkability and environmental scores are more
positive
B-1 Permanent Supportive Housing: The
element now includes Program H-F
(Municipal Code Updates) to
incorporate objective design
standards for ministerial design
review of multifamily uses. However,
the Program should clarify
permanent supportive housing
pursuant to Government Code
section 65651 will also be permitted
without discretionary action.

We have included a new program action in
Program H-F with this language, as shown
below.

New Action, Program H-F
Allow permanent and supportive housing
pursuant to Government Code section 65661
without discretionary action.

B-2 As noted in Finding A3 the element
requires a complete analysis of
potential governmental and
nongovernmental constraints.

Depending upon the results of that
analysis, the City may need to revise
or add programs and address and
remove or mitigate any identified
constraints.

See response to A3 above.

B-3 As noted in Finding A1, the element
requires a complete AFFH analysis.

Depending upon the results of that
analysis, the City will need to add or
revise programs. Goals and actions
must specifically respond to the
analysis and to the identified and
prioritized contributing factors to fair
housing issues and must be
significant and meaningful enough to
overcome identified patterns and
trends.

Further, as found in HCD’s prior
review, the element still must include
significant and meaningful placebased strategies for community revitalization with actions targeting
To respond the HCD’s AFFH evaluation of the
Housing Element implementation programs,
we have added actions, place-based
strategies, and/or metrics and milestones to
the following programs:

H-XX: Fair Housing Provider
H-E: Streamline Special Needs Housing
H-H: Workforce and Farmworker Housing
H-I: ADU Workforce Housing Incentive
Program
H-W: Missing Middle Housing
H-LL: Special Needs Housing Opportunities
H-GG: Affordable Homeownership
H-V: Multi-unit Development in High
Resource Areas
H-Q: Direct Assistance for ADU Development
H-R: Place-based ADU Strategy
H-A: Sites Inventory
H-K: Nonvacant Sites
H-JJ: Housing Coordinator
H-BB: Special Housing Needs Rehabilitation
H-AA: Vacation Rentals
H-X: Condominium Conversions
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the southeast quadrant of the City to
improve quality of life related to
housing, transportation, safety,
education, recreation, infrastructure,
etc., and quantified metrics that
target beneficial impacts for people,
households and neighborhoods ( e.g.,
number of people or households
assisted, number of housing units
built, number of parks or
infrastructure projects completed).

HCD will follow-up under a separate
cover with additional information.

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0.Introduction
Insert Cover over this page. Do not alter any Heading 1s underneath the covers.

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i
Table of Contents
Introduction ............................................................................................................................. iii

1. Policy Document
Policy Document Contents .................................................................................................................................................................... 1-1 Organization of the Policy Document.................................................................................................................................................... 1-3 Key Findings and Recommendations..................................................................................................................................................... 1-5 Goals, Policies, and Implementation Programs..................................................................................................................................... 1-9 Quantified Objectives....................................................................................................................................................................... 1-4943

2. Needs Assessment
Needs Assessment Contents ................................................................................................................................................................. 2-1

1. Introduction................................................................................................................................................................................ 2-7

2. Review of the Existing Housing Element .............................................................................................................................. 2-3535

3. Demographic and Economic Trends ..................................................................................................................................... 2-5958

4. Population and Employment Projections.............................................................................................................................. 2-8180

5. Housing Conditions.............................................................................................................................................................. 2-8584

6. Housing Market Conditions.................................................................................................................................................. 2-9897

7. Special Housing Needs..................................................................................................................................................... 2-109108

8. Non-governmental and Governmental Constraints.......................................................................................................... 2-131130

9. Opportunities for Energy Conservation............................................................................................................................. 2-190169

10. Zoning for a Variety of Housing Types.............................................................................................................................. 2-192171

11. Housing Resources........................................................................................................................................................... 2-198177 Appendix A: Affirmatively Further Fair Housing (AFFH)
AFFH Contents ......................................................................................................................................................................................A-1

1. Introduction................................................................................................................................................................................A-5

2. Summary of Fair Housing Issues.................................................................................................................................................A-9

3. Segregation and Integration Patterns and Trends....................................................................................................................A-14

4. Local Area of Knowledge ...................................................................................................................................................A-10099

5. Sites Inventory Analysis....................................................................................................................................................A-103101

6. Contributing Factors.........................................................................................................................................................A-110107 Appendix B: Comments on the Public Review Draft Housing Element.................................. B-1 Agenda Item #10.1.

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Introduction
Purpose of the Element
Since 1969, California has required that all local governments (cities and counties) adequately plan to meet the housing needs of everyone in the community. California’s local governments meet this requirement by adopting housing plans as part of their “general plan” (also required by the state). General plans serve as the local government’s "blueprint" for how the city and/or county will grow and develop and include seven required elements: land use, transportation, conservation, noise, open space, safety, and housing. The law mandating that housing be included as an element of each jurisdiction’s general plan is known as “housing-element law.” California’s housing-element law acknowledges that, in order for the private market to adequately address the housing needs and demand of Californians, local governments must adopt plans and regulatory systems that provide opportunities for (and do not unduly constrain), housing development. As a result, housing policy in California rests largely upon the effective implementation of local general plans and, in particular, local housing elements.

Although the Housing Element is one of seven required elements of the general plan, it has several unique requirements that set it apart from the other six. State law (Government Code Section 65580 (et seq.)) specifies in detail the topics that the housing element must address and sets a schedule for required updates every eight years. The housing element is also the only element reviewed and certified by the State for compliance with State law. Every jurisdiction in the State of California is required to submit a Housing Element to the Department of Housing and Community Development (HCD) for review and certification.

The 2023-2031 Housing Element establishes a comprehensive plan to address housing needs in St. Helena over the eight-year planning period between January 31, 2023 and January 31, 2031. The Housing Element sets the community goals and policies surrounding the development, rehabilitation, and preservation of housing units to meet the needs of St. Helena residents (present and future. St. Helena is a member of the Association of Bay Area Association of Governments and, therefore, is required submit an updated Housing Element to HCD by January 31, 2023.

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Housing Element Update Components
The 2023-2031 Housing Element Update consists of two parts; the Housing Needs Assessment, and this Housing Element Policy Document.

1. The Policy Document states goals, policies,
implementing program, and quantified objectives for the development, rehabilitation, and preservation of housing.

The Policy Document is the action plan that reacts directly to the findings of the Housing Needs Assessment and input
from the community. The City will implement the actions specified in the Policy Document throughout the planning period.

2. The Needs Assessment identifies and analyzes the
existing and projected housing needs, provides a list of sites for housing development that are adequate to accommodate the City’s regional housing needs allocation, documents constraints to housing production, and analyzes fair housing.

In short, the Needs Assessment provides the context for the City's housing action plan.

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1 1.Policy Document
.

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1-1
Policy Document Contents
Organization of the Policy Document .................................................................................... 1-3 Key Findings and Recommendations ..................................................................................... 1-5 Review of Existing Housing Element ..................................................................................................................................................... 1-5 Demographic and Economic Trends ...................................................................................................................................................... 1-5 Housing Conditions............................................................................................................................................................................... 1-5 Special Housing Needs.......................................................................................................................................................................... 1-6 Non-governmental and Governmental Constraints............................................................................................................................... 1-7 Sites Inventory and Zoning for a Variety of Housing Types ................................................................................................................... 1-7 Affirmatively Furthering Fair Housing.................................................................................................................................................... 1-8 Goals, Policies, and Implementation Programs ..................................................................... 1-9 Goal 1 A Diversity of Housing to Meet Local Needs ......................................................................................................................... 1-9 Goal 2 High-Quality Neighborhoods with a Balance of Housing Types ...................................................................................... 1-2119 Goal 3 Conservation of Existing Housing.................................................................................................................................... 1-3026 Goal 4 Assistance to Support Affordable Housing ...................................................................................................................... 1-3430 Goal 5 Resource Conservation.................................................................................................................................................... 1-4137 Goal 6 Affirmatively Furthering Fair Housing.............................................................................................................................. 1-4440 Quantified Objectives ....................................................................................................... 1-4943 Quantified Objectives by Type......................................................................................................................................................... 1-4943 Quantified Objectives Summary Table............................................................................................................................................. 1-5044 Agenda Item #10.1.

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Organization of the Policy Document
The 2023-2031 Housing Element Policy Document includes six goals, supported by policies and implementation programs that aim to address identified housing needs during the planning period. The goals, policies, and programs of the Housing Element establish a policy framework to guide city decision-making to meet identified housing needs. The Policy Document is organized under the following goal titles:

1. A Diversity of Housing to Meet Local Needs

2. High-Quality Neighborhoods with a Balance of Housing

3. Conservation of Existing Housing

4. Assistance to Support Affordable Housing

5. Resource Conservation

6. Affirmatively Further Fair Housing
Goals
The housing goals are articulated as general “end condition statements,” which describe a desired outcome or end state. The goals do not contain an action verb as they reflect a final statement of what the city hopes to achieve. Goals describe ideal future conditions for a topic and tend to be general and broad in nature. How the goal will be achieved is established via the applicable policies and programs.

Policies
Policies are statements on the position the City takes to implement a goal. Policies contained in the Housing Element are important statements as they provide a clear and unambiguous statement that guides a specific course of action for decision-makers to achieve a desired goal. Future actions and development must be consistent with these policies.

Programs
While many policies can be implemented as part of standard City operations, some policies require specific programs to assure their implementation. Housing programs define the specific actions the City will undertake to achieve the stated goals and policies.

For more information, please see the Policy Document Reader's Guide diagrams on the following page.

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Reader's Guide: Goals and Policies
Reader's Guide: Implementation Programs
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Key Findings and Recommendations
The following section summarizes the key findings in the Housing Needs Assessment and references the resulting programs.

Review of Existing Housing Element
Since the City of St. Helena adopted the Housing Element Update in 2014, the City successfully implemented a majority of the Housing Element implementation programs. Between 2014 and 2021, the City was successful in obtaining additional funding for affordable housing production, preserving existing affordable housing units, and promoting the expansion of multifamily and mixed use housing through the recent 2040 General Plan Update. The City also successfully implemented programs incentivizing and streamlining affordable housing development and revised development standards related to second units for state compliance. While the 2040 General Plan Update process required significant staff time and delayed implementation of some Municipal Code amendments, the City is currently (2022) undertaking a zoning code update that will address the remaining code amendments implementation measures during the 6th cycle. As the code update draws to its conclusion, the City will have more resources available to implement the remaining implementation actions, which have been continued and expanded in the 2023-2031 Housing Element.

Demographic and Economic Trends
Generally, the population of the Bay Area continues to increase because of natural growth and the strong economy drawing new residents to the region. The population of St. Helena increased by 2.1 percent from 2000 to 2020, which is lower than the growth rate of the Bay Area. In 2019, St. Helena’s youth population under the age of 18 was 1,050 and senior population 65 and older was 1,636. These age groups represent 17.2 percent and 26.8 percent, respectively, of St. Helena’s population. Program H-A commits the City to providing sufficient housing sites to meet the needs of the population and Programs H-H and H-I address workforce housing.

Housing Conditions
Number of Homes. The number of new homes built in the Bay Area has not kept pace with the demand, resulting in longer commutes, increasing prices, and exacerbating issues of displacement and homelessness.

The number of homes in St. Helena increased, 4.4 percent from 2010 to 2020, which is above the growth rate for Napa County and below the growth rate of the region’s housing stock during this time period. Program H-N, H-O work to facilitate higher density development, and H-P works to provide residential development opportunities in commercial areas through the implementation of mixed-use zoning.

Home Prices. A diversity of homes at all income levels creates opportunities for all St. Helena residents to live and thrive in the community.

Agenda Item #10.1.

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• Ownership. The largest proportion of homes had a value in the range of $1 million-$1.5 million in 2019. Home prices increased by 118.2 percent from 2010 to 2020. Program H-GG works to increase affordable homeownership opportunities in St. Helena through the pursuit of mortgage credit certificates.
• Rental Prices. The typical contract rent for an apartment in St. Helena was $1,470 in 2019. Rental prices increased by 15.7 percent from 2009 to 2019. To rent a typical apartment without cost burden, a household would need to make $59,160 per year. Programs H-DD, H-EE, H-FF, and H-HH work to assist the development of affordable housing. Program H-II includes a commitment to support the Housing Choice Voucher program and to support efforts to expending funding for the program.

Housing Type. It is important to have a variety of housing types to meet the needs of a community today and in the future. In 2020, 63.9 percent of homes in St. Helena were single family detached, 6.1 percent were single family attached, 6.2 percent were small multifamily (2-4 units), and 18.4 percent were medium or large multifamily (5+ units). Between 2010 and 2020, the number of single-family units increased more than multifamily units. Generally, in St. Helena, the share of the housing stock that is detached single family homes is above that of other jurisdictions in the region. Programs aimed at addressing the lack of affordable housing types include H-A, H-B, H-E, H-H, H-I, H-J, H-M, H-P, and H-W.

Cost Burden. A household is considered “cost-burdened” if it spends more than 30 percent of its monthly income on housing costs, while those who spend more than 50 percent of their income on housing costs are considered “severely cost-burdened.” In St. Helena, 21.1 percent of households spend 30-50 percent of their income on housing, while 16.6 percent of households are severely cost burden and use the majority of their income for housing. Lower-income, Latinx, and large households are disproportionally impacted by housing cost burdens. Programs including H-E, H-H, H-M, H-DD, H-EE, and H-FF work to reduce the costs of production or create more affordable housing opportunities by streamlining development approvals, incentivizing affordable housing types, generating funds, and reducing fees.

Special Housing Needs
People with Disabilities. In St. Helena, people with disabilities make up around 12 percent of the total population. Children (under 18) make up around 38 percent of the developmentally disabled population, while adults make up around 62 percent. Most of the developmentally disabled population reside with their parent, family, or guardian.

Senior Households. Senior households represent a higher percentage of the total households in St. Helena, at about 39 percent of households in the city. There is a large income disparity between seniors who rent housing and seniors who own their home. Most seniors who rent make 0 to 30 percent of AMI, and sixty-eight percent of senior households in this income category have housing cost burdens. By contrast, most seniors who own make greater than 100 percent of AMI; thirteen percent of senior households in this category experience housing cost burdens.

Agenda Item #10.1.

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Farmworkers. The number of permanent farm workers in Napa County has increase from 2,916 in 2002 to 4,290 in 2017, while the number of seasonal farm workers decreased from 7,855 to 5,734. In St. Helena, the migrant worker student population totaled 20 during the 2019-20 school year, an increase of two students since the 2016-17 school year.

Persons Experiencing Homelessness. According to a Point in Time Count provided by the Chief of Police, there is one homeless person who resides in St. Helena. Countywide, many of the persons experiencing homelessness report chronic substance abuse or mental illness.

Programs H-E, H-H, H-I, H-BB, H-FF, H-KK, H-LL, H-NN, H-OO respond to the city's special housing need by streamlining development review, incentivizing development, or providing directly funding for construction or rehabilitation of housing for those with special needs.

Non-governmental and Governmental Constraints
The non-governmental constraints that restrict building in St. Helena include the price of land, cost of construction, flooding, conservation easements and long-term vineyard leases, and a lack of rental accessory dwelling units. The governmental controls analyzed in this section were land use controls, codes and enforcements, on-and off-site improvements, fees and exactions, processing and permit procedures, and regulations affecting housing for persons with disabilities. The land use controls including zoning and current General Plan land use designations do not constrain residential development; however, some changes are necessary to streamline the design review process. Additionally, water and sewer access are constrained, and the City must prioritize service for proposed development that includes housing for lower-income households (Program H-C). Additionally, St. Helena must also amend the Zoning Code to allow for low barrier navigation centers, consistent with State law. See Program H-F for more information.

Sites Inventory and Zoning for a Variety of Housing Types Sites Inventory. In combination with the City’s pending projects and ADU development trends, the sites inventory provides adequate sites to meet the City’s RHNA allocation and buffer requirements. St. Helena received a RHNA of 256 total units distributed across very low-income (104 units), low-income (59 units), moderate-income (26 units), and above moderate-income (67 units) categories. A total of 83 lower income housing units can be accommodated on City-owned properties and 332 total housing units can be accommodated on vacant and non-vacant sites. Multiple property owners of vacant and non-vacant sites are supportive of and interested in housing development on their properties. See Program H-A for more information.

Zoning for a Variety of Housing Types. St. Helena’s Zoning Code allows for a variety of housing types in the City including multiple-family units, transitional and supportive housing, single-room occupancy units, manufactured and mobile homes, and accessory dwelling units. However, to comply with Section 65915 through 65918 of the California Government Code, St. Helena should amend the Zoning Code to reflect the new Agenda Item #10.1.

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maximum density bonus provisions that were adopted by the State in 2020. Program H-F commits the City to updating the Zoning Code for compliance with State law.

Affirmatively Furthering Fair Housing
Concentrations of Lower- and Moderate-Income Earning Populations. In St. Helena, residents with low and moderate household incomes are concentrated in the eastern portion of the city. The Housing Element ensures available land to accommodate all income levels on sites located across the city. Efforts to combat this impediment are outlined in Programs H-A, H-B, H-N, H-O, H-R, H-S, H-U, H-V, H-W, and H-AA.

Insufficient Housing Stock for Farmworkers. Farmworker housing is a critical need in Napa County and St. Helena due to the presence of year-round agricultural production. The migratory and sometimes seasonal nature of farm work poses housing challenges for the community and are seen as an impediment for St. Helena.

Efforts to combat this impediment are outlined in Programs H-E, H-H, H-I, and H-KK.

Lack of Affordable Housing Types. There is a lack of diversity in housing types that restricts development of affordable housing in St. Helena. Local land use and zoning regulations perpetuate this deficiency by limiting the form of housing that can be developed on a particular site. Much of the residentially zoned parcels within the city are zoned low and medium density residential and are not compatible with the construction of duplexes, triplexes, quadplexes and multifamily housing developments. The City is upzoning a number of parcels as a part of the Housing Element Update to allow higher density residential development. Efforts to further combat this impediment are outlined in Programs H-A, H-B, H-E, H-H, H-I, H-J, H-M, H-N, H-P, H-R, H-S, H-V, H-W, H-AA, H-DD, H-EE, H-FF, H-GG, H-LL, and H-NN.

Agenda Item #10.1.

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Goals, Policies, and Implementation Programs
Goal 1 A Diversity of Housing to Meet Local Needs
To facilitate development of a variety of housing types to meet the full range of housing needs throughout our community, with particular emphasis on housing for our local workforce, people with special housing needs, and people with extremely low, very low, low, and moderate incomes.

Policies
HE 1.1 Maintain a sufficient supply of land zoned for residential development to meet the identified housing need at all income levels. [Existing Policy HE 1.1, modified] HE 1.2 Work with property owners and developers to facilitate development of new affordable housing throughout the community. [Existing Policy HE 1.2, modified] HE 1.3 Encourage the development of affordable housing and remove non-governmental development constraints, as feasible. [Existing Policy HE 1.3, modified] HE 1.4 Remove governmental constraints to housing. [New Policy] HE 1.5 Address workforce housing needs by supporting in-fill and mixed-use development near downtown. [Existing Policy HE 1.4, modified]
HE 1.6 Encourage innovative housing types and designs. [Existing Policy HE 1.5] Implementation Programs
Implementation programs for this goal have been included in a table beginning on the following page.

Agenda Item #10.1.

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Timeframe
H-A Available Sites Inventory
The City will prepare a sites inventory and suitability analysis that identifies suitable sites for housing
development that allows targeted income housing
developers to have a clear idea of what sites are suitable for meeting the Regional Housing Needs of the City. To
accommodate the remaining lower-income RHNA of 156
units, the City of St. Helena will identify and rezone a minimum of 14 acres to the HDR zoning district, allowing exclusively residential uses and a minimum of 20 units per acre to a maximum of 28 units per acre by January 31,
2026. Rezoned sites will permit owner-occupied and rental multifamily uses by right pursuant to Government Code
section 65583.2(h) and (i) for developments in which 20 percent or more of the units are affordable to lower income households and will be selected from sites 2, 3, 5, 8, and 10 in the parcel listing (Table 58). As reflected in 11: Housing Resources, each site has the capacity to accommodate at least 16 units and will be available for development in the planning period where water, sewer, and dry utilities can be provided.Sites included in the inventory with a proposed zoning change shall be rezoned as proposed in 11: Housing Resources, incompliance with Govt. Code Section
65583.2(h) and (i). The City shall complete this rezoning effort within three years of the adoption deadline. The City will monitor progress toward program objectives and
implement additional measures as necessary if the metrics are not being met.

The City will maintain an inventory of parcels meeting the requirements of Government Code Section 65583.2(c); that is, vacant sites identified in two or more consecutive
Identify housing sites suitable to accommodate:
· Very low income: 104 units
· Low income: 59 units
· Moderate income 26 units
· Above Moderate income: 67 units
· Total: 256 units
Provide sites that proactively work to overcome
concentrations of lower- and moderate-income
earning populations; with the goal of facilitating
the development of 82 lower income units in the
western portion of the city
Provide sites appropriate for affordable housing
types
Commit to streamlining review of Hunter
Subdivision project to completion with the goal of
Building Permit applications in 2025. Evaluate
timeline at the end of 2025 and if determined
necessary, identify additional housing sites to
meet the City’s 6th Cycle RHNA requirements.

HE1.1 Planning
Department
General
Fund
(staff
time)
Within three
years of the
adoption
deadline
Publiclyavailable
inventory: by
2024
Hunter
Subdivision
Building
permits: 2025
Evaluate
timeline by
end of 2025
Agenda Item #10.1.

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housing elements or nonvacant sites identified in a prior housing element, that are identified to accommodate
housing for lower income households. This inventory shall be made available online. All previously used lower-income sites currently meet the lower-income density threshold (20 du/ac), however the City shall update the zoning code to allow by-right approval for housing developments that
include 20 percent or more of its units affordable to lower income households (Gov. Code, § 65583.2, subd. (c).) on these sites.

The City will consider AFFH in the identification of sites within the inventory and will work to provide sites that proactively work to overcome concentrations of lower- and moderate-income earning populations on the eastern
portion of the city.
[New Program]
H-B Growth Management System
The City will remove the Growth Management System
(GMS) from the Zoning Code.

Due to Senate Bill 330, the GMS cannot currently be
enforced. The City shall remove the GMS from the zoning code through the current cComprehensive zZoning cCode
Uupdate currently underway. The GMS has been removed
from the Draft Zoning Code, which is scheduled for
adoption in summer/fall 2023.
[Existing Program HE1.A, modified]
During the planning period, encourage the
development of:
· 4 very low-income units
· 4 low-income units
· 10 moderate-income units
· 10 above moderate-income units
Address the city's lack of affordable housing by
removing governmental constraints
HE1.1
HE1.4
Planning
Department
General
Fund
(staff
time)
Ongoing
Implementatio
n: immediate
Revised
Zoning Code:
by 2025 (prior
to sunset of
SB 330)
Agenda Item #10.1.

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H-C Water and Sewer Access
The City will continue to give priority access to water and sewer infrastructure to projects that include affordable housing units.

As required by State law, the City shall deliver the adopted housing element to water and sewer providers, including a cover memo describing the City’s housing element, as well as the City’s housing needs and regional housing need.
[Existing Program HE1.C, modified]
During the planning period, encourage the
development of:
· 8 very low-income units
· 8 low-income units
Establish specific procedures providing priority
access to water and sewer infrastructure to
developments with units affordable to lowerincome households, as required by State law. · Provide water and sewer providers with
the adopted housing element, including cover
memo, as required by State law.

HE1.3
HE1.4
Planning
and Public
Works
Departments
General
Fund
(staff
time)
Water
and
Sewer
Enterpris
e Funds
OngoingEstab
lish
procedure: by
2025
Provide
providers with
housing
element:
immediately
upon
adoption
H-D Road and Utility Improvement Coordination
The City will continue to work with private property
owners/developers to plan for road and utility
improvements necessary to support housing on sites
identified for lower-income housing, in the event these sites are developed. Funding for off-site improvements will be provided through development impact fees. The City shall annually evaluate funding levels and potential opportunities for use of the funds in line with this program. [Existing Program HE1.E]
During the planning period, encourage the
development of:
· 4 very low-income units
· 4 low-income units
· 4 units identified for seniors,
farmworkers, or persons with disabilities
HE1.2
HE1.3
Planning
Department
General
Fund
(staff
time)
OngoingThrou
ghout the
planning
period, as
needed
Evaluate
funding levels
and
opportunities:
annually
Agenda Item #10.1.

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H-E Streamline Special Needs Housing
The City will apply streamlined ministerial review to housing developments that meet the needs of lower income
households and special needs groups, such as seniors,
people with disabilities, farmworkers, and homeless families and individuals.

The City shall evaluate the streamlined review policy every two years to identify constraints on special needs housing production.

The City shall provide priority processing to development applications that work to provide housing for residents with special housing needs. The City shall also support these applicants by providing technical support through the
entitlement process and shall provide additional density bonuses and modifications to development standards
(beyond State law) to special needs housing projects
proposed on the western half of the city, where fair housing issues are less concentrated. [Existing Program HE1.F,
modified]
During the planning period, encourage the
development of:
· 15 very low-income units
· 8 low-income units
· 6 units identified for seniors,
farmworkers, or persons with disabilities
Address the lack of affordable housing types in
the city
Address the lack of farmworker housing in the city
Provide incentives that work to overcome
concentrations of affordable housing on the
eastern portion of the city.

HE1.4 Planning
Department
General
Fund
(staff
time)
Evaluate
constraints:
every two
yearsOngoing
Apply
streamlined
review:
throughout
planning
period
Agenda Item #10.1.

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H-F Municipal Code Updates
The City will review and amend the Municipal Code, to
comply with State law to:
· Allow low barrier navigation centers for compliance
with Government Code Sections 65660 and 65668
(AB 101).
· Define and aAllow for residential care homes
facilities of six or fewer in zones allowing singlefamily uses, subject only to the requirements of single-family uses, in compliance with State law
(HSC § 1568.0831); California Government Code
Section 65583and permit facilities with seven or
more beds in zones allowingall
multifamilyresidential useszones , with objectivity
and certainty similar to other residential uses of the
same formsubject only to the requirements
multifamily uses.
· Update Chapter 17.144 (Affordable Housing) to
reflect new maximum density bonus tier framework
in compliance with California Government Code
Sections 65915 through 65918.
· Amend the Zoning Ordinance to define “family” as
one or more persons living together as a single
housekeeping unit in a dwelling unit. The definition
should not distinguish between related and
unrelated individuals and should not impose a
numerical limit on the number of persons that
constitute a family.
· Update parking requirements related to emergency
shelters for compliance with Government Code
section 65583, subdivision (a)(4)(A) to require only
be the number of spaces necessary for staff
working in the shelter and no more than other uses
in the same zones.

Amend the Municipal Code for compliance with
State law by 20262025
Address the lack of affordable housing types in
the city by removing governmental constraints to
housing production
Amend the inclusionary housing ordinance to
update in-lieu fees to reflect real costs of
developing affordable housing, provide incentives
to construct workforce housing, and provide more
on-site housing requirements for affordable
housing development
HE1.4
HE6.1
Planning
Department
General
Fund
(staff
time)
By 20262025
Agenda Item #10.1.

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· Allow accessory dwelling units in all zones allowing
residential uses, including the AP Zone, mixed-use
and commercial zones.
· Update Chapter 17.116.030 (Accessory Dwelling
Units) for compliance with Government Code
section 65852.2.
· Update Chapter 173.200 (Reasonable
Accommodation) to remove discretionary finding
requirements that constrain development, including
finding #5, which considers impacts to surrounding
properties or uses.
· Incorporate objective design standards for singlefamily, small lot, and multifamily developments that provide a ministerial design review process
· Provide a by-right streamlined review process for
affordable housing developments meeting state
affordability thresholds, in compliance with SB 35
and SB 330.
· Allow permanent and supportive housing pursuant
to Government Code section 65661 without
discretionary action.
[Existing Program HE1.K, expanded]
Agenda Item #10.1.

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H-G Safety Element Update
The City will, in accordance with SB 1035, update the
General Plan Safety Element to include any new information on fire and flood hazards, as well as climate adaptation and resiliency strategies. In accordance with SB 99 and AB 747, the updated Safety Element will also include evacuation routes and their capacity, safety, and viability under a range of emergency scenarios and to include information
identifying residential developments in hazard areas that do not have at least two emergency evacuation routes. [New Program]
Update the Safety Element by 2024 HE1.4 Planning
Department
General
Fund
(staff
time)
2024
Agenda Item #10.1.

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H-H Workforce and Farmworker Housing
The City will exploreidentify, and adopt, as appropriate, incentives for development to address the housing needs of “workforce” and farmworker households, with priority
given to projects in lower-density higher income on the western half of the city.that overcome geographic
concentrations of lower- and moderate-income earners. As part of this effort, the City will explore the feasibility of adding an above moderate-income workforce housing
component to the Inclusionary Housing Ordinance
requirements and amend the Ordinance as appropriate.
[Existing Program HE1.H, modified]
Explore Identify and adopt, as appropriate,
development incentives such as higher density
and height allowances, a streamlined design
review process, and financial incentives, including
fee reductions and waivers and contributions from
the City’s Housing Trust Fund, to encourage the
development of workforce and farmworker
housing, including additional incentives for those
projects in low-density high-income areas
Encourage the development of:
· 10 units identified for workforce or
farmworker housing during the planning
period
· 2 workforce housing developments in
low-density high-income areas
Address the lack of affordable housing types in
the city
Address the lack of farmworker housing in the city
HE1.4 Planning
Department
General
Fund
(staff
time)
OngoingBy
2025
Agenda Item #10.1.

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H-I ADU Workforce Housing Incentive Program
The City will implement a program to provide financial
assistance for the development of accessory dwelling units in exchange for affordability restrictions that will provide workforce housing. Potential funding sources include, but are not limited to, Housing Trust Funds and Transient
Occupancy Tax revenues.

To encourage housing mobility and housing choice, the City shall provide marketing of the ADU Workforce Housing
Program (and financial incentives) targeted at low-density areas of the city, with particular emphasis on the western half of the city where fair housing issues and existing affordable units are less concentrated. As part of this effort, the City shall hold up to two multi-lingual engagement
events. [Existing Program HE1.I]
Establish an ADU Workforce Housing incentive
program
Market financial incentives to residents in LR and
MR zones, particularly on the western portion of
the City
Ein combination with Programs H-Q and H-R,
encourage the development of:
· 80 accessory dwelling units, targeting 60
on the western portion of the city
· 20 ADUs with affordability restrictions
during the planning period, including 10
15 within the western portion of the city,
consistent with AFFH.
· 15 ADUs near downtown
Address the lack of affordable housing types in
the city
Address the lack of farmworker housing in the city
HE1.4 Planning
Department
Housing
Trust
Funds
Transient
Occupan
cy Tax
State and
Federal
workforc
e
housing
programs
State and
Federal
grant
funding
Ongoing
Establish
program: by
20258
Provide
marketing and
engagement
events: 2025
Agenda Item #10.1.

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H-J Non-traditional Housing Types
The City will encourage development of co-housing,
ecohousing, a ‘green’ manufactured home, and other forms of housing, and will ensure these housing types are
considered in the city’s streamlined approval process.

The City will evaluate and update, as appropriate, current zoning practices to remove constraints to non-traditional housing types. The City will also amend the zoning code to provide objective standards for residential development that work for a variety of housing types, including nontraditional housing types. [Existing Program HE1.J, modified]
Evaluate current zoning practices to identify
constraints to non-traditional housing types by
2025.

Amend the zoning code to remove constraints and
provide objective design standards by 2026.

Encourage the development of:
· 10 missing middle units on infill parcels
or in areas within the western portion of
the city, consistent with AFFH.
· 4 non-traditional housing units during the
planning period.

Address the lack of affordable housing types in
the city
HE1.5 Planning
Department
General
Fund
(staff
time)
OngoingEnco
urage nontraditional
housing types:

Tthroughout
the planning
period
Evaluate
zoning: by
2025
Amend
zoning: by
2026
H-K Non-Vacant Sites
The City shall adopt a policy(ies) to incentivize new or more intense development on sites included in the sites inventory as lower-income capacity, including sites 7, 9, and 11 (for sites 1 and 2, see Program H-L. Incentives may include, but are not limited to, reducing development standards,
providing flexible parking standards, priority processing, or deferred fees. The City shall engage property owners within six months of adoption to discuss constraints and potential incentives.

Adopt policies that Incentivize the development of
new or more intense uses on non-vacant sites
identified as lower-income capacity to meet the
RHNA.

Encourage the construction of 42 new lowerincome units on sites 7, 9, and 11, including 32 on the western portion of the city
HE 1.1
HE 1.2
HE 1.3
Planning
Department
General
Fund
(staff
time)
Engage
property
owners:
within six
months of
adoption
Adopt
incentives:
2024
Agenda Item #10.1.

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H-L City- Oowned Sites
The City will maintain compliance with the Surplus Land Act throughout the 2023-2031 Housing Element planning
period. The City will assess the appropriateness of and consider implementing the following: outreach
opportunities with housing developers, requests for
proposals, development incentives, fee waivers, priority processing, and financial assistance (when available) to facilitate and incentivize developers to develop housing units on City-owned sites.

The City plans to make 3 properties available through the Surplus Land Act process over the next two years for a
potential development of 57 lower-income units. The City shall conduct studies of City owned sites included in the sites inventor to determine the most efficient use for
housing. These include sites 1, 2, and 3. Through this
process, the City shall engage local affordable housing developers to determine site constraints and potential
policies to meaningfulmeaningfully incentivize affordable housing development on these sites. The City shall proceed with the findings for housing development by 2026. The
City anticipates two-and-a-half years to enter into an
Exclusive Negotiation Agreement (Fall 2026), and one-anda-half additional years for land use entitlements and development agreements (Spring 2028).

City owned sites included in the inventory (sites 1-3) shall be rezoned incompliance with Govt. Code Section
65583.2(h) and (i) within three years of the adoption
deadline (by January 31, 2026.

Engage local affordable housing developers
immediately
Study city owned sites to determine the most
efficient use for affordable housing development
within the first year following adoption
By 2026, implement an action plan to sell, or
release an RFP to develop, City owned land for
affordable housing development based on the
findings of the conducted studies. Through the
action plan, establish and implement a variety of
incentives to facilitation housing development.

Maintain compliance with the Surplus Land Act
throughout the 2023-2031 Housing Element
Planning Period
Make properties available through the Surplus
Land Act process
Target Exclusive Negotiating Agreement by Fall
2026
Target land use entitlements issuance by Spring
2028
Encourage the development of 57 lower-income
units in the northeast quadrant of the city near
transit opportunities, and where fair housing
issues are less concentrated, and walkability and
environmental scores are more positive
HE 1.1
HE 1.2
HE 1.3
Planning
Department
General
Fund
(staff
time)
Engage
developers:
immediately
upon
adoption
Conduct
studies: by
July 2025
Implement
action plan
and incentives
for City
owned sites:
by 2026
Rezone sites:
by Jan. 31,
2026
Agenda Item #10.1.

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City of St. Helena 2023-2031 Housing Element Update Public Hearing Draft, April 2023W Dra Housing Policy Document | May 2022
1-21
Goal 2 High-Quality Neighborhoods with a Balance of Housing Types To plan for a balance of housing types throughout the community. [Existing Goal, modified]
Policies
HE 2.1 Encourage higher density development. [Existing Policy HE 2.1, modified] HE 2.2 Promote higher density development opportunities in low density, high resource areas. [New Policy]
HE 2.3 Promote mixed-use developments. [Existing Policy HE 2.3] HE 2.4 Promote accessory dwelling unit (ADU) production. [Existing Policy HE 2.4, modified] HE 2.5 Allow duplexes to the extent required by State law in all single-family residential zones consistent with SB 9. [New Policy]
HE 2.6 Promote the development of missing middle housing with an area median income target of 120 percent (moderate income). [New Policy]
HE 2.7 Promote a balance of housing types and unit sizes throughout the community. [Existing Policy HE 2.6, modified]
Implementation Programs
Implementation programs for this goal have been included in a table beginning on the following page.

Agenda Item #10.1.

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City of St. Helena 2023-2031 Housing Element Update HCD Review Draft, September 2022Revised HCD Draft, February 2023Public Hearing Draft, April 2023 1-22
Implementation Program Objectives Implements
What Policies
Who is
Responsible
Potential
Funding
Source
Timing
H-KH-MIncentives for Lower-Cost Housing
Types
The City will continue to provide incentives for
higher density housing and will explore possible
incentives for building attached market rate housing
units for rent and for sale. Incentives to may include, but are not restricted to, fast tracking development
applications, deferred development fees, reduced
parking and/or other city standards, and density
bonuses. [Existing Program HE2.A]
Encourage the development of 20 lower income units
during the planning period
Study potential incentives for attached market rate
units by 2027
Address the lack of affordable housing types in the
city
HE2.1 Planning
Department
General
Fund (staff
time)
OngoingThr
oughout the
planning
period
Attached
market-rate
housing
study by
2027
Agenda Item #10.1.

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City of St. Helena 2023-2031 Housing Element Update HCD Review Draft, September 2022Revised HCD Draft, February 2023Public Hearing Draft, April 2023 1-23
Implementation Program Objectives Implements
What Policies
Who is
Responsible
Potential
Funding
Source
Timing
H-LH-N Zoning to Facilitate Higher Density
Housing
The City will modify the Zoning Code to facilitate
higher density housing, consistent with the 2040
General Plan Update and Housing Sites Analysis,
and discourage the construction of oversize homes,
particularly within the western portion of the city,
consistent with AFFH.

The City shall revise maximum lot coverage to 55
percent and maximum height to 42 feet in the HR
zone and on key housing sites in the MR zone (see
Section 17.40.020(N)).

The City shall revise the zoning code to allow minor
modifications of up to 10 percent increase in lot
coverage standards and 5 percent (or two feet,
whichever is greater) in maximum height. Minor
modifications shall be approved by the Community
Development Director without a public hearing.

The City shall reduce parking requirements for
multifamily uses with three or more units to require
one parking space for studio or one-bedroom units.

The City shall revise Section 17.40.020 to allow
duplexes and triplexes and densities of 5.1 to 16
dwelling units per acres in the MR zone without a
conditional use permit. [Existing Program HE2.B,
modified]
Modify the development standards within the Zoning
Ordinance to encourage higher density developments
by 2026
Develop land use patterns that work to overcome
geographic concentrations of lower-and moderateincome earning populations Address the lack of affordable housing types in the
city
HE2.1
HE2.2
Planning
Department
General
Fund (staff
time)
By 2026
Agenda Item #10.1.

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City of St. Helena 2023-2031 Housing Element Update HCD Review Draft, September 2022Revised HCD Draft, February 2023Public Hearing Draft, April 2023 1-24
Implementation Program Objectives Implements
What Policies
Who is
Responsible
Potential
Funding
Source
Timing
H-MH-O Exemptions from Minimum
Density
The City will amend zoning regulations to prohibit
exemptions from minimum density requirements.
[Existing Program HE2.C]
Prohibit exemptions from minimum density
requirements
Encourage development patterns that work to
overcome geographic concentrations of lower-and
moderate-income earning populations
HE2.1
HE2.2
Planning
Department
General
Fund (staff
time)
By 2026
H-NH-P Mixed-use Development Types
The City will amend the Zoning Code to create and
implement the development criteria set for mixed
use development within St Helena. [Existing
Program HE2.G, modified]
Amend the Zoning Ordinance to create and
implement the development criteria set for mixed use
development by 2026
Encourage the development of 20 housing units in
mixed-use projects during the planning period
Explore and adopt, as appropriate, development
incentives such as higher density and height
allowances, a streamlined design review process, and
financial incentives, including fee reductions and
waivers and contributions from the City’s Housing
Trust Fund, to encourage employers to provide onsite employee housing Address the lack of affordable housing types in the
city
HE2.3 Planning
Department
General
Fund (staff
time)
By 2026
Agenda Item #10.1.

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City of St. Helena 2023-2031 Housing Element Update HCD Review Draft, September 2022Revised HCD Draft, February 2023Public Hearing Draft, April 2023 1-25
Implementation Program Objectives Implements
What Policies
Who is
Responsible
Potential
Funding
Source
Timing
H-OH-QDirect Assistance for ADU
Development
The City will continue to provide financial incentives, such as fee waivers and pre-approved plans, for
ADU development. .

The City will also explore additional options such as
covering the cost of a feasibility consult or the
license fee for pre-approved plans, or capping total
fees.

The City will work with Napa Sonoma ADU to
provide public information regarding ADUs on the
City website, including a guide for homeowners
explaining the benefits and procedures for adding
an ADU and links to resources, including the ADU
Feasibility Calculator, Home Match Program, and
Standard ADU Plans Program. [Existing Program
HE2.J, modified]
Provide direct financial incentives to 10 ADU projects
in the planning period
Explore additional financial incentives by 2025
Provide informational materials and technical
assistance regarding the development of ADUs to 30
households primarily in high resource areaslowdensity western portions of the city within the planning period
Address the lack of affordable housing types in the
city
HE2.4 Planning
Department
Housing
Trust Fund
General
Fund (staff
time)
OngoingExp
lore
additional
incentives:
by 2025
Provide
information
al materials:
by 2025
Engage
Napa
Sonoma
ADU:
annually
Agenda Item #10.1.

Page 716 of 1733 ends

City of St. Helena 2023-2031 Housing Element Update HCD Review Draft, September 2022Revised HCD Draft, February 2023Public Hearing Draft, April 2023 1-26
Implementation Program Objectives Implements
What Policies
Who is
Responsible
Potential
Funding
Source
Timing
H-PH-R Place-based ADU Strategy
The City will target specific areas for ADU incentives
and will create incentives to construct ADUs in the
low- and medium-density areas near downtown as
well as in areas with lower concentrations of lowerand moderate-income earning householdslowdensity higher-income areas of the city, particularly on the western portion of the city. Potential
incentives include, but are not restricted to, fast
tracking development applications, deferred
development fees, and reduced parking and/or other
city standards. [Existing Program HE2.K, modified]
Establish place-based ADU strategies and incentives
by 2026
In combination with Program H-I and H-Q, Encourage
the development of:
· 80 accessory dwelling units, targeting 60 on
the western portion of the city
· 20 ADUs with affordability restrictions during
the planning period, including 15 within the
western portion of the city.
· 15 ADUs near downtown
· 5 ADUs in high resource areas
Proactively work to overcome concentrations of
lower- and moderate-income earning households
Proactively work to relieve displacement pressures on
multifamily zones
HE2.2
HE2.4
Planning
Department
General
Fund (staff
time)
Ongoing
Establish
program: by
2026
H-QH-S Affordability Requirements for ADU
Incentives
The City will link financial incentives and
development standard variances to affordability
requirements for ADUs. Whenever the City assists in
the development of an ADU through financial
incentives or by granting a variance, the City will
require that either the main house or the ADU is
used as a rental unit affordable to lower- and
moderate-income households for a minimum of five
years through an affordable housing regulatory
agreement with the City. [Existing Program HE2.M,
modified]
Update the zoning ordinance to include affordability
requirements for ADU projects receiving financial or
regulatory incentives by 2026
Incentivize the development of:
· 12 very low-income units
· 14 low-income units
· 6 moderate income units
HE2.4 Planning
Department
Housing
Trust Fund
General
Fund (staff
time)
OngoingBy
2026
Agenda Item #10.1.

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City of St. Helena 2023-2031 Housing Element Update HCD Review Draft, September 2022Revised HCD Draft, February 2023Public Hearing Draft, April 2023 1-27
Implementation Program Objectives Implements
What Policies
Who is
Responsible
Potential
Funding
Source
Timing
H-RH-T Illegal Housing Units
The City will continue to respond to complaints
regarding illegal units. Additionally, the City will
work with the property owners to help bring illegal
units up to code and to abate the use of nonhabitable buildings as living units. [Existing Program HE2.N]
Respond to complaints regarding illegal units
Provide technical and financial support to assist five
lower income units to be brought up to code within
the planning period
HE2.4 Planning and
Building
Department
General
Fund (staff
time)
Housing
Trust Fund
OngoingThr
oughout the
planning
period
H-SH-U Place-based Density Increases
The City will revise the Zoning Code to allow urban
lot splits, duplexes, and other two-unit projects in
single-family residential zones in accordance with
Senate Bill 9. The City will also explore adopt
incentives, which may include fee reductions,
deferrals, or waivers; flexible development
standards; priority processing, or to allowallowing
triplexes on single-family lots if one unit ensures
affordability to lower- or moderate-income renters
by deed restriction. The City shall publicize
informational materials outlining policies and
incentives on the City website and through mailing
lists and social media outlets. [New Program]
Adopt incentives for small multi-unit SB 9 projects in
single-family zones by 2024
Publicize informational materials by 2024; update
within 30-days of changes
Revise the Zoning Code by 2026
Proactively work to overcome concentrations of
lower- and moderate-income populations
Proactively work to relieve displacement pressures in
multifamily zones
HE2.2
HE2.5
Planning
Department
General
Fund (staff
time)
Ongoing
Allow
duplexes: by
20246
Explore
Adopt
incentives:
2028by
2024
H-TH-V Multi-unit Development in Low-density
Higher-income High Resource Areas
The City will encourage the development of
affordable housing on in-fill parcels and in high
resource areaslow-density areas in the western
portion of the city, in line with the City's
commitment to affirmatively further fair housing. As
part of this effort, the City will explore and adopt,
Post an inventory of potential housing sites on the
City’s web site immediately following adoption of the
Housing Element
Explore revisions to development standards to
encourage multi-unit infill development (as part of
comprehensive zoning code update) by 2026
HE2.2, HE2.6 Planning
Department
City Council
General
Fund (staff
time)
Ongoing
Housing
sites posted
to website
in 2023
Agenda Item #10.1.

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City of St. Helena 2023-2031 Housing Element Update HCD Review Draft, September 2022Revised HCD Draft, February 2023Public Hearing Draft, April 2023 1-28
Implementation Program Objectives Implements
What Policies
Who is
Responsible
Potential
Funding
Source
Timing
revisions to development standard to encourage
multi-unit developments within existing
neighborhoods throughout the city. The City will
also explore additional incentives to encourage
affordable multi-unit projects in high resource areas,
including, but not limited to priority permit
processing, reduced or waived development fees,
reduced parking and/or other city standards, and an
additional density bonus. [Existing Program HE2.P,
modified]
Support Facilitate the development of three multiunit affordable lower-income housing projects on City-owned properties in the planning period
Support Facilitate the development of five lower- or
moderate-income infill projects in the planning period
Address disproportionate housing needs in infill
areas, including overpayment, overcrowding, and
displacement risk by increasing housing
opportunities; support facilitate seven SB9 lot splits
to increase housing opportunities in single family
neighborhoods in the planning period, with a goal of
facilitating development of five lower-income units
on these properties
Explore additional incentives for affordable multi-unit projects in high resource areaslow-density areas on
the western portion of the city by 20268
Encourage the development of eight lower- and eight
moderate income multi-family units in high resource
areas or on infill parcels within the planning period
Proactively work to overcome concentrations of
lower- and moderate-income populationshouseholds
on the eastern portion of the city
Address the lack of affordable housing types in the
city
Standards
update:
2026
Explore
potential
addition
incentives:
by 2026
Agenda Item #10.1.

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City of St. Helena 2023-2031 Housing Element Update HCD Review Draft, September 2022Revised HCD Draft, February 2023Public Hearing Draft, April 2023 1-29
Implementation Program Objectives Implements
What Policies
Who is
Responsible
Potential
Funding
Source
Timing
H-UH-W Missing Middle Housing
The City will review and amend the zoning code and
applicable development standards to encourage and
promote a mix of dwelling types and sizes,
specifically missing middle-density housing types
(e.g., triplexes, courtyard buildings, townhomes,
live/work) to create a diversity of housing types and
densities and increase the availability of affordable
housing to reduce displacement risk for residents
overpaying for housing.

Specifically, the City will add a new mixed use zone,
consistent with the 2040 General Plan Update, and
will evaluate and revise minimum lot sizes and
parking ratios, particularly in high resource, lowdensity areas. [New Program] Revise zoning standards to encourage missing middle
housing by 2026
To enhance housing mobility and housing choice,
encourage the development of a variety of missing
middle housing types in infill projects; support the
development of three missing middle housing
developments between three and 20 units
To enhance housing mobility, encourage the
development of 15 lower- and 15 moderate-income
units in low-density high-income resource areas
HE2.2
HE2.6
HE2.7
Planning
Department
General
Fund (staff
time)
OngoingRev
ise Zoning
Code: by
2026
Agenda Item #10.1.

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City of St. Helena 2023-2031 Housing Element Update Revised HCD Draft, February 2023Public Hearing Draft, April 2023
1-30
Goal 3 Conservation of Existing Housing
Improve and conserve existing housing, with particular attention to the rehabilitation and retention of existing affordable units. [Existing Goal] Policies
HE 3.1 Protect the existing stock of affordable and market rate housing. [Existing Policy HE 3.1] HE 3.2 Support the conservation of existing housing units for those with special housing needs, including seniors and others with special housing needs. [New Policy] HE 3.3 Monitor housing conditions. [Existing Policy HE 3.2] Implementation Programs
Implementation programs for this goal have been included in a table beginning on the following page.

Agenda Item #10.1.

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City of St. Helena 2023-2031 Housing Element Update HCD Review Draft, September Revised HCD Draft, February 2023Public Hearing Draft, April 20232022 1-31
Implementation Program Objectives
Implements
What
Policies
Who is
Responsible
Potential
Funding
Source
Timeframe
H-VH-X Condominium Conversion
The City will continue to restrict the conversion of rental units to condominiums. Current policy allows conversion to
condominiums under certain circumstances when the vacancy rate is high. Because the presence of second homes within the community results in an inflated vacancy rate, the City will update the current policy to eliminate the linkage to vacancy rates. To work to reduce displacement pressures in lowerresourced areas, the revised policy will completely restrict all conversions in the eastern portion of the city. [Existing Program HE3.A]
Preserve existing affordable housing stock
Update current policy to remove linkage to
vacancy rates
Completely restrict condominium conversion in
the eastern portion of the City
Address the lack of affordable housing types in
the city
HE3.1 Planning
Department
General
Fund
(staff
time)
Ongoing
Update
policy by
2026.

H-WH-YAffordable Housing Impact Fee
The City will continue to charge an affordable housing impact fee whenever housing units are converted to other uses. The City will exempt conversion projects that create affordable for-sale housing from this impact fee. Collected affordable housing impact fees will be used for the preservation and development of housing opportunities affordable to lowerand moderate-income households, and will give priority to projects in the eastern portion of the city where fair housing issues, and displacement risks exist in greater concentrations. [Existing Program HE3.B]
Evaluate the impact fee against the real cost of
affordable housing development every two years.

Discourage the conversion of residential uses to
nonresidential uses
Address the lack of affordable housing types in
the city by working to retain existing units or
generating funding for future affordable units
HE3.1 Planning
Department
General
Fund
(staff
time)
OngoingThr
oughout the
planning
period
Evaluate
impact fee:
every two
years
Agenda Item #10.1.

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City of St. Helena 2023-2031 Housing Element Update HCD Review Draft, September 2022Revised HCD Draft, February 2023Public Hearing Draft, April 2023 1-32
Implementation Program Objectives
Implements
What
Policies
Who is
Responsible
Potential
Funding
Source
Timeframe
H-XH-Z At-Risk Assisted Affordable Housing Units
Although there are no assisted affordable units currently atrisk of conversion to market rate in St. Helena, the City with the assistance of the Napa Housing Authority, shall continue to monitor assisted properties. If units are identified as at-risk of conversion, the City will work with the property owners and/or other parties to ensure that they are conserved as affordable housing.

The City will also engage with owners of deed-restricted moderate- income for-sale units (Marietta Townhomes and Voorhees Circle) at-risk of conversion to market rate within the planning period. The City will work with owners to find solutions to extend affordability requirements. [Existing Program HE3.C, modified]
Unless consistent with the terms of an affordable
housing agreement with the City of St. Helena,
prohibit the conversion of assisted affordable
units to market rate
Retain all assisted affordable units during the
planning period
Immediately (by 2024) engage homeowners with
expiring deed-restrictions
HE3.1 Planning
Department
General
Fund
(staff
time)
OngoingEng
age at-risk
property
owners:
immediately
, and twice
annually
thereafter
H-YH-AA Vacation Rentals
The City will continue to limit the conversion of market rate housing to vacation rentals and will abate the use of illegal vacation rentals, including time shares and fractional
interests.

To preserve existing affordable housing and reduce
displacement pressures, the City shall adopt a policy
restricting conversion of units occupied by lower- and
moderate- income households in the southeast quadrant of the city to vacation rentals. [Existing Program HE3.D]
Maintain the current stock of market rate
housing
Restrict the conversion of housing units to
vacation rentals occupied by lower- and
moderate-income households in the southeast
quadrant of the city where fair housing issues
exist in greater concentrations
Discourage the conversion of market rate
housing units to vacation rentals, particularly in
high resource areaslow-density higher-resourced
areas, consistent with AFFH
Address the lack of affordable housing types in
the city
HE3.1 Planning
Department
General
Fund
(staff
time)
OngoingThr
oughout the
planning
period
Agenda Item #10.1.

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City of St. Helena 2023-2031 Housing Element Update HCD Review Draft, September Revised HCD Draft, February 2023Public Hearing Draft, April 20232022 1-33
Implementation Program Objectives
Implements
What
Policies
Who is
Responsible
Potential
Funding
Source
Timeframe
H-ZH-BB Special Housing Needs Rehabilitation
Program
The City shall actively pursue federal and State funding sources, including CDBG, Affordable Housing and Sustainable Communities (AHSC), Permanent Local Housing Allocation
(PLHA), CalHome funds, HOME, and other grant sources to establish a program to support the rehabilitation needs of seniors and others with special housing needs, particularly on the eastern portion of the city where affordable units are generally concentrated and displacement risks are increased. [Source: New Program]
Pursue funding to assist with rehabilitation costs
for lower income households and seniors
During the Planning Period, encourage the
conservation rehabilitation/conservation of:
· 20 units accessible to seniors
· 10 units accessible to persons with a
disability
HE3.2 Planning
and Finance
Departments
CDBG,
AHSC,
PLHA,
CalHome,
HOME
Annually
and as
notices of
funding
availability
are
released.

H-AAH-CC Annual Progress Report
The City will continue to review housing needs, conditions, achievements and challenges as part of the City’s regular General Plan review and Annual Housing Element Progress Report, as required by State law. [Existing Program HE3.E] Submit the Annual Progress Report to the State
Department of Housing and Community
Development and the Governor’s Office of
Planning and Research by April 1st of each year
Provide transparency on housing-related actions
and programs
HE3.3
HE4.6
Planning
Department
General
Fund
(staff
time)
Annually
Agenda Item #10.1.

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1-34
Goal 4 Assistance to Support Affordable Housing
To provide technical and financial resources to support development of affordable housing in our community, especially housing that meets the needs of our local workforce, people with special housing needs, and people with moderate, low, and very low incomes.

Policies
HE 4.1 Develop permanent local sources of funding to support affordable housing. [Existing Policy HE 4.1]
HE 4.2 Aggressively pursue and ‘leverage’ State and Federal housing funds. [Existing Policy HE 4.2] HE 4.3 Address farmworker housing needs. [Existing Policy HE 4.3] HE 4.4 Support housing that meets special needs, including senior citizens and persons with disabilities. [Existing Policy HE 4.4]
HE 4.5 Explore methods to increase Housing Trust Fund money. [Existing Policy HE 4.5] HE 4.6 Provide transparency regarding information on housing-related actions, fees, and programs. [New Policy]
HE 4.7 Provide local preference in the procurement process when municipal funds may be used for housing. [New Policy]
HE 4.8 Give preference to projects providing workforce housing affordable to up to 140 percent of the AMI. [New Policy].

Implementation Programs
Implementation programs for this goal have been included in a table beginning on the following page.

Agenda Item #10.1.

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City of St. Helena 2023-2031 Housing Element Update HCD Review Draft, September Revised HCD Draft, February 2023Public Hearing Draft, April 20232022 1-35
Implementation Program Objectives Implements
What Policies
Who is
Responsible
Potential
Funding
Source
Timeframe
H-BBH-DD Revenue Generation for Affordable
Housing
The City will continue to generate revenues for affordable housing through the Affordable Housing Trust Fund and
Transient Occupancy Tax and will continue to use the
revenue to support the development or rehabilitation of affordable housing. [Existing Program HE4.B, modified]
Support the development or preservation of
five extremely low or very low-income units
Address the lack of affordable housing types
in the city
HE4.1
HE4.5
Planning
Department
General
Fund (staff
time)
Housing
Trust Fund
Transient
Occupancy
Tax
OngoingThrou
ghout the
planning
period
H-CCH-EE Reduced Fees for Affordable Housing
The City will continue to reduce, defer, or waive fees for affordable housing developments and will explore and
adopt as appropriate higher incentives for affordable
housing developments with units affordable to extremely low- and very low-income households. [Existing Program
HE4.C, modified]
Reduce fees for 30 extremely-low or very lowincome units Address the lack of affordable housing types
in the city
HE4.1 Planning
Department
General
Fund
Housing
Trust Fund
OngoingEvalu
ate and
adopt, as
appropriate,
potential
additional
incentives: by
2026
H-DDH-FF Extremely Low-Income Units
The City will continue to prioritize the use of the Affordable Housing Trust Fund in support of the development and
preservation of regulated affordable units for extremely low-income households. The City will immediately engage with developers interested in creating or preserving
housing for extremely low-income households to discuss
available incentives and any financial or technical
assistance the City can provide. [Existing Program HE4.D] Support the development or preservation of
six units for extremely low-income households
Address the lack of affordable housing types
in the city
HE4.1 Planning
Department
Housing
Trust Fund
OngoingEnga
ge
prospective
developers:
immediately
upon
identification
Agenda Item #10.1.

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City of St. Helena 2023-2031 Housing Element Update HCD Review Draft, September 2022Revised HCD Draft, February 2023Public Hearing Draft, April 2023 1-36
Implementation Program Objectives Implements
What Policies
Who is
Responsible
Potential
Funding
Source
Timeframe
H-EEH-GG Affordable Homeownership
The City will continue to pursue mortgage revenue bonds and/or mortgage credit certificates to promote affordable homeownership opportunities for moderate- and lowerincome households. The City shall evaluate these opportunities and engage with potential partnering
jurisdictions or institutions annually. The City shall also engage with local mortgage brokers and real estate agents to identify existing programs providing downpayment loans or direct assistance to first-time homebuyers and shall make this information available on the city’s website, as well as through up to two multi-lingual engagement events targeting the eastern portion of the city. [Existing Program HE4.E]
Research and identify potential funding
sources in 2024 and annually thereafter with
the goal of establishing a homeownership
assistance program in 2026
Collect and publicize information on existing
programs available to first-time and lowerincome prospective homeowners through State, Federal, or non-profit agencies within
18 months of adoption of the Housing
Element; hold up to two multi-lingual events
on the eastern portion of the City by 2026
Assist three lower- or moderate-income
households transition from rental housing to
homeownership
Address the lack of affordable housing types
in the city
HE4.2 Planning
and Finance
Departments
General
Fund (staff
time)
OngoingAnnu
ally
Identify
funding for
City led
program: in
2024 and
annually
thereafter
Collect and
publicize
information
on existing
programs:
within 18
months of
adoption
Targeted
engagement
events: by
2026
H-FFH-HH Additional Funding
The City will continue to pursue additional funding for affordable housing and will explore new options for
affordable housing funding. [Existing Program HE4.F,
modified]
Explore new funding sources bi-annually every
two years to support housing for lower- and
moderate-income households, seniors, and
residents with special housing needs
Address the lack of affordable housing types
in the city
HE4.1 Planning
and Finance
Departments
General
Fund (staff
time)
Ongoing
Explore new
opportunities:
biannuallyEve
ry two years
Agenda Item #10.1.

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City of St. Helena 2023-2031 Housing Element Update HCD Review Draft, September Revised HCD Draft, February 2023Public Hearing Draft, April 20232022 1-37
Implementation Program Objectives Implements
What Policies
Who is
Responsible
Potential
Funding
Source
Timeframe
H-GGH-II Section 8 Subsidies
The City will continue to partner with the City of Napa Housing Authority to provide rental assistance to low-, very low-, and extremely low-income households through
Housing Choice Voucher (Section 8) rent subsidy
certificates. [Existing Program HE4.G]
Support the City of Napa Housing Authority
rental assistance efforts; engage the Housing
Authority annually to explore
opportuntiesopportunities.

Provide informational materials regarding
Housing Choice Voucher subsidies on the City
website by 2024
Address the lack of affordable housing types
in the city
HE4.2 Planning
Department
General
Fund (staff
time)
OngoingEnga
ge the
Housing
Authority:
annually
Informational
materials: by
2024
H-HHH-JJ Housing Coordinator
While the City currently contracts with the City of Napa for Housing Authority services, the City will explore the
possibility of establishing a full-time, shared Housing Coordinator for the up-valley communities to: promote
development of new affordable housing in low-density
higher-resourced areas, assist lower-income households
obtain housing in higher resourced areas, and preserve
existing affordable units. The City shall and enter into a cost-sharing agreement, if feasible. The position would serve all of the up-valley communities, including Napa
County. [Existing Program HE4.H]
Meet with potential partner jurisdictions a
minimum of two times during the planning
period to explore options
Identify and procure funds to establish a
shared Housing Coordinator for the up-valley
communities to promote affordable
development in low-density higher resourced
areas, assist lower-income households obtain
housing in higher-resourced areas, and
preserve existing lower- and moderate-income
units
HE4.2 City
Manager
Planning
Department
General
Fund (staff
time)
CDBG,
AHSC,
PLHA),
CalHome,
HOME, and
other grant
sources
OngoingEnga
ge potential
partners: by
2026
Identify
potential
funding: by
2026
Agenda Item #10.1.

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City of St. Helena 2023-2031 Housing Element Update HCD Review Draft, September 2022Revised HCD Draft, February 2023Public Hearing Draft, April 2023 1-38
Implementation Program Objectives Implements
What Policies
Who is
Responsible
Potential
Funding
Source
Timeframe
H-IIH-KK Farmworker Housing Needs
The City will contribute staff time and City resources, as appropriate, to countywide farmworker housing efforts that may occur during the Housing Element planning period. The City will reach out to affordable housing developers to support regional and City efforts to develop farmworker housing, including assisting with financing or applications, incentives and concessions, expedited review or other
strategies to encourage the development of housing for
farmworkers. [Existing Program HE4.I]
Support local and regional efforts to develop
farmworker housing
Assist in the development of one farmworker
housing project during the planning period
Address the lack of farmworker housing in the
city
HE4.3 Planning
Department
General
Fund (staff
time)
Housing
Trust Fund
Outreach to
affordable
housing
developers by
2024 and
biannually
every two
years
thereafter
H-JJH-LL Special Needs Housing Opportunities
The City will encourage new developments to provide a
portion of units to meet the special housing needs of
seniors and persons with disabilities, including
developmental disabilities, throughout the city. The City will provide information on available incentives on the City website and shall immediately engage individuals or
agencies interested in special needs production to discuss opportunities and constraints specific to the parcel(s) being considered. [Existing Program HE4.J]
During the Planning Period, encourage the
development of:
· 10 units accessible to seniors
· 5 units accessible to persons with
disabilities
Address the lack of affordable housing types
in throughout the city
HE4.4 Planning
Department
General
Fund (staff
time)
OngoingInfor
mation to
website: by
2025
Engage
potential
developers:
immediately
upon
identification
Agenda Item #10.1.

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City of St. Helena 2023-2031 Housing Element Update HCD Review Draft, September Revised HCD Draft, February 2023Public Hearing Draft, April 20232022 1-39
Implementation Program Objectives Implements
What Policies
Who is
Responsible
Potential
Funding
Source
Timeframe
H-KKH-MM Housing Information Transparency
The City will, in accordance with AB 1483 (2019), obtain, maintain, update, and make publicly available information related to zoning ordinances, development standards, fees, exactions, affordability requirements, and fair housing laws from the Department of Housing and Community
Development, State Fair Employment, and Housing
Commission’s enforcement program, as well as programs
and funding sources for homeowners at risk of foreclosure, the State Historic Building Code, and information on energy conservation opportunities.

The City will, as appropriate, share this information on the City website and/or in hard copy form at City offices. Any changes to such information shall be made public within 30 days of changes. The City will provide these items in
Spanish, as funding and staff time allows. [New Program] Create and share a digital information
database in compliance with AB 1483 by 2024
Updated information is made publicly
available within 30 days of changes
Provide information in Spanish, as funding
allows
HE4.6 Planning
Department
General
Fund (staff
time)
OngoingData
base: By 2024
and annually
thereafter
Update
information:
within 30-
days of any
changes
H-LLH-NN Funding for New Special Housing
Needs
The City shall actively pursue federal and State funding sources, including CDBG, Affordable Housing and
Sustainable Communities (AHSC), Permanent Local Housing Allocation (PLHA), CalHome funds, HOME, and other grant sources to support the construction of housing for seniors and those with special housing needs. The City shall
periodically review available housing programs to identify additional funding sources. [Source: New Program]
Pursue funding to assist with construction and
rehabilitation needs of lower income
households and seniors
During the Planning Period, encourage the
development of:
· 20 units accessible to seniors
· 10 units accessible to persons with
disabilities
HE3.1
HE 4.1
HE4.2
HE4.4
Planning
and Finance
Departments
CDBG,
AHSC,
PLHA,
CalHome,
HOME
Annually and
as notices of
funding
availability
are release.

Agenda Item #10.1.

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Implementation Program Objectives Implements
What Policies
Who is
Responsible
Potential
Funding
Source
Timeframe
H-MMH-OO Unit Conversion for Extremely LowIncome Households The City will continue to explore the potential of using Affordable Housing Trust Fund money to purchase existing housing for conversion to restricted affordable housing and will commit funding as appropriate. Priority for use of Affordable Housing Trust Fund monies will be given to the creation of housing affordable to extremely-low-income
households, particularly within the western portion of the city, consistent with the commitment to overcome
geographic income disparities. [Existing Program HE4.L] Identify potential funding
Engage with owners of local market rate
multifamily units to discuss opportunities, if
funding allows
Assist in the conversion of two units from
market rate to extremely low-income during
the planning period
Proactively work to overcome concentrations
of lower- and moderate-income populations
Address the lack of affordable housing types
in the city
HE4.1 Planning
Department
Housing
Trust Fund
General
Fund (staff
time)
OngoingIdenti
fy potential
funding:
annually
Engage
owners:
immediately
as funding
and potential
properties are
identified
H-NNH-PP Surplus and Excess Public Land
The City will, in accordance with AB 1486 (2019) and AB 1255 (2019), annually identify and inventory a list of sites owned by the City that have been sold, leased, or otherwise disposed of in the prior year. This inventory shall be publicly available and be included in the Housing Element annual report presented to the City Council and submitted to HCD. [New Program]
Regularly maintain an inventory of publiclyowned surplus or excess land on the City website
Annually release information regarding
publicly-owned sites that have been sold,
leased, or disposed of
HE4.6 Planning
Department
General
Fund (staff
time)
Ongoing
2023, with
annual
updates
Agenda Item #10.1.

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1-41
Goal 5 Resource Conservation
To promote resource conservation by encouraging housing types and designs that use fewer resources (water, electricity, etc.) and therefore cost less to operate over time, supporting long-term housing affordability.

Policies
HE 5.1 Encourage alternative energy sources. [Existing Policy HE 5.1] HE 5.2 Encourage energy and resource conservation. [Existing Policy HE 5.2] Implementation Programs
Implementation programs for this goal have been included in a table beginning on the following page.

Agenda Item #10.1.

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City of St. Helena 2023-2031 Housing Element Update HCD Review Draft, September Revised HCD Draft, February 2023Public Hearing Draft, April 20232022 1-42
Implementation Program Objectives
Implements
What
Policies
Who is
Responsible
Potential
Funding
Source
Timeframe
H-OOH-QQ Green Building Ordinance
The City shall update the Green Building Ordinance, as
necessary, to meet or exceed periodic updates to the State’s Green Building Standards Code (CalGreen). [Existing
Program HE5.A, modified]
Ensure compliance with CalGreen
throughout the planning period
HE5.1 Planning
and Building
Department
General
Fund
(staff
time)
OngoingThroughout
the planning
period, as necessary
H-PPH-RR Alternative Energy Technologies
The City will continue to encourage the use of alternative energy technologies and will explore incentives for the use of solar energy in new and rehabilitated housing.

Incentives to adopt as appropriate include, but are not restricted to, ensuring a streamlined review process for applications, allowing applications to be submitted via email and paid by phone, deferred fees, and reduced
applicable city standards. [Existing Program HE5.B,
modified]
Encourage alternative energy technologies
in new and existing developments
Explore additional incentives for solar
installation
HE5.1 Planning
and Building
Department
General
Fund
(staff
time)
OngoingExplore
and adopt
incentives, as
appropriate: by
2026
H-QQH-SS Alternative Energy Technology
Information
The City will continue to provide public information on energy conservation and alternative energy technologies to residential developers, contractors, and property owners. [Existing Program HE5.C]
Provide information on the City website and
at City Hall regarding energy conservation,
alternative energy technology options,
possible sources of financing, and any
applicable information regarding necessary
local permits
HE5.1 Planning
and Building
Department
General
Fund
(staff
time)
Ongoing2023;
updated annually
thereafter
Agenda Item #10.1.

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Implementation Program Objectives
Implements
What
Policies
Who is
Responsible
Potential
Funding
Source
Timeframe
H-RRH-TT Cost-Effective Energy Conservation
The City will continue to require cost-effective energy conservation measures in all new and rehabilitated housing to promote long-term affordability for occupants. The City will adopt the State’s new Energy Efficiency Standards as part of any update to the California Building Standards Code and ensure that all new housing units constructed in the City meet or exceed these standards. [Existing Program HE5.D]
Promote long-term affordability
Adopt updated State energy efficiency and
building code standards, as necessary,
throughout the planning period
HE5.2 Planning
and Building
Department
General
Fund
(staff
time)
Triennially Every
three years
beginning in 2023
H-SSH-UU Energy Conservation Measures
The City will continue to participate in AB-811 programs and will explore additional state and federal sources of funding to finance local energy conservation measures.

Sources of state and federal funds include, but are not limited to, the California Energy Commission State Energy Program and Energy Efficiency and Conservation Block
Grant Program, and the Low-Income Home Energy
Assistance Program. [Existing Program HE5.E]
Identify and procure additional funding to
support energy conservation measures
Provide information on available assistance
programs on the City website by 2024
Assist three households, through financial
or technical assistance, with the
implementation of energy conservation
measures
HE5.2 Planning
and Finance
Departments
General
Fund
(staff
time)
State
and
Federal
Grant
Funds
OngoingThroughout
the planning period
Explore funding:
annually
Provide information
on assistance
programs: by 2024
H-TTH-VV Water Conservation
The City will continue to apply Municipal Code provisions pertaining to water resources, including requirements for water-efficient landscaping for new residential and
commercial construction, as well as implementing the
"Water Neutrality" policy for all new development.
[Existing Program HE5.H]
Reduce water consumption
Require water-efficient landscaping
Implement the "Water Neutral" policy
Implement the Water Efficient Landscape
Ordinance (WELO)
HE5.2 Planning
and Public
Works
Departments
General
Fund
(staff
time)
OngoingThroughout
the planning period
Agenda Item #10.1.

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1-44
Goal 6 Affirmatively Furthering Fair Housing
To assure that housing programs maximize opportunity and housing choice throughout the city and proactively work to overcome patterns of economic segregation and discrimination based upon age, sex, race, sexual orientation, religion, familial status, ethnic background, or disability. [Existing Goal, modified] Policies
HE 6.1 Support equal housing opportunities for all residents of St. Helena. [Existing Policy HE 6.1] HE 6.2 Support the fair housing services provider. [New Policy] HE 6.3 Support regional efforts to affirmatively further fair housing. [New Policy] HE 6.4 Ensure public investments are equitably distributed throughout the community. [New Policy]
HE 6.5 Consider affirmatively furthering fair housing goals in all housing related decisions. [New Policy]
Implementation Programs
Implementation programs for this goal have been included in a table beginning on the following page.

Agenda Item #10.1.

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City of St. Helena 2023-2031 Housing Element Update HCD Review Draft, September Revised HCD Draft, February 2023Public Hearing Draft, April 20232022 1-45
Implementation Programs Objectives
Implements
What
Policies
Who is
Responsible
Potential
Funding
Source
Timeframe
H-UUH-WW Affirmatively Furthering Fair
Housing
The City shall address disparities in housing needs and access to opportunity for all persons regardless race,
color, religion, sex, national origin, familial status, disability gender, gender identify, gender expression,
sexual orientation, marital status, ancestry, veteran or military status, source of income, and genetic
information as protected categories by the California
Fair Employment and Housing Act (Part 2.8
[commencing with Section 12900] of Division 3 of Title
2), Section 65008, and any other state and federal fair housing and planning law.

The City identified barriers to fair housing through the Affirmatively Furthering Fair Housing Assessment.

Actions the City will take to address the identified
barriers and foster an inclusive community, include:
· Concentrations of Lower- and Moderateincome Earning Populations: H-A, H-B, H-N, HO, H-R, H-U, H-V, H-W and H-OO. · Insufficient Housing Stock for Farmworkers: HE, H-H, H-I, and H-KK. · Lack of Affordable Housing Types: H-A, H-B, HE, H-H, H-I, H-J, H-M, H-N, H-P, H-Q, H-V, H-X,

H-AA, H-DD, H-EE, H-FF, H-GG, H-LL, H-NN,
and H-OO.
· Fair Housing Enforcement and Outreach: H-T,
H-II, H-JJ, H-WW, and H-XX.
· Limited Resources for Persons with Disabilities:

H-BB, H-LL, and H-NN; as well as objectives D,
F and G in this program.

A) Work to coordinate annual meetings with
jurisdictions and fair housing providers in the county
to assist with and participate in promoting fair
housing opportunities through pursing potential
funding opportunities and joint efforts aimed at
educating the community about fair housing issues
and resources
B) Promote the availability of bi-lingual resources by
ensuring that City -provided services and materials
are available in Spanish and that information is
included regarding the availability of interpretation
or translation services
C) Encourage Facilitate development of multifamily
housing in high resource areason the western
portion of the city by providing developers with
information on incentives for affordable multifamily
development and maintaining a list of available sites
(for metrics, see Program H-V)
D) Use local permitting and approval processes to
ensure all new multifamily construction, as well as
ADUs, meet the accessibility requirements of the
federal and state fair housing acts; with the goal of
facilitating the development of 30 units accessible to
seniors and other residents with special housing
needs
E) Affirmatively recruit a diverse and multi-lingual
staff, as positions become available
HE6.1
HE6.2
HE6.3
HE6.4
HE6.5
City Council
City
Manager
Planning
Department
General
Fund
(staff
time)
Ongoing
A and H:
annually
C: engage
with
developers
twice within
the planning
period
D: by 2027
F and G:
biannuallyEv
ery two years
Agenda Item #10.1.

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City of St. Helena 2023-2031 Housing Element Update HCD Review Draft, September Revised HCD Draft, February 2023Public Hearing Draft, April 20232022 1-46
Implementation Programs Objectives
Implements
What
Policies
Who is
Responsible
Potential
Funding
Source
Timeframe
· Place-based Strategies for Community
Preservation and Revitalization and
Displacement Protection: H-A, H-I, H-J, H-N, HQ, H-R, H-U, H-V, H-W, and H-WW.

The City has included additional objectives with this
program. The City shall monitor progress toward these
objectives annually in the Annual Progress Report and
shall implement additional measures as necessary.
[New Program]
F) Work with Napa Valley Transportation Authority
to explore lowering ridership costs for the VineGo
paratransit system
G) Work with the County of Napa to carry out an
ADA self-eEvaluation and transition plan to remove
barriers for persons with disabilities to facilities and programs in Napa County
H) Prioritize capital improvement projects for public
infrastructure improvements that facilitate
affordable housing development in low and
moderate resource areasin the eastern portion of the
city
H-VVH-XX Fair Housing Provider
The City will continue to utilize and support Fair Housing Napa Valley as the City's fair housing service provider, responsible for implementing fair housing programs,
receiving complaints, and providing referrals to
available resources when necessary. The City will work
with the Fair Housing Napa Valley to provide
educational materials to educate real estate
professionals, property owners and tenants on their
rights and responsibilities and the resources available to address fair housing issues. [Existing Program HE6.A,
modified]
Provide direct funding to Fair Housing Napa Valley
with of goal of providing up to $80,000 over the
planning periodand
Ssupport fair housing investigations with a goal of
assisting with five investigations of existing
affordable developments for rent in the southeast
quadrant of the city and fair housing issues are more
concentrated and displacement risk is higher
Provide multi-lingual informational materials to the
public regarding tenant rights, fair housing issues,
and resources on the City's websitewebsite and hold
one multi-lingual engagement event to present the
information targeting residents in the eastern
portion of the city
Provide a link to Fair Housing Napa Valley on the
City's website
HE6.2 City
Manager
Planning
Department
General
Fund
OngoingEnga
ge Fair
Housing
Napa Valley:
annually
Informational
materials to
City website:
by 2024
Engagement
event: 2025
Agenda Item #10.1.

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City of St. Helena 2023-2031 Housing Element Update HCD Review Draft, September Revised HCD Draft, February 2023Public Hearing Draft, April 20232022 1-47
Implementation Programs Objectives
Implements
What
Policies
Who is
Responsible
Potential
Funding
Source
Timeframe
H-YY Replacement Unit Program
The City will adopt a policy and will require replacement housing units subject to the requirements of
Government Code section 65915, subdivision (c)(3) on
sites identified in the site inventory when any new
development (residential, mixed-use or nonresidential)
occurs on a site that is identified in the inventory
meeting the following conditions:
• currently has residential uses or within the past
five years has had residential uses that have
been vacated or demolished, and
• was subject to a recorded covenant, ordinance,
or law that restricts rents to levels affordable to
persons and families of low or very lowincome, or
• subject to any other form of rent or price
control through a public entity’s valid exercise
of its police power, or
• occupied by low or very low-income
households
In order to mitigate the loss of affordable housing
units, require new housing developments to replace
all affordable housing units lost due to new
development.

HE3.1
HE6.1
Planning
Department
General
Fund
Implement:
immediately
Adopt policy:
by January
31, 2024
Agenda Item #10.1.

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City of St. Helena 2023-2031 Housing Element Update HCD Review Draft, September Revised HCD Draft, February 2023Public Hearing Draft, April 20232022 1-48
Implementation Programs Objectives
Implements
What
Policies
Who is
Responsible
Potential
Funding
Source
Timeframe
H-ZZ Lot Consolidation
To expand opportunities for additional affordable
housing, the City will encourage the consolidation of
small parcels to accommodate larger-scale and higher
density developments that are compatible with existing
neighborhoods. The sites inventory includes five parcels equating to 39 lower- and 39 moderate-income RHNA
units. These sites were identified based on common
ownership and contiguous lots. While all five parcels are within moderate resource areas, two of these parcels
(site 9) are located on the western portion of the city, an area with fewer fair housing issues, and adjacent to Spring Street in proximity to high-quality transit
opportunities.

While these parcels will be processed by-right pursuant to Gov. Code section 65583(c)), the City will also
implement other efforts to facilitate and encourage lot consolidation.

Post the sites on the City’s website by October 2023
and provide list to interested developers when
requested, and review annually for accuracy
Develop and implement incentives for lot
consolidation by January 2024 such as fee waivers,
reduced development fees, expedited permit
processing, greater density bonus incentives, and
modifications to parking, height, or setback
standards
Facilitate lot consolidation for high density
residential developments by providing appropriate
assistance to developers to encourage negotiations
between property owners
Encourage the development of 39 lower- and 39
moderate income units during the planning period.

To increase housing mobility and opportunities in
areas where fair housing issues are less
concentrated, encourage the development of 15
lower- and 15 moderate-income units on the
western portion of the City
HE 1.3
HE 4.6
HE6.1
Planning
Department
General
Fund
Housing
Trust
Fund
Post sites to
website: by
Oct. 2023
Implement
incentives: by
2024
H-AAA Permit Streamlining Act
The City shall amend the Municipal Code to specify who
is responsible for making CEQA determinations and
within the timeframes of PRC 21080.1 and PRC
21080.2; and determination of when the PSA is
triggered per Government Code 65950(a)(5) the Permit
Streamlining Act (PSA).

Amend the municipal code for compliance with State
law within 18 months of adoption of the Housing
Element
HE 1.3
HE 4.6
Planning
Department
General
Fund
(staff
time)
Within 18
months of
adoption of
the 2023-
2031
Housing
Element
Agenda Item #10.1.

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1-49
Quantified Objectives
Quantified Objectives by Type
One of the requirements of State law (California Government Code, Section 65583[b]) is that the Housing Element contains quantified objectives for the maintenance, preservation, improvement, and development of housing. State law recognizes that the total housing needs identified by a community may exceed available resources and the community's ability to satisfy this need. Under these circumstances, the quantified objectives need not be identical to the total housing needs, however, the quantified objectives shall establish the number of housing units by income category that can be realistically constructed, rehabilitated, and conserved. The City has established quantifiable objectives in implementation programs throughout the policy document. This section summarizes new construction, conservation, and special needs housing objectives for the 2023-2031 planning period.

New Construction Objectives
Extremely low-income 33 units
166 lower-income units
3023 total units
Very low-income 73 units
Low-income 60 units
Moderate-income 445 units 1367 moderate and abovemoderate units Above moderate-income 92 units Rehabilitation and Conservation Objectives
• Conservation of all existing affordable housing units. • Conserve 200 manufactured homes at manufactured home parks. • Rehabilitation of 20 units for seniors and 10 units for persons with a disability Agenda Item #10.1.

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1-50
Assistance for Special Needs Households
• 35 units of senior housing
• 18 units for persons with a disability
• 12 units for farmworkers
• Assist in the conversion of two units from market rate to extremely low-income during the planning period.
• Assist three lower- or moderate-income households transition from rental housing to homeownership
Quantified Objectives Summary Table
The City will strive to exceed the following targets for affordable housing development in St. Helena.

Extremely
Low
Very
Low Low Moderate
Above
Moderate Total
New Construction 33 73 60 445 92 3023
Rehabilitation 10 10 5 5 0 30
Conservation/Preservation 0 120 100 231 0 451
Agenda Item #10.1.

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1-51
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Agenda Item #10.1.

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St. Helena City CouncilMay 9, 2023

St. Helena City Council
May 9, 2023