Agenda — St. Helena City Council, September 23, 2025 (part 2 of 2)

83578.00012\42255084.1
Section 2. Amendment. Please see below (new language is underlined, deletions are in strikeout):

Subsection B (1) of Section 17.24.050 f the St. Helena Municipal Code is hereby amended to read as follows

1. Fences, hedges, or dense planting in the form of a hedge shall not exceed two feet forty-two inches in height when located in the visibility triangle as defined in Part V, Definitions and Rules of Measurement.

Chapter 17.32, Definition of Terms, Visibility Triangle Visibility triangle. On a corner lot, the triangle formed by lines extended from the face of the curb to their intersection and a line connecting the face of the curb extensions measured twenty five (25) 35 feet from their point of intersection. If no curb exists, the edge of the roadway or vehicular travel area shall be used as the point of measurement.

Figure 17.32(E). Visibility Triangle
Section 3. Severability. If any section, subsection, phrase, or clause of this ordinance is for any reason held to be unconstitutional, such decision shall not affect the validity of the remaining portions of this ordinance. The City Council would have passed this ordinance and each and every section, subsection, sentence, clause, or phrase not 25’
25’
Agenda Item #11.2.

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83578.00012\42255084.1
declared invalid or unconstitutional without regard to whether any portion of the ordinance would be subsequently declared invalid or unconstitutional.

Section 4. CEQA. This ordinance was assessed in accordance with the authority and criteria contained in the California Environmental Quality Act (CEQA), the State CEQA Guidelines (the Guidelines), and the environmental regulations of the City. The City Council hereby finds that this ordinance is exempt from review under CEQA under Section 15061(b)(3) of the State CEQA Guidelines because it can be seen with certainty that the provisions contained herein would not have the potential for causing a significant effect on the environment.

Section 5. Effective Date. This Ordinance shall take effect and be enforced within thirty (30) days from and after the date of its adoption by the City Council at a second reading and shall be posted and published in accordance with the California Government Code.

THE FOREGOING ORDINANCE was introduced at a regular meeting of the St.

Helena City Council on the 23rd day of September, 2025, and was adopted at a regular meeting of the St. Helena City Council on the day of , 2025, by the following vote:

AYES:

NOES:

ABSENT:

ABSTAIN:

APPROVED ATTEST
__________________________ _____________________
Paul Jamison Dohring, Mayor City Clerk
Agenda Item #11.2.

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INTERSECTION
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Wl'THIN 'THIS AREA ALL SHRUBS, BUSHES, FENCES AND OTI-iER IMPROVEMENTS SHALL BE RESTRICTED TO A 2'-0" (24") MAXIMUM HEIGHT, AND TREES MAINTAINED TO A CLEARANCE OF 7'-0" ABOVE GROUND (MIN.).

CITY OF ST. HELENA DA TE: NOV. 1993

VISIBILITY AND FENCING

REQUIREMENTS
STD. NO.
324
Agenda Item #11.2.

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17.52.170
Vision Triangle at Driveways and Intersections. Fences, walls or dense planting in the form of hedges shall not exceed two feet in height when located in the vision triangle of a driveway or intersection (see Public Works Department standard specifications), however, fences that are at least 50% open shall be permitted up to three feet in height. Trees located in the vision triangle shall be maintained to provide a clearance of seven and one‐half feet.

17.54.155
Visibility shall not be blocked between a height of two and seven and one‐half feet within the vision triangle of a driveway crossing a street right‐of‐way line, except that fences that are at least 50% open shall be permitted up to three feet in height. The length/width of the triangle varies depending on the type of street: local street = 10 feet; collectors=15 feet; arterials=20 feet depending on the type of street.

City of Napa:

10.32.020
Whenever the Traffic Engineer finds that any hedge, shrubbery, tree or fence or other obstruction, growing, erected or maintained in a parkway or on private property in the setback area obstructs the view of any driveway or intersection, or any traffic upon the streets approaching such driveway or intersection, he or she shall cause the hedge, shrubbery, tree, fence or other obstruction to be immediately removed or reduced in height. Such hazards may include any structure, fence, landscaping or other obstructions more than two feet in height above the level of the sidewalk or ground elevation, whichever is higher, in an area called a vision triangle as specified below, except that trees may be allowed when no foliage is closer to the ground than seven and one‐half feet and fences that are at least 50% open shall be permitted up to three feet in height.

A. At street intersections, the boundaries of the vision triangle are formed by measuring along the curb‐lines from the projected intersection a distance of 50 feet and then connecting the two points with a straight line.

B. At driveway entrances, the boundaries of the vision triangle are formed by measuring along the side of the paved driveway and along the street right‐of‐way line from their intersection a distance as specified below and then connecting the two points with a straight line:

1. Not less than 10 feet for local streets;

2. Not less than 15 feet for collector streets;

3. Not less than 20 feet for arterial streets

20.16.100
A vision triangle shall be reserved at all driveways as a public safety feature. Within this area, no vegetation shall exceed a height of three feet, except for trees that are pruned and maintained so as not to block the visibility of vehicles entering and exiting sites. The design and extent of the vision triangle shall be approved by the planning and building director.

20.16.005(E) Vision clearance, corner lots.

City of Healdsburg:

On corner lots, within a triangular area formed by the street property lines and a line connecting points on the street property lines 30 feet from the street intersection, no fence, wall, hedge, or other obstruction, except the natural grade of a site, shall exceed a height of 30 inches above established grade at the edge of the existing or proposed pavement, provided that trees pruned up to eight feet above street grade shall be permitted.

F. Width, corner lots.

The minimum width of corner lots in an R or ORM district shall be 20 percent greater than the minimum width for the district as otherwise provided.

Within a vision triangle
36 inch maximum height, with nothing over 24 inches in the first five feet behind the curb line NOTE: The boundaries of a vision triangle are formed by drawing lines from the point of intersection of a lot’s street corner property lines to points 40 feet along the two property lines, and then connecting the two points with a straight line.

City of Santa Rosa
Vision Triangle Standards
(Napa, Healdsburg, Santa Rosa, Petaluma, Sonoma, Cotati) Attachment 3 Agenda Item #11.2.

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20‐30.110(F)
(a) Vision triangle boundaries are formed by: (1) drawing a 40‐foot line along the face of curb or edge of one roadway to a point of intersection; (2) from the point of intersection, drawing a line 40 feet back along the face of curb or edge of the second roadway; and (3) connecting the end points of these two lines. Vision triangles at locations with all way stop controls or signalized intersections may be allowed less restrictive requirements with City Traffic Engineer approval. (b) Driveway vision triangle boundaries are formed by first drawing a 10‐foot line along the back edge of the sidewalk from the driveway and then drawing a 10‐foot line along the driveway edge abutting the sidewalk. Connecting these two legs completes the vision triangle.

13.020
Vision Triangle . The triangular area formed by the intersection of the extension of the curb lines and a line connecting them at points thirty‐five (35) feet from the intersection of the extended curb lines.

City of Petaluma For driveways, the site visibility triangle is determined by the triangular area formed as shown in Figure 13.1. For driveways, the measurement is taken from the back of the sidewalk, or where there is no sidewalk as determined by the Director. https://petaluma.municipal.codes/ZoningOrds/13.020
Standard Plans Sent a link to city standards in which I didn't find any info:

City of Sonoma https://www.sonomacity.org/documents/city‐engineer‐contract‐position‐provides‐services‐three‐basic‐areas‐review‐public‐ improvements‐private‐developments‐streets‐drains‐water‐lines‐etc‐capital‐improvement‐pr/ In the absense of a local standard plan, they use Caltrans standards.

Fences, walls, hedges, and other structures or vegetation shall not exceed a height of three feet within a clear vision triangle and the lower portion of tree crowns shall not be less than eight feet within a clear vision triangle. Clear vision triangles shall be delineated as follows:

A. Uncontrolled intersections: A triangular area bounded by the curb lines (tangents) and a diagonal line joining points on the tangents which are located thirty‐five foot back from what would be the point of these curb lines' intersection.

City of Cotati 17.14.040
B. Controlled intersections: A triangle having twenty‐five foot tangents at the curblines.

C. Driveways: A triangle having twenty‐five foot tangents at the outside line of the driveway and the curbline.

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Address Street Notes Non-Compliant Compliant Non-Compliant Compliant 1299 PINE ST Non-compliant X X
1605 SPRING MOUNTAIN RD Nothing has been done
1660 SPRING MOUNTAIN RD hedge too high X X
1810 SPRING MOUNTAIN RD Visibility set for 25' (clayton) X X 1746 MADRONA AVE Non-compliant X X
1702 MADRONA AVE
36" wall - vegetation noncompliant X X
1407 KEARNEY ST Non-compliant - 42" fence X X
1550 ALLYN AVE
Remove Bush Between Fence
and Tree X X
1580 HILLVIEW PL Reduce hedge height - fence 38" X X
1660 HILLVIEW PL hedge too high
1743 HILLVIEW PL Limb up tree X X
1604 MADRONA AVE High hedge - fence 38" X X
1895 MADRONA AVE High hedge X X
1256 STOCKTON ST 42" fence X X
1556 SPRING ST Non-compliant X X
2080 SPRING ST High hedge X X
1707 SCOTT ST large bushes X X
1530 STOCKTON ST Still out of compliance X X
1657 STOCKTON ST Limb up tree X X
2081 OLIVE AVE Minor Trim X X
1601 SULPHUR SPRINGS AVE High Hedge X X
1245 SPRING ST Non-compliant X X
Address Street Notes Photo Non-Compliant Compliant Non-Compliant Compliant 1020 VINTAGE AVE XX
825 ALLISON AVE XX
910 ALLISON AVE Tall Hedge X X
1227 EDWARDS ST XX
1250 CHURCH ST Slight Trimming needed X X
1135 PRATT AVE XX
1872 MAIN ST XX
West Side
East Side
Current Requirements
35 Ft. & 24" fence
Proposed Requirements
25 ft. & 42" fence
Current Requirements
35 Ft. & 24" fence
Proposed Requirements
25 ft. & 42" fence
Agenda Item #11.2.

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City of St. Helena
City Council
September 23, 2025
Project: ZOA 25-003 Visibility Triangle Standards
Amendment
Staff: Maya DeRosa, AICP, Community Development
Director
Community Development Department
Agenda Item #11.2.

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Background
Zoning Code has standards relating to vision triangles:
• Maximum height of vegetation, walls, fences inside triangle=2 feet • Length and area within a vision triangle: 35 feet from street corner Agenda Item #11.2.

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Background
• Public Works has standard (No. 324) relating to vision triangles that allows for a 25 foot vision triangle
25 feet
25 feet
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Background
• 299 street corners surveyed by
Fire Chief and Fire Inspector in
Jan 2024
• 66 properties found to be out of
compliance based on SHMC
standard (35 feet and max 2 feet
height)
• Summer 2024 City releases
educational and awareness
campaign to residents of vision
triangle requirements
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Background-Other Cities Research
• City of Napa, Healdsburg, Santa
Rosa, Petaluma and Cotati
• Range of standards for acceptable
length of vision triangle
• Generally allowable height was 36
inches
• (Attachment 3 of staff report)
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Field Research
Agenda Item #11.2.

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Field Research/Historic Stone Walls
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Field Research
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Feedback from Planning Commission
Discussion May 20, 2025
Generally Supported:
• Increasing the allowable height of
vegetation/ fences from 24” to a
maximum of 42”
• Reducing the length of a vision triangle
from 35 feet to 25 feet
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Safety Review
• Police Department did not have
safety concerns with the proposed
amendments to the vision triangle
standards
• Public Works Department
indicated that Caltrans data notes
that the line of sight for a driver is
42” high and therefore that should
be the maximum allowed height
Agenda Item #11.2.

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Recommended Redline Changes from
Planning Commission public hearing on
September 2, 2025:

Subsection B (1) of Section 17.24.050 f the St. Helena Municipal Code is hereby amended to read as follows:

Fences, hedges, or dense planting in the form of a hedge shall not exceed two feet forty-two inches in height when located in the visibility triangle as defined in Part V, Definitions and Rules of Measurement.

Agenda Item #11.2.

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Recommended Redline Changes:

Agenda Item #11.2.

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Recommended Redline Changes:

Figure 17.32 (E)
25'
25'
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Recommendation
Introduction and waive the first reading of a proposed ordinance to:
1) Find that the proposed changes to Chapter 17.30 of the Zoning Code are exempt from CEQA Guideline 15061 (b)(3); and
2) Approve and adopt Zoning Ordinance Amendment (ZOA 25-003) to amend Chapters 17.24.050 B (1) and 17.32, Definition of Terms, Visibility Triangles, of Title 17 of the St. Helena Municipal Code regarding vision triangle standards.

Agenda Item #11.2.

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Questions?
Agenda Item #11.2.

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Agenda Report to the City Council
Agenda Section: NEW BUSINESS
Department: Administration
DATE: September 23, 2025
FROM: Andrew Bradley, Program Manager
SUBJECT: Regional Climate Action and Adaptation Plan (RCAAP) Update and Discussion

RECOMMENDED
ACTION:

Receive a presentation on the City of St. Helena’s
progress on the administrative draft of the Regional
Climate Action and Adaptation Plan and an update on the Countywide Climate Action Committee activities. Provide input to staff and city representative on potential actions and next steps.

PREVIOUS COUNCIL
ACTION:

None.

STATEMENT OF THE
PURPOSE:

The purpose of this item is to solicit input from city
residents and council members on the draft Regional
Climate Action and Adaptation Plan (RCAAP) which will be discussed on September 30th at the Climate Action
Committee (CAC) meeting wherein Vice Mayor will
participate in the discussion.

FINANCIAL IMPACT: N/A
BACKGROUND:

Climate Action Committee (CAC)
In June 2019, the six jurisdictions in Napa County took action regarding the countywide commitment to address climate change and in 2020 formed the Napa County Climate Action Committee (CAC). The CAC consists of two elected officials from each of the six jurisdictions. The CAC is administered and staffed by Napa County. The CAC meets monthly as a collaborative framework to reduce greenhouse gas (GHG) emissions and limit future adverse impacts of climate change. Over the past 6 months, the CAC has focused on developing the Regional Climate Action and Adaptation Plan (RCAAP) that would prioritize climate action projects for the region and the City of Napa. All items discussed at the CAC meetings must be brought to Council for adoption or approval.

All partners on the Climate Action Committee (CAC) realize that each jurisdiction has unique needs, and desires input from elected leaders to help ensure the final plan reflects local and regional priorities.

The administrative draft of the Regional Climate Action and Adaptation Plan (RCAAP) aims to reduce greenhouse gas emissions and increase resilience to climate change impacts throughout the Napa region. The plan will guide Napa County, the cities within Agenda Item #13.1.

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the county. The RCAAP will prioritize emission reduction in the areas of transportation, building energy, waste disposal, water use, and land use. The RCAAP will also promote preparedness for climate-related hazards such as extreme weather, wildfires, and floods by strengthening critical infrastructure, restoring natural ecosystems, and improving emergency responses.

DISCUSSION:

Regional Climate Action and Adaptation Plan (RCAAP)
Local jurisdictions within Napa County including the Cities of American Canyon, Calistoga, Napa, and St. Helena, the Town of Yountville, and Napa County have come together to develop a Napa County Regional Climate Action and Adaptation Plan (RCAAP), and the public draft was released on August 1, 2025. The RCAAP can be found on the project webpage www.climateactionnapa.konveio.com. Public input and comments are invited during the 60-day public review period from August 1 to September 30, 2025. The RCAAP is a roadmap that identifies strategies, measures, and actions that guide the region to reduce greenhouse gas emissions and adapt to climate change. Shaped by input from residents, businesses, and community organizations across all six jurisdictions, it supports a more sustainable and resilient Napa County and requires coordinated action across the county. The RCAAP reflects solutions that are representative of the unique environmental, economic, and social characteristics of the county.

Community engagement ensures that the plan reflects the needs, priorities, and values of the people it serves. In 2024, public outreach and community engagement efforts resulted in responses and input from 310 individuals to an introductory survey which helped to gain a better understanding of how residents feel about climate change and how it affects their daily lives. Four community meetings were held in the summer of 2024 to identify existing conditions and key areas of concern for participants.

Furthermore, 20 community-based organizations (CBOs) partnered with the project team to hold focus group meetings to explore the needs of the community. Three community meetings were held on the draft RCAAP in August 2025.

Through the RCAAP, Napa County Jurisdictions have set countywide GHG emissions reduction targets for 2030, 2035, and 2045, which are aligned with the State of California’s goals. They include: 42 percent reduction below 2019 levels by 2030, 57 percent reduction below 2019 levels by 2035, and 85 percent reduction below 2019 levels by 2045. Climate action and sustainability are a priority for the City. The City declared a Climate Emergency in 2022. The Climate Emergency Resolution guides the city's actions to address the climate crisis. The Climate Emergency Resolution states; “The scientific evidence indicates that an urgent global climate mobilization effort to reverse global warming is needed as quickly as possible towards net zero climate pollutants from public and private operations within the City by 2030.” While legislative and regulatory actions at the regional, State, and federal levels will result in notable GHG emissions reductions on their own, additional efforts need to be taken locally by Napa County jurisdictions to fully achieve the established targets.

Agenda Item #13.1.

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These additional efforts come in the form of 46 distinct GHG reduction measures that were prepared for this RCAAP. Across the six emissions sectors (Building Energy, OnRoad Transportation, Solid Waste, Water and Wastewater, Agriculture, and Off-Road Equipment), 21 different GHG reduction strategies are supported by 46 measures and 107 actions. The GHG reduction measures reduce emissions from human activities (e.g., building energy use and transportation), and enhance carbon storage (e.g., carbon farming and restoring wildfire-affected areas).

Although 46 GHG reduction measures are included in the RCAAP, a few specific measures are projected to account for the vast majority of reductions from humancaused emissions by 2045. These include:
 BE-1: Retrofit Existing Buildings to Zero Carbon
 TR-9: Expand Renewable Diesel Availability
 AG-1: Reduce Fossil Fuel Consumption in Field Equipment  SW-1: Increase Solid Waste Diversion • SW-4: Increase Landfill Methane Capture Capacity
 WW-1: Reduce Methane Emissions from Wastewater Treatment Plants (BE = Building Energy; TR = On-Road Transportation; AG = Agriculture; SW = Solid Waste; WW = Imported Water & Wastewater)
Altogether, the six measures account for approximately 91 percent of total emissions reductions in 2045.

Implementation of the RCAAP will affect municipalities, businesses and residents which is why it is important for the public to participate in commenting of the draft document.

The draft RCAAP estimates that implementation of all 19 measures would cost Napa County governments approximately $1.1 billion to as much as $1.4 billion over 20 years, or approximately $57 million per year (RCAAP page 6-3).

City of St. Helena staff has modified table 3.1 (attached) by adding columns to provide city council with input related to the list of strategies.

Next Steps
Upon the conclusion of the draft RCAAP public review period on September 30th, a summary of comments will be prepared and shared with the Napa County jurisdictions.

The comments will be evaluated and the draft document will be refined in collaboration with input from the participating jurisdictions.

ENVIRONMENTAL REVIEW: N/A
GOAL:

Goal 2: Improve Infrastructure & Further Environmental Sustainability Goal 5: Enhance Quality of Life
Agenda Item #13.1.

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DOCUMENTS ATTACHMENTS:

RCAAP_PublicDraft_8-27-25_St Helena City Council
StHelena_GHG_ReductionMeasures_Evaluation Table 3-1_091725 v2 Agenda Item #13.1.

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Napa County Regional Climate Action and Adaptation Plan September 2025
Agenda Item #13.1.

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What is the RCAAP?
• Comprehensive, long-range, climate plan
• Achieves countywide GHG reduction targets and carbon
neutrality goals for 2030 and 2045
• Provides countywide strategy for climate adaptation and resilience.
• Builds on existing sustainability & climate initiatives • Regional, coordinated plan
• Addresses regional emissions and regional climate change impacts (all jurisdictions)
• Prepared and reviewed by member agencies of the Climate Action Committee (CAC):
• County of Napa
• City of American Canyon
• City of Calistoga
• City of Napa
• City of St. Helena
• Town of Yountville
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Why is the RCAAP Needed?
Our Climate Emergency Requires Urgent Action
Source: YPCCC (no date); figure developed by Ascent in 2025.

Agenda Item #13.1.

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Partnerships and
Collaboration
• 6 Local Jurisdictions
• Community
• Utilities
• Regional Agencies
• State of California
• Federal Government
We’re all in this together!
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Climate Action: GHG Mitigation
Agenda Item #13.1.

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Napa County’s Regional GHG Emissions Inventory (2019)
Agenda Item #13.1.

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Forecasted GHG Emissions, Targets, and GHG Reduction Measures Agenda Item #13.1.

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8 Regional Climate Action and Adaptation Plan
RCAAP GHG Reduction
Strategies
• 21 Strategies, aligned with GHG emissions
sectors + carbon sequestration opportunities
• 46 GHG Emission Reduction Measures
• 17 quantifiable measures
• 100+ Implementing Actions
• Many short-term actions (next 5 years)
• Long-term actions (beyond 5 years)
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9 Regional Climate Action and Adaptation Plan
Building Energy
• Clean and Efficient Energy Use in Existing Buildings
• Retrofit All Existing Buildings to Zero Carbon
• Energy Audits & Incentives
• Increase Renewable Energy Generation & Storage
• Sustainable Winery Certifications
• Zero-Carbon New Development
• Require New Buildings to be Zero-Carbon
• Energy Education, Awareness, and Behavior Change
• Empower Community to Reduce Building Energy Emissions Anthropogenic reductions in 2045: 58,375 MTCO2e
• 8% of all reductions
• 14% of all anthropogenic reductions
Agenda Item #13.1.

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Regional Climate Action and Adaptation Plan 10
Transportation
• Reducing How Much We Drive (vehicle miles traveled, or VMT)
• Increase Active Transportation Options
• Expand Mobility Options for Visitors/Tourism
• Reduce Winery Wastewater Hauling
• Electrification of Vehicles & Equipment
• Transition Fleets to ZEVs
• Increase EV Charging and Hydrogen Fueling Infrastructure • Expand Zero-Carbon Fuels
• Transportation Education
Anthropogenic reductions in 2045: 76,511 MTCO2e
• 10% of all reductions
• 18% of all anthropogenic reductions
Agenda Item #13.1.

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Regional Climate Action and Adaptation Plan 11
Solid Waste
• Promote Zero Waste
• Increase Solid Waste Diversion
• Reduce Construction & Demolition Waste
• Waste Education (Reduce/Reuse/Recycle/Compost)
• Reduce Existing Landfill Emissions
• Increase Methane Capture Capacity and Efficiency
• Support Waste-to-Energy
Anthropogenic reductions in 2045: 173,057 MTCO2e
• 23% of all reductions
• 41% of all anthropogenic reductions
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12 Regional Climate Action and Adaptation Plan
Water & Wastewater
• Reduce Water Waste
• Improve Water Conservation &( Efficiency
• Native and Drought-Tolerant Landscaping
• Reduce Methane Emissions from Treatment Plants
• Explore Recycled Water Opportunities
Anthropogenic reductions in 2045: 45,412 MTCO2e
• 6% of all reductions
• 11% of all anthropogenic reductions
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13 Regional Climate Action and Adaptation Plan
Agriculture and Open
Space
• Reduce Fossil Fuel Use in Farming Equipment
• Increase Carbon Farming
• Increase Sustainable Vineyard Certifications
• Sustainable Livestock Practices
• Expand Urban Forest
• Accelerate Woodland and Forest Restoration and
Stewardship
• Avoid or Minimize Carbon Stock Loss Attributable to
Land Use Change
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Climate Adaptation
Source: CA Adaptation Planning Guide
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Climate Adaptation & Resilience Strategies
• All-Hazards Approach to Climate
Resilience: People, Infrastructure,
Natural Resources
• Wildfire Risk Reduction and
Preparedness
• Extreme Heat Mitigation
• Enhanced Flood Protection
• Long-Term Adaptation to Sea-Level
Rise
• Energy Grid Resilience
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Regional Climate Action and Adaptation Plan 16
Implementation &
Monitoring
• Local adoption of the RCAAP (all 6 jurisdictions)
• Regionally-coordinated implementation strategy
• Ongoing Monitoring, Reporting, Updating
• Periodic GHG inventory updates
• Annual reporting on targets and key indicators
• Periodic updates to RCAAP
• Order-of-magnitude cost estimates for limited subset of measures • 9 GHG measures and 10 adaptation measures
• Important note: Not a full-scale cost estimate for entire plan.
• Potential funding & financing sources identified
• Funding and financing strategy tied to timing and
prioritization will be critical
Agenda Item #13.1.

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Regional Climate Action and Adaptation Plan 17
Next Steps
• Aug 1 – Sept 30, 2025: Public Review & Comment Period • Fall 2025 - Winter 2026: Review Comments, Prepare Final RCAAP, Complete Environmental Review Process
• Spring 2026: Adoption Hearings
• 2026 – 2045: RCAAP Implementation
Agenda Item #13.1.

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CITY OF ST HELENA
RCAAP TABLE 3.1 DRAFT EVALUATION
Measure ID Strategy/Measure Title 2030 2035 2045
Completed
or In
Progress
Viable with
limited
resources
Viable with
significant
resources
Not Viable
or Additional
Study Req'd
Strategy: Clean and Efficient Energy Use in Existing Buildings BE‐1 Retrofit Existing Buildings to Zero Carbon 38,703 57,957 36,412 X BE‐2 Energy Audits for Existing Non‐Residential Buildings X BE‐3 Increase Renewable Energy Generation 1,875 ‐ 3,510 X BE‐4 Increase Sustainable Winery Certification X
Strategy: Zero Carbon Development
BE‐5 Decarbonize New Buildings 19,418 18,428 21,963 X
Strategy: Energy Education, Awareness, and Behavior Change BE‐6 Empower Community to Reduce Building Energy Emissions X Strategy: Low Vehicle Miles Traveled
TR‐1 Reduce Vehicle Miles Traveled Countywide X
Strategy: Reduce Commercial VMT
TR‐2 Reduce Winery Wastewater Hauling Emissions 520 415 215 X Strategy: Zero Carbon Fuels
TR‐3 Expand Electric Vehicle Charging Infrastructure X
TR‐4 Leverage New Development to Support Zero‐Emission Vehicles X TR‐5 Increase Municipal Zero‐Emission Vehicle Adoption X TR‐6 Increase Commercial Zero‐Emission Vehicle Adoption X TR‐7 Increase Residential Zero‐Emission Vehicle Adoption X TR‐8 Restrict Development of New Fossil Fuel Pumps X
TR‐9 Expand Renewable Diesel Availability 17,830 36,228 43,785 X Strategy: Active Transportation
TR‐10 Implement the Active Transportation Plan 1,829 1,708 748 X Strategy: Transportation Demand Management (TDM)
TR‐11 Expand Transportation Demand Management Programs 3,689 2,351 673 X TR‐12 Fund Local Transportation Infrastructure Improvements X Strategy: Visitor TDMTR‐13 Reduce Vehicle Miles Traveled of Visitors to Napa County X Strategy: Parking
TR‐14 Reduce or Eliminate Parking Requirements X
Strategy: Transportation Education
TR‐15 Empower Community to Choose Active Transportation Options X Strategy: Electrification and Clean Alternatives
OF‐1 Reduce Landscaping‐Related Emissions 290 149 12 XOF‐2 Zero‐Emission Loading Docks 271 541 820 X OF‐3 Zero Carbon Construction Equipment ‐ Community ‐ 5,944 10,221 X OF‐4 Zero Carbon Construction Equipment ‐ Municipal 236 472 472 X Strategy: Promote Zero Waste
SW‐1 Increase Solid Waste Diversion 47,342 56,974 68,072 X SW‐2 Reduce Construction and Demolition Waste X
SW‐3 Waste Education and Awareness X
Strategy: Reduce Landfill Emissions
SW‐4 Increase Landfill Methane Capture Capacity 93,048 98,772 104,985 X 09/17/25
Agenda Item #13.1.

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CITY OF ST HELENA
RCAAP TABLE 3.1 DRAFT EVALUATION
Measure ID Strategy/Measure Title 2030 2035 2045
Completed
or In
Progress
Viable with
limited
resources
Viable with
significant
resources
Not Viable
or Additional
Study Req'd
SW‐5 Support Increased Methane Capture Efficiency at Regional Landfills X SW‐6 Support Waste‐to‐Energy Facilities X
Strategy: Wastewater Treatment
WW‐1 Reduce Methane Emissions from Wastewater Treatment Plants 32,739 43,227 45,412 X Strategy: Promote Recycled Water
WW‐2 Explore Recycled Water Opportunities X
Strategy: Water Use Efficiency Conservation
WW‐3 Reduce Residential Water Use XWW‐4 Prioritize Native Drought Tolerant Plants in Municipal Landscaping X WW‐5 Reduce Wasteful Potable Water Use XWW‐6 Reduce Public Distribution System Water Loss X Strategy: Reduce Water Loss
WW‐7 Improve Water Efficiency and Conservation X
Strategy: Reduce GHGs from Agricultural Equipment
AG‐1 Reduce Fossil Fuel Consumption in Field Equipment 25,316 49,020 52,862 X AG‐2 Promote Sustainable Agricultural Equipment X
Strategy: Increase Carbon Storage
AG‐3 Expand Carbon Farming PracƟces† X
AG‐4 Report on Carbon Farming PracƟces† X
AG‐5 Expand the Urban Forest† X
AG‐6 Accelerate Woodland and Forest Habitat RestoraƟon and Stewardship in Rural Areas† 82,201 123,302 164,403 X Strategy: Reduce Emissions from Vineyard Management
AG‐7 Increase Sustainable Vineyard CerƟficaƟon† 20,778 63,556 167,444 X Strategy: Reduce Emissions from Livestock
AG‐8 Enhance Sustainable Livestock Practices X
Strategy: Avoid or Minimize Carbon Sequestration Loss
AG‐9 Avoid or Minimize Carbon Sequestration Losses Associated with Development Projects X Total Annual Reductions from human‐caused sources only 283,105 375,696 386,653 Reductions Needed to Meet 2030 and 2045 Targets1 189,219 227,410 368,542 On Track to Meet Target? Yes Yes Yes
Total Annual Reductions from all sources 386,084 562,553 718,500 Reductions Needed to Meet the 2045 Carbon Neutrality Goal1 189,219 227,410 547,378 On Track to Meet 2045 Carbon Neutrality Goal? Yes Yes Yes Notes: N/A = not available. Refers to a qualitative measure. MTCO2e = metric tons of carbon dioxide equivalent. Values may not sum due to rounding. † Refers to GHG reducƟon through non‐anthropogenic source. 1 See Table 2.5Source: Analysis conducted by Ascent in 2024. 09/17/25
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Napa County Regional Climate Action and Adaptation Plan September 2025
Agenda Item #13.1.

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Why is the RCAAP Needed?
Our Climate Emergency Requires Urgent Action
Source: YPCCC (no date); figure developed by Ascent in 2025.

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Climate Action: GHG Mitigation
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Napa County’s Regional GHG Emissions Inventory (2019)
Agenda Item #13.1.

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Forecasted GHG Emissions, Targets, and GHG Reduction Measures Agenda Item #13.1.

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Climate Adaptation
Source: CA Adaptation Planning Guide
Agenda Item #13.1.

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From: Christopher J Warner
To: Public Comment; Erika Opp
Cc: Paul Dohring; Michelle Deasy; Andrew Bradley; Maya DeRosa Subject: Preliminary Comments - Draft Regional Climate Action and Adaptation Plan - Agenda Item 13.1 - St. Helena City Council Meeting, Sept. 23, 2025
Date: Friday, September 19, 2025 3:08:17 PM
Attachments: Draft RCAAP Comments St. Helena and CAC Summary of Recommendations.pdf Draft RCAAP Comments St. Helena and CAC.pdf
Attached are preliminary comments on Agenda Item 13.1, the Draft Regional Climate Action and Adaptation Plan (RCAAP). Also attached is a summary of recommendations included in the preliminary comments. These comments also will be shared with the Napa Climate Action Committee. These comments are solely personal and not in any official capacity or representing any third party or entity.

Thank you for your consideration of these comments.

Christopher J. Warner
1434 Grayson Avenue
St. Helena, CA 94574
(415) 309-9572
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1 Christopher J. Warner
Preliminary Comments on
Draft Napa Regional Climate Action and Adaptation Plan
September 19, 20251
Summary of Recommendations
The Draft RCAAP’s voluntary measures and programs are worthy of consideration and potential funding by the Climate Action Committee, participating jurisdictions and the public.

However, the mandatory greenhouse gas reduction and climate adaptation measures recommended by the Draft RCAAP are not supported by environmental analysis, quantitative benefit-cost evaluations, consideration of impacts on vulnerable and disadvantaged communities, or feasible funding to pay for the government costs of implementation. These proposed mandatory measures and programs should not be considered or adopted until the missing analyses, evaluations and assured sources of funding are completed and available for review and public consideration.2

1. RECOMMENDATION: Public comments and final adoption of the Draft Plan by participating jurisdictions should not be scheduled until the required environmental and legal reviews and modifications to the RCAAP in response to the environmental and legal reviews are completed and available to the public.

2. RECOMMENDATION: The Draft RCAAP should not be considered and adopted until realistic sources of funding and budgets for the $1.1 billion in governmental costs of implementing the plan are identified and assured, particularly in light of severe current reductions in available state and federal funding.

3. RECOMMENDATION: The Draft RCAAP should include benefit-cost evaluations for each proposed measure and program, consistent with benefit-cost methods for government programs and regulations, before the Draft RCAAP is submitted to the Napa jurisdictions and the public for consideration. Specific benefit-cost evaluations are required for the mandatory building electrification measures that would force Napa homeowners, schools, hospitals, offices, restaurants, stores, hotels, wineries, government buildings and other property and building owners to stop using their gas appliances and retrofit and rewire all 1 These comments are solely personal and individual, and not provided in any official capacity and not on behalf of any third party or entity.
2 These comments do not address the potential changes in assumptions in the Napa greenhouse gas inventory used in the draft RCAAP, which appear to assume that any changes in greenhouse gas emissions since the 2019 data used in the inventory, such as changes in vehicle miles traveled (VMTs) or water consumption due to COVID, water rate increases, or other factors, should be excluded from the GHG inventory. See draft RCAAP, Appendix B, Greenhouse Gas Inventory Memorandum, November 29, 2022, p. 1 (“The update year of 2019 was selected because this was the latest year in which data were most complete and excludes data anomalies due to the COVID-19 pandemic starting in 2020, such as reduced transportation emissions from increase telecommuting.”) Agenda Item #13.1.

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2 their existing residential and non-residential buildings at an average cost of $30,000- $100,000 per home and building, and require electrification of all new housing and buildings. Other potentially costly mandatory measures would be imposed on municipal water and waste disposal systems; existing wineries, vineyards and agriculture; residential water uses and rates; home hardening; vehicle use by commuters, visitors and residents; availability of public parking, etc. None of the mandatory measures and programs should be adopted until specific cost estimates and benefit-cost evaluations are completed for each measure and program.

4. RECOMMENDATION: The procedural schedule should be modified to consider and complete the changes to General Plans, Housing Elements, zoning and building codes and local climate plans that would be required prior to adoption and implementation of the Draft RCAAP.

5. RECOMMENDATION: The confusion as to whether the Draft RCAAP is intended to require new, mandatory measures unanimously agreed to by all participating jurisdictions and/or enforceable by an independent new “joint powers authority” should be resolved before any further public, stakeholder or local government consideration of the Draft RCAAP.

6. RECOMMENDATION: The equity and affordability analysis of the Draft RCAAP and its impacts on vulnerable and disadvantaged communities should be developed and included prior to any consideration of the Draft RCAAP by participating jurisdictions and the public.

7. RECOMMENDATION: The Draft RCAAP should not be considered by the participating jurisdictions and the public until the estimated compliance costs to the public and all affected stakeholders are included in the Draft RCAAP.

8. RECOMMENDATION: The Draft RCAAP’s proposed mandatory residential and nonresidential building electrification measures should not be adopted unless the quantitative benefits to Napa residents and businesses significantly exceed the costs of compliance and the impacts on real estate market values and appraisals that impact property tax revenues.

9. RECOMMENDATION: Similar to the existing building electrification mandate, the Draft RCAAP’s proposed new building electrification mandate should not be adopted unless the direct benefits and costs to new housing and buildings are evaluated and the benefits significantly exceed the costs to new and affordable housing, economic development and the local Napa economy.

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1 Christopher J. Warner
Preliminary Comments on
Draft Napa Regional Climate Action and Adaptation Plan
Submitted to
St. Helena City Council, September 23, 2025 Meeting, Agenda Item 13.1 And to Napa Climate Action Committee
September 19, 20251
Summary.

The Draft RCAAP’s voluntary measures and programs are worthy of consideration and potential funding by the Climate Action Committee, participating jurisdictions and the public. However, the mandatory greenhouse gas reduction and climate adaptation measures recommended by the Draft RCAAP are not supported by environmental analysis, quantitative benefit-cost evaluation, impacts on vulnerable and disadvantaged communities, or feasible funding to pay for the government costs of implementation. These proposed mandatory measures and programs should not be considered or adopted until the missing analyses, evaluations and assured sources of funding are completed and available for review and public consideration.2
Discussion.

As a threshold matter, the Climate Action Committee staff should be commended for providing a draft regional climate action plan for initial public consideration. The work put into the Draft RCAAP so far is extraordinary, particularly for its recommendation of voluntary actions that members of the public can take themselves to address climate change.
1 The following are preliminary comments on the Draft Napa Regional Climate Action and Adaptation Plan (Draft RCAAP). These comments are personal, and not in any official capacity or representing any third party or entity.

These preliminary comments will be supplemented as more information and content are added to the Draft RCAAP. 2 These comments do not address the potential changes in assumptions in the Napa greenhouse gas inventory used in the draft RCAAP, which appear to assume that any changes in greenhouse gas emissions since the 2019 data used in the inventory, such as changes in vehicle miles traveled (VMTs) or water consumption due to COVID, water rate increases, or other factors, should be excluded from the GHG inventory. See draft RCAAP, Appendix B, Greenhouse Gas Inventory Memorandum, November 29, 2022, p. 1 (“The update year of 2019 was selected because this was the latest year in which data were most complete and excludes data anomalies due to the COVID-19 pandemic starting in 2020, such as reduced transportation emissions from increase telecommuting.”) Agenda Item #13.1.

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2 However, as discussed below, the Draft RCAAP fails to include essential information and benefit-cost analyses on its proposed mandatory measures. These analyses are essential for consideration by the Napa Climate Action Committee, elected leaders, communities, and members of the public. The Draft RCAAP is not ready for consideration or adoption until this missing information and analysis is included and the Draft RCAAP complies with environmental and other legal requirements.

The Draft Plan must be modified to answer the following three basic questions, before it can be considered by the public and participating jurisdictions:
• How much will it cost Napa residents, businesses, schools, hospitals and local governments to comply with the Draft Plan?
• Where will Napa local governments get the $1.1 billion in funding required just to implement and enforce the Draft Plan?
• How will the Draft Plan impact workers and other vulnerable and disadvantaged community members in Napa, including impacts on affordable housing, living and commuting expenses, jobs and small businesses?
Comments on RCAAP Procedural and Legal Status, and
Schedule for Adoption

1. Lack of Required Environmental and Legal Reviews.

The Draft RCAAP has not completed required environmental review. The Climate Action Committee staff has recommended seeking to avoid full environmental review, contrary to the Committee consultant’s recommendations on CEQA.
3 Even if limited, the initial environmental review will not be available for 6- 9 months, and a full environmental review including a program environmental impact report will take more than a year.
3 February 20, 2025 CEQA Approach Memorandum submitted to the Climate Action Committee, pp. 5- 6, 11 (“Due to the deferential standard of review and high degree of legal defensibility, as well as the anticipated potential for significant (and perhaps unavoidable at the program-level) impacts, Ascend encourages the preparation of a PEIR for the RCAAP”).

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3 Additionally, municipal and state regulations that prohibit the distribution of natural gas to existing building and property owners have been declared unlawful by the Ninth Circuit, United States Court of Appeal.4 The Draft RCAAP’s proposal to ban the use of natural gas by mandating that existing residential and non-residential buildings be retrofitted to eliminate the use of gas and gas appliances will not only be significantly costly to the public, but also may be unlawful and barred by the federal courts.

RECOMMENDATION: Public comments and final adoption of the Draft Plan by participating jurisdictions should not be scheduled until the required environmental and legal reviews and modifications to the Draft RCAAP in response to the environmental and legal reviews are completed and available to the public.

2. Lack of Funding for Local Government Costs of Implementing the Draft RCAAP.

The Draft RCAAP includes no assured funding to cover the $1.1 billion- $1.4 billion estimated government implementation costs required by the Draft RCAAP’s measures and programs.5 Unless funding for government implementation costs is assured, it is not feasible for affected Napa governments to evaluate the cost-effectiveness and fiscal feasibility of the proposed measures and programs in the Draft RCAAP.

RECOMMENDATION: The Draft RCAAP should not be considered and adopted until realistic sources of funding and budgets for the governmental costs of implementing the plan are identified and assured, particularly in light of severe current reductions in available state and federal funding.

3. Lack of Modifications and Consistency Reviews of Jurisdictions’ General Plans, Housing Elements, Hazard Mitigation Plans, Local Climate Plans, Zoning Codes, Building Codes, Etc.

The Draft RCAAP’s procedural schedule includes no schedule for the required modifications to the participating jurisdictions’ General Plans, 4 Cal. Rest. Ass'n v. City of Berkeley, 89 F.4th 1094 (9th Cir. 2024). 5 Appendix I, “Cost and Funding Analyses” of the RCAAP indicates that the “implementation” point-cost estimate of $1.1 billion may range 30% higher, i.e. to as high as $1.4 billion. Appendix I, p. I-2.

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4 Housing Elements, Hazard Mitigation Plans, local climate plans, zoning and building codes, and potential CEQA mitigation measures. These modifications and reviews must be considered and completed prior to approving and implementing the recommended mandatory individual greenhouse gas reduction and climate adaptation measures in the Draft RCAAP.

RECOMMENDATION: The procedural schedule should be modified to require consideration and completion of required changes to General Plans, Housing Elements, Hazard Mitigation Plans, zoning and building codes and local climate plans prior to adoption and implementation of the Draft RCAAP.

4. Lack of Clarity Regarding Whether the Draft RCAAP’s Measures and Programs Are Voluntary or Mandatory When Adopted by the Local Governments, or Will Be Enforced by an Independent “Joint Powers Authority”.

The Draft RCAAP as written provides for adoption of numerous legally binding greenhouse gas reduction measures and unbudgeted programs that each Napa local government would be required to enforce against residents, businesses, agricultural entities, housing developers, retailers, workers, visitors and the local governments themselves. The Draft RCAAP also as written appears to be intended to be adopted as a single “regional climate plan” with no separate modifications or changes by individual Napa jurisdictions, but including a yet undetermined sharing and allocation among the individual participating jurisdictions of the $1.1 billion in government implementation costs and yet undetermined costs of compliance to the public, residents and businesses in each of the jurisdictions.

Contrary to these provisions of the Draft RCAAP as written, initial comments by elected leaders of the various local governments during presentations by Committee staff appeared to be confused as to whether the individual measures and programs in the Draft RCAAP are intended to be voluntary, or whether the plan is intended to be adopted by each jurisdiction “up or down” without separate changes.

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5 Additionally, Committee staff are considering whether enforcement of the Draft RCAAP should be delegated to a new “joint powers authority” instead of to each individual Napa jurisdiction.

RECOMMENDATION: This confusion as to whether the Draft RCAAP is intended to require new, mandatory measures unanimously agreed to by all participating jurisdictions or enforceable by an independent new “joint powers authority” should be resolved before any further public, stakeholder or local government consideration of the Draft RCAAP.

Comments on Substantive Omissions in the Draft
RCAAP

1. Lack of Benefit-Cost and Equity Evaluations for Each of the Mandatory Greenhouse Gas Reduction and Climate Adaptation Measures, and Lack of Cost Estimates for the Compliance Costs of Each.

Contrary to California and federal standards on new government regulations and projects,6the Draft RCAAP has no benefit-cost evaluations or cost effectiveness evaluations for each of its 47 targeted and mandatory greenhouse gas reduction measures and programs that Napa governments including St. Helena would be required to adopt and begin implementing in 2026. 30 of the greenhouse gas reduction measures have no quantification of greenhouse gas reductions at all.7
RECOMMENDATION: The Draft RCAAP should include benefit-cost evaluations for each proposed measure and program, consistent with benefitcost methods for government programs and regulations, before the Draft 6 See. e.g., OMB Circular No. A-94, Guidelines and Discount Rates for Benefit-Cost Analysis of Federal Programs; Transportation Economics | Caltrans; Benefit-Cost Analysis | Organizing and Planning for Operations - FHWA Office of Operations; Benefit Cost Analysis (BCA) | Mass.gov Benefit Cost Analysis (BCA) | Mass.gov ; the social cost of carbon used in GHG-related benefit-cost evaluations is a monetary estimate of the damage caused by emitting one ton of carbon dioxide. The monetary value used by the federal government has ranged between $51- $255 per ton, with discount rates of 3% and 7%. The lack of benefit-cost evaluations in the draft RCAAP is not a new issue for Napa climate planning. See Napa Register article, August 17, 2018 at Napa County's draft climate action plan has its critics | News | napavalleyregister.com. 7 Draft RCAAP, p. 3-3; pp.3-4- 3-6, Table 3-1. Inexplicably, Table 3-1 at pp. 3-4- 3-6 lists 47 targeted measures with 30 lacking any quantification of greenhouse gas reductions, while p. 3-3 lists 46 targeted measures.

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6 RCAAP is submitted to the Napa jurisdictions and the public for consideration.

The Draft RCAAP has no “affordability” analysis, and no “equity” evaluation of the impact of the Draft RCAAP on low-income, disadvantaged and vulnerable communities, particularly regarding availability of affordable housing and convenient transportation.

RECOMMENDATION: The equity and affordability analysis of the Draft RCAAP should be developed and included prior to any consideration of the Draft RCAAP by participating jurisdictions and the public.

The “cost estimates” provided in the Draft RCAAP only cover government implementation costs, not the costs to the general public, households, residents, workers or businesses to comply with the Draft RCAAP. Even as so limited, the Draft RCAAP estimates that the costs to Napa governments to implement the Draft RCAAP for 19 of the proposed greenhouse gas reduction measures and “climate adaptation” measures would be from $1.1 billion to as much as $1.4 billion.8
Divided up by the population of each of the participating Napa jurisdictions, St. Helena’s governmental costs of implementation alone could be 4% or $44- $56 million or higher.

The Draft RCAAP provides no estimates of the costs of compliance by residents, homeowners, wineries, hotels, retailers, and other members of the public and businesses et al. However, it is reasonable to expect that the compliance costs overall could be as much as an order of magnitude higher than $1.1- 1.4 billion estimates of governmental implementation costs.
8 Appendix I, “Cost and Funding Analyses” of the RCAAP indicates that the “implementation” point cost estimate of $1.1 billion may range 30% higher, i.e. to as high as $1.4 billion. Appendix I, pp. I-2, I-4. The “implementation cost” estimates for each mandatory measure include some nominal estimates of rebates to offset compliance costs, but none of the rebates would offset actual compliance costs. For example, the “rebates” estimated for building electrification retrofits of all existing buildings would be limited to $2,000 per residential building and $3,500 per non-residential building, far less than the current market costs for such retrofits. Appendix I, Attachment I-1, Estimate 1, Sheet 2, lines 7 and 8.

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7 RECOMMENDATION: The Draft RCAAP should not be considered by the participating jurisdictions and the public until the estimated costs to the public and all affected stakeholders are included in the Draft RCAAP.

2. The Costs of the Mandatory Greenhouse Gas Reduction Measures and Climate Adaptation Measures Are Likely Significant and Potentially Unlawful.

Existing Building Electrification Mandate. The most costly greenhouse gas reduction measure recommended by the Draft RCAAP is to mandate that all 56,000 residential homes and buildings and all 35,000 non-residential restaurants, retail stores, wineries and other buildings be “retrofit” to be “zero-carbon” and “electrified,” which means prohibiting use of gas appliances and converting all the buildings to electricity.9
Non-residential buildings including schools, hospitals, stores, restaurants, hotels, offices, wineries and public buildings would need to begin to be retrofitted, converted to electrification and stop using natural gas beginning as early as 2026.

Residential buildings and homes would need to be retrofitted and stop using natural gas beginning in 2031 (only because the California Legislature has prohibited adoption of stricter local building codes before 2031, in order to make housing more affordable.) Even if the effective date for the residential building mandatory retrofits were delayed until 2031, adoption of the building electrification standards beginning in 2026 would likely have an immediate, significant impact on the market value of all residential real estate properties and residential real estate sales, as well as on appraisals for calculating property taxes and revenues. Potential buyers would adjust their purchase offers downward to reflect the $30,000 to $100,000 in retrofit costs that each property owner would incur to comply with the new building electrification standards beginning in 2031.

The governmental cost of implementing and enforcing these new “building electrification” mandates is estimated to be $448 million. 10 The cost of the actual
retrofits and conversion to electrification would be from $30,000 to as much as $100,000 per residential home and building alone, based on PG&E cost 9 Draft RCAAP, “Measure BE-1: Retrofit Existing Buildings to Zero Carbon, pp. 3-10- 3-12; Appendix H, Implementation Matrices, Action BE-1-F, p. H-1.
10 Appendix I, p. I-4.

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8 estimates for building electrification and “de-carbonization,” as well as the recent per-unit costs for electrification of Laurel Manor multi-family housing in the City of Napa.11
This means the total compliance and implementation costs for all 56,000 residential homes and buildings in the County could be over $2 billion (residential buildings alone; costs for non-residential buildings would likely be similar on a per unit basis.)
RECOMMENDATION: The Draft RCAAP’s proposed mandatory residential and non-residential building electrification mandate should not be adopted unless the quantitative benefits to Napa residents and businesses significantly exceed the costs of compliance and the impacts on real estate market values and the appraisals that impact property tax revenues.

New Building Electrification Mandate. New housing and buildings— including affordable housing, rental housing, retail stores, restaurants, government buildings, schools, hospitals, hotels, office buildings, wineries, etc.—would be required to be fully “zero carbon” and not use natural gas beginning in 2026, resulting in immediate, significant additional costs for new and affordable housing in Napa.
12 The Draft RCAAP provides no estimates for the additional costs or the impact of this new government mandate on affordable and new housing.

RECOMMENDATION: Similar to the existing building electrification mandate, the Draft RCAAP’s proposed new building electrification mandate should not be adopted unless the direct benefits and costs to new housing and buildings are evaluated and the benefits significantly exceed the costs to new and affordable housing, economic development and the local Napa economy.

Other costly measures recommended by the Draft RCAAP include:
a. Green Certification of All Wineries. Require all new wineries, winery retrofits, and additions greater than 10 percent to comply 11 City of Napa Housing Authority, Resolution approving Laurel Manor building electrification project, September 2, 2025 ($2.5 million total estimated costs for 50 housing units= $50,000 per unit; PG&E Supplemental Testimony, California State University- Monterey Bay zonal electrification project, Table 1- 3, p. 1-13, November 15, 2024 ($30,499 per unit cost for electrification); PG&E 2027 General Rate Case, Alternative Energy Program workpapers, May 15, 2025 ($100,000 per unit costs of electrification). 12 Draft RCAAP, “Decarbonize New Buildings,” pp. 3-16- 3-17; Appendix H, Action No. BE-5-A, p. H-4.

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9 with “sustainability certification” standards, targeting 75 percent of all existing vineyard acreage to be certified by 2030.
13 No cost
estimates are provided.
b. Restrict fossil fuel use by agricultural field equipment and irrigation pumps, replace with renewable electricity only.14 No cost estimates are provided.
c. Implement “transportation demand management” ordinances and measures to reduce “vehicle miles traveled” by residents, workers and visitors, and reduce existing public and off-street parking in existing and new housing and building developments.15 No cost estimates are provided.
d. Require and mandate reusable food ware and waste reduction, and commercial food waste diversion.16 No cost estimates are provided.
e. Restore and re-forest 20% of all areas affected by wildfire since 2017.17 No cost estimates are provided.
f. Require all existing and new residential and commercial structures to implement “home hardening” to protect against wildfires.18 No costs estimates are provided.
g. Reduce indoor residential water use and impose new water conservation standards and tiered water rates, including prohibition on “wasteful” water uses such as use of potable water for irrigation, even during non-drought conditions. 19 No
cost estimates are provided.
h. Multiple mandatory measures requiring municipal
infrastructure, equipment and vehicles to be retrofitted or 13 Draft RCAAP, “Measure BE-4: Increase Sustainable Wine Certification;” p. 3-15; “Measure AG-7: Increase Sustainable Vineyard Certification;” pp. 3-67- 3-68; Appendix H, Action No’s BE-4-B, 4-E, AG-7-F, pp H-4, H-27. 14 Draft RCAAP, Appendix H, Action No’s AG-1-A- AG-9-C generally, pp. H-24- 28. 15 Draft RCAAP, Appendix H, Action No’s TR-1-C- TR-14-C, OF-2-A, OF-2-C, generally, pp. H-6- - H-14. 16 Draft RCAAP, Appendix H, Action No’s SW-1-B, SW-1-D, SW-1-E, pp. H-14- H-15. 17 Draft RCAAP, “Measure AG-6: Restore Woodland and Forest Habitat,” pp.3-65- 3-66. 18 Draft RCAAP, Appendix H, Action No’s ALL-3.2, p. H-29. 19 Draft RCAAP, Appendix H, Action No’s WW-3-A, 3-F, 4-C, 4-E, 5-A, 5-B, 5-C, 7-E-7-I, 7-V, 7-X, 7-Y, 7-Z, pp.

H-19- H-24.

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10 replaced to achieve greenhouse gas reduction and climate adaptation standards.20 No cost estimates are provided.

RECOMMENDATION: These additional measures and programs should not adopted until specific cost estimates and benefit-cost evaluations are completed.

Respectfully submitted,
Christopher J. Warner
1434 Grayson Avenue
St. Helena, CA 94574
[email protected]
20 Draft RCAAP, Greenhouse Gas Reduction and Climate Adaptation Measures, generally as applicable to municipal and governmental buildings, facilities, utility infrastructure, equipment and vehicles.

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From: Jeff Farmer
To: Public Comment
Subject: Item 13.1: Regional Climate Action and Adaptation Plan Date: Sunday, September 21, 2025 5:45:17 AM
Honorable Mayor and City Council:

Idling vehicles are a big source of pollution especially nitrous oxide. According to the EPA idling vehicles emit 20 times more pollution than vehicles going 30mph. Yet there is no discussion in the report on this.

Anyone who has driven down Hwy 29 in the early morning or late afternoon has seen hundreds of cars idling at the signal light at Madison in Yountville. Another big idling area is the Hwy 12/ Hwy 29 intersection at the airport.

There are probably more.

But Item TR-12, pg 61 of the report has transportation improvements as not available. Spending money to improve our transportation system to reduce idling is a potential area of improvement and has the benefit of not forcing drivers to do anything differently. Roundabouts are one obvious solution. Another innovation is the "turn on yellow if safe" lights along Jefferson Street in Napa between Third Street and Clay. This can mean less idling for cars waiting to make left turns. Every little bit helps. We do have roundabouts at First Street/Hwy29 and Hw12/Hwy221 and they have been very effective to keep traffic moving. I wonder if pre and post pollution measurements were done to see how much they decreased pollution.

At the last ATSC meeting on September 3rd we had a robust discussion of this draft report. However, the opinions I express above are personal and not those of the ATSC committee.

Jeff Farmer
Chair, ATSC
St. Helena
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From: Richard Seiferheld
To: Public Comment
Cc: Paul Dohring; Michelle Deasy; Aaron Barak; Kate Spadarotto; Billy Summers Subject: Draft Regional climate Action and Adaptation Plan - Agenda item 13.1 St. Helena City Council Meeting, Sept. 23 2025
Date: Sunday, September 21, 2025 1:05:46 PM
Although I serve on the St. Helena ATSC committee, these comments reflect my personal views only and do not represent the committee or any other party.

Overall, the draft report is well organized and clearly states the Plan’s goals and objectives.

The documentation of climate change issues is strong and supported by solid data.

That said, the Plan has significant shortcomings. The most critical is its failure to address funding for implementation and monitoring. Success will require additional staff, yet the report assumes federal support will cover gaps between state and local funding. If those funds do not materialize, city and county budgets will be forced to absorb the costs at the expense of essential services. Given the current federal administration’s position on climate policy, the Plan should confront these risks directly and propose contingencies. Furthermore, frequent references to DEI and environmental justice, while important, may actually disqualify the Plan from federal funding sources.

Another concern is whether the data projections through 2040 fully account for the greenhouse gas impacts of state-mandated housing growth (over 204 new units, including Hunter and the Spring Street projects) and the likely addition of one or more hotels.

Finally, the projections appear to assume ongoing growth in agriculture and tourism at historic rates. Recent indicators suggest these sectors may slow or even decline. The Plan should acknowledge this uncertainty and adjust its assumptions accordingly.

Richard Seiferheld
[email protected]
707 695 0915
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From: Christina Benz
To: Public Comment
Cc: Linda Brown; Lynne Baker; Jim Wilson
Subject: Public Comment for Item 13.1, September 23 St. Helena City Council Meeting Date: Tuesday, September 23, 2025 12:37:33 PM
Please share this comment with the Council.

We would like to thank you for moving forward with the Regional Climate Action and Adaptation Plan. It’s a pretty big deal—to commit, as an entire county, to taking action on climate change. And it’s a common-sense strategy: as a rural county with a low population, we can be more effective with a regional approach.

The Plan will help you evaluate and prioritize future actions, but we applaud you for not waiting for an official plan to tackle reducing emissions.

There appears to be confusion on the part of the public about how the Plan will be implemented. The plan provides a list of actions that will reduce emissions of climate pollutants. What actions are prioritized will depend on the community’s opportunities, available funding, and what actions your Council deems most relevant.

At the Napa County Climate Action Committee meeting this Friday, there will be a presentation of a new tool (“Total Climate Accounting”) that can assist with prioritizing actions based on how much excess heat is eliminated. A pilot study was conducted by Napa Recycling and Waste Services using this tool to evaluate their composting operation and the possible addition of an anaerobic digester.

The Adaptation Strategies in the Plan will be useful because they can provide a ‘climate lens’ to evaluate future projects. For example, can we plant more street trees during this repaving project to provide shaded parking and a cooler neighborhood? Can pavement for a project be porous so that rainwater can be collected and stored as groundwater? The RCAAP can help you put a climate lens on every decision you make, and, by doing so, improve the quality of life for the city’s residents by making the air cleaner, the water supply more secure, and neighborhoods greener and cooler. Please keep moving forward with the RCAAP and with climate action as a high priority.

Thank you.

Chris Benz
Napa Climate NOW!
Agenda Item #13.1.

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315 Greenbach St.

Napa, CA 94559
Agenda Item #13.1.

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Outlook
FW: united-states-v-city-of-morgan-hill_55d210d778116e7f6a06a45033acdac0 From Maya DeRosa <[email protected]>
Date Wed 1/7/2026 1:33 PM
To Anil Comelo <[email protected]>
Cc Andrew Bradley <[email protected]>
1 attachment (235 KB)
united-states-v-city-of-morgan-hill_55d210d778116e7f6a06a45033acdac0.pdf; FYI

MAYA DEROSA, AICP

COMMUNITY DEVELOPMENT DIRECTOR
City of St. Helena | Community Development Department
1088 College Avenue | St. Helena, CA 94574
Direct: (707) 967-2783 | [email protected]| http://cityofsthelena.gov/planning From: Christopher J Warner <[email protected]>
Sent: Wednesday, January 7, 2026 9:05 AM
To: RCAAP <[email protected]>
Cc: Michelle Deasy <[email protected]>; Maya DeRosa <[email protected]>; MeetingClerk <[email protected]>
Subject: united-states-v-city-of-morgan-hill_55d210d778116e7f6a06a45033acdac0 Please include this recent lawsuit in the RCAAP public record and share with members and staff of the Napa Climate Action Committee.

Thank you!
Christopher Warner
St Helena
Agenda Item #13.1.

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Complaint of the United States
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27 BRETT A. SHUMATE
Assistant Attorney General
YAAKOV M. ROTH
Principal Deputy Assistant Attorney
General
CHARLES E.T. ROBERTS
(PA Bar No. 326539)
Counsel to the Assistant Attorney
General
U.S. Department of Justice
Civil Division
950 Pennsylvania Ave., NW
Washington, DC 20530
(202) 305-1141
[email protected]
Counsel for the United States
STANLEY E. WOODWARD, JR.

Associate Attorney General
ADAM R.F. GUSTAFSON
Principal Deputy Assistant Attorney General
JOHN K. ADAMS
Senior Counsel

DAVIS FORSYTHE
Senior Counsel
U.S. Department of Justice
Environment and Natural Resources Division
CRAIG H. MISSAKIAN
United States Attorney

UNITED STATES DISTRICT COURT FOR THE

NORTHERN DISTRICT OF CALIFORNIA

THE UNITED STATES OF AMERICA,
Plaintiff,
v.

CITY OF MORGAN HILL, CITY OF

PETALUMA,
Defendants.

No. ________

COMPLAINT FOR DECLARATORY

AND INJUNCTIVE RELIEF
Case 5:26-cv-00056-BLF Document 1 Filed 01/05/26 Page 1 of 15 Agenda Item #13.1.

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27 Plaintiff, the United States of America, by and through its undersigned counsel, brings this civil action for declaratory and injunctive relief, and alleges as follows:

PRELIMINARY STATEMENT

1. From the day President Trump took office, his Administration has prioritized cutting energy costs for all Americans, restoring consumer freedom, and unleashing American energy dominance. Unleashing American Energy, 90 Fed. Reg. 8,353 (Jan. 20, 2025) (Executive Order 14154). Ensuring that all Americans have reliable access to affordable energy not only makes good economic sense, it also strengthens national security.

2. Sadly standing in the way of that progress, many states and localities haveenacted “energy policies that threaten American energy dominance and our economic and national security.” Protecting American Energy from State Overreach, 90 Fed. Reg. 15,513 (Apr. 8, 2025) (Executive Order 14260). Recognizing that these radical measures, “weaken our national security and devastate Americans by driving up energy costs for families coastto-coast,” and that “Americans must be permitted to heat their homes, fuel their cars, and have peace of mind—free from policies that make energy more expensive and inevitably degrade quality of life,” the President directed the Attorney General “to take all appropriate action to stop” measures she “determines to be illegal.” Id.

3. The City of Morgan Hill (“Morgan Hill”) and the City of Petaluma (“Petaluma”) have just such measures on their books. In 2019, Morgan Hill banned natural gas infrastructure in newly constructed buildings. In 2021, Petaluma followed suit. In pursuit of “electrification,” these bans deny consumers reliable, resilient, and affordable energy, as well as the use of commonplace gas appliances for cooking, heating, and other household needs. But natural gas is often the lowest cost and most efficient energy source for uses like these—outperforming electric on both expense and lifecycle emissions. See Dep’t of Energy, Energy Conservation Program for Consumer Products: Representative Average Unit Costs of Energy, 89 Fed. Reg. 83,672, 83,673 (Oct. 17, 2024).

Case 5:26-cv-00056-BLF Document 1 Filed 01/05/26 Page 2 of 15 Agenda Item #13.1.

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27 4. The natural gas bans not only impose crushing costs on California residents but are also unlawful. As the Ninth Circuit held just last year, “completely prohibiting the installation of natural gas piping within newly constructed buildings” is “preempted by Congress” in the Energy Policy and Conservation Act. California Rest. Ass’n v. City of Berkeley, 89 F.4th 1094, 1098 (9th Cir. 2024), amended on denial of reh’g en banc (citing 42 U.S.C. § 6297(c)). Under that controlling precedent, Morgan Hill’s and Petaluma’s natural gas bans are invalid—as numerous other California cities have recognized when recently repealing or suspending their equivalent bans.

5. The United States brings this declaratory and injunctive action to stop these Cities from enforcing the preempted measures that drive up costs and reduce consumer freedom.

PARTIES

6. Plaintiff, the United States of America, enforces federal laws such as the Energy Policy and Conservation Act through its Executive agencies, including the Department of Energy.

7. Defendant City of Morgan Hill is a municipal corporation organized and existing under and by virtue of the laws of the State of California.

8. Defendant City of Petaluma is a municipal corporation organized and existing under and by virtue of the laws of the State of California.

JURISDICTION, VENUE, AND DIVISIONAL ASSIGNMENT

9. The Court has jurisdiction over this action under 28 U.S.C. §§ 1331 and 1345.

10. Morgan Hill’s and Petaluma’s natural gas bans conflict with and are preempted by federal law, and do not satisfy the requirements of any exception to preemption.

11. There is no set of circumstances under which Morgan Hill’s and Petaluma’s natural gas ban would be valid under federal law. The bans’ limited exceptions do not save them from preemption.

12. Morgan Hill’s and Petaluma’s natural gas bans threaten and harm the United States’ Case 5:26-cv-00056-BLF Document 1 Filed 01/05/26 Page 3 of 15 Agenda Item #13.1.

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27 sovereign interest in the supremacy and enforcement of federal law, specifically the Energy Policy and Conservation Act.

13. Morgan Hill’s and Petaluma’s natural gas bans also undermine and conflict with federal energy policy. For example, the measures(i) prohibit the use of products that the United States Department of Energy regulates and that may be distributed in commerce if in compliance with those federal regulations, thereby disrupting the agency’s implementation of the federal statutory scheme, (ii) create a patchwork of inconsistent regulation in an area where Congress imposed a uniform, national energy conservation standards with exceptions permitted only in narrow circumstances, and (iii) harm the United States’ interest in protecting Americans’ access to reliable, resilient, and affordable energy. To the extent the natural gas bans apply to new construction undertaken by the Federal Government or its contractors within the cities, they also impose financial harm on the United States and taxpayers by increasing costs.

14. A favorable ruling would redress the United States’ harms.

15. The Court has the authority to provide the relief requested under the Supremacy Clause, U.S. Const. art. VI, cl. 2, as well as 28 U.S.C. §§ 1651, 2201, and 2202, and its inherent equitable powers.

16. Venue is proper in this District under 28 U.S.C. § 1391 because Morgan Hill and Petaluma are located within this District and the acts and events giving rise to the claims occurred at least in part in this District.

17. Assignment to either the San Francisco/Oakland or San Jose Division is proper under Civil Local Rule 3-2(c) because a substantial part of the events or omissions that give rise to the claims are located in these Divisions, as Petaluma is in Marin County and Morgan Hill is in Santa Clara County.

Case 5:26-cv-00056-BLF Document 1 Filed 01/05/26 Page 4 of 15 Agenda Item #13.1.

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27 MORGAN HILL’S GAS BAN

18. In November 2019, the City Council of Morgan Hill “adopted Ordinance 2306 establishing Chapter 15.63 (Prohibition of Natural Gas Infrastructure in New Buildings) requiring all new buildings (residential, commercial, and industrial), after March 1, 2020, to be all-electric.” City of Morgan Hill Housing Element 2023-2031, App’x H3, Opportunities for Energy Conservation at H-3-4 (adopted Jan. 25, 2023). 1

19. A true and correct copy of Ordinance 2306, which took effect March 1, 2020, is attached as Exhibit A. See City of Morgan Hill, Ordinance 2306. 2

20. Ordinance 2306’s intent and effect are to ban gas appliances in new buildings.

21. Ordinance 2306 added a new Chapter to Title 15 of the Morgan Hill Code of Ordinances, which states:
a. Natural gas infrastructure shall be prohibited in newly constructed buildings.

1. Exception: Natural gas infrastructure may be permitted in a newly constructed building if the applicant establishes that it is not physically feasible to construct the building without natural gas infrastructure. For purposes of this exception, “physically feasible” to construct the building means either an all-electric prescriptive compliance approach is available for the building under the Energy Code or the building is able to achieve the performance compliance standards under the Energy Code using commercially available technology and an approved calculation method.
b. To the extent that natural gas infrastructure is permitted, it shall be permitted to extend to any system, device, or appliance within a building for which an equivalent allelectric system or design is not available. 1 https://www.morganhill.ca.gov/DocumentCenter/View/43250/H3_MH-HE_Opportunities_ for_Energy_Conservation
2 https://publicrecords.morganhill.ca.gov/WebLink/DocView.aspx?id=439086&dbid=0& repo=CityofMorganHill
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27 c. Newly constructed buildings shall nonetheless be required at a minimum to have sufficient electric capacity, wiring and conduit to facilitate future full building electrification.
d. The requirements of this section shall be deemed objective planning standards under Government Code section 65913.4 and objective development standards under Government Code section 65589.5.

Morgan Hill Code of Ordinances Ch. 15.63.040.

22. Under Ordinance 2306, “‘Natural gas infrastructure’ shall be defined as fuel gas piping, other than service pipe, in or in connection with a building, structure or within the property lines of premises, extending from the point of delivery at the gas meter as specified in the California Mechanical Code and Plumbing Code.” Morgan Hill Code of Ordinances Ch.

15.63.030.E.

23. Under Ordinance 2306, “‘Newly constructed building’ shall be defined as a building that has never before been used or occupied for any purpose.” Morgan Hill Code of Ordinances Ch. 15.63.030.F.

24. Ordinance 2306 also includes a “Public interest exemption,” which states:
a. Notwithstanding the requirements of this chapter and the greenhouse gas emissions and other public health and safety hazards associated with natural gas infrastructure, minimally necessary and specifically tailored natural gas infrastructure may be allowed in a newly constructed building provided that the entitling body establishes that the use serves the public interest. In determining whether the construction of natural gas infrastructure is in the public interest, the city may consider:

1. The availability of alternative technologies or systems that do not use natural gas;

2. Any other impacts that the decision to allow natural gas infrastructure may have on the health, safety, or welfare of the public.
b. If the installation of natural gas infrastructure is granted under a public interest exemption, the newly constructed buildings shall nonetheless be required at the Case 5:26-cv-00056-BLF Document 1 Filed 01/05/26 Page 6 of 15 Agenda Item #13.1.

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27 minimum to have sufficient electric capacity, wiring and conduit to facilitate future full building electrification.

Morgan Hill Code of Ordinances Ch. 15.63.050.

25. In December 2023, the City Council voted to reaffirm and keep in place Ordinance 2306.

Moore, Michael, City Council affirms ban on gas in new homes, commercial buildings, The Morgan Hill Times (Dec. 12, 2023). 3

26. As a practical matter, Ordinance 2306 functions to ban all use of gas appliances in new buildings not subject to one of the limited exceptions.

27. Ordinance 2306 is and may be enforced by the City, its departments, and employees. See Morgan Hill Code of Ordinances Chs. 15.08.090, 15.63.040.

PETALUMA’S GAS BAN

28. In May 2021, the City Council of Petaluma “adopted an all-electric ordinance … for all Newly Constructed Buildings and Substantial Building Alterations.” City of Petaluma All-Electric Code.4

29. A true and correct copy of that Ordinance 2775, which took effect June 16, 2021, is attached as Exhibit B. See City of Petaluma, Ordinance 2775. 5

30. Ordinance 2775’s intent and effect are to ban gas appliances in new buildings and substantial building alterations.

31. Ordinance 2775 added a new Chapter to Title 17 of the Petaluma municipal code, which states:
a. Newly constructed buildings and substantial building alterations must satisfy the definition of an all-electric building and/or have an all-electric design, except as otherwise provided in this chapter.
3 https://morganhilltimes.com/city-council-affirms-ban-on-gas-in-new-homes-commercialbuildings/ 4 https://cityofpetaluma.org/allelectric/
5 https://petalumadocs.cityofpetaluma.net/WebLink/DocView.aspx?id=431492&dbid=0& repo=Petaluma&cr=1
Case 5:26-cv-00056-BLF Document 1 Filed 01/05/26 Page 7 of 15 Agenda Item #13.1.

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27 b. As of the effective date of this chapter, applicants are ineligible to apply for and the building official may not grant permits that would convert an all-electric building to a mixed-fuel building where the application was submitted on or after the effective date of this chapter.
c. The requirements of this section are and shall be deemed objective planning standards for purposes of Government Code Section 65913.4 and objective development standards for purposes of Government Code Section 65589.5, as those sections may be amended from time to time.

Petaluma Mun. Code Ch. 17.09.030.

32. Under Ordinance 2775, an “‘All-electric building’ is a building that uses a permanent supply of electricity as the source of energy for all space heating, water heating (including pools and spas), cooking appliances, and clothes drying appliances, and has no natural gas or propane plumbing installed in the building.” Petaluma Mun. Code Ch. 17.09.020.B.

33. Under Ordinance 2775, “‘All-electric design’ means a plan or plans for a building or portion thereof that uses a permanent supply of electricity as the source of energy for all space heating, water heating (including pools and spas), cooking appliances, and clothes drying appliances, and has no natural gas or propane plumbing installed in the building.” Petaluma Mun. Code Ch. 17.09.020.C.

34. Under Ordinance 2775, “‘Newly constructed building’ shall mean any building that: (1) is proposed to be located in whole or in part within the city; (2) is not an alteration or addition to or repair of an existing building; (3) is subject to the city’s regulatory authority pursuant to the city’s general plan, Implementing Zoning Ordinance, SmartCode and/or any adopted specific plan or other city land use regulation, regardless of whether a discretionary permit is required or not; and (4) has not been granted and/or is not subject to a valid building permit that remains in effect.” Petaluma Mun. Code Ch. 17.09.020.J.

35. Under Ordinance 2775, “‘Substantial building alteration’ shall mean an alteration or addition to an existing building involving removal of more than fifty percent of the Case 5:26-cv-00056-BLF Document 1 Filed 01/05/26 Page 8 of 15 Agenda Item #13.1.

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27 perimeter of the exterior walls of the existing building or the addition of more than fifty percent of the gross floor area to the existing building.” Petaluma Mun. Code Ch.

17.09.020.K.

36. Ordinance 2775 also includes a series of “Exceptions,” including:
a. Additions and alterations to existing buildings, except for substantial building alterations; and
b. The use of portable propane appliances outside of the building envelope, such as for outdoor cooking and outdoor heating appliances; and c. Essential services buildings that are electric ready; and d. Back-up power facilities for essential services buildings; and e. Development projects that have obtained vested rights prior to the effective date of this chapter pursuant to a preliminary affordable housing project application in accordance with Government Code Section 65589.5(o), a development agreement in accordance with Government Code Section 65866, a vesting tentative map in accordance with Government Code 66998.1, or pursuant to the ruling in Avco Community Developers Inc. v. South Coast Regional Communication (1976) 17 Cal. 3d 785, or pursuant to other applicable statutory or case law.

Petaluma Mun. Code Ch. 17.09.040.

37. Ordinance 2775 also includes a discretionary “Infeasibility waiver.” Petaluma Mun.Code Ch. 17.09.050.

38. And Ordinance 2775 includes a section entitled “No appliance or appliance system requirement,” which states:

Nothing in this chapter is intended to amend or conflict with and nothing in this chapter shall be construed so as to amend or conflict with any provisions of the National Appliance Energy Conservation Act, and nothing in this chapter is intended to impose and nothing in this chapter shall be construed so as to impose a requirement to use or install any particular appliance or appliance system.

Case 5:26-cv-00056-BLF Document 1 Filed 01/05/26 Page 9 of 15 Agenda Item #13.1.

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27 Petaluma Mun. Code Ch. 17.09.090.

39. As a practical matter, Ordinance 2775 functions to ban all use of gas appliances in new buildings and substantial building alterations not subject to one of the limited exceptions.

40. Ordinance 2775 is and may be enforced by the City, its departments, and employees. See Petaluma Mun. Code Ch. 17.09.060.

FEDERAL ENERGY POLICY AND CONSERVATION ACT

41. The Supremacy Clause of the United States Constitution mandates that “[t]his Constitution, and the Laws of the United States which shall be made in Pursuance thereof . . . shall be the supreme Law of the Land . . . any Thing in the Constitution or Laws of any State to the Contrary notwithstanding.” U.S. Const. art. VI, cl. 2.

42. One such law of the United States, which must be given preemptive effect under the Supremacy Clause, is the Energy Policy and Conservation Act (EPCA).

43. Congress passed EPCA to establish a “comprehensive energy policy” addressing “the serious economic and national security problems associated with our nation’s continued reliance on foreign energy resources” laid bare by the early 1970s oil crisis. Air Conditioning & Refrigeration Inst. v. Energy Res. Conservation & Dev. Comm’n, 410 F.3d 492, 498 (9th Cir. 2005).

44. In service of its goals to promote both domestic energy supply and energy conservation, Congress began regulating many appliances’ energy efficiency and energy use. See id.

45. Originally, EPCA permitted more substantial state and local involvement in appliance regulation. Id. at 499. But Congress narrowed that authority as it directed increasingly greater federal involvement. Amendments in the 1970s and 1980s eventually mandated federal standards for many appliances and authorized the Department of Energy to issue new or revised standards. See id. at 499–500.6
6 EPCA addresses consumer products and industrial equipment separately. See 42 U.S.C. §§ 6291–6309 (consumer); id. §§ 6311–6317 (industrial). The provisions are substantially similar, and nothing at issue turns on the specific type of product involved. For convenience, this Case 5:26-cv-00056-BLF Document 1 Filed 01/05/26 Page 10 of 15 Agenda Item #13.1.

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27 46. Products covered by EPCA now may only be “distribute[d] in commerce” if they conform with the applicable federal standard, which requires testing in accordance with standardized, detailed test procedures. 42 U.S.C. § 6302(a)(5); see id. §§ 6292, 6293, 6295, 6314; 10 C.F.R. Parts 429–31.

47. Pursuant to EPCA, there are several covered products fueled by natural gas for which energy conservation standards are in place. See, e.g., 10 C.F.R. §§ 430.32(d) (residential water heaters), (e) (residential furnaces), (h) (residential clothes dryers), (i) (direct heating equipment), (j) (cooking tops and ovens), (k) (pool heaters), 431.77(a) (gas-fired commercial warm air furnaces), 431.87 (commercial packaged boilers), 431.110 (commercial storage water heaters, instantaneous water heaters, and hot water supply boilers).

48. To give effect to federal standards, ensure that manufacturers are able to market and sell products that conform with them, preserve product utility, improve energy efficiency and grid resilience, and conserve consumer choice, Congress also broadened EPCA’s preemption clause.

49. As amended, EPCA preempts not only state and local regulations that are stricter than (and therefore would effectively supersede) a federal standard, but more broadly any regulation “concerning the energy efficiency, energy use, or water use of” products subject to a federal standard. Id. § 6297(c).

50. EPCA defines “energy use” as “the quantity of energy directly consumed by a consumer product at point of use.” Id. § 6291(4).

51. EPCA provides limited exceptions to this general rule of preemption. One option is that states and localities may ask the Department of Energy to waive this preemption, but Congress strictly cabined this waiver authority both procedurally and substantively, in service of the goals described supra ¶ 48. See id. § 6297(c)(2), (d). For example, EPCA Complaint cites the consumer product provisions. Cf. Air Conditioning & Refrigeration Inst., 410 F.3d at 496 n.2 (taking a similar approach).

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27 prohibits waiving preemption of state and local measures that are “likely to result in the unavailability . . . of performance characteristics [or] features” in covered products available within a state or locality. Id. § 6297(d)(4). So too if the “regulation will significantly burden manufacturing, marketing, distribution, sale, or servicing of the covered product on a national basis.” Id. § 6297(d)(3).

52. Congress also specified that “regulation[s] or other requirement[s] contained in a State or local building code for new construction concerning the energy efficiency or energy use of [a] covered product” are preempted unless they satisfy all of seven enumerated conditions. Id. § 6297(f)(3); see id. § 6297(c)(3). One of those conditions is that the “code does not require that the covered product have an energy efficiency exceeding the applicable energy conservation standard established in or prescribed under section 6295 of this title.” Id. § 6297(f)(3)(B).

53. Morgan Hill’s and Petaluma’s Ordinances “concern the . . . energy use” of products subject to a federal standard. Id. § 6297(c). As the Ninth Circuit explained, “a building code that prohibits consumers from using natural gas-powered appliances in newly constructed buildings necessarily regulates the ‘quantity of energy directly consumed by [the appliances] at point of use’” and is therefore preempted by EPCA. California Rest.

Ass’n, 89 F. 4th at 1102 (alteration in original); see id. (“EPCA preempts [the municipality’s] regulation here because it prohibits the installation of necessary natural gas infrastructure on premises where covered appliances are used.”), id. at 1103 (“[A] building code that bans the installation of piping that transports natural gas from a utility’s meter on the premises to products that operate on such gas ‘concerns’ the energy use of those products as much as a direct ban on the products themselves.”).

54. Numerous other California cities have repealed or suspended their equivalent or similar gas bans in light of the California Restaurant Association decision. E.g., City of Los Angeles, Ordinance No. 188,716 (June 24, 2025) (repealing Ordinance No. 187,714); 7 7 https://cityclerk.lacity.org/onlinedocs/2022/22-0151_Ord_188716_dated_9-3-25.pdf Case 5:26-cv-00056-BLF Document 1 Filed 01/05/26 Page 12 of 15 Agenda Item #13.1.

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27 City of San Luis Obispo, City of SLO Pauses All-Electric Rule for New Builds (July 18, 2023);8 City of Encinitas, Ordinance No. 2023-75 (June 14, 2023) (suspending electrification mandate);9 City of Santa Cruz, Resolution NS-30,156 (June 13, 2023) (suspending enforcement of Natural Gas Prohibition Ordinance).10

55. The City of Morgan Hill has not sought a preemption waiver from the Department of Energy for Ordinance 2306.

56. The City of Petaluma has not sought a preemption waiver from the Department of Energy for Ordinance 2775.

57. Nor do the Ordinances qualify for any other exception to preemption by EPCA, including that for certain qualifying building codes under 42 U.S.C. § 6297(f)(3).

58. EPCA’s broad preemption provision therefore bars Morgan Hill’s and Petaluma’s Ordinances because they prohibit products that are subject to a federal energy conservation standard from using energy.

59. The Ordinances therefore are invalid under the Supremacy Clause.

CLAIM FOR RELIEF
COUNT ONE – VIOLATION OF THE SUPREMACY CLAUSE
(PREEMPTION BY THE ENERGY POLICY AND CONSERVATION ACT)

60. Plaintiff hereby re-alleges the preceding paragraphs of the Complaint as if fully stated herein.

61. Morgan Hill’s Ordinance imposing a natural gas ban is preempted in its entirety by EPCA.

62. Petaluma’s Ordinance imposing a natural gas ban is preempted in its entirety by EPCA.

63. There is no set of circumstances under which the Ordinances would be valid.

64. The Ordinances concern the energy efficiency and energy use of all gas appliances in newly constructed buildings, including appliances covered by EPCA. 8 https://www.slocity.org/Home/Components/News/News/9883/ 9 https://encinitas.granicus.com/MetaViewer.php?view_id=2&clip_id=3217&meta_id=168521 10 https://ecm.cityofsantacruz.com/OnBaseAgendaOnline/Meetings/ViewMeeting?id=2123& doctype=2
Case 5:26-cv-00056-BLF Document 1 Filed 01/05/26 Page 13 of 15 Agenda Item #13.1.

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27 65. The Ordinances do not fall within EPCA’s or any other exceptions to preemption.

66. The Federal Government is harmed and will be harmed by continued enforcement of the Ordinances.

67. Accordingly, Morgan Hill’s Ordinance imposing a natural gas ban is and should be declared invalid under the Supremacy Clause and its enforcementshould be permanently enjoined.

68. And Petaluma’s Ordinance imposing a natural gas ban is and should be declared invalid under the Supremacy Clause and its enforcement should be permanently enjoined.

PRAYER FOR RELIEF
WHEREFORE, the United States respectfully requests the following relief:
a. That this Court enter a judgment declaring that Morgan Hill’s and Petaluma’s natural gas ban Ordinances are preempted by federal law and do not satisfy any exception to such preemption, and are accordingly void and unenforceable; b. That this Court enter a judgment permanently enjoining Defendants from enforcing or attempting to enforce Morgan Hill’s and Petaluma’s natural gas ban Ordinances because they are preempted by federal law and do not satisfy any exception to such preemption, and are accordingly void and unenforceable;
c. That this Court award the United States its costs and fees in this action; and d. That this Court award any other relief it deems just and proper.

Case 5:26-cv-00056-BLF Document 1 Filed 01/05/26 Page 14 of 15 Agenda Item #13.1.

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Complaint of the United States - 14 -
1 2
3 4
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7 8
9 10
11 12
13 14
15 16
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27 DATED: January 5, 2026 Respectfully submitted,
/s/ Charles E.T. Roberts
CHARLES E.T. ROBERTS
Counsel to the Assistant Attorney General
U.S. Department of Justice
Civil Division
Counsel for the United States
Case 5:26-cv-00056-BLF Document 1 Filed 01/05/26 Page 15 of 15 Agenda Item #13.1.

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Agenda Report to the City Council
Agenda Section: NEW BUSINESS
Department: Planning
DATE: September 23, 2025
FROM: Maya DeRosa, Community Development Director
SUBJECT: Receive Report from Staff and Consultant on Housing Element Site 10 (1933 Spring Street) Alternatives Analysis

RECOMMENDED
ACTION:

Receive report from staff and consultant.

PREVIOUS COUNCIL
ACTION:

On April 23, 2024, as part of the Housing Element General Plan Amendment and rezoning approvals by City Council,
staff was directed to work with a group of neighbors and a consultant to explore alternative sites on the West side for High Density Residential development thereby allowing a possibility of downzoning Site 10 from High Density
Residential to Medium Density Residential.

STATEMENT OF THE
PURPOSE:

To review the criteria for Housing Element site selection and the conclusions of the Site 10 Alternatives analysis which concluded that there were no suitable alternative Housing Opportunity Sites.

FINANCIAL IMPACT: None.

BACKGROUND:

On August 19, 2025, the City held a Housing Laws public meeting and some public feedback requested that the City have a public meeting to present the findings of the Housing Element Site 10 alternatives analysis which was released to the public on February 3, 2025.

The impetus for the preparation of this alternatives analysis prepared by the Housing Element consultant was initiated in 2024 when the City Council approved and adopted the required General Plan amendments and up-zonings of multiple Housing Element Sites. Noticing requirements included sending a mailed public hearing notice to all residents within 300 feet of the subject parcel. Many of the residents who received a public hearing notice of the up-zoning of 1933 Spring Street from Medium Density (MR) to High Density (HR) were unaware that the 4.4-acre vineyard parcel was already zoned for residential uses and were opposed to further increasing the density to up to 28 units per acre which is allowed in the HR zone. At the City Council hearing to adopt the zoning map changes on April 23, 2024, the City Council directed staff to study alternative sites to Housing Element Site 10 and include interested citizens in the process.

Agenda Item #13.2.

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The discussion below summarizes the report criteria and conclusions.

Additionally, on August 25, 2025, the owner of Housing Element Site 10, 1933 Spring Street, filed a Preliminary Application to build 78 townhomes on the vineyard parcel and that application is posted on the City Community Development website (currently under department review). The applicant is not requesting any discretionary action approvals at this time and therefore is a "by right" project. This means there are no public hearings prior to a City determination.

DISCUSSION:

Site 10 Alternatives Study
The goal of this study was to analyze sites on the west side of the City that met the stringent Housing Element Site Selection State criteria, that could be designated as High Density Residential (HR), thereby allowing for a potential scenario of Site 10 to be downzoned to Medium Density Residential (MR) via a Housing Element amendment process (subject to the approval process by the State). In 2024, the City engaged the professional assistance of the Housing Element consultant, Mintier Harnish, with the preparation of the alternative sites analysis.

The Housing Element consultant with the input from the citizen group and staff, studied a total of 16 potential alternative sites. Replacement sites, at minimum, must provide total capacity for the 44 lower-income units assumed at Site 10. The capacity did not have to be contained within a single replacement site. The State’s highly prescriptive criteria (see page 4 of Attachment 1) severely limited the number of sites that could be eligible for the designation of HR. The evaluation criteria included reviewing zoning, acreage, whether the site was vacant, within the Urban Limit Line, FEMA flood zone, Fire Hazard Severity Zone and distance from utility infrastructure.

The conclusion of the study is that each of those sites is not viable due to various factors/constraints as noted in the methodology on page 5 of the report and also in Table 1. Therefore, until the State changes its onerous criteria, there is no viable alternative.

Note: The preliminary application submitted recently to develop 78 townhomes on Site 10 is undergoing ministerial review by staff (with no city council action warranted) as required by state law. Therefore, no action on that project can be taken under this agenda item.

ENVIRONMENTAL REVIEW: Not a project subject to CEQA.

GOAL:

Miscellaneous/Other
Agenda Item #13.2.

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DOCUMENTS ATTACHMENTS:

Housing Element Site 10 Alternatives Site Analysis
Site 10 Follow Up FAQ pdf
Agenda Item #13.2.

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Final, December 2024 | 1
City of St. Helena
2023-2031 Housing Element:

Alternative Sites Evaluation
Introduction
Background
The City’s 2023-2031 Housing Element was adopted by the City Council on May 9, 2023. The adopted Housing Element included 12 key housing opportunity sites, of which seven sites were designated to be rezoned in order for the City to meet its assigned Regional Housing Needs Allocation (RHNA) of 256 units during the course of the eight-year housing element cycle (the other key opportunity sites do not require rezoning, as their existing zoning was adequate for the density needed to meet RHNA obligations).

During the General Plan Amendment and rezoning process of the Opportunity Sites described in the adopted Housing Element, the City received much public opposition to the rezoning of Opportunity Site #10 (Site #10) from Medium Density Residential to High Density Residential. The City Council directed staff to work with community members and explore an overlay and other options including other sites and units to replace Site #10 after adoption of the ordinance and recertification of the Housing Element by HCD.

Since the site selection process is prescribed by State law and the Housing Element consultant is most knowledgeable about the criteria and working with HCD, the City has expanded the scope of work for its housing element consultant team (Mintier Harnish) to include investigation of potential alternatives to the inclusion of Site #10.

Citizens’ input group. To assist in this effort, the City established a citizens’ input group to discuss and evaluate potential alternatives. The citizens input group held an initial meeting on May 30, 2024. During the meeting, three potential sites for were discussed, including:

1. A privately-owned 5.7-acre parcel, APN 009-180-041, located at 657 Main street.

2. Potential surplus acreage at the 7.7-acre St. Helena Elementary site, APN 009-231-003, located at 1325 Adams Street.

3. A partially-vacant 3.0-acre parcel owned by the Church of Latter-Day Saints, APN 009-391-014, located 2222 Spring Street.

An initial evaluation of these sites indicated each is non-vacant and currently in active use, as shown on the figures below. The site on Main Street has several buildings on site, including existing active uses.

Additionally, surplus acreage on the St. Helena Elementary site is used as sports fields and play areas and the partially-vacant church site includes the church parking lot.

Further, input from a citizens input group participant indicated that the interests of the current property owners may constrain housing development on these sites. The owner of 657 Main Street let an existing entitlement on the parcel expire and is not likely to pursue redevelopment in the planning period.

Agenda Item #13.2.

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City of St. Helena | Alternatives to Site #10 Introduction Final, December 2024 | 2
Additionally, the City was informed that, when engaged by residents, neither the St. Helena Unified School District nor the Church of Latter-day Saints expressed interest in developing their properties for housing.

Due to the presence of active uses and the lack of property-owner interest in redevelopment, these sites are not feasible for lower-income RHNA capacity during the planning period and were not evaluated further in this report.

Figure 1: Aerial Image of 657 Main Street
Agenda Item #13.2.

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City of St. Helena | Alternatives to Site #10 Introduction Final, December 2024 | 3
Figure 2: Aerial Image of 1325 Adams Street (St. Helena Elementary School) Figure 3: Aerial Image of 2222 Spring Street (Church of Latter-Day Saints) Agenda Item #13.2.

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City of St. Helena | Alternatives to Site #10 Introduction Final, December 2024 | 4
Purpose of this Evaluation
At City Council’s direction, this report evaluates potential replacement sites for Site #10. Replacement sites, at minimum, must provide total capacity for the 44 lower-income units assumed at Site #10. This capacity does not have to be contained within a single replacement site.

Relevant State Law
• State law dictates requirements for lower-income sites, including:
o Sites must be between 0.5 acres and 10 acres
o Rezone sites must accommodate a minimum of 20 dwelling units per acre and 16 units per site
• Due to the threat of wildfire, State law requires residential developments to have at least two emergency evacuation routes. Replacement sites should comply with this requirement unless the City has plans to alleviate evacuation challenges associated with single access residential neighborhoods.
• Due to the requirements of AB 686 (2017), cities and counties are now required to plan higher density low-income sites in areas with higher incomes, better schools, increased access to parks and environmental opportunities, and better employment outcomes. For St. Helena, this meant planning for affordable housing on the western half of the city. Opportunity Site #10 is located within this half of the city and assumes capacity for 44 lower- and 44 above moderate-income units in a high resource area. If Site #10 is removed, any site(s) replacing the lower-income capacity must be located similarly within the western portion of the city and have a total lower-income capacity of no less than 44 lower-income units.
1 • State law requires that lower income sites be in proximity to transportation and services.

Replacement sites should not be identified in remote locations on the western edges of the city. 1 Due to the surplus capacity planned to meet the above moderate-income RHNA in the Housing Element, the 44 above moderate-income units assumed at Site #10 do not need to be replaced if the site is removed.

Agenda Item #13.2.

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City of St. Helena | Alternatives to Site #10 Introduction Final, December 2024 | 5
Approach/Methodology:

Using information provided in the 2015 Feasibility Analysis and Comparison of Sites for New Affordable Housing Development, the Preliminary Sites Inventory developed during the 6th-cycle Housing Element Update2, and parcel data provided by Napa County GIS, the Consultants first identified vacant and severely underutilized parcels in the city.

The Consultants then limited the list of potential replacement sites to those located in higher resource areas west of Main Street.

Finally, the Consultants gathered and evaluated critical data points for each qualifying site. Several constraints were considered for each site, such as environmental concerns, utility access, feasibility of redevelopment during the next planning period, and realistic capacity assumptions. including:
• Lot size
• Existing land use and zoning
• Vacancy status and existing uses on site3
• Location in relation to the ULL
• FEMA flood zone
• Fire hazard severity zone
• Distance to existing utility infrastructure
• Site-specific constraints
• Potential to accommodate lower-income capacity
2 The Preliminary Sites Inventory considered but rejected several sites due to environmental constraints, inappropriate site size, site specific constraints, or necessary infrastructure improvements including utilities and roadway extensions that would make development of housing within the next 8 years not feasible. 3 Napa County parcel data is provided by the County Assessor’s Office based on taxed uses. Because tax-exempt uses are often identified as vacant, the vacancy status of each site was verified using aerial imagery (i.e. not all sites identified as vacant by search of records are actually vacant).

Agenda Item #13.2.

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City of St. Helena | Alternatives to Site #10 Introduction Final, December 2024 | 6
Conclusion
Of the 16 potential sites identified as vacant or severely underutilized on the western portion of the City:
• 13 sites are completely constrained and are not appropriate for lower-income residential development.
• One site (Site F) is a parking lot constrained by existing zoning and an active use on site.

Additionally, the current utilization of the site (essential Sager Ford guest and employee parking) indicates that redevelopment in the planning period may not be feasible. To include this site, the City would need to engage the property owner to confirm interest in selling the parcel or developing housing on site in the planning period. If rezoned to high density residential, the site could provide realistic capacity for 17 units, however, due to the active use on site and lack of surplus acreage, this site is not appropriate for lower-income capacity and is not an alternative to Site #10. • One site (Site I) is appropriate for residential development if rezoned but is located in a FEMA flood plain. The site is an underutilized parking lot for Umpqua Bank. To assume lower-income capacity on the site, the City would need to provide an analysis of why the flood zone would not preclude development of housing in the near term and would need to add or modify Housing Element programs, as appropriate, to incentivize and encourage residential development. If rezoned to HR, the City can assume capacity for 14 units on site, however, due to the active use on site and lack of surplus acreage, this site not appropriate for lower-income capacity and is not an alternative to Site #10.
• One Site (Site L) is constrained only by existing zoning. The vacant 1.5-acre site is located along N.

Crane Avenue between Mitchell Drive and Spring Street. If rezoned to HR, the site could accommodate a maximum capacity of 42 units and a realistic capacity of 29 lower-income units.

Due to limited acreage, this site alone is insufficient to replace Site #10. Additionally, this parcel could potentially face the same neighbor opposition as Site #10.

The analysis shows that the City does not have alternative sites with potential to provide the minimum needed lower-income unit capacity to replace Site #10. Given the available sites west of Highway 29, replacing Site #10 is not viable. Table 1, beginning on the following page, includes a summary of each site included in the evaluation.

Agenda Item #13.2.

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Final, December 2024 | 7
Table 1: Site Evaluation Summary
Site
APN and
Location Acres
Appropriate for Lower Income Housing
Constraints Evaluation
Potential
Lowerincome
Zoning Vacant Capacity
Within
Urban
Limit Line
FEMA
Flood
Zone
Fire
Hazard
Severity
Zone
Distance from
Existing Utility
Infrastructure
A 009-392-045;
Adjacent to
the cemetery,
near Spring St.
and Valley
View

2.04 PQP No ULL
bisects
the parcel
No None 0.2 miles,
existing uses
obstructing
path
Existing agricultural
use on site; only
partially within the
ULL; existing creek
runs through site; not
adjacent to existing
utility infrastructure
This site is not
appropriate for lowerincome capacity and is
not a potential
alternative to Site #10.
0 units
B 009-392-035;
0 Crane
Avenue

3.17 I Yes Yes Yes None 0.01 miles
Existing creek runs
through site; title
issues with Crane
Avenue ROW;
location within a
FEMA flood zone
This site is not
appropriate for lowerincome capacity and is
not a potential
alternative to Site #10.
0 units
C 009-392-014;
Spring St. near
intersection
with Sylvander
Avenue

5.01 PQP No Yes No None 0.01 miles
Non-vacant: existing
cemetery on site
This site cannot
accommodate
residential uses and is
not appropriate not a
potential alternative to
Site #10.
0 units
D 009-350-065;
1701 Grayson
Avenue St.

11.17 PQP No Yes No None 0.01 miles
Non-vacant: existing
school on site; no
surplus acreage
Development of the
site is constrained by
the current use [a
school with no surplus
acreage]. Due to this
constraint, the parcel
is not appropriate for
lower-income capacity
and is not a potential
alternative to Site #10.
0 units
E 009-350-033;
360 South
Crane Ave.

10.00 PR No Yes No None 0.15 miles
Non-vacant: existing
community park
Development of the
site is constrained by
the current use [an
existing community
park with no surplus
acreage]. Due to this
constraint, the parcel
is not appropriate for
lower-income capacity
and is not a potential
alternative to Site #10.
0 units
Agenda Item #13.2.

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City of St. Helena | Alternatives to Site #10 Introduction Final, December 2024 | 8
Site
APN and
Location Acres
Appropriate for Lower Income Housing
Constraints Evaluation
Potential
Lowerincome
Zoning Vacant Capacity
Within
Urban
Limit Line
FEMA
Flood
Zone
Fire
Hazard
Severity
Zone
Distance from
Existing Utility
Infrastructure
F 009-434-009;
1286 Sulphur
Springs Ave.

0.88 SC No Yes No None 0.01 miles
Non-vacant: existing
parking lot (Sager
Ford). Essential part
of business.

Well-used parking lot:
feasibility of
redevelopment in
planning period is very
low. No indication
that the owner would
sell or redevelop.

Due to the active use
on site and lack of
surplus acreage, this
site is not a potential
alternative to Site #10.
0 units
G 009-180-012;
1405 Charter
Oak Ave.

3.98 I No Yes Yes None 0.18 miles
Non-vacant: corp yard
with miscellaneous
improvements;
location within a
FEMA flood zone;
existing creek runs
through site; distance
from utility
infrastructure;
Charter Oak Road
runs through the site
This site is not
appropriate for lowerincome capacity and is
not a potential
alternative to Site #10.
0 units
H 009-263-014;
No street
access,
adjacent to
1057 Main
Street

1.62 MU No Yes Yes None 0.1 miles
Non-vacant: existing
paved surfaces;
location within a
FEMA flood zone; no
direct street access;
potential Oak Ave
extension would go
through the middle
This site is not
appropriate for lowerincome capacity and is
not a potential
alternative to Site #10.
0 units
I 009-263-013;
1057 Main
Street

0.75 CB No Yes Yes None 0.05 miles
Non-vacant: existing
parking lot (Umpqua
Bank); location within
a FEMA flood zone
Well-used parking lot:
feasibility of
redevelopment in
planning period is very
low.

If rezoned to HR the
City has a maximum
capacity of 21 units
and a realistic capacity
assumption of 14 units.

Due to limited acreage
and location within a
FEMA flood zone, this
site is not a potential
alternative to Site #10.
0 units
J 009-263-005;
1301 Mitchell
Drive

0.88 PQP No Yes Yes None 0.01 miles
Non-vacant: PG&E
site with
miscellaneous
This site is not
appropriate for lowerincome capacity and is 0 units
Agenda Item #13.2.

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City of St. Helena | Alternatives to Site #10 Introduction Final, December 2024 | 9
Site
APN and
Location Acres
Appropriate for Lower Income Housing
Constraints Evaluation
Potential
Lowerincome
Zoning Vacant Capacity
Within
Urban
Limit Line
FEMA
Flood
Zone
Fire
Hazard
Severity
Zone
Distance from
Existing Utility
Infrastructure
improvements;
location within a
FEMA flood zone;
large easement that
limits developable
acreage, potential site
for Oak Avenue
extension, former
hazmat clean-up site
not a potential
alternative to Site #10.

K 009-600-003;
Adjacent to
1711 Spring St.

0.76 PR No Yes Yes None 0.01 miles
Non-vacant: existing
community park;
location within a flood
plain
Due to the current use
on site, this parcel is
not appropriate for
lower-income capacity
and is not a potential
alternative to Site #10.
0 units
L 009-322-009;
Adjacent to
1053 Crane
Ave.

1.5 MR Yes Yes Yes
(partial)
None 0.01 miles
In appropriate zoning:
site must be rezoned
to HR to provide
lower-income
capacity.

If rezoned to HR, the
site could
accommodate a
maximum capacity of
42 units and a realistic
capacity of 29 units.

However, likely to face
same upzoning
opposition as Site 10.
29 M 009-690-023;
Adjacent to
1780 Dean
York Lane

1.00 LR-1A Yes Yes No None 0.05 miles
Recently approved for
the development of a
new market-rate
single-family home
Due to the pending
project on this site, it is
not a potential
alternative to Site #10.
0 units
N 009-131-039;
Adjacent to
2486 Spring
Mountain
Road

5.00 WW Yes Yes No None 0.3 miles
Located at the end of
a road without
secondary access;
not adjacent to
existing utility
infrastructure; not in
proximity to
transportation and
services
This site is not
appropriate for lowerincome capacity and is
not a potential
alternative to Site #10.
0 units
O 009-131-045;
Adjacent to
2500 Spring
Mountain
Road

19.12 WW Yes Yes No High 0.75 miles
Lack of road access;
significant distance
from existing utility
infrastructure; not in
proximity to
transportation/service
s; steep topography;
This site is not
appropriate for lowerincome capacity and is
not a potential
alternative to Site #10.
0 units
Agenda Item #13.2.

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City of St. Helena | Alternatives to Site #10 Introduction Final, December 2024 | 10
Site
APN and
Location Acres
Appropriate for Lower Income Housing
Constraints Evaluation
Potential
Lowerincome
Zoning Vacant Capacity
Within
Urban
Limit Line
FEMA
Flood
Zone
Fire
Hazard
Severity
Zone
Distance from
Existing Utility
Infrastructure
owner opposition;
high fire hazard
severity zone
P 009-591-001;
Mitchell Dr.
between
Voorhees
Circle and St.

James Dr.

0.84 PR No Yes Yes None 0.01 miles
Non-vacant: existing
community park;
location within a flood
plain
Due to the current use
on site, this parcel is
not appropriate for
lower-income capacity
and is not a potential
alternative to Site #10.
0 units
Total 29
Individual Site Evaluations
We have included a detailed evaluation of each site on the following pages.

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City of St. Helena | Alternatives to Site #10 Individual Site Evaluations Final, December 2024 | 11
Site A: 009-392-045 | Address: None; directly adjacent to the cemetery; closest intersection is Spring St. and Valley View APN Acres
Land Use
Designation Zone Vacant Within ULL
FEMA
Flood
Zone
Fire
Hazard
Severity
Zone
Distance to Utility
Infrastructure Other
Potential
LowerIncome
Capacity
009-392-045 2.04 Public & QuasiPublicPQP No ULL bisects the parcel (at Sulphur
Creek)
No None 0.2 miles, existing uses
obstructing path
Existing agricultural use on
site; Sulphur Creek runs
through the site
0 Evaluation: This 2.04-acre site is zoned PQP and could accommodate residential uses if rezoned. The site has several issues however, including that the parcel: has an existing agricultural use on site; is only partially within the ULL; has an existing creek (Sulphur Creek) running through it; and is not adjacent to existing utility infrastructure. The site would require infrastructure improvements including utilities and roadway extensions that would make development of housing within the next 8 years not feasible. Due to these constraints, this site is not appropriate for lowerincome capacity and is not a potential alternative to Site #10.

Agenda Item #13.2.

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City of St. Helena | Alternatives to Site #10 Individual Site Evaluations Final, December 2024 | 12
Site B: 009-392-035 | Address: 0 Crane Avenue

APN Acres
Land Use
Designation Zone Vacant Within ULL
FEMA
Flood
Zone
Fire Hazard
Severity
Zone
Distance to
Utility
Infrastructure Other
Potential
LowerIncome
Capacity
009-392-035 3.17 Industrial I Yes Yes Yes None 0.01 miles Industrial site, title issues with Crane Avenue Right of Way (ROW),
creek through parcel
0 Evaluation: This 3.17-acre site is zoned I and could accommodate residential uses if rezoned. The site has a several issues however, including an existing creek running through the site, title issues with Crane Avenue ROW, and location within a FEMA flood zone. These issues pose significant constraints that limit the potential for affordable residential development in the planning period. Due to these constraints, this site is not appropriate for lower-income capacity and is not a potential alternative to Site #10.

Agenda Item #13.2.

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City of St. Helena | Alternatives to Site #10 Individual Site Evaluations Final, December 2024 | 13
Site C: 009-392-014 | Address: None; Spring Street south of Valley View Street

APN Acres
Land Use
Designation Zone Vacant Within ULL
FEMA
Flood
Zone
Fire
Hazard
Severity
Zone
Distance to Utility
Infrastructure Other
Potential
LowerIncome
Capacity
009-392-014 5.01 Public & QuasiPublicPQP No Yes No None 0.01 miles St. Helena Public Cemetery; no surplus
acreage
0 Evaluation: This 5.01-acre site is zoned PQP is not vacant. The site is part of the St. Helena Public Cemetery and is not appropriate for residential uses. Due to the existing use on site, this parcel is not a potential alternative to Site #10.

Agenda Item #13.2.

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City of St. Helena | Alternatives to Site #10 Individual Site Evaluations Final, December 2024 | 14
Site D: 009-350-065 | Address: 1701 Grayson Avenue St.

APN Acres
Land Use
Designation Zone Vacant Within ULL
FEMA
Flood
Zone
Fire
Hazard
Severity
Zone
Distance to Utility
Infrastructure Other
Potential
LowerIncome
Capacity
009-350-065 11.17 Public & QuasiPublicPQP No Yes No None 0.01 miles Parcel is the school site for St. Helena Primary; no
surplus acreage
0 Evaluation: This 11.17-acre site is zoned PQP and is not vacant. The parcel is part of the St. Helena Primary School site and is currently developed with buildings and sports fields. The parcel does not include surplus acreage. Due to the current use on site, this parcel is not appropriate for lower-income capacity and is not a potential alternative to Site #10.

Agenda Item #13.2.

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City of St. Helena | Alternatives to Site #10 Individual Site Evaluations Final, December 2024 | 15
Site E: 009-350-033 | Address: 360 South Crane Avenue

APN Acres
Land Use
Designation Zone Vacant Within ULL
FEMA
Flood
Zone
Fire
Hazard
Severity
Zone
Distance to Utility
Infrastructure Other
Potential
LowerIncome
Capacity
009-350-033 10.00 Parks and
Recreation
PR No Yes No None 0.15 miles Parcel is a park with misc. improvements; no surplus
acreage (Crane Park)
0 Evaluation: This 10-acre site is zoned PQP and is not vacant. The site is a community park, built out with sports fields and activity areas, and does not include surplus acreage. Due to the current use on site, this parcel is not appropriate for lower-income capacity and is not a potential alternative to Site #10.

Agenda Item #13.2.

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City of St. Helena | Alternatives to Site #10 Individual Site Evaluations Final, December 2024 | 16
Site F: 009-434-009 | Address: 1286 Sulphur Springs Avenue

APN Acres
Land Use
Designation Zone Vacant Within ULL
FEMA
Flood
Zone
Fire
Hazard
Severity
Zone
Distance to Utility
Infrastructure Other
Potential
LowerIncome
Capacity
009-434-009 0.88 Service
Commercial
SC No Yes No None 0.01 miles Contains improvements;
no surplus acreage;
essential to active
business
0 Evaluation: This 0.88-acre site is zoned SC and is not vacant. The site is a parking lot for Sager Ford and is used as guest and employee parking.

The parking lot is essential to the operation of the business; the dealership could not function without it. Additionally, there is no indication that the owner would sell or redevelop the property for housing within the planning period. The site has redevelopment potential, however, and could be included if the property owner is interested in selling the parcel or developing housing on site. The City would need to engage the owner to confirm this interest. If rezoned to high density residential, the site could have a maximum capacity of 24 units and realistic capacity assumption of 17 units. Due to the active use on site and lack of surplus acreage, this site cannot provide lower-income capacity and is not a potential alternative to Site #10.

Agenda Item #13.2.

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City of St. Helena | Alternatives to Site #10 Individual Site Evaluations Final, December 2024 | 17
Site G: 009-180-012 | Address: 1405 Charter Oak Avenue

APN Acres
Land Use
Designation Zone Vacant Within ULL
FEMA
Flood
Zone
Fire
Hazard
Severity
Zone
Distance to Utility
Infrastructure Other
Potential
LowerIncome
Capacity
009-180-012 3.98 Industrial I No Yes Yes None 0.18 miles Contains Misc. Buildings Corp Yard; odd shape limits
developable acreage
0 Evaluation: This 3.98-acre site is zoned I and could accommodate residential uses if rezoned and redeveloped. This site is the City Corporate Yard. Due to environmental constraints, this site is not ideal as a Housing Opportunity Site. The site is located within the flood zone and Sulphur Creek crosses through the southwest portion of the site. Additionally, Charter Oak Road runs diagonally through much of the site, bisecting the site in half. These issues pose significant and potentially costly constraints that limit the potential for affordable residential development in the planning period. Due to these constraints, this site is not appropriate for lower-income capacity and is not a potential alternative to Site #10.

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City of St. Helena | Alternatives to Site #10 Individual Site Evaluations Final, December 2024 | 18
Site H: 009-263-014 | Address: No street access, closest address is 1057 Main Street.

APN Acres
Land Use
Designation Zone Vacant Within ULL
FEMA
Flood
Zone
Fire
Hazard
Severity
Zone
Distance to Utility
Infrastructure Other
Potential
LowerIncome
Capacity
009-263-014 1.62 Service
Commercial
MU No Yes Yes None 0.1 miles No direct street access;
potential Oak Ave
extension would go through
the middle
0 Evaluation: This 10-acre site is zoned MU and could accommodate residential uses if redeveloped. The has several issues, however, including no street access, miscellaneous improvements on site, location within a FEMA flood zone, and potential for the Oak Avenue extension to bisect the parcel. Due to these constraints, this site is not appropriate for lower-income capacity and is not a potential alternative to Site #10.

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City of St. Helena | Alternatives to Site #10 Individual Site Evaluations Final, December 2024 | 19
Site I: 009-263-013 | Address: 1057 Main Street

APN Acres
Land Use
Designation Zone Vacant Within ULL
FEMA
Flood
Zone
Fire
Hazard
Severity
Zone
Distance to Utility
Infrastructure Other
Potential
LowerIncome
Capacity
009-263-013 0.75 Central Business CB No Yes Yes None 0.05 miles Miscellaneous improvements on site
(parking for Umpqua Bank)
0 Evaluation: This 0.75-acre site is zoned CB and could accommodate residential uses if rezoned and redeveloped. The site has a few issues, including an existing parking lot and location within a FEMA flood zone. If rezoned to HR, the site could accommodate a maximum capacity of 21 units and a realistic capacity of 14 units. To assume lower-income capacity on the site, however, the City would need to provide an analysis of why the flood zone would not preclude development of housing in the near term and would need to add or modify Housing Element programs, as appropriate, to incentivize and encourage development. Due to existing use on site, limited acreage, and location within a FEMA flood zone, this site is not a potential alternative Site #10.

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City of St. Helena | Alternatives to Site #10 Individual Site Evaluations Final, December 2024 | 20
Site J: 009-263-005 | Address: 1301 Mitchell Drive

APN Acres
Land Use
Designation Zone Vacant Within ULL
FEMA
Flood
Zone
Fire
Hazard
Severity
Zone
Distance to
Utility
Infrastructure Other
Potential
LowerIncome
Capacity
009-263-005 0.88 Central
Business
PQP No Yes Yes None 0.01 miles Improvements on site (paving); PG&E site, former hazmat clean-up site, large
easement through the middle, potential
Oak Ave extension would go through the
middle
0 Evaluation: This 0.88-acre site is zoned PQP and could accommodate residential uses if rezoned and redeveloped. The site is owned by PG&E and is used as a staging site. The site has several issues, including existing uses and improvements on site, a large easement that limits the developable area, location within a FEMA flood zone, and potential for the Oak Avenue extension to bisect the parcel. Additionally, the site was a former hazmat clean-up site and was remediated for hazardous materials from a manufactured gas plant that operated on the site from 1883 to 1926. Due to these constraints, this site is not appropriate for lower-income capacity and is not a potential alternative to Site #10.

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City of St. Helena | Alternatives to Site #10 Individual Site Evaluations Final, December 2024 | 21
Site K: 009-600-003 | Address: Along Spring Street; closest address is 1711 Spring St.

APN Acres
Land Use
Designation Zone Vacant Within ULL
FEMA
Flood
Zone
Fire
Hazard
Severity
Zone
Distance to Utility
Infrastructure Other
Potential
LowerIncome
Capacity
009-600-003 0.76 Parks and
Recreation
PR No Yes Yes None 0.01 miles Existing community park
on site (Baldwin Park)
0 Evaluation: This 0.76-acre site is zoned PR and is a community park (Baldwin Park). Due to the current use on site, this parcel is not appropriate for lower-income capacity and is not a potential alternative to Site #10.

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City of St. Helena | Alternatives to Site #10 Individual Site Evaluations Final, December 2024 | 22
Site L: 009-322-009 | Address: None; Adjacent to 1053 Crane Avenue

APN Acres
Land Use
Designation Zone Vacant Within ULL
FEMA
Flood
Zone
Fire
Hazard
Severity
Zone
Distance to Utility
Infrastructure Other
Potential
LowerIncome
Capacity
009-322-009 1.5 Medium Density
Residential
MR Yes Yes Partial None 0.01 miles 29
Evaluation: This 1.5-acre site is zoned MR and can accommodate residential uses. The site is partially located within a FEMA 500-year flood zone (along Crane Avenue frontage), however due to the decreased flood risk and minimally impacted parcel area, this is not a constraint to development. If rezoned to HR, the site could accommodate a maximum capacity of 42 units and a realistic capacity of 29 lower-income units.

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City of St. Helena | Alternatives to Site #10 Individual Site Evaluations Final, December 2024 | 23
Site M: 009-690-023 | Address: None; Adjacent to 1780 Dean York Lane

APN Acres
Land Use
Designation Zone Vacant Within ULL
FEMA
Flood
Zone
Fire
Hazard
Severity
Zone
Distance to Utility
Infrastructure Other
Potential
LowerIncome
Capacity
009-690-023 1.00 Low Density
Residential
LR-1A Yes Yes No None 0.05 miles Project recently approved on site
0 Evaluation: This 1-acre site is zoned LR-1A and can accommodate residential uses. The site was recently approved for the development of a new market-rate single-family home, however, and is not appropriate for rezoning at this time. Due to the pending project on this site, it is not a potential alternative to Site #10.

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City of St. Helena | Alternatives to Site #10 Individual Site Evaluations Final, December 2024 | 24
Site N: 009-131-039 | Address: None; Closest address is 2486 Spring Mountain Road

APN Acres
Land Use
Designation Zone Vacant
Within
ULL
FEMA
Flood
Zone
Fire
Hazard
Severity
Zone
Distance to
Utility
Infrastructure Other
Potential
LowerIncome
Capacity
009-131-039 5.00 Woodlands &
Watershed
WW Yes Yes No None 0.3 miles No direct access to the existing utility infrastructure; located at the end of a road without secondary
access; steep topography, surrounded by singlefamily uses owned by property owner. No indication owner would see or redevelop
0 Evaluation: This 5-acre site is zoned WW and could accommodate residential uses if rezoned. The site is located in an extremely low-density area west of Beringer Vineyards that can only be accessed by Spring Mountain Road. The area has steep topography and would require infrastructure improvements including utility and roadway extensions. The costs involved with developing roadway extensions, mitigating topography issues, and connecting to utility infrastructure are significant and costly constraints to the development of affordable residential uses on this site. Due to these constraints, this site is not appropriate for lower-income capacity and is not a potential alternative to Site #10.

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City of St. Helena | Alternatives to Site #10 Individual Site Evaluations Final, December 2024 | 25
Site O: 009-131-045 | Address: None; Closest address is 2500 Spring Mountain Road

APN Acres
Land Use
Designation Zone Vacant Within ULL
FEMA
Flood
Zone
Fire
Hazard
Severity
Zone
Distance to
Utility
Infrastructure Other
Potential
LowerIncome
Capacity
009-131-045 19.12 Woodlands &
Watershed
WW Yes Yes No High 0.75 miles No direct access to the existing utility infrastructure; no services; no access;
steep topography; owner owns
surrounding parcels and appears to
value space/privacy
0 Evaluation: This 19.12-acre site is zoned WW and could accommodate residential uses if rezoned. The site has several issues however, including lack of road access, significant distance from existing utility infrastructure, and steep topography. Development of the site would require infrastructure improvements including utilities and roadway extensions that would make development of housing within the next 8 years not feasible Additionally, the owner of the parcel (and the adjacent parcels) values privacy and would not support the development of high density uses on the site. Finally, the site is too large to meet the State’s assumptions regarding sites suitable for lower-income housing, which include sites that are between 0.5 and 10 acres in size. These issues pose significant and extremely costly constraints that limit the potential for affordable residential development in the planning period. Due to these constraints, this site is not appropriate for lower-income capacity and is not a potential alternative to Site #10.

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City of St. Helena | Alternatives to Site #10 Individual Site Evaluations Final, December 2024 | 26
Site P: 009-591-001 | Address: None; Mitchell Drive, between Voorhees Circle and St. James Drive

APN Acres
Land Use
Designation Zone Vacant Within ULL
FEMA
Flood
Zone
Fire
Hazard
Severity
Zone
Distance to Utility
Infrastructure Other
Potential
LowerIncome
Capacity
009-591-001 0.84 Parks and
Recreation
PR No Yes Yes None 0.01 miles Existing City park on site (Mary Fryer Park)
0 Evaluation: This 0.84-acre site is zoned PR and is not vacant. The site is a community park (Mary Fryer Park) and is located in a FEMA flood zone.

Due to the current use on site, this parcel is not appropriate for lower-income capacity and is not a potential alternative to Site #10.

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1933 Spring (Housing Element Site 10) FAQ
Can City down zone a Housing Element site?
• If the City wanted to down zone a Housing Element site, the City would need to find an alternative site that met the HCD criteria for Opportunity Sites. It should be noted that the Alternatives Sites analysis for Site 10 (dated December 2024)concluded that there were no other feasible sites to replace Site 10 on the west side of the city.
• As part of this Study, the Housing Element consultant conducted an exhaustive search for 16 other sites to replace Site 10 that were identified as vacant or severely underutilized. These other sites were not found suitable because of issues related to zoning, Urban Limit Line, FEMA zone, Fire Hazard Zone, or distance from infrastructure.
• So, if the City was to down zone Site 10, it would result in the City having a non-compliant Housing Element and St. Helena would be subject to the Builders Remedy.

What is Builders Remedy?
• Prevents jurisdictions from denying certain housing projects • Projects do not have to comply with the jurisdiction’s zoning ordinance or general plan
• The City may not limit heights or require setbacks
• Allows for by-right development of multi-family projects on these sites Consequences of swapping out a site?
• Doing so would require that the City start the Housing Element site selection process again with HCD and the community.
• As noted above, this would leave the City liable for Builder’s Remedy projects until the City completes a new public review process, new HCD review cycles and adoption hearings before the updated Housing Element could be considered for certification.

Spring St Site 10:
• When did the General Plan change this land use from Agricultural to residential?
1975
• How many years has site 10 been a residential land use (Medium Density Residential)?
50 (since 1975 as a Medium Density site: range 5.1 to 16.0 units per acre.

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• What is the allowed density of MR?

5.1 to 16.0 units per acre
• What is the allowed density of High Density (HR)?

16.1 to 28 units per acre
• How many units could be built on site 10 (4.4 acres) under the HR zoning? 123 units
• How many units are being proposed for Site 10 by the current owner? 78 • What year was this site added to Housing Element as a Housing Element opportunity site?
In the 5th cycle Housing Element, certified by HCD in 2009 • When did the City identify this as a site for upzoning to HR? o As part of the 6th cycle Housing Element, the City was required to identify sites that could accommodate increased density on the west side. o Public meetings to discuss the various potential sites were held on January 20, 2022 (Workshop #2) and February 22, 2022 (Joint CC/PC meeting) o The direction requested at the February 22, 2022 joint meeting (see agenda page):
 Are there any sites that should be added to the sites inventory? If so why?
 Are there any sites that should be removed from the sites inventory? If so, why?
 Confirm the proposed or amended sites inventory and direct staff to proceed with the Housing Element Update.
o All the housing sites are shown on Figure 49 of the Housing Element adopted in September 2023 (and this figure was included in earlier versions of the Housing Element released to the public on June 29, 2022. (See end of this FAQ)
• When was a notice of Site 10 being upzoned sent to the owner? Letters were sent out to property owners of Housing Element Opportunity Sites on July 27, 2022 notifying the owner that their site has been identified as a possible site to accommodate future housing sites.

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The formal zoning action notices for the April 2, 2024 Planning Commission hearing were sent certified mail to the opportunity site owners on March 20, 2024. • How was the community alerted to this zoning change to HR as part of the Housing Element?
o As noted previously in this FAQ, there were two focused meetings in 2022 to request public input on the proposed opportunity sites prior to the release of the first public draft of the Housing Element.
o In the February 22, 2022 staff report, it is noted that the Housing Element Focus Group suggested that Site 10 be up-zoned from Medium Density Residential to High Density Residential.
o The advertisement for these meetings took place via the newspaper articles, social media posts and eblasts from the City.
• Can the City change the zoning of a site while a Preliminary Application is under review?
o The zoning could be changed but the change would not be applicable to the project under review due to the applicant having submitted a preliminary application on August 26, 2025, which locks in the standards and fees applicable to the project as those in effect on that date. Also rezoning this site would bring the City’s Housing Element out of compliance and there could be many repercussions, including Builders Remedy.

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Figure 49-Residential Site Inventory Map
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Housing Element Site 10
Alternative Sites Evaluation
City of St. Helena
City Council Meeting
September 23, 2025
1 Agenda Item #13.2.

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Purpose
 As directed by the City Council in 2024, the purpose of the report was to evaluate potential replacement sites for Site #10.  Replacement sites, at minimum, must provide total capacity for the 44 lower-income units assumed at Site #10.
 This capacity does not have to be contained within a single replacement site.
2 Alternative Sites Evaluation
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Information Sources
 Citizens input group
 Available GIS data
 2015 Feasibility Analysis and Comparison of Sites for New Affordable Housing Development
 The Preliminary Sites Inventory developed during the 6th-cycle Housing Element Update.
3 Alternative Sites Evaluation
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 Replacement Site Requirements
• Size: 0.5 - 10.0 acres
• Density: Minimum 20 du/ac and 16 units per site
• Location: Within proximity to transportation and services • Fair Housing (AB 686): Replacement sites must be in a high resource area (western portion of the city), similarly to Site #10
4 Alternative Sites Evaluation
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Citizen’s Input Group
 Three sites were suggested/discussed:
• 657 Main St
• 1325 Adams Street
• 2222 Spring Street
5 Alternative Sites Evaluation
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 657 Main St
• Not vacant
• Active uses on site
• Owner let an entitlement
expire; likely not interested
in redevelopment
6 Citizen’s Input Group
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 1325 Adams
• St. Helena Elementary
• Not vacant
• Sports fields and play areas
• When engaged by
residents, owners showed
no interest in developing
vacant acreage
7 Citizen’s Input Group
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 2222 Spring Street
• Church of Latter-Day Saints
• Not vacant
• Includes church parking lot
• When engaged by
residents, owners showed
no interest in developing
vacant acreage
8 Citizen’s Input Group
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 Steps:
• Identified vacant and severely underutilized parcels
• 16 sites were identified and evaluated
• Existing conditions: Lot size, land use and zoning, and existing uses • Environmental and physical constraints
• Distance from existing utility infrastructure
• Potential to accommodate lower income housing
9 Alternative Sites Evaluation
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10 Alternative Sites Evaluation
Site evaluations
are summarized
in Table 1
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11 Alternative Sites Evaluation
Individual site
evaluations follow
the summary
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Summary
 13 sites are completely constrained and are not appropriate for lower-income residential development
• Many sites have active uses
• Several have road or utility access issues
• Several are in a flood zone
12 Alternative Sites Evaluation
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13 Alternative Sites Evaluation
Site F Site I
Conclusion:

Constrained by
active use/
insufficient available
acreage
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14 Alternative Sites Evaluation
Site L
Conclusion:
• The site can accommodate realistic capacity
of 29 units
• This site alone is insufficient to replace Site #10
• Could face same neighbor opposition as Site #10
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Conclusion
 The City does not have alternative sites with potential to provide the minimum needed lower-income unit capacity to replace Site #10.  Given the available sites west of Highway 29, replacing Site #10 is not viable.
15 Alternative Sites Evaluation
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Discussion and Public Comment
16 Alternative Sites Evaluation
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From: Amy Particelli
To: Public Comment
Subject: City Council Meeting 9.23
Date: Saturday, September 20, 2025 9:04:57 PM
Dear Mayor and Councilmembers,
I want to express my disappointment with the upzoning of 1933 Spring Street (Site 10) and now with the staff report’s conclusion that there are “no viable alternative sites.” When the city rezoned this site to high density last year, the Council promised to study alternatives. The analysis dismissed options too quickly. For example, the Crane Avenue parcel could have supported nearly 30 lower-income units if rezoned. Multiple smaller sites together could have met the target, but instead the City concluded that only Site 10 would work.

This decision is especially troubling because Site 10 is a historic vineyard, part of St. Helena’s agricultural and cultural identity. How was that not heavily weighted in the decision? Upzoning it to high density has now invited a project that will overwhelm the neighborhood, create safety hazards, and erase this piece of history.

I also question why the City did not work harder with HCD to negotiate substitutions. Other cities have done so. St. Helena chose the path of least resistance and left one neighborhood to bear an enormous burden.

If the City can claim “no alternatives” to justify high-density zoning, any neighborhood could be next. That fractures trust and undermines the principle of shared responsibility in planning for housing.

I urge the Council to recognize that upzoning Site 10 was a mistake and to keep pushing for alternatives with the State. We need housing solutions that balance compliance with protecting our neighborhoods and history.

Thank you,
Amy Particelli
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From: Christy Palmisano
To: Public Comment
Subject: Opposition to Sure 10 Spring Street RENTAL development! Date: Saturday, September 20, 2025 6:00:20 PM
As a resident of Hudson Avenue, my property is directly impacted by the size and scale of this rental project on Site 10 on Spring Street. Not only is this high density three-story develop going to be impacting my privacy as the third story is much higher than any home ever permitted in our neighborhood, but the impact of water use and parking does not seem possible or responsible with the 78 families having at least two cars per unit moving into the area. Our community was hoping for medium density which would have been gracious and accepted by all. Instead, we have an overshadowed dense building that will only provide 15 homes that will be affordable, the rest being market rate to the advantage of the developer, not the city. I appreciate that fact that our city needs more affordable housing but destroying a historic neighborhood seems like a very high price for our community pay for fifteen units.

Sincerely,
Christy Palmisano
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From: Pierre Birebent
To: Public Comment
Subject: Spring street housing development, site 10
Date: Monday, September 22, 2025 9:19:41 AM
Dear Sir, Madam,
I am writing to explain my concern about the new housing project on the small vineyard on Spring street.

Not only will it affect the whole neighborhood and lower the real estate value of all the surrounding homes, but mostly the concern is about traffic and water need.

Spring street and Valley view street are the direct access to the primary and the high school .

Very busy during school hours.

Building a village on Spring street will enormously affect the already congested traffic in St Helena.

Those units will have between 3 to 4 cars per household.

This will inject 250 to 350 cars in the traffic, right in the middle of town.

I believe such a project should be done of the outskirts of town, just like Stone Bridge is, on College ave.

I will also raise the need for electricity during a heat spike for example, is PGE ready for a surcharge ?
Global warming means we need more trees and not 3 story buildings.

I am not sure this city council is much concern about the needs and wishes of St Helena residents.

Sincerely yours
Pierre Birebent
St Helena resident since 1988
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From: Maxine Angell
To: Public Comment
Subject: 1933 Spring Street/ Public comment for City Council Agenda Item 13. 2 9/23/25 Date: Monday, September 22, 2025 12:26:20 PM
Dear Mayor Dohring and Council Members;
I have lived in St Helena for 33 years and am one house away from the proposed development at 1933 Spring
Street. As I stated last year at the Planning Commission and City Council meetings, I am opposed to this project for numerous reasons, including but not limited to the following: the size of project, the number of units, failure to provide traffic studies or objective data on negative impacts of project on the neighborhood, destruction of a historical property built in 1910 and the loss of neighborhood charm.

At both the Planning Comission and CIty Council meetings last year, there was standing room only and overwhelming opposition to this project. Given the concerns of so many neighbors and residents, it is discouraging to see little done in the ensuing year, to find an alternate site and address neighbors concerns.

Due to the oppostion, planning staff promised a review of alternate sights. It appears from the Final Report, over a year later, that there it does not appear pursued alternate sights with due diligence. The Final Report lacks specifics and appears to restate generalities that were addressed last year.

I remain opposed to the rezoning at 1933 Spring Street and hope that the city staff will find an alternate site
or at the very least provide objective studies about traffic, and all the other concerns raised by neighbors and
residents of St. Helena last year that have not been addressed.

Sincerely,
Maxine L. Angell
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residential neighborhood.

The proposed rezoning will lower my property value and change the quiet, peaceful character of the neighborhood. Valley View Street is used to bypass the freeway and is too congested, as it is. There are many areas of town that are more suitable for a high density project such as the one that is proposed, some have been previously identified, some not.

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Dear Mayor Dohring & St. Helena City Council Staff,
I am writing as a concerned resident of St. Helena to express my strong opposition to the proposed development behind my home at 1106 Valley View Street. This project presents serious risks to the safety, well-being, and character of our neighborhood.

Our streets are quiet, residential, and not designed to handle the significant increase in vehicle traffic and noise that this development would bring. Children regularly walk and ride bikes to schools in the area, and the added congestion would dramatically increase the risk of accidents.

The increase in traffic would not only make daily life less safe but also complicate emergency access for first responders.

Of particular concern is the impact on fire safety. In the event of a wildfire or other emergency requiring evacuation, the added density and traffic could create dangerous bottlenecks, putting residents, including children and elderly neighbors, at risk. Our community’s ability to evacuate quickly and safely should be a top priority, yet this development would make that far more difficult. With the increase of more than 70 units which could equate to more than 300 new residents in a 4 acre parcel, this would greatly increase our risk of safety which we have been used to over the years.

Furthermore, the construction itself would introduce heavy equipment and constant large vehicle movement near homes, further endangering pedestrians and children. The long-term effect of the development would permanently alter the peaceful, safe character of our neighborhood. Not to mention the 40’ height of the proposed buildings which would then be the tallest buildings on the west side of St. Helena (and honestly throughout most of town!). It makes absolutely no sense to build such a large development in this small of a space which would ruin the quiet charm of this neighborhood.

I urge the City Council to prioritize the safety of children, the wellbeing of residents, and emergency preparedness when reviewing this proposal. I strongly request that the Council reject this development and seek alternatives that protect the integrity, safety, and livability of our community. I appreciate the review of other spots around town that this housing element requirement could go – but I strongly believe that there must be some other alternative than the current site 10. And the fact that the rezoning happened without any input or warning to all of us residents that surround the site really speaks volumes to how this has come about lately.

Thank you for your attention to this critical matter. I am available to provide further input or participate in discussions regarding this proposal.

Sincerely,
Brittany Anderson
1106 Valley View Street
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From: Erin Przybylinski
To: Public Comment
Cc: Peter Przybylinski
Subject: Comments for tonight’s meeting
Date: Tuesday, September 23, 2025 1:35:18 AM
Dear Council Members,
As we will be unable to attend tonight’s meeting, we wanted to go on record to reiterate our disappointment that site 10 was rezoned as a high density site. It’s hard to fathom how as individual homeowners any small improvement project is held to great scrutiny, but now three, three story buildings are permitted in the middle of a predominantly single story home development.

If there is any chance at all that the height and number of units for this much needed housing could be curbed, we would encourage you to pursue it at all costs. The long term community feel would be worth it for all residents.

As an additional note, street parking on southern Hudson is a already at a premium, and there is quite a blind spot exiting Hudson Ave to spring street, so please ensure the developer is providing for a minimum of 156 parking spots on site. Traffic patterns right in front of site 10 are quite intense during school drop-off/pickup times, so this safety situation will need to be addressed as well.

Thank you for your time,
Erin and Pete Przybylinski
1184 Hudson Ave
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From: Stefano Particelli
To: Public Comment
Subject: Spring street development
Date: Monday, September 22, 2025 8:57:17 PM
Good evening Councilmembers,
The staff report's conclusion that Site 10 is the only viable option contradicts state housing law. Owner disinterest, existing uses, or partial floodplain designations are not valid reasons to exclude parcels from the Housing Element inventory.

HCD guidance allows combining smaller sites to meet lower-income housing capacity. The report itself notes that Site L could yield 29 units if rezoned. When paired with other underutilized parcels, the 44-unit requirement can be met without overconcentrating density on one site.

Focusing the project on Spring Street also raises concerns about wildfire evacuation and infrastructure. For these reasons, Site 10 should not be considered the only option, and the City should pursue a lawful amendment by process to identify alternatives.

Thank you.

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From: Jessica Hague
To: Public Comment
Cc: Jessica Hague
Subject: Public Comment: Agenda Item 13.2 - Sept 23 2025 Meeting Date: Tuesday, September 23, 2025 2:50:02 PM
To Mayor Paul Dohring, Vice Mayor Michelle Deasy, City Council Members: Aaron Barak, Kate Spadarotto, Billy Summers,
I am writing to express my extreme disappointment in the city’s process to evaluate the viability of other sites, which was promised to the significant number of residents, like me, who opposed the rezoning of site 10 to high density last year. Unsafe evacuation routes, inadequate sewer infrastructure, lack of ADA compliant sidewalks and crosswalks are among the issues requiring consideration of this Council before finalizing any decision on site 10.

Having reviewed the developer’s plans for site 10, the density proposed on this site is simply unsafe for the neighborhood. With one driveway to access the development, evacuation of 120++ cars onto Spring Street will put all of the residents in the surrounding Hudson Avenue, Valley View, Sylvaner, and White Sulphur Springs neighborhoods in jeopardy in the event of a wildfire.

Concerns over the lack of adequate sewer infrastructure on Spring Street was raised last year by a resident who lives on Spring Street directly across from site 10.

The neighborhood lacks safe and ADA compliant sidewalks and crosswalks on Spring Street between Valley View and North Crane Avenue.

Obstructed views by heritage oak trees for vehicles traveling on south Hudson Avenue onto Spring Street increases risks of significant traffic congestion particularly at peak commute and school transit times, and vehicle and pedestrian accidents.

As a longtime resident of Hudson Avenue, I urge the council to look at meeting HUD’s affordable housing requirement through the combination of sites F, I, J, K and/or M.

Site L will most assuredly receive the same upzoning opposition as site 10.

Respectfully,
Jessica Hague
1154 Hudson Avenue Homeowner
Agenda Item #13.2.

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Agenda Item #13.2.

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From: Patti Antonaccio
To: Public Comment
Subject: Spring Street Development
Date: Tuesday, September 23, 2025 2:26:39 PM
Dear City of St. Helena,
Please reconsider zoning this site to medium density which is in keeping with the neighborhood. Three story units will tower over the 1 story homes next to it and will be a blight. Two stories would be much better plus there needs to be landscaping barriers between the one story homes and the more than one story development! This a travesty and I believe will hurt tourism, new residents will not want to live here or existing residents will want to leave St Helena.

Thank you for your time and consideration.

Patti
Patti Antonaccio
Travel Advisor
St Helena Travel
1100 Hudson Ave.

St. Helena, CA 94574
707 963 8464
[email protected]
CST#2011247-10
Agenda Item #13.2.

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From: Tina
To: Cindy Tzafopoulos; Public Comment
Cc: David Prueter; Thomas DeGeorgio; Max Angell
Subject: Follow-up on Site #10 and Housing Element Concerns Date: Tuesday, September 23, 2025 2:47:53 PM
Ladies and Gentlemen,
I am following up on my correspondence from last year regarding Site #10 and the proposed 78-unit lower/mid-income housing development. I understand that City staff had recently explored alternative parcels, yet the study appears to have focused exclusively on areas west of Highway 29.

I’m unsure why this limitation was imposed, as I believe there are potential parcels east of Highway 29 that could be suitable for affordable housing development.

If Site #10 remains the only proposed location for this project, I urge the City to recognize its responsibility in mitigating potential negative impacts on the surrounding neighborhood and to ensure that the developer meets all standards that prevent undue hardship on existing residents. Specifically, I would like to raise the following concerns:

1. Impact on Property Value
The introduction of a high-density development will likely impact property values in the surrounding area. The City and the builder should take responsibility for any loss in property value and explore appropriate compensation or mitigation measures.

2. Noise and Quality of Life
Our neighborhood is known for its tranquility. The increase in density and associated activity will significantly raise noise levels. The City should require the developer to install effective sound barriers to protect the peaceful environment of existing homes.

3. Brown Water Issues
The issue of brown water remains unresolved in our area. Prospective residents should be fully informed of this situation, and steps must be taken to address and rectify the underlying problems before any occupancy.

Agenda Item #13.2.

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4. Water Supply and Pressure
We have already experienced periods of low water pressure. With the addition of 78 units, this will only worsen. The City should require the developer to fund and construct a new water supply line to support increased demand and improve water quality.

5. Emergency Evacuation & Fire Safety
Our neighborhood was dangerously close to the 2020 wildfires, with nearby residents evacuated. Increasing population density in this area will pose a serious risk during emergencies. The City should consider constructing a new through-street to facilitate emergency access and evacuation.

6. Traffic and Parking Congestion
Street parking is already heavily used. The addition of potentially 100 or more vehicles will strain the area further. The City should require the builder to include adequate off-street parking, such as a parking garage, to prevent overflow onto residential streets.

7. Public Safety & Crime Prevention
Our area currently enjoys a low crime rate. However, a significant increase in rental units may change the dynamics. The City must assess the need for additional police resources to ensure public safety is maintained.

8. Hospital and Medical Services Capacity
Local healthcare facilities are already operating near capacity. With a growing population, access to timely medical services could be affected. The City should work with healthcare providers to evaluate and address future capacity needs.

9. Energy Demand and Reliability
We experience periodic power outages, and additional demand could worsen the situation. PG&E must provide a plan to ensure reliable service as the population grows. Additionally, the burden of higher time-of-use electricity rates (4–9 PM) remains a concern.

In closing, while I support responsible housing development, I believe it must be balanced with the well-being of current residents. I respectfully ask the City to address these concerns before proceeding with the approval or Agenda Item #13.2.

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development of Site #10.

Thank you for your time and attention.

Sincerely,
Tina & Tom
1180 Valley View Street
713-907-9667
Sent from my iPhone
On Apr 22, 2024, at 3:02 PM, Cindy Tzafopoulos
<[email protected]> wrote:

Received.

From: Tina DeGeorgio <[email protected]>
Sent: Monday, April 22, 2024 1:59 PM
To: Planning Commission <[email protected]>; Maya DeRosa <[email protected]>; cityclerk <[email protected]>; Paul Dohring <[email protected]>; Eric Hall <[email protected]>; [email protected]; Billy Summers <[email protected]>; Patrick Kenealy <[email protected]>
Cc: Thomas DeGeorgio <[email protected]>
Subject: [External] Rejection of Spring Street site 10 Rezoning Importance: High
Dear City Council,
I humbly would like to renew my request to reject High Density development on site 10. I submit this request, in addition to all my prior requests (dated March 5th and March 24th). I have been a resident owner, in St. Helena, for nearly 4 years. I feel like my voice is not being heard. The reasons why we purchased our home are many. While too many to individually list here, many can be found on the City’s web page. A small friendly family oriented community, with rich history. Most importantly the City has protected the Agenda Item #13.2.

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beauty and tranquility of our 5+ square acre city by imposing building height restrictions, not allowed big box stores and promoting the wine industry. Our leaders have always acted with a long term view of the future.

We do not support the High Density development on site 10. This effort is a short a sighted plan to solve much bigger issue. I believe that if proper due diligence and proper notice is made to interested parties better options would come to the fore. Attempts to solve the Housing Element issue with a hastily developed and contorted plan is destined for failure. A high density development on site 10 would negatively impact our community in terms of traffic and street over crowding. Already limited parking would get much worse. An already taxed water and sewer system would most certainly fail or need replacement. We are currently experiencing brown water issues and power outages. They are still not resolved. Health and safety issues such as fire evacuation and public safety would certainly be at risk.

Our city was founded in the 1800’s, it has prospered since then, lets not take steps backwards. There are alternative solutions that fit with the vision of our forefathers and provide a long term solution, we just need to embrace them.

It is worth taking the time to explore these options going forward when redoing the Housing Element.

Finally, I would like to thank you for your service to our beautiful community.

I understand the heavy burden that comes with your role. I stand ready to support a plan that supports all of our 5,000 plus residents now and into the future.

Tina & Tom DeGeorgio
1180 Valley View Street
St. Helena, CA
Agenda Item #13.2.

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From: Mcknz
To: Public Comment
Subject: Site 10 rezone
Date: Tuesday, September 23, 2025 4:18:01 PM
Unfortunately, we are unable to be at the meeting tonight however, I would like to strongly suggest that the city Council Direct further site reviews in regards to maintaining medium density on site 10 and finding additional density to meet our quotas required by the state on other parcels.

High density projects will cause numerous issues within our community.

The staff report shows lack of effort in trying to solve the situation the State has created. There are means, without mass housing being situated in the middle of a small home community, To solve this issue. Other places on the west side that we should be able to meet the quota and keep the zoning on site 10 at medium density.

We must preserve the quality of living in Saint Helena, and I think we can do it and still have viable options for housing for our workers and our low income individuals.

Multi story mass housing also will not solve our senior citizens housing needs. It will only accommodate young able body people.

Thanks,
Laura Keir
1094 Valley View St
St Helena
Agenda Item #13.2.

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PUBLIC COMMENT FOR THE SEPTEMBER 23, 2025 CITY COUNCIL
I'm Pat Kenealy, and I live on Spring Street
I was part of the City Council that assigned City staff to find an alternative to Site 10.

Here the Council is again, a year later, in receipt of a "nothing can be done" response from the Planning Department and a hired consultant.

The report contains no creative thinking on breaking out of the legal box they described back then, and no thinking "outside the box" on how solve this problem for the citizens.

It's very disappointing, and valuable time has passed. Once again the citizens are being told only “we notified you”; once again the citizens are learning that the Planning Department not is pro-actively looking out for them.

So here are three hopefully-helpful suggestions for what to do now. I suggest:

First and most importantly, the City Council should NOT accept the report tonight. The matter needs further analysis led by a higher level of City leadership. Don't let the accepting of the report become a tacit approval of its findings.

It's the Council's EXACT ROLE to push back when needed.

Second suggestion: the City Council should be explicit on who will lead on this issue:

1. The Mayor?

2. The City Council or one of its members?

3. The Planning Commission?

4. The City Manager?

5. The City Attorney?

6. The City Planning Department Head again?

7. A better consultant?
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SOMEHOW, THE COMBINATION OF ALL THESE FOLKS IS NOT

PROTECTING US FROM THE CREEPING SUBURBANIZATION OF OUR
SEMI-RURAL TOWN.

We need a Council Point Person on Site 10, perhaps the Mayor himself.

Finally, the Council should instruct City staff to SUPPORT the citizens in exploring new alternatives, not just notify the citizens and move on.

Possibilities still exist:

1. Swapping Parcel 10 for some other City-owned parcel

2. Expanding the search for alternative sites to ALL parts of Saint Helena. That's not what the Sacramento prefers but I believe the regulators would compromise on this issue if pushed.

3. Working with the City Attorney to buy the concerned parties time to explore alternatives. Now, more urgent real work must begin, but we’ll need time

4. Finding out what amount of money it would take to buy the parcel from the current owner

5. Engage directly, at a senior level with the current owner if he or she is a neighbor, and see if they will be flexible

6. Helping a collection of neighbors work together to buy some or all of the parcel. Throughout the US and the world there are pocket parks owned by abutting property owners. When
abutting properties include such rights, their values go way up.

7. Lobby Sacramento, and join the movement of California Cities opposing centralized housing mandates, and learn their best practices.

8. Refute some of the consultant’s misstatements about
availability of public transportation and actual availability of alternate sites

9. Find ways to work BEYOND the HCD process.

10. These are half just some ideas. I'm sure there are more

I'LL STOP THERE BUT THIS ISSUE HAS COME TO THE TOP OF THE AGENDA FOR GOOD REASON. I REMIND THE COUNCIL TO

REMEMBER THE VOTERS AND SEND THIS BACK TO THE STAFF FOR MORE WORK.

Agenda Item #13.2.

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St. Helena City CouncilSeptember 23, 2025

St. Helena City Council
September 23, 2025