St. Helena City Council
February 10, 2026






 


 
 






 













!"#$
%#

&'(
)(*
+#

&,!("
Agenda Item #11.1.




 

 

  

 

 



 

!
"#
$
%&"$ !"'()"*)+", !%"'-.)
/




01 

 





 1
 

  




 


12
3 2



1
2
02   3
1
 / 





4




 2 5  1

 

 
 2






1
1
1



2

 4
 


 67

 1
5

48 9 2 
1 25 :;1



 
 


;
 3



1




1
/ <



 


 
1


1
2
23
1
< 3:=
 >

Agenda Item #11.1.


















 
  







 


 

  

 







 








 





 





 


 











 











 








 











 












!"
 




#$%




 "&'
























 

 


"  


















 

(


#)$*

 



 +








  ,

 





 








 














 






)#

Agenda Item #11.1.

















 


  
 


!" #$%&%' ( #)
%
Agenda Item #11.1.










 
















!"#
$%&'!(&!)*+!,+-!.& !)/$+% 0

1

1






2

3
 


 1







 2343

5



2










6

1

7








1

  


1

8









1

9





1
3








321
 31
3
3







 :

3;







3



 


3




2



3




 




 0
<
=



1

4


3

3


3




Agenda Item #11.1.


 














































































































 











 ! 


"# 






# 






#$%




 !







#
$ 







































  ! 
 



$

 &





















 !
#

$

!'
#





#


#






 
  

$ ()*+,-./01+21/3-)45367+-681-3)/0+9-1*+:1;+,/06<6;+./7+=;.46<<6+(.93+9-1*+>6?+@1-AB+,<.)/+C6<.D5E-)F-6+./7 G)-;36/+>1H6;+21/3-)45367+-6;6.-2IB JKLMNOPQRSNTUOVSWXXNWTMQ+-681-3;+1/+/.3)1/.<+;31-)6;+.2-1;;+3I6+Y/)367+Z3.36;+?)3I+.+9125;+1/+2-)*)/.< [5;3)26B+\6+);+9-1*+58;3.36+>6?+@1-AB ]K^URSP^UX+);+.+/.3)1/.<+-681-36-+91-+(I6+()*6;_+4.;67+)/+Z6.33<6B ,+`6-;)1/+19+3I);+.-3)2<6+.886.-;+)/+8-)/3+1/+_+Z623)1/+,_+a.06+bc+19+3I6+>6?+@1-A+67)3)1/+?)3I+3I6+I6.7<)/6d+,/+e`.25.3)1/+C);.;[email protected]; )/+3I6+f.A)/0 Agenda Item #11.1.

On housing and zoning code, my observations
Dear Mayor Dohring, Vice Mayor Deasey, Councilmembers, and Staff, (My views as a resident, not in any other role)
I have several zoning code items I intend to raise for discussion; however, I would like to begin with what I believe is the most pressing issue, as it directly affects our ability to meet our RHNA obligations and the stated goals of our General Plan.

This concern arose from a meeting I was asked to attend by Kelso, developer’s representative for the Spring Grove project, prior to the Planning Commission hearing. I attended only to ask clarifying questions. One response, in particular, raised significant concern.

Inclusionary Housing and AMI Targeting
Spring Grove proposes 41 units, of which 8 are designated as affordable. These 8 units are split evenly:
• 4 units at 100% AMI
• 4 units at 120% AMI
I asked why none of the affordable units were targeted at 80% AMI or below. Kelso stated that the zoning code does not require it. This interpretation was later confirmed by consulting staff, who directed me to the Inclusionary Housing Requirements section of the zoning code and noted that the code is more lenient for owner-occupied (for-sale) projects than for rentals. See code sections at the end referenced.

As currently written, the code:
• Requires half of the inclusionary units to be at 100% AMI • Allows the other half to be:
o 80% AMI only if the developer elects to do so (with an incentive), or o 120% AMI, with no requirement to provide lower-income units In other words, for owner-occupied projects, there is no requirement to provide units at 80% AMI or below.

Conflict with RHNA and Housing Element Goals
According to our Housing Element, 163 of the 256 RHNA units required by 2031 fall within the Very Low and Low Income categories—approximately 64% of our total obligation.

Yet only 20% of units in most housing developments are required to be affordable, and for owner-occupied projects, those affordable units may entirely avoid the 50–80% AMI categories.

The Spring Grove project is a clear example:
• 41 total units
• Zero units at 50–80% AMI
Given limited sites and a five-year timeline, I do not see a realistic path to achieving 163 lower-income units without:
• Significant philanthropic intervention, or
• Meaningful amendments to the zoning code to better target these income levels ADUs and Missed Opportunities
State law allows ADUs to be counted across income categories, which can help distribute RHNA obligations more equitably. ABAG’s summary of this approach is linked here for reference.

However, St. Helena’s zoning code appears to:
• Exclude ADUs from affordable housing counts altogether, SEE CODE Section 17.30.030A. • Count them only toward moderate income, where we already have minimal RHNA obligations (only 26 units) (I don’t see this in writing in the zoning code, this was a verbal confirmation from staff) This is particularly concerning because ADUs are one of the few housing types that:
• Can be built incrementally
• Do not require large redevelopment sites
• Can naturally serve lower-income households
Local ADU Regulations as a Deterrent
The argument has been made that ADUs in St. Helena are “not typically rented.” I would suggest that this may be the result of our own regulatory framework, including:

1. Requiring a separate water hookup, which is financially prohibitive. Also not a state mandate.

Agenda Item #11.1.

2. Limiting ADU size below what state law allows, reducing sizes of families that might need more space.

3. Imposing architectural requirements that reduce livability, including: SEE ADU ordinance no 2025-002 o Mandatory stylistic matching to the primary residence o Window and door restrictions within 30 feet of property lines that require clerestory or obscured glazing, effectively eliminating views and daylight
These requirements make ADUs more expensive, less livable, and less appealing—particularly for seniors, caregivers, or local workers.

Additionally, family-occupied ADUs (e.g., for parents or adult children) may not generate documented rent, yet still provide essential housing. Discounting these uses ignores real housing outcomes.

Broader Implications
What concerns me most is that our current approach appears to:
• Enable development on valuable sites “by right” that won’t achieve the intended desire for affordable housing, Spring Grove as example.
• Maximize market-rate production while meeting only the minimum affordable requirements (conflicts with general plan)
• Fall short of achieving our lower-income housing goals • Require future upzoning or site identification, leading to overbuilding and infrastructure strain There are also fiscal implications. In communities across California, nearby property values have declined following similar development patterns, resulting in reassessments and reduced property tax revenue, lower tax base.

General Plan Consistency
This approach appears inconsistent with our General Plan, particularly the Growth Management Policies (GP p.64), which states to limit approval of market rate residential development. See image below.

Closing
I believe we are undermining our own housing goals through the way our zoning code is written and applied. I respectfully request that Council and staff closely examine:
• AMI targeting requirements for owner-occupied projects • The treatment of ADUs in RHNA accounting
• Local ADU regulations that exceed or conflict with state intent I appreciate the opportunity to raise these concerns and look forward to continued discussion.

Sincerely,
Michelle Covell
SEE below
From Staff Presentation Aug 19th, special joint meeting Agenda Item #11.1.

From the Housing Element.

From the zoning code – see the red circled word, IF
Agenda Item #11.1.

Zoning code – ADUS do not count towards affordable units.

Association of Bay Area Governments – ABAG
Agenda Item #11.1.

https://abag.ca.gov/sites/default/files/documents/2022-03/ADUs-Projections-Memo-final.pdf (page 64, Growth Management Policies – General plan 2040 St Helena) https://www.cityofsthelena.gov/DocumentCenter/View/5275/ADU-Code-Update-2025-PDF ADU ORDINANCE 2025 -002
Lisa Wise Consulting doc
Agenda Item #11.1.

Agenda Item #11.1.

On math: A thought on numerators and denominators.

My brain woke me up again in the middle of the night. It asked me a simple, intriguing queson that sent my brain on a spree.

At a planning commission this month, a queson from a resident triggered a discussion, and a consulng planner said something like: by lowering the denominator, the percentage of the density is actually higher. That phrase stuck in my brain—hence the queson it asked.

In a percentage, what do the numerator and denominator represent conceptually, and how can you affect a be"er outcome? Since the piece I wrote on the zoning code, and thinking about that 163 over 256, lower income 50–80% AMI over median/moderate 100/120% AMI, respecvely, the queson that sll remains for me is 256 over X. What is X, the total amount of housing overall that we will end up building in order to achieve the 256 units required by RHNA?
Since the code language on owner-occupied units doesn’t even require 50–80% AMI units, and that represents 163 of the 256, there is no real math problem that is calculable to figure out X.

I’m not a mathemacian. Sure, I liked math in school, but most of it is gone these days. I wouldn’t know what to do with a squiggly-line equaon if my life depended on it, even though back then I enjoyed solving those kinds of problems. So right now, I can only work in basic, conceptual math on this word problem: how many total units will we need to build to achieve RHNA?
This also brings up in my mind, the concept of efficiency. For example, total efficiency would be if we built 256 over 256 = 100%, and had a direct approach to achieving the numbers. Least negave impact on the system and infrastructure.

Every percentage has two parts: a numerator and a denominator. The numerator is the thing you’re counng. The denominator is the total you’re measuring it against. And the percentage is just the rao between the two. Here’s the thing: changing the numerator and changing the denominator are not the same.

When you change the numerator, you’re changing the thing itself. In the case of housing, this is the goal or target number required by RHNA. When you increase that numerator, you’re increasing efficiency. This takes effort, and it ma"ers.

When you change the denominator, you’re changing the frame. The pool is ge@ng bigger or smaller, and the percentage changes, but the underlying outcome might not change at all. There are ways to control the denominator, and it changes the way things are measured, and I think this concept needs further analysis.

Here’s an example:
10/100 = 10%.
20/200 = 10%.

In a small town, with limited resources like land, water, sewer capacity, and road widths, there is a significant impact between those two raos, even though they have the same percentage.

What I see that is broken right now is that the zoning code for owner-occupied units does not have any requirement for the 163 units required out of the 256, and this directly impacts the efficiency of achieving the goal.

There has to be a plan in place to target that number directly. Whether it is through Housing Impact Fees (HIF) being collected locally or through the Napa County HIF, there needs to be a be"er strategy.

If we were doing a very straighorward calculaon:
20% of X = 256
X = 1,280.

Since the 20% in the owner-occupied units does not include the 50–80% AMI category, we would need to hope there is an alternate plan in place to achieve the 163 units. Perhaps it will be Our Town St. Helena that contributes to that directly, through HIFs and philanthropy. Perhaps fundraising is the soluon.

Agenda Item #11.1.

However, for me right now, without knowing the direct strategy to efficiently achieve the target, my brain is unfortunately worried about the denominator. My brain says the best outcome for our town would be to hit the required RHNA number with the least amount of extra market-rate units—the housing our town doesn’t need more of and that will only add strain to our resources. So the framework, the denominator, is really important to control.

We appear to have either not counted ADUs at all or counted them toward a category that doesn’t need help—the moderate-income 26/256. This is one way we are shoong ourselves in the foot with the denominator. The other way is by not wring into the zoning code a direct effect on the 50–80% AMI categories, affecng the numerator.

Without understanding the mechanisms, it could easily be 256/3,000. Or ? We have designated 12 sites as by-right, and there are targeted numbers per site. However, if each project doesn’t hit those targets, we will need to find other sites to achieve the numbers. What is the back-up plan? At the end of the day, the numerator is our target. The denominator is what we need to try to control. The St.

Helena General Plan wants the denominator as low as possible. There are people out there seeing numbers being added to the numerator and not caring what happens to the denominator. The denominator is what our reality will be, the side effect of this mandate on our town, what we need to put guardrails on.

Here’s the scky wicket. It boils down to the math, and the codes and laws we have to follow. From what I can tell, the developers know how to get their math to pencil out. They know the codes and the mechanisms to work within, and the laws are now wri"en to protect them. This is purely an observaon—and kudos to them for figuring it out.

What I want to know is: who’s doing the math for our town? Because I’d like to see the work. I’d like to see how the math pencils out for this town, and maybe even check it, to make sure the outcome is by design, not by happenstance.

Anyone else out there curious about seeing the work?
Agenda Item #11.1.

This is not a Nimby-Yimby situation.

Michelle Liu Covell
Jan 28, 2026
Please watch this video - noted times.

Tuesday, December 2, 2025 PC hearing video
https://sthelena.civicweb.net/document/275629/?splitscreen=true&media=true Watch at 1 hour 55 minutes, where Mary Stephenson speaks. She is a housing advocate for decades. Hear what she says – too long to transcribe.

Watch at 2 hours 21 minutes. Autumn Anderson, affordable housing advocate, Yimby, expresses her frustration. “I share the same concerns about affordability and as a commissioner who was on the housing element subcommittee, we worked really hard to rezone to make it feasible to build all of the housing that we are required to build in our RHNA allocation. That doesn’t mean we have any control over whether or not it gets built, and that’s really frustrating. And I would like to see all of the parcels we’ve upzoned actually be used in the way that we intended, when we upzoned them, and actually have them supply housing that our local workforce can live in. I don’t think this housing (Spring Grove Project) is that. I understand its all legal and by-right, but it doesn’t accomplish what we need it to accomplish.”
Before this is framed as just another NIMBY situation, I want to point out that two affordable housing advocates— one of whom is a YIMBY, to my knowledge—have both said that this project does not serve the intent of affordable housing.

Why this matters:

We have a limited number of sites. There is no cap on these types of projects, meaning all 12 sites, and potentially more, could be developed this way. The result would be a significant amount of housing, but none of it truly affordable. For those who support genuinely affordable homes, it’s important to recognize that laws written to encourage affordable housing are, in cases like this, failing to meet their intent.

If the goal is real affordable housing, this project is not a good example. As affordable housing advocates have expressed here, even with these laws in place and projects like this being approved, we can still miss the opportunity to create housing that is truly affordable.

This raises a broader challenge for our community. Can we move past the NIMBY–YIMBY framing and take a more thoughtful look at whether we are actually achieving our goals? Can we acknowledge that, at times, we need to be more intentional than the laws themselves and find better ways to deliver real affordable housing? There is a real risk that we approve projects that do not serve the intended purpose. In doing so, we may use up valuable and limited resources—land, water, sewer capacity—without providing affordable homes for the workforce and families needed to sustain the community we say we want to build.

So, if your initial reaction is that this is simply another NIMBY argument, I encourage you to take a closer look at the details and the materials. A deeper review may show that raising these concerns is not opposition to affordable housing, but an effort to make sure we don’t miss another important opportunity to get it right.

Sincerely.

Michelle Liu Covell
Spoken as a resident and not in any other role
Agenda Item #11.1.

Please take a look at the two plans below.

Public comment - as resident 1.27.26 City Council
Michelle Liu Covell
This proposal includes 41 for-sale units. Of those, 8 are considered “affordable” under the current code: 4 at 100% AMI and 4 at 120% AMI. The remaining units are market rate and are expected to sell in the low millions.

It’s also important to note that buyers of the affordable units will s1ll be responsible for HOA fees, u1li1es, and other ongoing costs. Those expenses are not subsidized; the only affordability component is the ini1al sale price of the unit.

The project is proposed on a 2.53-acre site.
___________________________________________________________ This proposal below includes 39 rental units, all of which are 100% affordable, and is being developed by the nonprofit Our Town St. Helena. The project is located on a 1.75-acre site.

Agenda Item #11.1.

The development includes apartments of various sizes, along with a central community space that provides shared laundry facili1es, common areas, a kitchen, and a designated teen space. The buildings are centered around a play area, crea1ng an environment designed to support residents and families.

This approach focuses not only on housing affordability, but also on crea1ng the condi1ons that help people and families succeed.

Both of these projects are located here in St. Helena.

One is being developed by a nonprofit.

One is being developed as a for-profit project.

The conversa1on we are trying to have is about finding the smartest way to work within the state’s one-size-fits-all laws while s1ll mee1ng the specific needs of our community. That requires listening to one another and working together as a team, as Billy men1oned.

Agenda Item #11.1.

This is not about classism or eli1sm, and it’s not a NIMBY–YIMBY debate. It’s about seAng our town up for longterm success and being thoughBul with our limited resources.

It’s also about seAng up the people who invest in and choose to live here for success, alongside those who need affordable housing. As public servants, we have a responsibility to consider the en1re community and to come to each mee1ng with an open mind.

I worry that, at 1mes, people are arriving at mee1ngs with their posi1ons already decided. If we want the best outcomes for St. Helena, we owe it to the community to stay open, curious, and willing to engage with the full picture.

This is not a Nimby-Yimby situa1on. With limited resources, land, water/sewer etc, we have to be wise about the projects that are proposed, and to understand what we need to do with what we have, the General Plan, Zoning Codes, etc to make the most out of each site to serve what this town really needs. There is a lot at risk.

Agenda Item #11.1.

From: Katie Somple
To: Public Comment
Subject: Cumulative Risk Governance
Date: Thursday, February 5, 2026 5:03:45 PM
St Helena Council, Planning Commission, and Staff:

I am in 100% in agreement with the recent letter resident Michelle Covell wrote to you, and to state government officials raising the red flag regarding non-cumulative governing of St Helena. From scarcity of resources (immutable fact) and fire incident evacuation options.

I realize St Helena, like many other small, rural towns in Califirnia, has been placed under undue pressure from a state mandate to build affordable housing, but what wgat have allowed to take place instead is an excuse to build market rate homes, not affordable housing. St Helena needs more million-dollar houses like swiss cheese needs more holes. As it stands out infrastructure cries for a moratorium on expansion until we can repair, replace and replenish the resources that EXISTING residents and businesses need and pay for ( through the nose, mind you). The housing projects you've approved fly in the face of reasonable and responsible governing. Why on god’s earth would you do this? If we MUST expand housing on the broken back of insufficient resources to fulfill the state’s irresponsible, cookie-cutter mandate for AFFORDABLE housing, why have you succumbed to undesirable projects that ‘technically’ tick off the state’s checklist without truly fulfilling the very real need for affordable housing? This is not land stewardship, it’s a manipulative loophole in response to the state’s overt blackmail. Please enlighten me. What I’m missing in this political board game?
Thank you for considering my concerns and observations. message from: Katie Somple
Agenda Item #11.1.

From: Aña Ramirez
To: Public Comment
Subject: Support housing in St Helena
Date: Friday, February 6, 2026 1:10:04 PM
City Council of St Helena,
I’ve never written a letter like this before, but I felt like I had to after I saw a Gen H insta reel about a new housing project in your town. I just wanted to say that I support it.

I’ve loved your town since I was a kid. I never got to live there, but I worked on Main Street when I was in high school. I was a server. On my breaks I would walk around town and always wished I could live there someday I also thought it was cool you had a bar named after me . But that was never really possible. When I heard about this project near where I used to walk around, and that it would include some affordable homes, it honestly made me excited.

My parents came to Napa Valley as immigrants to work in the vineyards. They didn’t have much, but they stayed because they loved it here and believed that if you worked hard you could build a life. I grew up here, went to school here, and now I’m raising my own kids here. I want them to grow up in the same Valley that raised me. But every year it feels harder to see how that’s going to work without more housing.

My husband works, I work, and we still feel like we’re just barely getting by. Buying a home feels impossible and even renting keeps getting more stressful. A lot of people act like the housing problem only matters in Napa, but that’s not true. It affects St. Helena, Yountville, all of it. These towns don’t work on their own. The people who clean, cook, teach, serve, and take care of things there mostly can’t afford to live there anymore. But with 8 affordable homes here, maybe they could.

I’m not asking for huge buildings or for towns to lose what makes them special. I’m just asking for housing in places that already make sense.

Sometimes it feels like certain towns are expected to stay exactly the same forever, even if that means regular families get pushed out. But communities are supposed to grow and make room for the next generation, not shut the door behind them.

I don’t live in St. Helena, but what happens there affects all of us in the valley. I hope the Council will support the Spring Grove project and support families who are just trying to stay in the place they’ve always called home.

Agenda Item #11.1.

Thank you for taking the time to read this.

Sincerely,
Aña Ramirez
Napa
Agenda Item #11.1.

From: Susan McWilliams
To: Public Comment
Subject: We support Michelle Liu’s letter
Date: Saturday, February 7, 2026 8:36:07 AM
She raises serious concerns about increased housing density and fire evacuation routes. Please address this critical issue.

Susan and Terry McWilliams
40-year residents of St. Helena
Sent from my iPhone
Agenda Item #11.1.

From: Daniel Hale
To: Andrew Bradley; Erika Opp; Paul Dohring; Michelle Deasy; Michelle Deasy; Aaron Barak; Aaron Barak; Billy Summers; Kate Spadarotto
Cc: Christopher Warner; sue
Subject: Spring Grove proposal path
Date: Saturday, February 7, 2026 11:43:52 AM
Andrew,
Please place the following comment on the agenda for the 10 FEB City Council meeting relating to the Spring Grove Proposal. Call text or email with any questions.

Thanks,
Daniel Hale
Saint Helena City Council Members,
I believe it is clear at this point that this proposal is burdened by fundamental and unresolved deficiencies.

In reviewing the process, it is difficult to understand how the project has advanced so far given the number of unanswered questions, unresolved issues, and significant gaps that remain.

These concerns range from General Plan, Zoning Code inconsistencies and incompatibilities that place HCD certification in question, as well as approaches to health and safety that rely on disregarding objective standards. Instead it depends on requiring extraordinary, and unrealistic levels of execution that meanwhile do not achieve compliance. That non-compliance suggests performance within the narrowest of margins and fails to account for known crisis behaviors, thereby placing citizens and our valued and capable fire professionals at greater risk than code is designed to mitigate.

It is evident that City Ventures submitted a largely standardized, off-the-shelf template, one designed to maximize buildout rather than respond meaningfully to the specific context, fabric, and regulatory framework, into which it seeks to insert itself. While profit is not inherently problematic, it cannot be the sole driver. While the state anticipates leveraging the clear opportunities that State mandates intend to provide, it does so with the clear understanding that State and Local objective health and safety standards remain constant and enforceable.

It is important to state clearly that the responsibility for submitting a project that complies with all applicable State and Local codes, as well as the General Plan, rests entirely with the applicant. While this is no small task, it remains the applicant's burden and obligation.

As acknowledged by both Planning staff and the applicant, SB 330 vests a project upon submission of a preliminary application and fixes the objective standards against which the project must be evaluated to those in effect at that time. This includes applicable State law and the City of St. Helena’s objective General Plan policies, zoning regulations, and applicable building and fire code provisions, including any duly adopted municipal amendments in effect at the time of preliminary application.

SB 330 does not excuse non-compliance, it freezes standards. It does not waive them. It establishes certainty by ensuring that the applicable rules do not change mid-stream. This framework is intended to Agenda Item #11.1.

provide predictability not only to developers, but also to City staff and residents throughout the review process.

Following submission, it is the municipality's responsibility to thoroughly review the application and identify any deficiencies. That review commonly occurs over multiple stages, and errors or oversights can arise on all sides, particularly when navigating nuanced local requirements. However, once deficiencies are identified, the obligation remains with the applicant to address them fully and to reconfigure the proposal as necessary to achieve compliance with all applicable objective standards.

On 21 Jan 2025 PC Meeting, both the applicant and City Staff were put on notice that the single access drive was a material deficiency in the proposal and fell outside of compliance to that reasoned and objective safety standard, as was the proposals gaping deficiencies in regard to flag lot standards (an objective standard that is built upon the legitimate concern to mitigate known hazards in bottleneck situations inherent in flag lot configurations).

A simple look back at the record of that Planning Commission meeting demonstrates a shining moment of checks and balances and scrutiny. Chair Ponte made clear the second access way was a material issue. He directed the applicant, staff and the City attorney to examine it and reconfigure proposal as needed to address this deficiency. He also demanded investigation into adherence to the strictly objective flag lot sections of municipal code. Anything that occurred moving the proposal forward, while pushing those material objective deficiencies aside raises startling concerns regarding the integrity of the review process and knowingly sets the entire proposal into a precarious position.

Once deficiencies are identified by credible sources, and the Spring Grove Proposal has multitudes, the obligation remains with the applicant to address them fully, correctly, and legally. Sure, the processes arduous, but denial of a project should not be interpreted as failure, nor as an endpoint. A denial simply provides an opportunity for reconsideration, learning, and the submission of an alternative proposal in a configuration that is compliant with all applicable objective State and Local Plans, Codes, and standards. It is clear that has not been done.

This process should not be driven by fear, blame, desperation, or expedience. It should be guided by a shared commitment to getting it right, without excuses, and by our responsibility as stewards of the community fabric we value and seek to protect, preserve and sustain. On that principle, I believe we can find common ground.

Sincerely,
Daniel Hale
On critical and correct path that serves the applicant, the State, Saint Helena staff, Planning Commission, City Council, and the Citizens of St Helena:

Subject: Spring Grove Proposal- Specific Adverse impacts to Public Health and Safety
St Helena City Council, and residents of St Helena,
On February 10, 2026, the St. Helena City Council will consider the Spring Grove Proposal.

Agenda Item #11.1.

The administrative record contains substantial evidence-derived from credible independent and “expert” sources-demonstrating that the Spring Grove Proposal violates numerous specific, objective, and mandatory provisions of State law, the City of St. Helena General Plan, and the St. Helena Municipal
Code.These conflicts are not discretionary, or interpretive.

They involve core, objective standards adopted for the express purpose of protecting public health, life safety, emergency access, and the City’s ability to provide essential public services.

The record further establishes that, as proposed, the project would result in a specific, adverse impact on public health and safety, as defined by Government Code §65589.5 (d) (2). This finding is not speculative. It is based on objective, quantifiable deficiencies and conflicts with adopted standards that were in effect at the time the application was deemed complete.

These impacts are significant, measurable, and directly attributable to the project's noncompliance with critical health and safety requirements, including but not limited to those governing emergency access, infrastructure capacity, and service provision. The administrative record demonstrates that no feasible mitigation measures exist that would satisfactorily avoid or reduce these impacts to an acceptable level. The only legally supportable means of avoiding the identified public health and safety impacts is denial of the project, Any alternate configuration, would reasonably require a new analysis, none of which has been prepared, provided,
considered or demonstrated to be in compliance.

State housing law does not compel cities to approve housing projects that violate objective health and safety standards, nor does it authorize or suggest that local governments ignore, waive, degrade, or disregard such standards. To the contrary, Government Code §65589.5 expressly preserves the authority, and the obligation of local agencies to deny or condition projects where a specific, adverse impact on public health or safety is supported by substantial evidence in the record.

Accordingly, approval of the Spring Grove Proposal at its proposed density would be inconsistent with State law, the Agenda Item #11.1.

City's General Plan, and the St. Helena Municipal Code, and would expose the City to legal vulnerability by disregarding mandatory, objective standards designed to protect life and safety. I urge the City Council to uphold its legal duty to enforce these standards and to reject any action or activity that would knowingly accept reduced or unsafe conditions. BY DENYING THE PROPOSAL, the Council will act in compliance with the law and fulfill its fundamental responsibility to protect the health and safety of the St. Helena community as I am convinced it is dedicated to do.

Thank you for your consideration,
Daniel Hale 1565 Pine Street Saint Helena
Agenda Item #11.1.

From: Wayne Leong
To: Andrew Bradley; City Clerk; Contact City Council
Subject: Public Comment – Spring Grove (PL24-065) – Zari Wildland Fire Analysis Date: Sunday, February 8, 2026 7:53:47 PM
Attachments: Spring Grove - Wildland Fire Analysis - 02.06.2026 (1).pdf Dear Mayor Dohring and Members of the City Council,
Please accept the attached Zari Consulting Group Phase 3 Wildland Fire Analysis for the Spring Grove project (PL24-065) as written public comment for the February 10, 2026 City Council meeting.

This is a professional fire-protection engineering analysis prepared under NFPA 1140 standards and the St. Helena Fire Code. It evaluates wildfire hazard, emergency access, and evacuation feasibility for the site and concludes that the project’s single access road and constrained layout create a quantifiable life-safety risk that cannot be mitigated by sprinklers or landscaping alone.

I respectfully urge the Council to review this report in advance of taking action, as it goes directly to the City’s obligation to evaluate public health and safety before approving the Vesting Tentative Map.

Respectfully submitted
Wayne Leong
www.leongarch.com + www.leong-leong.com
Napa Valley + New York
P.O. Box 2, St. Helena, CA 94574
t: (707) 963-5461
Agenda Item #11.1.

Zari Consulting Group, Inc | Fire Protection Engineers | Building Code Experts 755 Baywood Drive, 2nd Floor | Petaluma, CA | 94954
t +1.888.779.3397 | ZariCode.com

WILDLAND FIRE ANALYSIS
PHASE 3
Spring Grove
1447, 1505, and 1515 Spring Street
St. Helena, CA
February 6, 2026
© 2026 ALL RIGHTS RESERVED.

Agenda Item #11.1.

3rd Party Plan Review 1 February 6, 2026
Spring Grove ZCG No. 0126009

TABLE OF CONTENTS
Contents

1. INTRODUCTION 3

2. PROJECT DESCRIPTION 4
a) Existing Conditions 4
b) Proposed Construction 5
c) Construction and Infrastructure 6

3. WILDFIRE ASSESSMENT 7
a) Vegetation Density 7
b) Climate and Environmental 8
c) Topography and Slope 8
d) Wind Effects 9
e) Fire History 9
f) Adjacent Properties 10

4. EMERGENCY EVACUATION ANALYSIS 11
a) Site Evacuation Constraints 11
b) City of St. Helena Evacuation Protocols 11
c) Site Access (NFPA 1140 & SHMC 15.36.100) 12
d) Staging and Evacuation 12

5. CONSTRUCTION IN WILDFIRE PRONE AREAS 13
a) Construction 13
b) NIST Hazard Mitigation Methodology (HMM) for High Density 14

6. WILDFIRE MITIGATION 15
a) Defensible Space 15
b) Vegetation and Maintenance 16
Agenda Item #11.1.

Wildfire Analysis 2 February 6, 2026
Spring Grove ZCG No. 0126009
c) Irrigation Strategies 16
d) Relative Water Content (RWC) 16
e) Soil Maintenance 17
f) Tank and Hydrant Systems 17
g) Evacuation Road 17

7. CONCLUSION 18
Agenda Item #11.1.

Wildfire Analysis 3 February 6, 2026
Spring Grove ZCG No. 0126009

1. INTRODUCTION
Zari Consulting Group, Inc. (ZCG) has been retained to perform a detailed Wildland Fire Analysis for the proposed Spring Grove residential development located at 1447, 1505, and 1515 Spring Street in St. Helena. The primary objective of this analysis is to evaluate the wildfire hazards associated with the site’s specific location, its local topography, and its existing vegetative fuels.

This report serves as a fire protection engineering assessment, providing evidence-based recommendations intended to mitigate the risk of structure ignition and facilitate safe, efficient emergency operations in an area recognized as one of the most fire-prone regions in California.

This report utilizes the 2022 edition of NFPA 1140, Standard for Wildland Fire Protection, which serves as the primary consolidated national standard for fire management and infrastructure protection. Furthermore, this review incorporates the St. Helena Municipal Code (SHMC) Chapter

15.36, which adopts and amends the California Fire Code to address the unique geographical, climatic, and topographical challenges specific to the St. Helena area. Specifically, SHMC

15.36.010 provides foundational findings stating that response time and aggressive on-site fire mitigation, including the use of fire-resistant materials, and internal sprinklers, are critical to public health and safety.

As fire protection engineers, we emphasize that code compliance is the absolute minimum standard. However, in high-hazard zones, good engineering practices dictate that a more stringent approach to community safety is required. This analysis is built upon the "two-pronged approach" identified by the State Fire Marshal: aggressive fuel modification combined with exterior exposure protection. By addressing the property as a whole, this report seeks to provide a guideline for future Napa County developments. This involves shifting the perspective from merely defending a home to engineering a resilient community where structural integrity, landscape management, and evacuation protocols work together to increase life safety.

This analysis integrates the latest CAL FIRE Local Responsibility Area (LRA) Fire Hazard Severity Zone (FHSZ) maps. As of February 2025, CAL FIRE has reclassified significant portions of the Napa Valley floor between St. Helena and Calistoga as a Very High Wildfire Hazard Severity Zone.

This reclassification is a regulatory shift, highlighting the increased risk resulting from a combination of volatile vegetation, accumulated fuel loads, and changing climate factors. Data from First Street (Fire Factor) indicates that St. Helena possesses a "Major" risk of wildfire, with 99% of all properties (approximately 2,304 properties) having a significant risk of being affected by wildfire over the next 30 years. This report also factors in the 2024 Citywide Evacuation Drill data, USDA "Wildfire Risk to Communities" metrics, and current 2025 CAL FIRE incident data to ensure the development is prepared for modern and future emergency scenarios. Adhering only to minimum state standards in a region where fire behavior frequently overwhelms standard suppression resources is considered an operational risk to both life and property.

Agenda Item #11.1.

Wildfire Analysis 4 February 6, 2026
Spring Grove ZCG No. 0126009

2. PROJECT DESCRIPTION
a) Existing Conditions
The project site currently consists of three parcels totaling approximately 2.52 acres of land that has historically served as a lower-density residential and agricultural buffer. Currently, the site is developed with older single-family residences and associated wood-frame outbuildings. The existing environment is defined by a dense over-canopy of mature trees, unmaintained shrubbery, and a creek that runs along the southern boundary.

While the topography at the immediate street level is relatively flat, the site is situated at the absolute toe of the western foothills of the Mayacamas Mountains. This location acts as a natural catchment area for wind-driven embers and convective heat descending from the forested slopes above.

Existing fuel conditions reflect decades of growth, where accumulated surface litter and "ladder fuels" (shrubs and low branches that allow ground fires to climb into the canopy) have created an environment prone to high-intensity burning. The current vegetation includes a mix of invasive annual grasses and aging hardwood species that have not been subjected to a regular maintenance, resulting in dense vegetation that provides high-continuity fuels for a fire front.

Agenda Item #11.1.

Wildfire Analysis 5 February 6, 2026
Spring Grove ZCG No. 0126009
b) Proposed Construction
The proposed project involves the demolition of the existing residences to clear the way for a highdensity modern subdivision of 41 solar-powered, all-electric townhome-style condominiums (Buildings 1–6). This shift from three low-density homes to 41 high-density units represents a nearly 13-fold increase in the life load and an increase in the concentrated fuel load of the property. The design introduces modern architectural features such as "paseos" (narrow pedestrian corridors) and closely grouped multi-unit blocks that require specific fire-protection features.

The transition to all-electric living is a positive step for energy efficiency, but the concentration of solar panels and potentially on-site energy storage systems (ESS) adds a layer of complexity for fire department suppression efforts. Solar arrays can maintain dangerous voltages even after main power is cut, and high-density wood-frame construction combined with localized electrical hazards can lead to rapid fire growth scenarios. The close proximity of these buildings to one another creates a heightened risk of house to house fire spread via embers of plastic, fabric, and building materials.

In a high-wind event, the lack of separation between the six building groups can create a fire where it spreads from structure to structure through radiant heat and ember intrusion. This density (16.3 units/acre) essentially creates an fuel load within a wildland area, requiring the entire site to function as a singular unit.

Agenda Item #11.1.

Wildfire Analysis 6 February 6, 2026
Spring Grove ZCG No. 0126009
c) Construction and Infrastructure
The framework for the Spring Grove development is defined by its architectural features and the egress constraints of its high-density site plan. In a Very High Fire Hazard Severity Zone, the proposed construction materials and infrastructure determines the community fire protection features. The following parameters detail the proposed construction type, expected population density, and the infrastructure limitations that impact both fire mitigation and emergency response. • Construction Type: Type V-B (wood-frame, non-rated). This construction type relies on combustible structural members (2x4 or 2x6 framing). Without fire-rated exterior assemblies, the subdivision is vulnerable to external radiant heat and ember storms. In a Wildland Urban Interface (WUI) environment, Type V-B construction requires the highest level of external hardening to survive a wildfire passage. The use of wood-based structural elements means that once an ignition occurs, the structure itself becomes a fuel source for its neighbors.
• Occupancy: Group R-2 (Multi-family Residential).
• Estimated Population: Based on unit configurations of 3 to 4 bedrooms per unit, the site is projected to house between 112 and 143 residents at full occupancy. This population density increases the life load on the site's egress infrastructure. During an emergency, over 100 people and dozens of vehicles would be attempting to exit via a single road while fire engines are attempting to stage and deploy.
• Infrastructure Constraints: The site utilizes a restrictive "flag-pole" layout. A single 26- foot-wide access drive (Street A) provides the only ingress and egress for the entire development. This configuration creates a single point of failure for both evacuation and emergency response, where a single incident (fallen tree, blocked vehicle, or fire event at the entrance) could effectively isolate the entire community from emergency services.

Furthermore, the 93,518 square feet of building area requires a robust water supply that may exceed the capacity of a single-ended main, potentially leading to pressure drops when multiple hydrants are opened simultaneously.

Agenda Item #11.1.

Wildfire Analysis 7 February 6, 2026
Spring Grove ZCG No. 0126009

3. WILDFIRE ASSESSMENT
Common topographic fire hazards.(Left) Creeks can collect dry debris, increase heat, and funnel superheated air. (Middle) Wind can be directed over mountains. (Right) The steepness of a slope can significantly influence fire spread behavior. Images adapted from FEMA publications (2023). a) Vegetation Density
The vegetation in the St. Helena area consists of mixed-severity fire zones. According to recent satellite data (LiDAR) and regional surveys, the density profile in these high-risk zones typically breaks down as 57% grass (under 1 foot), 14% shrubs (1–15 feet), and 29% trees (over 15 feet). • Chaparral (Dense Shrublands): Present on the nearby hillsides, characterized by Manzanita and Chamise (1–15 ft tall). These are highly volatile fuels that form continuous, interwoven stands. These species contain flammable resins and oils that allow them to burn with extreme intensity even when green. By age 50, hard chaparral can consist of up to 50% dead, dry, and highly flammable material. This old growth chaparral is often described by firefighters as highly flammable due to its ability to generate 30-foot flames in moderate winds.
• Hardwood Forests/Oak Woodlands: Species such as California bay, madrone, and oak predominate. Due to decades of fire suppression, these forests are often 5–6 times denser than historic conditions. This overcrowding leads to excessive competition for water, higher tree mortality (aggravated by drought and beetle infestations), and a dangerous increase in surface fuels (leaf litter and downed branches).
• Ladder Fuels: LiDAR mapping focusing on the 1–4 meter zone indicates a significant presence of ladder fuels such as shrubs, vines, and lower branches that allow ground-level fires to climb into the tree canopy. This transitions a manageable surface fire into a highintensity crown fire that is difficult to suppress from the ground and produces continuous ember hazards.
• Riparian Fire Wick: The southern creek setback acts as a natural fuel wick. Per SHMC

15.36.010(A), the city finds that vegetation is a primary factor contributing to fire potential.

Contrary to some expectations, research from 2000–2018 shows that most structures destroyed in California wildfires were located in hardwood forests, woodlands, or shrublands rather than coniferous forests. The riparian zone provides a continuous, unmaintained fuel path that leads fire directly to the foundations of Buildings 1, 2, and 6.

Agenda Item #11.1.

Wildfire Analysis 8 February 6, 2026
Spring Grove ZCG No. 0126009
b) Climate and Environmental
St. Helena experiences a Mediterranean climate characterized by hot, dry summers and low fuel moisture. Data from First Street indicates a projected temperature increase of 1 to 4 degrees F over the next 30 years. These rising temperatures increase the rate of evaporation and the "Vapor Pressure Deficit" (VPD), causing soil and vegetation to dry more quickly and remain flammable for longer periods throughout the year.

Combined with "Diablo Winds" (hot, dry northeasterly winds), these conditions accelerate fire spread at rates that overwhelm standard suppression resources. Recent history shows that aboveaverage precipitation often leads to abnormal vegetation growth, resulting in even higher fuel loads during subsequent dry seasons (notably seen in 2017, 2018, and 2020). This cycle is a defining feature of the Napa Valley fire environment, making current fuel conditions highly deceptive. During these wind events, relative humidity can drop into the single digits, making every leaf and mulch bed on the property a potential ignition point for wind-blown embers. c) Topography and Slope
The site’s position at the base of a significant western slope is a major risk factor. Fire travels significantly faster uphill due to pre-heating of fuels but, nocturnal drainage flow of dry, cold air can also push fires downhill toward the valley floor with enhanced speed. NFPA 1140 Section 24.3.1.1 requires engineers to document the structure’s location in relation to topographical features like natural chimneys, ridges, saddles, or steep draws.

The Mayacamas Mountains to the west of the site act as a massive heat-sink and wind-funnel.

During a wildfire, these slopes project radiant heat and wind-driven embers directly toward the Spring Grove site. Because fire effectively doubles in speed for every 10-degree increase in slope, any fire starting on the ridges above St. Helena will reach the city limits in a fraction of the time anticipated on level ground. The project site sits in a natural catchment area where these topographical heat-flow patterns converge. This positioning means that structures are exposed to the maximum intensity of fire coming off the hills, as flames can reach their greatest length just as they hit the level ground of the valley floor.

Agenda Item #11.1.

Wildfire Analysis 9 February 6, 2026
Spring Grove ZCG No. 0126009
d) Wind Effects
Wind is the most influential variable in fire events in the Napa Valley. Historically, wind-driven embers have been documented traveling over 1 mile ahead of the actual fire front, igniting homes before the main fire front arrives. In a high-density development like Spring Grove, the narrow spacing between the six building groups can create a wind-tunnel or Venturi effect.

This accelerates the movement of embers through the community, forcing them into building crevices, vents, and eaves. This structure-to-structure ignition, where the heat from one burning building ignites its neighbor, is the leading cause of structure loss in urban WUI disasters. Without substantial separation or aggressive hardening, the 41 units act as a single, massive fuel block.

Additionally, wind patterns in the valley can shift rapidly, making evacuation routes that appear safe at the onset of a fire suddenly untenable due to thick smoke and blowing debris. e) Fire History
Overall, St. Helena is categorized as a high hazard area for wildfires. The City of St. Helena "Fire Resilience" website explicitly states that "residents live and work in a fire-prone area." According to Cal Fire Hazard Severity Zone map, the high severity zone is located 0.5 miles from the proposed Spring Grove site. Recent history confirms that Napa County remains under constant threat from wildfire ignitions, even during years with high rainfall. Modern fire events are becoming increasingly destructive due to urban expansion into wildland areas, with the 2020 fire season alone burning over 200,000 acres in Napa County alone.

Fires in Napa County:
• 2017 Tubbs Fire: Demonstrated the "urban conflagration" effect, where fires starting in wildlands penetrated city limits and destroyed homes in "lower risk" urban areas through massive ember storms in neighboring Sonoma County. 36,807 acres (57.5 sq. miles) • 2020 Glass Fire: Burned 40,000+ acres, causing destruction to wineries, resorts (such as Meadowood), and 308 homes in Napa County. It demonstrated that fires can jump the Napa River and Hwy 29 with ease, directly threatening the core of St. Helena.

Agenda Item #11.1.

Wildfire Analysis 10 February 6, 2026
Spring Grove ZCG No. 0126009
• 2025 Berry Fire: Occurred in the Knoxville Recreation Area. Managed by the CAL FIRE Sonoma-Lake-Napa Unit, it serves as a contemporary reminder of persistent ignition potential and the continuous demand on regional fire resources. • 2025 Pickett Fire: Napa County. The fire spread rapidly through terrain fueled dry vegetation typical in this area. Reaching a final size of 6,819 acres (10.3 sq. miles) • 2017 North Bay Fires (Atlas & Nuns): Part of a historic "Firestorm" that destroyed over 1,200 structures in Napa County alone. The Nuns fire burned largely in the Mayacamas Mountains west of the site.
• 2020 LNU Lightning Complex: The largest fire in Napa County history, burning approximately 165,000 acres within the county (about one-third of its total land area). It destroyed over 522 structures in Napa County, proving that lightning-caused conflagrations can overwhelm urban centers.
• 1964 Hanley Fire: A historic precursor following a nearly identical path to modern fires, confirming a multi-generational fire cycle driven by the region's unique geography.

Modern fires in Napa County are documented as more destructive than similarly sized historical fires. For example, the 2020 Glass Fire caused significantly more structural damage than historical events of similar acreage due to increased density in the Wildland Urban Interface (WUI). This trend highlights the inadequacy of traditional buffer zones when faced with modern climate stressors. f) Adjacent Properties
The site is surrounded by residential properties and open land with heavy fuel loads. The proposed density of 16.3 units/acre is significantly higher than the surrounding single-family dwellings, creating a localized high-intensity fuel source. Data from "Wildfire Risk to Communities" identifies St. Helena as having high susceptibility due to the wildfire likelihood and populated areas.

Per SHMC 15.36.100, Developments of one, two-family or multi family dwellings where the number of dwelling units exceeds thirty (30) shall be provided with two separate and approved fire apparatus access roads, and shall meet the requirements of Section D104.3. Reference sections below.

If a fire starts in the creek or an adjacent property, the lack of significant separation between the townhome blocks increases the likelihood that the entire 41-unit community will be involved simultaneously. This density turns a single structure fire into a multi-building conflagration that can quickly exhaust local fire department resources. Under NIST Scenario 3 (SSD less than 25 feet), adjacent structure ignition becomes the primary driver of structure loss, far outweighing the threat of direct wildland flame contact. The physical proximity of Building 5 to the southern boundary makes it a primary target for exposure from the creek corridor.

Agenda Item #11.1.

Wildfire Analysis 11 February 6, 2026
Spring Grove ZCG No. 0126009

4. EMERGENCY EVACUATION ANALYSIS
Emergency evacuation is the foremost life-safety priority for the Spring Grove development. The following analysis evaluates the proposed site plan against City of St. Helena emergency protocols and state/national standards.
a) Site Evacuation Constraints
The Spring Grove subdivision is currently designed with only one primary ingress and egress point (Street A). With an estimated population of 112 to 143 residents and approximately 82 to 93 vehicles, the internal roadway system is prone to total blockage during a egress event. The "flagpole" layout on Street A creates a bottleneck where a single abandoned vehicle, a fallen tree, or an active fire at the entrance would effectively trap the entire population of the 41-unit development.

The impact of a single-exit environment during a smoke-filled emergency often leads to panic driven blockages. In the event of a rapid-onset wildfire, the arrival of fire engines on Street A could simultaneously prevent residents from fleeing while responders are attempting to enter, creating an inherent risk.
b) City of St. Helena Evacuation Protocols
As demonstrated during the June 19, 2024, Citywide Evacuation Drill, St. Helena utilizes specific life-safety markers that the Spring Grove project must integrate:
• Hi-Lo Sirens: In an emergency, the Police Department will utilize "Hi-Lo" sirens to signal an immediate evacuation order. The narrow 26-foot throat of Street A must remain clear of all obstructions to allow these emergency vehicles to navigate while residents are attempting to exit.

Agenda Item #11.1.

Wildfire Analysis 12 February 6, 2026
Spring Grove ZCG No. 0126009
• Evacuation Tags: Residents must place designated tags on their homes or doors to signal that the premises have been cleared. This ensures that first responders do not waste critical minutes performing "primary searches" of structures while a fire front is approaching. • Evacuation Meeting Points: Residents of the Spring Grove development (located West of Main Street) are directed to evacuate to St. Helena Primary School at 1701 Grayson Avenue. The evacuation route involves navigating Spring Street to Main Street, a corridor that is historically prone to extreme congestion during regional events. The project must have a formal community evacuation plan that coordinates these actions for the additional population.
c) Site Access (NFPA 1140 & SHMC 15.36.100)
Good engineering practice and NFPA 1140 Table 11.1.4.1(a) mandate that any residential development exceeding 30 households must be equipped with at least two separate fire access routes. The St. Helena municipal code specifically amended the CFC to state: SHMC 15.36.100, Developments of one, two-family or multi family dwellings where the number of dwelling units exceeds thirty (30) shall be provided with two separate and approved fire apparatus access roads, and shall meet the requirements of Section D104.3.

Given the Very High Fire Hazard Severity Zone designation of the Napa Valley floor, a secondary access point is a non-negotiable life-safety requirement. A "remote" access point is defined as being located a distance away from the primary entrance equal to at least half the diagonal dimension of the property. The lack of a secondary exit is the single greatest life-safety liability in the current proposal.
(Left) Schematic illustrating common life safety concerns and stresses affecting the general public, first responders, and the overall transportation network during major wildfire events. (Right) Diagram illustrating the concept of providing separate and independent egress routes from a neighborhood to improve evacuation safety during wildfire conditions. d) Staging and Evacuation
During a rapid-fire event, the Fire Department must stage apparatus (engines and aerial trucks) to perform structure protection while residents are simultaneously attempting to evacuate. The lack of on-site staging areas in the current proposal means that a fire truck parked on Street B to protect Building 1 would physically block the only evacuation path for residents in Buildings 2 through 6.

This creates a trap where emergency response activity directly inhibits the life-safety of the residents. Strategic planning requires that access roads be wide enough to allow for apparatus flow and simultaneous resident egress.

Agenda Item #11.1.

Wildfire Analysis 13 February 6, 2026
Spring Grove ZCG No. 0126009

5. CONSTRUCTION IN WILDFIRE PRONE AREAS
Regulation of structures in Wildland Urban Interface (WUI) zones focuses on creating a "defensible structure" that can survive the passage of a fire front without direct human intervention. Per the latest data, homes built under California's Chapter 7A WUI codes are three times more likely to survive than older structures. The Spring Grove project shall consider these standards not just as a code requirement, but as a core design philosophy.
a) Construction
The Spring Grove subdivision can improve structural hardening to withstand intense ember storms and radiant heat by incorporating the following elements:
• Roofing: Constructed with Class A fire-rated materials, such as composite shingles, metal, clay, or concrete tile. Class A roofing is the first line of defense against overhead ember ignition. Any roof-mounted solar arrays must be installed such that they do not create "debris traps" where leaves and twigs can collect under the panels. • Ember-Resistant Vents: Attic, eave, and crawlspace vents should demonstrate the ability to resist the intrusion of flame and embers. Vents must be screened with corrosion-resistant, noncombustible wire mesh with openings not to exceed 1/8 inch, complying with ASTM E2886. This specific mesh size is proven to block up to 80% of hazardous firebrands while still allowing necessary airflow.
• Exterior Siding and Walls: Exterior vertical walls of noncombustible or ignition-resistant materials such as fiber-cement siding, brick, stucco, or masonry. Wood-based siding is highly discouraged and at minimum should meet strict 1-hour fire ratings if utilized. The first 6 inches of vertical space above any horizontal surface (decks, soil) should be a noncombustible material to prevent wicking fire into the wall cavity. • Windows and Doors: Exterior windows and glass within doors should be dual-pane tempered glass. This resists the intense radiant heat that causes single-pane glass to shatter, which would otherwise allow embers to enter and ignite the home's interior. Exterior doors must be solid-core or fire-rated for at least 20 minutes. • Decks and Overhangs: Walking surfaces of decks and porches must be constructed of noncombustible materials. All eaves and overhanging projections must be "boxed-in" (soffited) with ignition-resistant materials to prevent embers from finding weak areas in the roof-to-wall junction. Wood decks attached to homes act as "fuses," carrying ground fire directly to the structure's siding and eaves.

Agenda Item #11.1.

Wildfire Analysis 14 February 6, 2026
Spring Grove ZCG No. 0126009
b) NIST Hazard Mitigation Methodology (HMM)
The National Institute of Standards and Technology (NIST) is an agency of the U.S. Department of Commerce. NIST’s Engineering Laboratory, specifically its Fire Research Division, provides the scientific basis for fire codes and standards through advanced research on Wildland Urban Interface (WUI) fire behavior. NIST research (specifically Technical Note 2205) indicates that in high-density developments like Spring Grove, the primary fire threat transitions from wildland embers to adjacent structure exposure.
• High Structure Density Risk: NIST findings state that "one structure ignition leads to large losses in high-density communities. Spacing between homes affects community survivability. In this 41-unit configuration, complete structure and parcel hardening are essential for the survivability of the entire community. If Building 3 ignites, its radiant heat will likely ignite Building 4 unless both are fully hardened. • Projections and Appendages: Fences, patio covers, and other attached structures must meet 1-hour fire ratings. Noncombustible "breaks" must be installed in any continuous fencing that connects buildings to one another. Wood-to-wood contact between fences and homes shall be evaluated and approved.

Agenda Item #11.1.

Wildfire Analysis 15 February 6, 2026
Spring Grove ZCG No. 0126009

6. WILDFIRE MITIGATION
a) Defensible Space
Per NFPA 1140 Section 26.1 and SHMC 15.36.080, a mandatory 100-foot defensible space is required, focusing on the "Home Ignition Zone" (HIZ). Priority must be given to the area 100 to 200 feet from the structures:

1. Zone 0 (The Ember-Resistant Zone, 0–5 feet): This is the most critical zone. It must be entirely noncombustible (rock, stone, or concrete). No mulch, firewood, furniture, woody shrubs, or overhanging branches are permitted. This zone prevents smoldering material from igniting the building at the sill plate. Any vegetation in this zone must be limited to sparse, low-growing succulents with extreme water content.

2. Zone 1 (The Lean, Clean, and Green Zone, 5–30 feet): Remove all dead plants, pine needles, and surface litter. Prune trees to a height of 6–10 feet from the ground to eliminate "ladder fuels." Ensure horizontal separation between tree crowns (minimum 10 feet) to prevent fire spread across the canopy.

3. Zone 2 (The Reduced Fuel Zone, 30–100 feet): Create vertical and horizontal spacing between shrubs and trees. Mow grass to a maximum height of 4 inches to reduce flame length and intensity. This zone serves to slow the fire down before it reaches the structures.

Agenda Item #11.1.

Wildfire Analysis 16 February 6, 2026
Spring Grove ZCG No. 0126009
b) Vegetation and Maintenance
A formal Vegetation Management Plan (VMP) must be a condition of approval. Per NFPA 1140 Section 26.2.2, all live vegetation must be maintained annually before the start of the summer fire season. Maintenance must include the removal of ladder fuels to preclude ground fires from spreading into the tree canopy. The developer must comply with the City’s annual Weed Abatement Program to reduce community-wide risk. The City Manager’s "Fire Resilience" strategy emphasizes that "each person is responsible for making their own property as fire resistant as possible." c) Irrigation Strategies
A high-efficiency, permanent, and automated irrigation system must be maintained for all Zone 1 vegetation. Research indicates that keeping landscape moisture content high significantly reduces the probability of spot-fire ignition from flying embers. The system should be designed to allow the Fire Department to pre-wet the perimeter during a high-wind event and must remain operational even if municipal power is lost through the use of backup power or gravity-fed systems. Smart controllers that shut off during high-wind events to preserve pressure should be avoided in favor of manual overrides for fire staff.
d) Relative Water Content (RWC)
We recommend the exclusive use of "fire-wise" plants. Species with high Relative Water Content (RWC) do not contain flammable resins, oils, or waxes. Deciduous trees (Oaks, Maples) are preferred over coniferous species (Pines, Junipers), which act as standing fuel. A formal list of approved species with high RWC must be incorporated into the project’s final landscape design to ensure compatibility with the Wildland Urban Interface (WUI) environment. Non-native, highly flammable species like Eucalyptus or Acacia must be strictly prohibited.

Agenda Item #11.1.

Wildfire Analysis 17 February 6, 2026
Spring Grove ZCG No. 0126009
e) Soil Maintenance
Foundations must be kept clear of excessive organic mulch or surface litter. In Wildland Urban Interface (WUI) fires, structures are often lost because organic mulch smolders for hours after the fire front passes, eventually igniting the wood-frame structure. Noncombustible soil covers (gravel, rock, or bare soil) are required within the first 5 feet of each building. Additionally, soil stabilization is required to prevent post-fire erosion and debris flow from the western slopes, which can damage structures after the fire is extinguished.
f) Tank and Hydrant Systems
A formal fire water analysis is required per SHMC 15.36.090. The system must confirm that the GPM and pressure are sufficient for a high-density Type V-B subdivision. • Hydrant Staging: Per NFPA 1140 Section 15.3, fire hydrants must be placed so apparatus can stage and connect without blocking the only access road. • Bollard Protection: Mandatory for the hydrant on Street C to ensure that the water supply is not disabled by an accidental vehicle impact during an evacuation. • Main Looping: We recommend looping the internal water mains to ensure a redundant supply to every building. A dead-end main on Street B could lead to pressure loss if the single supply line is compromised.
g) Evacuation Road
The single access road (Street A) is a "single point of failure" and a primary life-safety concern. • Capacity: 41 high-density units represent approximately 143 residents and dozens of vehicles attempting to exit via one 26-foot road.
• NFPA 1140 Table 11.1.4.1(a) and SHMC 15.36: Requires at least two separate and remote access routes for developments over 30 units.
• Operational Hazard: Lessons from Southern California and the 2024 St. Helena drills prove that single-access communities face significantly higher mortality risks during rapid-onset fires. A secondary, remote evacuation route is a life-safety necessity to avoid gridlock.

Without this redundancy, the project introduces a material health and safety concern that cannot be mitigated through building hardening alone.

Agenda Item #11.1.

Wildfire Analysis 18 February 6, 2026
Spring Grove ZCG No. 0126009

7. CONCLUSION
Based on SHMC Chapter 15.36, the 2025 CAL FIRE maps, and the "Major Risk" Fire Factor assessment, the Spring Grove subdivision faces a material and high risk of wildfire danger. The combination of dense Type V-B wood construction, a single point of access, and proximity to highintensity fuels creates an inherent risk that minimum building codes do not fully mitigate. Recent fire history, including the 2020 LNU Lightning Complex and Glass Fire, proves the reality that fire in the Napa Valley frequently outpaces standard suppression capabilities.

The protection of the existing and future residents depends on a design that prioritizes ignition resistance and evacuation redundancy. By implementing a defensible space strategy, hardening homes against embers, and providing a secondary evacuation route, the developer can mitigate the material health and safety risks inherent to this project. Failure to address the access redundancy and site constraints will result in a community that is fundamentally vulnerable to the next regional fire.

Please don’t hesitate to contact our office if you have any questions or would like to discuss our comments in further detail.

ZARI CONSULTING GROUP, INC. ZARI CONSULTING GROUP, INC.

Duran Muniz Joseph P. Zari, PE
Project Manager Principal
Agenda Item #11.1.

From: Wayne Leong
To: City Clerk
Subject: Fwd: Rebuttal to City Attorney Memo re Fire Access – Spring Grove (PL24-065) Date: Sunday, February 8, 2026 7:59:09 PM
Attachments: 260208 - Rebuttal to City Attorney Memo re Fire Access.pdf City Clerk,
In the event Andrew is not available to submit this comment letter for the Feb 10 City Council meeting, please submit it.

Thank you,
Wayne
www.leongarch.com + www.leong-leong.com
Napa Valley + New York
P.O. Box 2, St. Helena, CA 94574
t: (707) 963-5461
---------- Forwarded message ---------
From: Wayne Leong <[email protected]>
Date: Sun, Feb 8, 2026 at 12:53 PM
Subject: Rebuttal to City Attorney Memo re Fire Access – Spring Grove (PL24-065) To: Andrew Bradley <[email protected]>,
<[email protected]>
Andrew and City Council Members:

I submit this comment to directly rebut the City Attorney’s memorandum titled “Memo re Wolfe Letter re Spring Grove,” dated February 5, 2026.

The memo’s central conclusion—that the Spring Grove project may lawfully be approved with a single fire apparatus access road—is incorrect as a matter of municipal law.

At the time the Spring Grove Vesting Tentative Subdivision Map application was deemed complete, the 2022 St. Helena Fire Code was in effect. St. Helena Municipal Code §15.36.110(D) is clear and mandatory: residential developments exceeding 30 units shall be provided with two separate and approved fire apparatus access roads. This requirement contains no waiver, no discretionary exception, and no sprinkler substitution. The Spring Grove project proposes 41 units served by a single access road and therefore does not comply.

The City Attorney’s analysis rests on the erroneous premise that local fire code amendments “expired” on December 31, 2025. Municipal ordinances do not expire by operation of a new state code cycle.

Local fire-safety standards adopted pursuant to Health & Safety Code §§17958.5 and 17958.7 remain in effect unless and until repealed by ordinance. No such repeal exists. Absent repeal, §15.36.110(D) Agenda Item #11.1.

remains fully enforceable.

The memo also conflates building permit review with entitlement approval. The possibility that a future building permit may be reviewed under the 2025 California Fire Code does not authorize the City to approve a vesting tentative map that violates existing municipal law. An unlawful entitlement cannot be cured at the permit stage.

The suggestion that a sprinkler exception from the model Fire Code survives by implication is likewise incorrect. When the City amended Appendix D “to read as follows,” it legally replaced the section. The omission of the sprinkler exception was deliberate and has been carried forward through successive adoption cycles.

Finally, Housing Element policies, zoning density ranges, SB 330, and the Housing Accountability Act do not override mandatory, objective life-safety standards. Where density objectives conflict with fire access requirements, safety controls. Neither staff error nor delay can vest the City into approving a project that violates its own code.

The Council’s lawful options are therefore limited and clear:

Require a second approved fire apparatus access road; or Require the project to be reduced to 30 units or fewer.

Approving a 41-unit project with only one access road would exceed the Council’s authority and expose the City to avoidable legal and public safety risk.

Respectfully submitted,
Wayne Leong
www.leongarch.com + www.leong-leong.com
Napa Valley + New York
P.O. Box 2, St. Helena, CA 94574
t: (707) 963-5461
Agenda Item #11.1.

From: David Lattin
To: Public Comment
Subject: Fwd: Fire Safety Concerns Regarding the Spring Grove Development Date: Sunday, February 8, 2026 10:29:01 PM
Please enter the letter below into public comment.

Thank you,
David Lattin
Sent from my iPhone
Begin forwarded message:

From: David Lattin <[email protected]>
Date: February 8, 2026 at 10:33:20 AM MST
To: [email protected]
Subject: Fire Safety Concerns Regarding the Spring Grove Development Dear Chief Sorensen,
My wife, Kendra, and I have lived at 1433 Spring Street since 1987. Over the years, we have self-evacuated several times at the advice of the City and County Fire Departments when fire threatened our town. We did so to avoid the potential for dangerous auto congestion during a rapid evacuation under catastrophic fire conditions. (Friends of mine over in Sonoma County have relayed horror stories to me).

We are deeply concerned for the potential dangers posed by the Spring Grove development that is planned behind our home. With the recent fire safety consultant’s report that has come to our attention, it appears that a number of ‘red flag’ construction violations have been ignored by City Council during the approval process.

Before you are asked to weigh in again, please read (or reread) the Zari Consulting Group Fire Safety Report for the items that concern us and should deeply concern the City and you. In our minds, the City has the OBLIGATION to modify the design of this development to address these concerns. California housing mandates CANNOT override County or City fire safety regulations.

We are in favor of housing to be built behind us. We are totally against it as it is currently designed.

Respectfully,
David Lattin and Kendra Craven
Agenda Item #11.1.

Agenda Item #11.1.

February 9, 2026
By Email
Mayor Paul Dohring
Members of the City Council
City of St. Helena
1088 College Avenue
St. Helena, CA 94574
[email protected]
[email protected]
Re: Vesting Tentative Map and Water Neutrality Agreement for Spring Grove Development Project (File No. PL24-065); Fire Access Road Requirements
Dear Mayor Dohring and Councilmembers:

Please accept and consider the following points and concerns, submitted on behalf of the Saint Helena Neighborhood Association (“SHNA”), prepared in response to the February 5, 2026 Memorandum from the City Attorney (“BBK Memo”), which addressed concerns raised in our earlier letter of January 27, 2026.

The BBK Memo advances several arguments to avoid St. Helena’s mandatory dual fire apparatus access road requirement. Each argument fails as a matter of law.

The central premise of the BBK Memo, that the City’s carefully enacted local fire safety amendments somehow expired automatically on January 1, 2026, contradicts both the plain language of California law and basic principles of municipal legislative authority. Local ordinances do not vanish into thin air simply because the state updates the baseline standards upon which the local ordinances are based. The City’s local amendments to the 2022 California Fire Code, including the dual access road requirement, remain binding law until the City Council affirmatively repeals or modifies them through proper legislative process. The requirement is therefore applicable to the Spring Grove Project.

Agenda Item #11.1.

St. Helena City Council
February 9, 2026

I. Local Fire Code Amendments Do Not Automatically Expire The BBK Memo argues that the City’s local amendments to the 2022 California Fire Code “are no longer in effect” as of January 1, 2026. This misconstrues Health & Safety Code § 17958 and contradicts basic principles of municipal law.

A. The Statute Contains No Automatic Expiration Provision Health & Safety Code § 17958(a) provides that local amendments “shall become effective 180 days after publication of the California Building Standards Code by the California Building Standards Commission.” This provision establishes when local amendments become effective; it does not speak to when they expire. The statute is silent on expiration, and the BBK Memo cites no authority holding that local building code amendments automatically sunset when new state codes are published.

Under BBK’s interpretation, every three years, during the triennial code adoption cycle, California’s 482 cities and 58 counties would simultaneously lose all local fire safety, seismic, and building standards for the approximately 180-day period between state publication and local re-adoption. Emergency access roads, earthquake protections, and wildfire protection requirements would evaporate statewide. The Legislature could not have and did not intend such a patently chaotic result.

B. Legislative Intent Confirms Continuity of Local Amendments Assembly Bill 130 (2025), which added subdivision (b) to Health & Safety Code § 17958, directly refutes BBK’s position. Subdivision (b)(1) restricts new residential amendments from October 1, 2025 to June 1, 2031, unless they are “substantially equivalent to changes or modifications that were previously filed by the governing body of the city or county and were in effect as of September 30, 2025.” This language presumes that local amendments adopted under prior code cycles remain “in effect” during the transition to new codes.

If BBK’s interpretation were correct, and all 2022 amendments expired on January 1, 2026, then nothing would have been “in effect as of September 30, 2025” Agenda Item #11.1.

St. Helena City Council
February 9, 2026

for jurisdictions to carry forward. The statutory exception would be meaningless.

Courts reject interpretations that render statutory language surplusage. (Asian Americans Advancing Justice v. Padilla (2019) 41 Cal.App.5th 850,863 (“When statutory language is clear and unambiguous, there is no need for construction and courts should not indulge in it”): Yes in My Backyard v. City of Culver City (2023) 96 Cal.App.5th 1103, 1116 (courts avoid statutory constructions that result in surplusage”).)
C. Municipal Ordinances Persist Until Repealed
St. Helena Municipal Code § 15.36.100(D), adopted by Ordinance No. 22-12 on December 13, 2022, is a duly enacted municipal law. Under California law, ordinances remain in effect until repealed or superseded by subsequent legislative action. The City Council has not repealed Ordinance 22-12. The BBK Memo acknowledges that the City has only “introduced” amendments to adopt the 2025 Code but has not yet adopted them. Until that adoption occurs, the 2022-based local amendments remain operative.

BBK’s interpretation would lead to an outcome that even the City Council has not effectuated: the premature repeal of fire safety standards through mere passage of time rather than deliberative legislative action.

II. St. Helena’s Ordinance Language Unambiguously Deleted The Sprinkler Exception
The BBK Memo argues further that even if the City’s local amendments remain in effect, the sprinkler exception was never deleted because St. Helena “only lists language actually being modified.” This likewise contradicts the plain text of St.

Helena’s ordinances and basic principles of statutory construction.

A. “Amended to Read as Follows” Means What it Says – The Sprinkler Exception is Removed
SHMC § 15.36.100(D) states:

Agenda Item #11.1.

St. Helena City Council
February 9, 2026

Section D107.1, One or two-family dwelling residential developments, California Fire Code 2022, Appendix [D], is amended to read as follows:

Developments of one, two-family or multi family dwellings where the number of dwelling units exceeds thirty (30) shall be provided with two separate and approved fire apparatus access roads, and shall meet the requirements of Section D104.3. (Emphasis added.)
The phrase “amended to read as follows” is legislative drafting language that signals complete replacement of a code section. When a legislative body amends a section “to read as follows,” it replaces the entire section with new text. What follows the colon is the complete, operative provision.

If the City Council intended only to add “or multi family” while preserving the model code’s sprinkler exception, it would have drafted the ordinance to say so explicitly. It might have said: “Section D107.1 is amended by adding the words ‘or multi family’ after ‘two-family dwellings’ in the first sentence.” Or: “The following text is added to Section D107.1...” But that is not what the ordinance says.

Instead, by stating the section “is amended to read as follows,” followed by text that contains no exception, the City Council enacted a complete replacement provision that deliberately omits the state’s sprinkler exception, and then re-enacted it on three separate occasions.

B. The BBK Memo’s Interpretation Contradicts The City Council’s Express Findings
The BBK Memo suggests the deletion of the exception was inadvertent, asserting that “nothing in the ordinance or staff reports...made any mention of a deliberate intention to delete the exception.” (BBK Memo at 4.) This assertion is incorrect.

St. Helena adopted its deletion of the sprinkler exception based on express legislative findings under Health & Safety Code § 17958.7. Those findings, codified at SHMC § 15.36.030, identify specific “local climatic, geological, or topographic conditions” that justify stricter fire access standards:

Agenda Item #11.1.

St. Helena City Council
February 9, 2026

A. The city is characterized by a narrow valley floor surrounded and intermingled with steep hill terrain, containing areas which are very susceptible to wildland fires.
[¶]
C. St. Helena is divided geographically into two parts by the north to south flow of the Napa River. Significant damaging flooding occurs in portions of the city approximately every five to ten (10) years.... This natural barrier can serve as a severe impediment to public safety services because of the severity of slopes and the existence of natural barriers such as the Napa River, Sulphur Creek, and York Creek.

These findings make clear why the City rejected the state’s sprinkler exception:
the City’s topography creates single points of failure for emergency access. When the Napa River floods, Sulphur Creek overflows, or wildfire conditions block roadways, internal sprinklers cannot substitute for redundant access routes. Sprinklers protect structures from internal fire spread; they do nothing to maintain emergency vehicle access or resident evacuation routes when external conditions block the sole access road.

The City Council made these findings three times, in Ordinance 16-15 (2016), Ordinance 19-10 (2019), and Ordinance 22-12 (2022), filing them with the California Building Standards Commission each time as required by statute. The legislative record accordingly shows that deletion of the sprinkler exception was not inadvertent; it was a deliberate policy choice grounded in documented local conditions and executed through proper legislative process.

C. The “Routine Practice” Argument Lacks Legal Authority The BBK Memo asserts that “City staff has confirmed that it is the city’s routine practice to only list language actually being modified when listing the local amendments.” (BBK Memo at 4.) Even if this characterization of staff practice were accurate, it cannot override the plain language of a duly enacted ordinance.

Courts interpret ordinances according to their express terms, not according to staff practices or unexpressed intentions. (Move Eden Housing v. City of Livermore (2025) 114 Cal.App.5th 1282, 1293-1294 (if the statutory language is unambiguous, then its plain meaning controls). Where ordinance language is unambiguous, as it is here, courts do Agenda Item #11.1.

St. Helena City Council
February 9, 2026

not engage in speculation about what the drafters might have meant or what staff practices might suggest.

Furthermore, the BBK Memo provides no citation to any resolution, staff report, or ordinance establishing this alleged “routine practice.” Without documentary evidence, this assertion is simply attorney argument. It cannot overcome the clear statutory language of SHMC § 15.36.100(D).

III. The D106/D107 Distinction Is Irrelevant And Was Deliberately Rejected By the City
The BBK Memo argues that Section D106.1 (governing multi-family projects of 100+ units) controls instead of Section D107.1 (governing one and two-family residential developments of 30+ units), and that the Project is therefore exempt because it has only 41 units. (BBK Memo at 4.) This argument fails for two reasons.

A. St. Helena Deliberately Amended D107.1 to Include Multi-Family Developments
The model California Fire Code distinguishes between:
• Section D106 (“Multiple-family residential projects”) • Section D107.1 (“One- or two-family dwelling residential developments”) The City modified Section D107.1 by adding “or multi family” to bring multi-family developments within its stricter 30-unit threshold. This was not a scrivener’s error.

The City deliberately expanded D107.1’s scope to cover projects that would otherwise fall under D106’s more lenient 100-unit threshold.

The BBK Memo acknowledges this, noting that “staff intends to strike the local modification to Section D107.1 adding “or multi family” as unnecessarily duplicative' in the forthcoming 2025 adoption. (BBK Memo at 4.) This admission confirms two things: (1) the “or multi family” language was a deliberate local modification, and (2) it remains in effect in the current code.

Agenda Item #11.1.

St. Helena City Council
February 9, 2026

B. The Ordinance’s Plain Language Governs
SHMC § 15.36.100(D) states that “Developments of one, two-family or multi family dwellings where the number of dwelling units exceeds thirty (30) shall be provided with two separate and approved fire apparatus access roads.” The Spring Grove development is a 41-unit town home project. It “exceeds thirty (30)” units.

Under the plain language of the ordinance, it requires two access roads.

IV. Housing Policy Arguments Cannot Override Express Public Safety Requirements
The BBK Memo advances two policy arguments: (1) requiring dual access would conflict with the Housing Element’s unit projections and (2) allowing single access is consistent with “the City's other planning documents.” (BBK Memo at 5.) Neither argument provides a legal basis to ignore the City’s fire safety requirements.

The Housing Element is a planning document that projects development capacity based on zoning and general plan designations. It does not, and indeed cannot, waive objective development standards like fire apparatus access roads. If site constraints prevent a parcel from meeting fire access requirements at maximum theoretical density, the parcel may simply be developable at lower density or may require property acquisition to achieve secondary access.

Fire safety requirements and housing goals must both be satisfied. When they conflict, the City may need to find alternative sites to meet Regional Housing Needs Allocation numbers, adjust densities, or assist developers in acquiring necessary access easements. What the City cannot do is administratively waive mandatory lifesafety standards to accommodate a developer’s preferred project design.

The BBK Memo candidly admits that “site constraints preclude a secondary access to the Project without the developer acquiring additional land from other private property owners.” (BBK Memo at 5.) This is precisely the situation that fire access requirements are designed to address: preventing approval of projects that cannot meet minimum safety standards due to site limitations.

Agenda Item #11.1.

St. Helena City Council
February 9, 2026

The fact that requiring compliance would be inconvenient or costly for the developer does not create an exception to mandatory safety standards. If the site cannot accommodate the required infrastructure, the developer’s remedies are to (1) acquire additional property for secondary access, (2) reduce the project size, or (3) seek a different site. The developer does not have a fourth option: judicially rewriting St. Helena’s fire code.

V. The Housing Accountability Act Does Not Bar Enforcement Of Fire Safety Standards
Finally, BBK argues that the time to raise objections under Government Code § 65589.5(j)(2)(A)(i) has expired. (BBK Memo at 5.) This argument likewise misconstrues both the Housing Accountability Act (“HAA”) and the City's enforcement authority.

A. The HAA Does Not Create Vested Rights in Noncompliant Projects
The HAA’s streamlining provisions require cities to identify noncompliance with objective development standards within specified timeframes. But these provisions do not vest rights in projects that do not comply with applicable health and safety standards, especially State-promulgated standards. The HAA prohibits cities from disapproving compliant projects; it does not require cities to approve noncompliant ones.

If City staff initially misinterpreted the applicability of the fire code (as the BBK Memo suggests), that does not cure the Project’s actual noncompliance. The California Fire Code and St. Helena’s local amendments remain objective, applicable standards. The Project must either comply with them or obtain necessary variances or modifications through proper administrative processes.

Moreover, life-safety codes are not waivable through procedural defaults.

Even if the HAA’s 30-day or 60-day windows for compliance review had somehow created an estoppel (they did not), the City retains authority to enforce mandatory safety standards at the building permit stage and throughout construction. Fire Agenda Item #11.1.

St. Helena City Council
February 9, 2026

apparatus access roads are not optional amenities subject to negotiation; they are non-negotiable safety infrastructure.

VI. Even If the 2025 State Fire Code Applies, the City Can Carry Forward Its Amendments
The BBK Memo is correct that the California Fire Code itself is a state standard not subject to local vesting. (BBK Memo at 2.) However, this does not resolve the question of which fire code provisions apply to the Project.

First, as discussed in Section I, St. Helena’s current local amendments remain in effect until superseded by newly adopted amendments. The City has not yet adopted the 2025 Code with new local amendments. Second, when the City does adopt the 2025 Code, it may (and under Health & Safety Code § 17958(b)(1) is expressly authorized to) carry forward amendments that were “in effect as of September 30, 2025” and are “substantially equivalent” to prior amendments. Given that the same topographical conditions identified in SHMC § 15.36.030 continue to exist, the City would be well within its authority to re-adopt substantially similar provisions deleting the sprinkler exception for the 2025 Code cycle.

Thus, even under the developer’s preferred timeline, the Project would ultimately be subject to the same dual-access road requirement, either under the stilleffective 2022-based amendments, or under substantially equivalent amendments that the City adopts for the 2025 Code.

VII.. Conclusion
The BBK Memo’s arguments fail at every level:
• Local fire code amendments do not automatically expire when new state codes are published;
• The ordinance language “amended to read as follows” unambiguously replaced Section D107.1 with text that deliberately omits the sprinkler exception;
• The deletion was neither inadvertent nor unexplained; it was supported by express legislative findings about local topography that have been filed with the state three times over at least nine years;
Agenda Item #11.1.

St. Helena City Council
February 9, 2026

• The City deliberately expanded Section D107.1 to cover multi-family projects, rejecting the distinction the developer now attempts to exploit; • Policy arguments about housing goals and site constraints do not override mandatory safety standards; and
• The Housing Accountability Act does not vest rights in noncompliant projects or bar enforcement of fire safety requirements In sum, the Spring Grove development is subject to Municipal Code §

15.36.100(D), which requires two separate and approved fire apparatus access roads for developments exceeding 30 units. The Project has 41 units and proposes only one access road. It does not comply.

The remedy is straightforward: the developer must either (1) acquire the necessary property interests to provide a code-compliant secondary access road, or (2) reduce the project to 30 or fewer units. No amount of legal argument can alter the physical reality that St. Helena’s topography creates genuine public safety hazards when developments lack redundant emergency access.

Thank you for your consideration of these concerns.

Most sincerely,

M. R. WOLFE & ASSOCIATES, P.C
Mark R. Wolfe
On behalf of Saint Helena Neighborhood
Association
MRW:
cc: City Attorney ([email protected])
Agenda Item #11.1.

YIMBY Law
2261 Market Street STE 10416
San Francisco, CA 94114
[email protected]
2/09/2026
City of St. Helena
City Council
465 Main St.

St. Helena, CA 94574
[email protected]
Re: Subdivision approval for 1447, 1505, 1515 Spring Street, Agenda Item 11 Dear St. Helena Planning Commission,
YIMBY Law is a 501(c)3 non-profit corporation, whose mission is to increase the accessibility and affordability of housing in California. YIMBY Law sues municipalities when they fail to comply with state housing laws, including the Housing Accountability Act (HAA). This Commission has an obligation to abide by all relevant state housing laws when evaluating the above captioned proposal, including the HAA. Should the City fail to follow the law, YIMBY Law will not hesitate to file suit to ensure that the law is enforced.

This development will consist of 41 units of townhomes with 8 deed-restricted affordable units, located on Housing Element opportunity site 9. As you have already identified, the site’s residential capacity is critically underutilized, and is already consistent with both the St. Helena General Plan and the applicable zoning designation. Your staff have adequately laid out the legal necessity of approving this project’s Vesting Tentative Subdivision Map.

California Government Code § 65589.5, the Housing Accountability Act, prohibits localities from denying housing development projects that are compliant with the locality’s zoning ordinance or general plan at the time the application was deemed complete, unless the locality can make findings that the proposed housing development would be a threat to public health and safety.

The most relevant section is copied below:
(j) When a proposed housing development project complies with applicable, objective general plan and zoning standards and criteria, including design review standards, in effect at the time that the housing development project's application is determined to be complete, but the local agency proposes to disapprove the project or to approve it upon the condition that the project be developed at a lower density, the local agency shall base its decision regarding the proposed housing development project upon written findings supported by substantial evidence on the record that both of the following conditions exist:
(1) The housing development project would have a specific, adverse impact upon the public health or safety unless the project is disapproved or approved upon the condition that the project be developed at a lower density. As used in this paragraph, a "specific, adverse impact" means a significant, quantifiable, direct, and unavoidable impact, based on objective, identified written public health or safety standards, policies, or conditions as they existed on the date the application was deemed complete.
1 Agenda Item #11.1.

(2) There is no feasible method to satisfactorily mitigate or avoid the adverse impact identified pursuant to paragraph (1), other than the disapproval of the housing development project or the approval of the project upon the condition that it be developed at a lower density. . . .
(4) For purposes of this section, a proposed housing development project is not inconsistent with the applicable zoning standards and criteria, and shall not require a rezoning, if the housing development project is consistent with the objective general plan standards and criteria but the zoning for the project site is inconsistent with the general plan. If the local agency has complied with paragraph (2), the local agency may require the proposed housing development project to comply with the objective standards and criteria of the zoning which is consistent with the general plan, however, the standards and criteria shall be applied to facilitate and accommodate development at the density allowed on the site by the general plan and proposed by the proposed housing development project.

The above captioned proposal is zoning compliant and general plan compliant, therefore, you must approve the application and all necessary permits or maps, or else make findings to the effect that the proposed project would have an adverse impact on public health and safety, as described above.

A Density Bonus is being sought in order for the Project proponent to be granted waivers to which they are entitled under California state Density Bonus Law, California Government Code § 65915(e), so long as there are no specific, adverse impacts, upon health, safety, or the physical environment, and there are no feasible methods to satisfactorily mitigate or avoid the specific adverse impacts. The HAA, § 65589.5 (j)(3) specifies that the receipt of a density bonus does not constitute a valid basis on which to find a proposed housing development project is inconsistent, not in compliance, or not in conformity, with an applicable plan, program, policy, ordinance, standard, requirement, or other similar provision.

In light of the fact that health and safety issues form limited reasons to disapprove of this project, local opponents of housing affordability have submitted comments alleging that it contains inadequate fire safety measures. The St. Helena Fire Department has concluded that the project poses no public safety threat, and has directly refuted the third party report alleging that such threats exist.

I am signing this letter both in my capacity as the Executive Director of YIMBY Law, and as a resident of California who is affected by the shortage of housing in our state, and would be eligible to apply for residency in the proposed housing development project.

Sincerely,
Sonja Trauss
Executive Director
YIMBY Law
YIMBY Law, 2261 Market Street STE 10416, San Francisco, CA 94114 2 Agenda Item #11.1.

JOSHUA S. DEVORE
[email protected]
|
February 9, 2026
Mayor Paul Dohring
Vice Mayor Michelle Deasy
Council Member Aaron Barak
Council Member Kate Spadarotto
Council Member Billy Summers
RE: PL24-065 Spring Grove Vesting Tentative Map and In Lieu Retrofit Fee Dear Mayor Dohring, Vice Mayor Deasy and Council Members:

We write briefly on behalf of our client, Julie Dickson, to respond to certain of the moreproblematic assertions in the January 27, 2026, Memorandum of BBK responding to our Comments of January 23 and 26.

The Minor Design Review Was Ineffectual
The Community Development Director lacked the legal authority to approve the project’s design as a Minor Design Review. The authority apparently relied upon, granted under SHMC § 17.05.080, applies explicitly only at the building permit stage:

The following activities are subject to all design criteria of the city; however, the review shall be conducted administratively by the community development director as a component of the building permit review.

Because the project is a tentative subdivision map application, not a building permit, and of “residential … buildings that do not comply with the applicable design standards of Chapter 17.16, Residential Zoning Districts…” they are subject as a matter of law to Major Design Review by SHMC 17.05.070(B)(8).

Although counsel suggests that the project could be deemed as consistent with the zoning code after considering all waived standards, the project objectively (1) did not comply with the applicable design standards at the time of application; and (2) in either case, the authority to grant such approval was never delegated to the Community Development Director.

Agenda Item #11.1.

February 9, 2026

|
SHMC Table 17.03.030 does not grant the Community Development Director power to approve design reviews in connection with subdivision maps. Vesting tentative subdivision maps are not building permits, and their approval authority is specifically assigned pursuant to SHMC Chapter

16.16. The contents – including the design of the structures for purposes of a vesting map under SHMC § 16.16.030 – are to be considered and recommended by the Planning Commission pursuant to SHMC § 16.16.060.

The City’s Municipal Code does not grant the Community Development Director the power to supersede the expressly delegated power to the Planning Commission of vesting tentative map review. SHMC § 2.28.020, which defines the duties of the Planning Director, grants no such power to the Planning Director, but rather specifically provides only the duty to make recommendations.

Counsel cites no provision of the City code that allows for approval authority, and municipal staff can act only with delegated authority.
1 Void acts of a public officer cannot be ratified. The design approval was legally ineffectual, and an asserted failure to appeal the design review is irrelevant because the design review, as a matter of law, is a nullity.

The Failure to Comply with the Garage Setback Is a Safety Hazzard Counsel agrees that the design does not comply with the required garage setbacks from the street. The underlying reason why garages are to be setback are not merely aesthetic as counsel appears to suggest without citation. Rather, the required 10’ setback of SHMC § 17.16.040(A)(7)(e) creates space between the street and the garage door for a car. The project ignores that practicality.

Further, the City’s response to the Zari report is that a ladder can be deployed to reach the third stories of the development and shows a photograph of a ladder in a driveway. (Feb. 10 Staff Report p. 256.) Because of the failure to comply with the garage setback, the base of that ladder would be in the street, blocking any emergency vehicles from passing.

The reality is that the project’s design is fundamentally unworkable and unsafe because there are no driveways in front of the garages, only aprons and curb cuts. It is not conceivable that every garage will be pristine and empty for two cars to readily park effortlessly. The ill-conceived design with no street parking anywhere near the residences will inevitably mean cars will be improperly parked obstructing the garages or travel lanes. It also places the homes closer to vehicle exhaust.

Failure to comply with SHMC § 17.16.040(A)(7)(e) is a health and safety hazard that is incapable of mitigation.
1 Compare with: Californians for Homeownership, Inc. v. City of La Habra, No. G064286, 2025 WL 4056820, at *5 (Cal. Ct. App. Dec. 18, 2025) (authority was delegated to City Manager by code.) Agenda Item #11.1.

February 9, 2026

|
The Failure to Comply with Egress Requirements Is a Safety Hazard Counsel’s letter concedes that certain of the units do not comply with required entry design standards. Again, there is no evidence that these are merely simple aesthetic rules: they facilitate safe ingress and egress from buildings in the case of emergency. There are no stated plans to warn residents of these exceptions and the safety hazard they present. The recent “FAQs” added to the Staff Report assert that “Entry design is not under purview of the City Council” but (1) as noted above, no legal design review has occurred; and (2) more importantly, the safety of the project is the ultimate responsibility of the City Council.

Counsel contends that the California Residential Code applies rather than the California Building Code, but cites no authority for that proposition. The Residential Code applies to Townhouses only where they have “a yard or public way on not less than two sides.” (Residential Code R202, Definitions, “Townhouse Unit”.) However, the proposed streets have not been “deeded, dedicated or otherwise permanently appropriated to the public for public use” and are not “public ways.” (Id, Public Way.) The project thus does not qualify as Townhouse Units, but rather proposed multifamily structures subject to the California Building Code.

Moreover, Counsel’s letter baldly asserts that the City claims to not be “aware of any obstructions that would prevent an individual from accessing the public way.” (S.R. pp. 244-45) Yet, the only egress doors do not exit to the public way, directly contrary to the building code. The Residential Code is the same as the CBC: R318.1 Means of Egress, “The required egress door shall open directly into a public way or to a yard or court that opens to a public way.” Instead, they exit away from the internal private streets, towards flammable materials such as wooden fences and vegetation; and the (potentially burning) buildings are between their doors and the private street.

Even assuming the Residential Code applies:
“The purpose of this code is to establish the minimum requirements to safeguard the public health, safety and general welfare through structural strength, means of egress facilities, stability, access to persons with disabilities, sanitation, adequate lighting and ventilation and energy conservation; safety to life and property from fire and other hazards attributed to the built environment; and to provide safety to fire fighters and emergency responders during emergency operations.”
Cal. Res. Code § 1.1.2 Purpose (emphasis added).

There is no direct exit route from the buildings to a public way or safe place of refuge. Again, this presents a direct risk to public safety.

Agenda Item #11.1.

February 9, 2026

|
The Single Access Point and Backwards Design Is a Safety Hazard We note further that, as set forth in the Zari reports, the single vehicular access point of the project, coupled with its unusual design of placing the only egress doors on the back side of the buildings away from the street, present a development that is at odds with protecting public health and safety. The City Council is under no obligation to approve this unusual and unsafe design. Rather, it has an obligation to protect the City’s existing and future residents, and mitigate the City’s financial risk in the event of a catastrophe from a design that has been documented to be unsafe by a noted expert.

Sincerely,

DICKENSON, PEATMAN & FOGARTY PC
Joshua S. Devore
cc: City Clerk
Ethan Walsh, Esq.

Agenda Item #11.1.

From: Corey Smith
To: Public Comment
Subject: Fwd: Housing Vote Tomorrow
Date: Monday, February 9, 2026 1:55:16 PM
Can you please add to the public record?
---------- Forwarded message ---------
From: Corey Smith <[email protected]>
Date: Mon, Feb 9, 2026 at 12:57 PM
Subject: Housing Vote Tomorrow
To: <[email protected]>, <[email protected]>, <[email protected]>, <[email protected]>, <[email protected]>
Mayor and City Council Members,
I hope this email finds you well. I'm reaching out regarding a proposed housing project on Spring Street ahead of Tuesday's council hearing.

While we have not reviewed the details of the project itself, it came across our radar as a result of the application before the City Council being continued twice, which caused it to surface in broader conversations among housing policy and advocacy organizations. We are now following the project’s approval process.

We understand that city staff has found it is consistent with applicable standards, including the city’s Housing Element. I want to remind you that the Housing Element is the city's plan to build (much needed) housing. Each city must do its fair share. In addition to this project following the city's own guidelines as a Housing Element site, it's critical that each city follow state housing law.

This is critical because California’s housing shortage is not an abstract policy problem, but a lived reality shaped by decades of underbuilding. When individual cities fail to plan for and allow their fair share of housing, the impacts are pushed onto neighboring communities and future generations, which constrains supply, increases competition for existing homes, and limits who can realistically live and work in a community.

State housing law exists to ensure that every city contributes to addressing this imbalance, rather than deferring responsibility or relying on others to absorb growth. Approving housing that is consistent with adopted plans reflects a commitment to long-term stability, opportunity, Agenda Item #11.1.

and ensuring communities remain functional, resilient, and accessible across income levels.

Please let me know if you have any questions,
Corey Smith
Executive Director, Housing Action Coalition
--
Corey Smith 陈锐 | Pronouns: He/Him
Executive Director | Housing Action Coalition
555 Montgomery Street, Suite 720, San Francisco, CA 94111 Cell: (925) 360-5290 | Office: (415) 300-0967
Email: [email protected] | Web: housingactioncoalition.org Please note the new email and website.

To opt out of all HAC emails, respond to this email with "unsubscribe all". --
Corey Smith 陈锐 | Pronouns: He/Him
Executive Director | Housing Action Coalition
555 Montgomery Street, Suite 720, San Francisco, CA 94111 Cell: (925) 360-5290 | Office: (415) 300-0967
Email: [email protected] | Web: housingactioncoalition.org Please note the new email and website.

To opt out of all HAC emails, respond to this email with "unsubscribe all".

Agenda Item #11.1.

From: Richard Corsetti
To: Public Comment
Subject: Spring Grove Housing Project
Date: Tuesday, February 10, 2026 9:31:21 AM
There are several issues that the City Council and legal needs to address before approval can be granted for this project. One of the most important is the need to have two roads leading in and out of the site to allow fire and emergency vehicles in and resident evacuations.

Sincerely,
Richard Corsetti
1401 Spring Street
Agenda Item #11.1.

2.10.26 Dear City Council,
Please provide clarity regarding the attached. There are many parcels within town that fall into the “flag lot” category, and there is general consensus among the professional community that the proposed project parcel distinctly falls within this municipal code definition. When the conflict around this specific item was first brought to the attention of the planning commission on the 21st of January 2025 staff was asked to provide clarity. Other than the attached section from the current project staff report I can find no other reference.

This would appear to be distinctly material given the request for tentative subdivision map approval as well as multiple other concerns that have been raised. What is the reasoning and justification for not adhering to the municipal definition and codified development restrictions?

PROPOSED SITE DESCRIPTION
Spring Grove is a high-density residential development. This project is designated as a Housing Development Project per Government Code section 65589.5(h)(2), emphasizing all-electric living.

Site Location: The project site encompasses three distinct parcels totaling approximately 2.52 acres at 1447, 1505, and 1515 Spring Street. Situated on the west side of St. Helena, the site is bordered by Spring Street and St. James Drive. The parcels at 1447 and 1515 Spring create "Site9" within the 2023-31 Housing Element. While 1505 Spring serves as the primary mediumdensity access corridor, the main residential footprint is zoned for high-density residential (HR).

This specific configuration creates a "flag-pole" style layout, where the primary access road (Street A) traverses a relatively narrow strip to reach the bulk of the development. This complicates fire apparatus maneuvers and limits the visibility of responders entering the site.

The constrained nature of the "flag" portion of the lot means that any incident occurring at the entrance (Street A) would effectively isolate the 41 homes from emergency services.

FD Response: The proposed Spring Grove Subdivision meets minimum lot width dimensional requirements and therefore does not meet the definition of a “flag lot”. Therefore, Fire Department
access is not constrained.

St Helena municipal definition of “flag lot”:
“Flag lot” means a lot in which the buildable portion of the lot is connected to and accessible from a public or private right-of-way by a narrow strip of land. The wider, buildable portion of the lot is situated behind adjoining lots which front on the same public or private street. Also known as a “panhandle lot.”
Agenda Item #11.1.

Thank you for providing clarity on this matter.

Sincerely,
Joshua Parke
Agenda Item #11.1.

St Helena City Council, SH City Management, SH Fire officials, Understanding the process by which the State Fire Code is adopted and amended is critical to this discussion.

With each adoption cycle, and with any subsequent amendments, local jurisdictions are expected to analyze the State Code and make modifications based on specific local conditions. These local findings must clearly identify the conditions present and explain the reasons for any amendments. This practice is explicitly allowed and encouraged by the State, and St. Helena, like other municipalities, has consistently followed this approach.

Within the St. Helena Fire Code, Sections 15.36.010 (General Findings), 15.36.020 (Codes Adopted), and

15.36.030 (Specific Findings for Code Amendments) clearly document the City's reasoned and thoughtful approach to adopting and amending the State Fire Code in response to local conditions. These code sections are attached for reference, along with the Fire Map located on pages 9-21 of St. Helena’s General Plan, Element 9: Public Health, Safety, and Noise.

Together, these documents explain the basis for the City's fire code amendments and the local conditions that necessitate them. In particular, Section 15.36.100, Fire Apparatus Access Roads, makes clear that residential proposals exceeding 30 units require two fire apparatus access drives. The rationale for deleting Exceptions 1 and 2 is clearly supported by local conditions and strengthens the objective standard requiring two access drives. The code further specifies that these access drives must be separated in accordance with the requirements of Section D104.3.

For additional context, this approach is consistent with standard practice throughout the region. Municipalities facing similar conditions, including Sonoma, Healdsburg, and Calistoga, have also removed Exceptions 1 and 2 from their fire codes. Calistoga has gone a step further by lowering the threshold for requiring a second access drive from 30 units to 20 units, reinforcing the importance of multiple access routes for emergency response. An excerpt from the Calistoga Municipal Code is included below for reference.

Taken together, these examples demonstrate that St. Helena's fire code amendments are well within accepted practice, firmly grounded in documented local conditions, and aligned with regional standards intended to enhance public safety and emergency access.

State housing law does not compel cities to approve housing projects that violate objective health and safety standards, nor does it authorize or suggest that local governments ignore, waive, degrade, or disregard standards that have been amended to address specific local conditions. To the contrary, Government Code §65589.5 expressly preserves the authority-and the obligation-of local agencies I urge the City Council to uphold its legal duty to enforce these standards and to reject any action or activity that would knowingly accept reduced or unsafe conditions by disregarding mandatory, objective standards designed to protect life and safety.

Agenda Item #11.1.

Excerpts form SHMC 15.36 Agenda Item #11.1.

r::.
c::

Map from ST Helena General Plan:
9 public health, safety, and noise
Dato Source: Fire Threat. Fire and Resource Assessment Program (FRAP), Col Fire, 2005; City of St Helena, 20/B;Napo County,2018; Dyett & llliotia,2018 roo,,,.,,,,.,.

FireThreat Level (Cal Fire) L... Urban Limit Line
- Extreme Threat Study Areas
Very HighThreat City of St.Helena
D HighThreat
LJ Moderate Threat
D Little or No Threat
:
r•...

Fif!ure 9.8
Wild FireThreat
---- ■
1,000 000 4,000
Agenda Item #11.1.

107377\19232513v1 www.coxcastle.com 107377\19236158v2 Los Angeles | Orange County | San Francisco Cox, Castle & Nicholson LLP
50 California Street, Suite 3200
San Francisco, California 94111-4710
P: 415.262.5100 F: 415.262.5199
Linda C. Klein
415.262.5130
[email protected]
File No. 107377
February 10, 2026

VIA E-MAIL
Ethan J. Walsh
City Attorney
City of St. Helena
1088 College Avenue
St. Helena, CA 94574
Re: 1447, 1505, and 1515 Spring Street
APNs: 009-590-003, 009-590-005-000, and 009-590-010
To Mr. Walsh:

We write on behalf of our client, City Ventures (“Applicant”), concerning its proposed 41-lot subdivision (“Project”) at 1447, 1505, and 1515 Spring St (“Property”) in the City of St.

Helena (“City”). Several public commenters have submitted correspondence to the City to contest the Project’s design and safety features. City staff, including you, have responded to those comments, explaining why the Project meets applicable, objective standards and must be approved. You requested that the applicant also respond to comments, providing supplemental information to help the public understand how the law applies to the Project and requires its approval.

The proposal before the City Council is the Project’s vesting tentative map (“VTM”) and Water Neutrality In-Lieu Retrofit Fee. The City has already determined the Project is exempt from the California Environmental Quality Act (“CEQA”) and granted a demolition permit and Minor Design Review approval (including approval of the requested State Density Bonus Law (“SDBL”) waivers). The time to appeal these approvals has expired.

1. Project and Permitting Background
The Project seeks to convert three existing single-family homes into 41 solar, all-electric townhouse-style homes with private garages distributed throughout six buildings on the roughly

2.53-acre site. The Project includes 93 parking spaces, comprised of two dedicated spaces within each home’s garage, as well as 11 surface parking stalls, over 50 bicycle parking spaces, and extensive landscaping, incorporating mature trees and vegetation along with new plantings chosen to complement the project design and setting.

The Project complies with the Property’s General Plan land use designation and the Housing Element. 1505 Spring Street is designated “Medium Density Residential,” which Agenda Item #11.1.

107377\19236158v2
permits densities between 5.1 and 16 dwelling units per acre. 1447 and 1515 Spring Street, where the development would occur, are designated “High Density Residential,” which permits

16.1 to 28 dwelling units per acre.

The Property was a housing opportunity site in the 2015–2023 Housing Element and remains a housing opportunity site in the current 2023–2031 Housing Element (“Housing Element”). The Housing Element states that 1447 and 1515 Spring Street could have 62 units but that the City anticipates the construction of 48 units.1 The parcels at 1447 and 1515 Spring, where the proposed townhomes are to be constructed, are zoned high-density residential. 1505 Spring is medium-density residential and will provide access to the development. The City has calculated that, combined, the Project parcels have an allowable density of between 15.5 and 27.3 units/acre. At an overall density of

16.2 units/acre, Spring Grove will be at the low end of the allowed density range.

Per the City’s Inclusionary Housing ordinance, 20 percent of the Project’s units will be affordable to moderate-income households. Under SDBL, project’s where at least 10 percent of the units would be affordable for moderate-income households to buy enjoy certain benefits, including unlimited waivers or reductions of development standards. (Gov. Code, § 65915, subds. (b)(1)(D), (e)(1); see Bankers Hill 150 v. City of San Diego (2022) 74 Cal.App.5th 755, 775 [“so long as a proposed housing development project meets the criteria of the Density Bonus Law by including the necessary affordable units, a city may not apply any development standard that would physically preclude construction of that project as designed”].) The Applicant requested eleven waivers to allow the Applicant to physically construct the Project as designed.

2. None of Commenters’ Critiques Provides a Basis to Deny the Project The Project is a housing development project under the Housing Accountability Act (“HAA”) that is consistent with applicable, objective standards (meaning objective standards not waived under the SDBL). (See Gov. Code, § 65589.5, subds. (h)(2), (j)(1).) The HAA prohibits the City from disapproving the Project or conditioning its approval on reducing density2 unless the City makes written findings supported by a preponderance of the evidence on the record that both of the following conditions exist:
(A) The housing development project would have a specific, adverse impact upon the public health or safety unless the project is disapproved or approved upon the condition that the project be developed at a lower density. . . . [and] 1 The addendum to the General Plan Environmental Impact Report for the Housing Element found no significant impacts from the Housing Element related to emergency response plans, exposure to wildfires, or public facilities. (Housing Element Addendum, available at https://www.cityofsthelena.gov/DocumentCenter/View/559/GeneralPlan-EIR-Addendum--April-2023-PDF.) 2 The Project already is at the minimum density permitted by the City on the Property, and this is another reason the City cannot approve the Project conditioned on lower density.

Agenda Item #11.1.

107377\19236158v2
(B) There is no feasible method to satisfactorily mitigate or avoid the adverse impact identified pursuant to paragraph (1), other than the disapproval of the housing development project or the approval of the project upon the condition that it be developed at a lower density.
(Gov. Code, § 65589.5, subd. (j)(1).) A “specific, adverse impact” means “a significant, quantifiable, direct, and unavoidable impact, based on objective, identified written public health or safety standards, policies, or conditions as they existed on the date the application was deemed complete.” (Ibid.) A specific, adverse impact upon public health and safety arises infrequently. (Id., subd. (a)(3).) Importantly, SDBL waivers are not a valid basis to determine the Project is inconsistent with an otherwise applicable, objective standard. (Id., subd. (j)(3); see id., subd. (f)(1) [“[n]othing in this section shall limit a project’s eligibility for a density bonus, incentive, or concession, or waiver or reduction of development standards and parking ratios, pursuant to Section 65915”].)
As described below, none of the issues raised by public commenters show that the Project would have an unmitigable “a specific, adverse impact upon the public health or safety.” a. Single Point of Access for Emergency Vehicles
Several commenters claim that the Project violates state and local fire codes for providing one point of access for emergency vehicles. The Project is in full compliance with fire safety regulations for multiple-family residences. Even if the Project was considered to be comprised of one or two-dwelling residences, the Project complies with fire codes. i. The Project Meets the Applicable Fire Code Requirements Under the 2025 Fire Code, Appendix D, no second fire apparatus access road is required for multiple-family dwellings unless there are more than 100 units. (24 Cal. Code Regs., § D106.1 (2025).) The City has not adopted modifications to the 2025 Residential Code. (See Health & Safe. Code, §§ 17958.7, 18941.5 [requiring cities to make certain findings before adopting modifications to state building code].) Thus, the Project, which proposes only 41 multiple family dwelling units, requires no second fire apparatus road.3 Even if the Project proposed development of one- or two-family dwellings, the Project would comply with Fire Code. Under the 2025 Fire Code, Appendix D, “developments of oneor two-family dwellings where the number of dwelling units exceeds 30 shall be provided with two separate and approved fire apparatus access roads.” (24 Cal. Code Regs., § D107.1 (2025).) But “where there are more than 30 dwelling units accessed from a single public or private fire apparatus access road and all dwelling units are equipped throughout with an approved automatic sprinkler system . . . access from two directions shall not be required.” (Id., § D107.1.1 (2025).) Here, the exception to the two-access-road requirement applies. All of the Project’s dwelling 3 The Zari Consulting Group, a consultant hired by community members concerned about the Project, agreed with the City’s classification of the Project, concluding that the Project would be classified as “multi-family residential.” (Zari Consulting Group, 3rd Party Plan Review (Jan. 26, 2026), at p. 2.) Agenda Item #11.1.

107377\19236158v2
units will be equipped throughout with an approved automatic sprinkler system, meeting applicable, objective fire safety standards.

In a letter dated February 9, 2026, Mr. Wolfe argues that the City’s amendments to the 2022 Fire Code remain effective in 2026 and do not need to be readopted. He is incorrect. The California Building Codes are updated every three years, with the latest update taking effect on January 1, 2026. According to the California Building Standards Commission, “[e]ven if a local government does not adopt Title 24 by ordinance [by Title 24’s effective date], Title 24 becomes the applicable code for all building occupancies by default.” (Cal. Building Standards Commission, Guide for Local Amendments of Building Standards (July 2024, 7th Ed.), at p. 4.4) In addition, amendments to Title 24 “must be adopted for each new edition of Title 24.” (Id., at p. 5; see, e.g., Staff Report to Sunnyvale City Council (Sept. 30, 2025) [“All local jurisdictions are required to hold public hearings and adopt these codes with any local amendments by January 1, 2026, or be mandated to accept by default the version adopted by the State.”]5; City Manager Report to Berkeley city Council (Oct. 28, 2025), at p. 8 [“The City Council could . . . take no action and allow the state mandated codes to take effect without local amendments specifically designed for Berkeley.”]6.)7
ii. Even if City Modifications to the 2022 Fire Code Applied, the Project Meets City Requirements
Even under the City’s modifications to the 2022 Fire Code, the lack of a second fire access does not result in an inconsistency with the City’s code and even if it did, there is no evidence that the lack of a second access results in a specific, adverse impact upon public health or safety.8
First, it is unclear that the City removed exceptions to Section D107.1, which had substantially the same language in the 2022 Code as it does in the 2025 Code. While the City amended Section D107.1 to include “multi family dwellings,” it did not amend Section D107.1.1 or D107.1.2. (Mun. Code, § 15.36.100.D.) Nor did the City alter Section 106.1, which applies 4 Available at https://www.dgs.ca.gov/bsc/codes/local-amendments-to-building-standards---ordinances. 5 Available at https://sunnyvaleca.legistar.com/LegislationDetail.aspx?ID=7682689&GUID=33162351-432E-4616- 996F-0D05C49AF7D2&FullText=1.
6 Available at https://berkeleyca.gov/sites/default/files/documents/2025-10- 28%20Item%2017%20Adoption%20of%20Berkeley%20Building%20Codes%2C%20Including%20Local%20Ame ndments.pdf.
7 Mr. Wolfe’s reliance on Assembly Bill 130 also is misplaced. There is no inconsistency with Assembly 130’s language and the fact that cities that failed to carry forward their amendments to state building codes by January 1, 2026, would be subject to the 2025 Building Code without local amendments. 8 The Applicant has a conversation with the neighboring property owner to ask about an easement to allow a second point of access. That owner stated that price would be very high (above fair market value) because it opposed the Project. Although a second access is not required, if the City decides the public good would be better served by the Project having a second access, it could take the necessary property through its eminent domain power, showing that the lack of a second access cannot be used to deny the Project or condition it on fewer units.

Agenda Item #11.1.

107377\19236158v2
to multiple-family dwellings and allows up to 100 units with a single fire access road. The Fire Department interprets the City’s amendments to the 2022 Code as leaving the exceptions intact.9 Second, even if the City deleted the exception provided by Fire Code section D107.1, the Project still complies with City Code. City Code section 15.36.110 allows the city manager, the fire chief, and the fire code official “to modify any of the provisions of the California Fire Code upon application in writing by the owner or lessee, or his or her duly authorized agent, when there are practical difficulties in the way of carrying out the strict letter of the fire code; provided, that the spirit of the fire code shall be observed, public safety secured, and substantial justice done.” (Id., § 15.36.110.) The Fire Department, which reviewed all Project applications, found the Project met the spirit of the Fire Code when it determined the Project consistent with all applicable, objective standards. The Project meets this spirit because it complies with state codes and will install a robust fire sprinkler system.

Third, no commenter has provided a preponderance of evidence that the Project, by having one point of fire access, would result in a specific, quantifiable adverse impact that is not addressed by the Project’s sprinkler system and other fire safety measures, including the installation of fire water lines, fire hydrants, and fire riser rooms. For example, commenters noted that the City amended the Fire Code because the City is “characterized by a narrow valley floor surrounded and intermingled with steep hill terrain, containing areas which are very susceptible to wildland fires” and other general findings about the City as a whole. (E.g., Letter from Mr. Wolfe (Jan. 27, 2026), quoting Mun. Code, § 15.36.030.A.) The Property, however, is essentially flat, surrounded by residential development, and served by straight, standard width streets. The Property is not in a mapped fire zone or an area designed as “wildland urban interface.” While commenters relayed general fears and hypotheticals, they did not point to specifics that would require denial of the Project or approval conditioned on fewer units. b. Dead End at Street B
Under the 2025 Fire Code, “[d]ead-end fire apparatus access roads in excess of 150 feet in length shall be provided with an approved area for turning around fire apparatus.” (24 Cal.

Code Regs., § 503.2.5 (2025).) The Zari Consulting Group claims that the Project violates this California Fire Code section by providing no hammerhead or turnaround at the east end of Street B. But the Zari Consulting Group mismeasured Street B, which is not more than 150 feet in length from the end of the hammerhead return, which is the point from which the dead end is measured. (Response from the Fire Department to the Zari Consulting Group Report, part of the February 10, 2026, City Council Staff Report for the Spring Grove Project (“February Project Staff Report”), at pp. 263–264 of the pdf.) Accordingly, no turnaround is required.

Even if Street B was more than 150 feet, which it is not, the Fire Code states that the “fire code official is authorized to increase the dimension of 150 feet (45 720 mm) where any of the following conditions occur: [t]he building is equipped throughout with an approved automatic 9 The Fire Department’s response to Zari Consulting Group’s comments explains that its policy is to interpret any local amendment to the California Fire Code that does not specifically negate an exception in the Fire Code as leaving that exception in place.

Agenda Item #11.1.

107377\19236158v2
sprinkler system.” (24 Cal. Code Regs., § 503.1.1.1.) The Project is so equipped. Further, the Fire Department reviewed the Project plans for compliance with applicable state and local Fire Codes and confirmed that turning radii are adequate throughout the Property. Thus, the dead end of Street B presents no adverse impact upon public health or safety and provides no reason to deny the Project or condition its approval on reduced density. c. Fire Hose Reach
The Zari Consulting Group claims that the Project violates Fire Code by exceeding the allowable distance between access roads and a point on the exterior wall of Building 2. This claim is incorrect and ignores an applicable exception.

Under the 2025 California Fire Code, a “fire apparatus access road . . . shall extend to within 150 feet of . . . all portions of the exterior walls of the first story of the building as measured by an approved route around the exterior of the building or facility.” (24 Cal. Code Regs., § 503.1.1 (2025).) According to the Fire Department diagrams in its response to Zari Consulting Group, all exterior walls of Building 2 are accessible within 150 feet for fire hoses. (February Project Staff Report, at p. 266 of the pdf.) Regardless, the Fire Code offers an exception to this rule: “the fire code official is authorized to increase the dimension of 150 feet where . . . the building is equipped throughout with an approved automatic sprinkler system installed in accordance with [provisions of the Fire Code].” (24 Cal. Code Regs., § 503.1.1 (2025).) Such an approved automatic sprinkler system will be installed throughout the Project’s buildings. Additionally, the Fire Department has 200-foot fire hoses, removing any concern about hoses being too short to reach the rear of Building 2. Thus, the Fire Department had authority to and did approve the Project as meeting Fire Code. Moreover, there is no evidence that the need for an extension hose, assuming arguendo that such a need exists, creates a significant, quantifiable adverse impact on public health and safety. d. Water Supply and Fire Flow
Zari Consulting Group suggests, but provides no evidence to support, that the municipal water system may lack sufficient flow to provide the Project with sufficient water for fire protection. The Fire Department has reviewed the Project and based knowledge of the municipal water system came to the opposite conclusion. Moreover, the CEQA addendum prepared for the Housing Element, which anticipated more units on the Property than the Project proposes, concluded that the City could meet the fire demand of such development. (City of St. Helena 2023 General Plan Update Addendum (Apr. 2023), at p. 75.) e. Staging Constraints
Zari Consulting Group alleges that the Project presents a narrow layout that may create bottlenecks for emergency vehicles. The Fire Department, in its review of the Project, found no such issue. The Project meets the required widths and clearances established in the Fire Code. (See 24 Cal. Code Regs., §§ 503.2.1, 503.2.2 (2025).) In addition, the Project’s covenants, conditions, & restrictions (“CC&Rs”) will require homeowners to park in their garages and Agenda Item #11.1.

107377\19236158v2
prohibit use of garages for storage. The Applicant has developed townhomes substantially similar to the homes proposed here throughout California and can attest to the fact that owners comply with the CC&Rs. Thus, there are no staging constraints. f. Aerial Apparatus Access
The analysis by Zari Consulting Group lastly claims that the Project’s plans do not demonstrate the required unobstructed width or vertical clearance for aerial ladder trucks. The Fire Department has verified that aerial equipment can access the third-story windows throughout the Project area. (See 24 Cal. Code Regs., § D105.1 (2025) [outlining aerial apparatus requirements]; see also February Project Staff Report, at p. 256 of the pdf [providing photographic evidence that the Fire Department’s ladders can reach heights greater than what the Project proposes].) Further, to the extent the City wants to require that the information be added more clearly on the building permit plans, it can do so without denying the Project or conditioning its approval on reduced density.
g. Payment of an In-Lieu Fee for Water Neutrality
Several public commenters took issue with the Project’s payment of an in-lieu fee to satisfy the City’s Water Neutrality Policy. Paying the in-lieu fee, however, fulfills the City’s requirements.

City Code allows for compliance with the Water Neutrality Policy through either (1) water supply and conservation projects; or (2) payment of an in-lieu fee. (Mun. Code, § 13.12.030.) By the Water Neutrality Policy’s terms, the fee amount is “equivalent” to the cost of retrofitting properties with sufficient water-saving devices to be water neutral and the cost of staff time. (Ibid.) Here, the engineering department approved the fee for the Project, which will provide more than enough funding to reach water neutrality because the analysis assumes an occupancy of eight people per townhome, which greatly exceeds the likely occupancy. (See February Project Staff Report, at p. 13 [outlining water neutrality calculations].) There is no evidence that the City will not use the fee as stated, thereby ensuring the Project does not alter the City’s water consumption. The Project will also be extremely water efficient, particularly compared to existing housing stock in the City. The Project therefore has no adverse impact on water neutrality, complies with the City’s applicable, written standards, and would not cause a significant adverse impact on public health or safety.
h. Design Features
Commenters have also provided subjective critiques of the Project’s aesthetics. These critiques are irrelevant to the decision before city council.

Under the HAA, the City must approve the Project if it “complies with applicable objective general plan, zoning, and subdivision standards and criteria” and does not present a specific, adverse impact on public health or safety. (Gov. Code, § 65589.5, subd. (j)(1) [emphasis added].) Under the HAA, “objective” means “involving no personal or subjective Agenda Item #11.1.

107377\19236158v2
judgment by a public official and being uniformly verifiable by reference to an external and uniform benchmark or criterion available and knowable by both the development applicant or proponent and the public official.” (Id., subd. (h)(9).) Commenters’ aesthetic critiques do not relate to such objective standards and have no bearing on public health or safety, and are thus irrelevant to council’s decision. (See, e.g., Letter from the California Department of Housing and Community Development to the Town of Mill Valley (Nov. 2, 2022), at pp. 3–4 [examples of what qualifies as an “objective” standard];10 see generally California Renters Legal Advocacy and Education Fund v. City of San Mateo (2021) 68 Cal.App.5th 820 [explaining the meaning of “objective” under the HAA].)
i. Additional Commenter Concerns
Public commenters also criticized the Project’s SDBL waivers and environmental analysis. The City’s responses to comments have addressed these concerns. As the City noted, absent a finding of a specific adverse impact, the City is obliged to grant the Project’s waivers under the SDBL. (See Gov. Code, § 65915, subd. (e).) Neither the City’s issuance of a California Environmental Quality Act (“CEQA”) exemption for the Project, nor the City’s design review approval of the Project (including the waivers granted as part of that process) is currently before the Council. And none of the other commenter concerns rises to the level of a “specific, adverse impact upon public health or safety.”

3. Penalties Under State Law if the City Denies the Project or Requires the Project to Have Fewer Units
As explained above, the Project is consistent with all applicable, objective standards, and thus protected by the HAA. If the City denies the Project in violation of the HAA, it risks the following penalties:
 The City may be subject to an HAA enforcement suit by the applicant, a person who would be eligible to apply for residency in the housing development project, or a housing organization. (Gov. Code, § 65589.5, subd. (k)(1)(A)(i).) o Senate Bill (“SB”) 808 has recently accelerated the timeline for judicial review of a housing development permit denial. Now, once a petitioner files suit to contest the denial, the court clerk must set a hearing for review of the petition no later than 45 calendar days from the date of filing. The court must render its decision no later than: (1) 30 calendar days after the matter is submitted; or (2) 75 calendar days after the petition is filed, whichever is earlier. (Code Civ. Proc., § 1094.9, subd. (d).)
 A reviewing court must issue an order compelling the city to comply within a time period not to exceed 60 days, and that order can include an order that the city “take 10 Available at https://www.hcd.ca.gov/sites/default/files/docs/planning-and-community/HAU/mill-valley-TA110222.pdf.

Agenda Item #11.1.

107377\19236158v2
action on the housing development project.” (Gov. Code, § 65589.5, subd. (k)(1)(A)(ii).)
 The court may also issue an order directing the city to “approve the housing development project” if the court finds that the city acted in “bad faith” when it disapproved or conditionally approved the housing development in violation of the HAA. (Gov. Code, § 65589.5, subd. (k)(1)(A)(ii).)
 The court must award reasonable attorney’s fees and costs of suit to the plaintiffs/applicants. (Gov. Code, § 65589.5, subd. (k)(1)(A)(ii).) Recently, Assembly Bill (“AB”) 712 confirmed that this provision is mandatory and expanded coverage beyond just HAA claims so that mandatory fee recovery applies to all claims asserting rights under broadly defined housing reform laws. (Gov. Code, § 65914.2, subd. (b)(1).)
 If the city fails to comply with the court’s order, then the court “shall impose” upon the city fines in a minimum amount of $10,000 per housing unit in the housing development project. Because the Project consists of 41 units, the total amount of fines could be a minimum of $410,000. In determining the amount of this fine, the court must consider the city’s progress in attaining its Regional Housing Needs Allocation (“RHNA”) numbers and any prior violations of the HAA. (Gov. Code, § 65589.5, subd. (k)(1)(B).)
 If the City were to persist in its denial despite a court order, then the City risks the court finding that the city acted in “bad faith” by failing to carry out the court’s order within the time period prescribed by the court, at which point the court “shall multiply” the amount of the fine identified above by a factor of five. Assuming a court were to impose the minimum of $10,000 per housing unit for a total of $410,000, the fine against the city under these circumstances could amount to $2,050,000. (Gov. Code, § 65589.5, subd. (l).)
 Pursuant to recent amendments to the HAA, if a court has previously found that the city violated the HAA within the “same planning period,”11 then the court also “shall multiply” these fines “by an additional factor” for each previous violation. (Gov.

Code, § 65589.5, subd. (l).)
Should the City violate state housing laws, the financial risks are large. For example, the City of Berkeley was ordered to pay $1.4 million to reimburse a developer for its attorneys’ fees and 2.6 million in fines when a judge determined it violated the HAA. (Frances Dinkelspiel, Berkeley must pay $4M after illegally blocking housing project at Ohlone shellmound site, 11 This phrase is not defined in the HAA. Presumably, this phrase is a reference to the Housing Element cycle, which is set to expire in 2031 for the City of St. Helena.

Agenda Item #11.1.

107377\19236158v2
Berkeleyside (Feb. 16, 2024).12) The City of La Cañada Flintridge also received an adverse ruling on claims under the HAA and had to pay the developer’s attorneys’ fees and costs. That city contemplated appealing the adverse decision but opted not to do so when ordered to post a $14 million bond to cover the developer’s potential losses from litigation delay. (Jeff Collins, La Cañada Flintridge Abandons ‘Builder’s Remedy’ Appeal, Pasadena Star-News (Mar. 7, 2025).13) In addition to financial penalties, the City also would still have to approve the Project.

In sum, the California Legislature has sought to discourage local jurisdictions from disapproving housing, particularly housing identified to meet that jurisdiction’s RHNA in its Housing Element.

4. Conclusion
For the foregoing reasons, there is no basis to deny the Project or to condition Project approval on reducing units. There is no evidence showing that the Project would have a specific adverse impact on public health or safety if approved with the conditions the City has already proposed.14 The City can avoid steep penalties by voting to approve the Project.

Finally, it should not be lost that the Project will help to meet the pressing need for housing—including affordable housing—in the City. We therefore urge City Council to approve the Project.

Sincerely,
Cox, Castle & Nicholson LLP
Linda C. Klein
Cc: Kelso Barnett
12 Available at https://www.berkeleyside.org/2024/02/16/court-ruling-1900-fourthstreet#:~:text=new%20window)%20Facebook- ,1900%20Fourth%20St.,used%20to%20build%20affordable%20housing. 13 Available at https://www.pasadenastarnews.com/2025/03/05/la-canada-flintridge-abandons-builders-remedyappeal/. 14 These conditions already including the requirement for “NFPA 13 fire sprinklers,” compliance with the City’s Fire Code, and one-hour minimum fire resistant construction in certain areas.

Agenda Item #11.1.

From: Duran Muniz
To: City Clerk; Public Comment
Cc: Joseph P. Zari, PE; Tamara Sorensen; Cameron Crebs
Subject: Re: Spring Grove - Plan Review Report
Date: Tuesday, February 10, 2026 11:17:55 AM
Attachments: Spring Grove - Wildland Fire Analysis - 02.10.2026.pdf Dear City Staff,
We are submitting the attached Wildland Fire Analysis for the proposed Spring Grove development located at 1447, 1505, and 1515 Spring Street in St. Helena, CA.

This analysis includes:

A wildland hazard assessment of the surrounding area
An emergency evacuation evaluation for the proposed development Case studies and examples of regional traffic and evacuation performance from other properties and emergency events throughout California.

Please feel free to contact me with any questions.

Thank you,
Duran Muniz | Project Manager
Zari Consulting Group, Inc.

Fire Protection Engineers | Building Code Experts
C: +1.707.338.0728 | [email protected]
www.ZariCode.com
West Coast Regional Offices
755 Baywood Drive, 2nd Floor | Petaluma, CA 94954
350 Rhode Island Street, South Building Suite 240 | San Francisco, CA 94103 South-West Regional Office
600 17th Street, Suite 2800 South | Denver, CO 80202
Mid-West Regional Office
14301 FNB Parkway, Suite 100 | Omaha, NE 68154
East Coast Regional Offices
90 Canal Street, 4th Floor | Boston, MA 02114
1500 Market Street 12th Floor – East Tower | Philadelphia, PA 19102 From: Duran Muniz <[email protected]>
Sent: Monday, February 9, 2026 2:18 PM
Agenda Item #11.1.

To: [email protected] <[email protected]>; [email protected] <[email protected]> Cc: Joseph P. Zari, PE <[email protected]>; Tamara Sorensen <[email protected]>; Cameron Crebs <[email protected]> Subject: Spring Grove - Plan Review Report
We are submitting the attached Third‑Party Plan Review for the proposed Spring Grove development located at 1447, 1505, and 1515 Spring Street in St. Helena, CA. This review evaluates the proposed site layout, infrastructure, and overall community design as currently submitted.

The report includes an assessment of the fire hazard history of the area and evaluates the required fire department access, including the need for a secondary entrance for a project of this size.

It also identifies several items that do not meet current code requirements, including:

Non‑compliant dead‑end fire access conditions exceeding allowable lengths without a turnaround.

Fire hose reach and travel distances that exceed the 150‑foot maximum permitted by code.

As outlined in the report, there are multiple areas where the proposed design does not meet the California Fire Code and applicable NFPA standards, and where modifications will be required. In addition to the identified code deficiencies, the report emphasizes that, given the high‑hazard wildland‑urban interface conditions, the fire history in St. Helena, and the egress constraints of the site, the development should be evaluated using a more conservative approach. Meeting only the bare minimum code requirements would not adequately address the elevated risks associated with this location.

I will follow this submittal with a Wildland Fire Analysis for the proposed site and the surrounding St. Helena area tomorrow morning.

Please feel free to reach out with any questions.

Thank you,
Duran Muniz | Project Manager
Zari Consulting Group, Inc.

Fire Protection Engineers | Building Code Experts
C: +1.707.338.0728 | [email protected]
www.ZariCode.com
West Coast Regional Offices
755 Baywood Drive, 2nd Floor | Petaluma, CA 94954
350 Rhode Island Street, South Building Suite 240 | San Francisco, CA 94103 Agenda Item #11.1.

South-West Regional Office
600 17th Street, Suite 2800 South | Denver, CO 80202
Mid-West Regional Office
14301 FNB Parkway, Suite 100 | Omaha, NE 68154
East Coast Regional Offices
90 Canal Street, 4th Floor | Boston, MA 02114
1500 Market Street 12th Floor – East Tower | Philadelphia, PA 19102 Agenda Item #11.1.

Zari Consulting Group, Inc | Fire Protection Engineers | Building Code Experts 755 Baywood Drive, 2nd Floor | Petaluma, CA | 94954
t +1.888.779.3397 | ZariCode.com

WILDLAND FIRE ANALYSIS
PHASE 3
Spring Grove
1447, 1505, and 1515 Spring Street
St. Helena, CA
February 10, 2026
© 2026 ALL RIGHTS RESERVED.

Agenda Item #11.1.

3rd Party Plan Review 1 February 10, 2026
Spring Grove ZCG No. 0126009

TABLE OF CONTENTS
Contents

1. INTRODUCTION 3

2. PROJECT DESCRIPTION 4
a) Existing Conditions 4
b) Proposed Construction 5
c) Construction and Infrastructure 6

3. WILDFIRE ASSESSMENT 7
a) Vegetation Density 7
b) Climate and Environmental 8
c) Topography and Slope 8
d) Wind Effects 9
e) Fire History 9
f) Adjacent Properties 10

4. EMERGENCY EVACUATION ANALYSIS 11
a) Site Evacuation Constraints 11
b) City of St. Helena Evacuation Protocols 12
c) Site Access (NFPA 1140 & SHMC 15.36.100) 12
d) Staging and Evacuation 13

5. REGIONAL TRAFFIC AND EVACUATION ANALYSIS 14

6. CONSTRUCTION IN WILDFIRE PRONE AREAS 15
a) Construction 15
b) NIST Hazard Mitigation Methodology (HMM) 16

7. WILDFIRE MITIGATION 17
a) Defensible Space 17
Agenda Item #11.1.

Wildfire Analysis 2 February 10, 2026
Spring Grove ZCG No. 0126009
b) Vegetation and Maintenance 18
c) Irrigation Strategies 18
d) Relative Water Content (RWC) 18
e) Soil Maintenance 19
f) Tank and Hydrant Systems 19
g) Evacuation Road 19

8. CONCLUSION 20
Agenda Item #11.1.

Wildfire Analysis 3 February 10, 2026
Spring Grove ZCG No. 0126009

1. INTRODUCTION
Zari Consulting Group, Inc. (ZCG) has been retained to perform a detailed Wildland Fire Analysis for the proposed Spring Grove residential development located at 1447, 1505, and 1515 Spring Street in St. Helena. The primary objective of this analysis is to evaluate the wildfire hazards associated with the site’s specific location, its local topography, and its existing vegetative fuels.

This report serves as a fire protection engineering assessment, providing evidence-based recommendations intended to mitigate the risk of structure ignition and facilitate safe, efficient emergency operations in an area recognized as one of the most fire-prone regions in California.

This report utilizes the 2022 edition of NFPA 1140, Standard for Wildland Fire Protection, which serves as the primary consolidated national standard for fire management and infrastructure protection. Furthermore, this review incorporates the St. Helena Municipal Code (SHMC) Chapter

15.36, which adopts and amends the California Fire Code to address the unique geographical, climatic, and topographical challenges specific to the St. Helena area. Specifically, SHMC

15.36.010 provides foundational findings stating that response time and aggressive on-site fire mitigation, including the use of fire-resistant materials, and internal sprinklers, are critical to public health and safety.

As fire protection engineers, we emphasize that code compliance is the absolute minimum standard. However, in high-hazard zones, good engineering practices dictate that a more stringent approach to community safety is required. This analysis is built upon the "two-pronged approach" identified by the State Fire Marshal: aggressive fuel modification combined with exterior exposure protection. This report factors in state-wide data identifying California as having the second-largest number of small communities with limited evacuation routes in the nation. By addressing the property as a whole, this report seeks to provide a guideline for future Napa County developments.

This analysis integrates the latest CAL FIRE Local Responsibility Area (LRA) Fire Hazard Severity Zone (FHSZ) maps. As of February 2025, CAL FIRE has reclassified significant portions of the Napa Valley floor between St. Helena and Calistoga as a Very High Wildfire Hazard Severity Zone.

Data from First Street (Fire Factor) indicates that St. Helena possesses a "Major" risk of wildfire, with 99% of all properties (approximately 2304 properties) having a significant risk of being affected by wildfire over the next 30 years. This report also factors in findings from StreetLight Data which highlights the extreme vulnerability of rural communities with limited escape routes. Adhering only to minimum state standards in a region where fire behavior frequently overwhelms standard suppression resources is considered an operational risk to both life and property.

Agenda Item #11.1.

Wildfire Analysis 4 February 10, 2026
Spring Grove ZCG No. 0126009

2. PROJECT DESCRIPTION
a) Existing Conditions
The project site currently consists of three parcels totaling approximately 2.52 acres of land that has historically served as a lower-density residential and agricultural buffer. Currently, the site is developed with older single-family residences and associated wood-frame outbuildings. The existing environment is defined by a dense over-canopy of mature trees, unmaintained shrubbery, and a creek that runs along the southern boundary.

While the topography at the immediate street level is relatively flat, the site is situated at the absolute toe of the western foothills of the Mayacamas Mountains. This location acts as a natural catchment area for wind-driven embers and convective heat descending from the forested slopes above.

Existing fuel conditions reflect decades of growth, where accumulated surface litter and "ladder fuels" (shrubs and low branches that allow ground fires to climb into the canopy) have created an environment prone to high-intensity burning. The current vegetation includes a mix of invasive annual grasses and aging hardwood species that have not been subjected to a regular maintenance, resulting in dense vegetation that provides high-continuity fuels for a fire front.

Agenda Item #11.1.

Wildfire Analysis 5 February 10, 2026
Spring Grove ZCG No. 0126009
b) Proposed Construction
The proposed project involves the demolition of the existing residences to clear the way for a highdensity modern subdivision of 41 solar-powered, all-electric townhome-style condominiums (Buildings 1–6). This shift from three low-density homes to 41 high-density units represents a nearly 13-fold increase in the life load and an increase in the concentrated fuel load of the property. The design introduces modern architectural features such as "paseos" (narrow pedestrian corridors) and closely grouped multi-unit blocks that require specific fire-protection features.

The transition to all-electric living is a positive step for energy efficiency, but the concentration of solar panels and potentially on-site energy storage systems (ESS) adds a layer of complexity for fire department suppression efforts. Solar arrays can maintain dangerous voltages even after main power is cut, and high-density wood-frame construction combined with localized electrical hazards can lead to rapid fire growth scenarios. The close proximity of these buildings to one another creates a heightened risk of house to house fire spread via embers of plastic, fabric, and building materials.

In a high-wind event, the lack of separation between the six building groups can create a fire where it spreads from structure to structure through radiant heat and ember intrusion. This density (16.3 units/acre) essentially creates an fuel load within a wildland area, requiring the entire site to function as a singular unit.

Agenda Item #11.1.

Wildfire Analysis 6 February 10, 2026
Spring Grove ZCG No. 0126009
c) Construction and Infrastructure
The framework for the Spring Grove development is defined by its architectural features and the egress constraints of its high-density site plan. In a Very High Fire Hazard Severity Zone, the proposed construction materials and infrastructure determines the community fire protection features. The following parameters detail the proposed construction type, expected population density, and the infrastructure limitations that impact both fire mitigation and emergency response. • Construction Type: Type V-B (wood-frame, non-rated). This construction type relies on combustible structural members (2x4 or 2x6 framing). Without fire-rated exterior assemblies, the subdivision is vulnerable to external radiant heat and ember storms. In a Wildland Urban Interface (WUI) environment, Type V-B construction requires the highest level of external hardening to survive a wildfire passage. The use of wood-based structural elements means that once an ignition occurs, the structure itself becomes a fuel source for its neighbors.
• Occupancy: Group R-2 (Multi-family Residential).
• Estimated Population: Based on unit configurations of 3 to 4 bedrooms per unit, the site is projected to house between 112 and 143 residents at full occupancy. This population density increases the life load on the site's egress infrastructure. During an emergency, over 100 people and dozens of vehicles would be attempting to exit via a single road while fire engines are attempting to stage and deploy.
• Infrastructure Constraints: The site utilizes a restrictive "flag-pole" layout. A single 26- foot-wide access drive (Street A) provides the only ingress and egress for the entire development. This configuration creates a single point of failure for both evacuation and emergency response, where a single incident (fallen tree, blocked vehicle, or fire event at the entrance) could effectively isolate the entire community from emergency services.

Furthermore, the 93,518 square feet of building area requires a robust water supply that may exceed the capacity of a single-ended main, potentially leading to pressure drops when multiple hydrants are opened simultaneously.

Agenda Item #11.1.

Wildfire Analysis 7 February 10, 2026
Spring Grove ZCG No. 0126009

3. WILDFIRE ASSESSMENT
Common topographic fire hazards.(Left) Creeks can collect dry debris, increase heat, and funnel superheated air. (Middle) Wind can be directed over mountains. (Right) The steepness of a slope can significantly influence fire spread behavior. Images adapted from FEMA publications (2023). a) Vegetation Density
The vegetation in the St. Helena area consists of mixed-severity fire zones. According to recent satellite data (LiDAR) and regional surveys, the density profile in these high-risk zones typically breaks down as 57% grass (under 1 foot), 14% shrubs (1–15 feet), and 29% trees (over 15 feet). • Chaparral (Dense Shrublands): Present on the nearby hillsides, characterized by Manzanita and Chamise (1–15 ft tall). These are highly volatile fuels that form continuous, interwoven stands. These species contain flammable resins and oils that allow them to burn with extreme intensity even when green. By age 50, hard chaparral can consist of up to 50% dead, dry, and highly flammable material. This old growth chaparral is often described by firefighters as highly flammable due to its ability to generate 30-foot flames in moderate winds.
• Hardwood Forests/Oak Woodlands: Species such as California bay, madrone, and oak predominate. Due to decades of fire suppression, these forests are often 5–6 times denser than historic conditions. This overcrowding leads to excessive competition for water, higher tree mortality (aggravated by drought and beetle infestations), and a dangerous increase in surface fuels (leaf litter and downed branches).
• Ladder Fuels: LiDAR mapping focusing on the 1–4 meter zone indicates a significant presence of ladder fuels such as shrubs, vines, and lower branches that allow ground-level fires to climb into the tree canopy. This transitions a manageable surface fire into a highintensity crown fire that is difficult to suppress from the ground and produces continuous ember hazards.
• Riparian Fire Wick: The southern creek setback acts as a natural fuel wick. Per SHMC

15.36.010(A), the city finds that vegetation is a primary factor contributing to fire potential.

Contrary to some expectations, research from 2000–2018 shows that most structures destroyed in California wildfires were located in hardwood forests, woodlands, or shrublands rather than coniferous forests. The riparian zone provides a continuous, unmaintained fuel path that leads fire directly to the foundations of Buildings 1, 2, and 6.

Agenda Item #11.1.

Wildfire Analysis 8 February 10, 2026
Spring Grove ZCG No. 0126009
b) Climate and Environmental
St. Helena experiences a Mediterranean climate characterized by hot, dry summers and low fuel moisture. Data from First Street indicates a projected temperature increase of 1 to 4 degrees F over the next 30 years. These rising temperatures increase the rate of evaporation and the "Vapor Pressure Deficit" (VPD), causing soil and vegetation to dry more quickly and remain flammable for longer periods throughout the year.

Combined with "Diablo Winds" (hot, dry northeasterly winds), these conditions accelerate fire spread at rates that overwhelm standard suppression resources. Recent history shows that aboveaverage precipitation often leads to abnormal vegetation growth, resulting in even higher fuel loads during subsequent dry seasons (notably seen in 2017, 2018, and 2020). This cycle is a defining feature of the Napa Valley fire environment, making current fuel conditions highly deceptive. During these wind events, relative humidity can drop into the single digits, making every leaf and mulch bed on the property a potential ignition point for wind-blown embers. c) Topography and Slope
The site’s position at the base of a significant western slope is a major risk factor. Fire travels significantly faster uphill due to pre-heating of fuels but, nocturnal drainage flow of dry, cold air can also push fires downhill toward the valley floor with enhanced speed. NFPA 1140 Section 24.3.1.1 requires engineers to document the structure’s location in relation to topographical features like natural chimneys, ridges, saddles, or steep draws.

The Mayacamas Mountains to the west of the site act as a massive heat-sink and wind-funnel.

During a wildfire, these slopes project radiant heat and wind-driven embers directly toward the Spring Grove site. Because fire effectively doubles in speed for every 10-degree increase in slope, any fire starting on the ridges above St. Helena will reach the city limits in a fraction of the time anticipated on level ground. The project site sits in a natural catchment area where these topographical heat-flow patterns converge. This positioning means that structures are exposed to the maximum intensity of fire coming off the hills, as flames can reach their greatest length just as they hit the level ground of the valley floor.

Agenda Item #11.1.

Wildfire Analysis 9 February 10, 2026
Spring Grove ZCG No. 0126009
d) Wind Effects
Wind is the most influential variable in fire events in the Napa Valley. Historically, wind-driven embers have been documented traveling over 1 mile ahead of the actual fire front, igniting homes before the main fire front arrives. In a high-density development like Spring Grove, the narrow spacing between the six building groups can create a wind-tunnel or Venturi effect.

This accelerates the movement of embers through the community, forcing them into building crevices, vents, and eaves. This structure-to-structure ignition, where the heat from one burning building ignites its neighbor, is the leading cause of structure loss in urban WUI disasters. Without substantial separation or aggressive hardening, the 41 units act as a single, massive fuel block.

Additionally, wind patterns in the valley can shift rapidly, making evacuation routes that appear safe at the onset of a fire suddenly untenable due to thick smoke and blowing debris. e) Fire History
Overall, St. Helena is categorized as a high hazard area for wildfires. The City of St. Helena "Fire Resilience" website explicitly states that "residents live and work in a fire-prone area." According to Cal Fire Hazard Severity Zone map, the high severity zone is located 0.5 miles from the proposed Spring Grove site. Recent history confirms that Napa County remains under constant threat from wildfire ignitions, even during years with high rainfall. Modern fire events are becoming increasingly destructive due to urban expansion into wildland areas, with the 2020 fire season alone burning over 200,000 acres in Napa County alone.

Fires in Napa County:
• 2017 Tubbs Fire: Demonstrated the "urban conflagration" effect, where fires starting in wildlands penetrated city limits and destroyed homes in "lower risk" urban areas through massive ember storms in neighboring Sonoma County. 36,807 acres (57.5 sq. miles) • 2020 Glass Fire: Burned 40,000+ acres, causing destruction to wineries, resorts (such as Meadowood), and 308 homes in Napa County. It demonstrated that fires can jump the Napa River and Hwy 29 with ease, directly threatening the core of St. Helena.

Agenda Item #11.1.

Wildfire Analysis 10 February 10, 2026
Spring Grove ZCG No. 0126009
• 2025 Berry Fire: Occurred in the Knoxville Recreation Area. Managed by the CAL FIRE Sonoma-Lake-Napa Unit, it serves as a contemporary reminder of persistent ignition potential and the continuous demand on regional fire resources. • 2025 Pickett Fire: Napa County. The fire spread rapidly through terrain fueled dry vegetation typical in this area. Reaching a final size of 6,819 acres (10.3 sq. miles) • 2017 North Bay Fires (Atlas & Nuns): Part of a historic "Firestorm" that destroyed over 1,200 structures in Napa County alone. The Nuns fire burned largely in the Mayacamas Mountains west of the site.
• 2020 LNU Lightning Complex: The largest fire in Napa County history, burning approximately 165,000 acres within the county (about one-third of its total land area). It destroyed over 522 structures in Napa County, proving that lightning-caused conflagrations can overwhelm urban centers.
• 1964 Hanley Fire: A historic precursor following a nearly identical path to modern fires, confirming a multi-generational fire cycle driven by the region's unique geography.

Modern fires in Napa County are documented as more destructive than similarly sized historical fires. For example, the 2020 Glass Fire caused significantly more structural damage than historical events of similar acreage due to increased density in the Wildland Urban Interface (WUI). This trend highlights the inadequacy of traditional buffer zones when faced with modern climate stressors. f) Adjacent Properties
The site is surrounded by residential properties and open land with heavy fuel loads. The proposed density of 16.3 units/acre is significantly higher than the surrounding single-family dwellings, creating a localized high-intensity fuel source. Data from "Wildfire Risk to Communities" identifies St. Helena as having high susceptibility due to the wildfire likelihood and populated areas.

Per SHMC 15.36.100, Developments of one, two-family or multi family dwellings where the number of dwelling units exceeds thirty (30) shall be provided with two separate and approved fire apparatus access roads, and shall meet the requirements of Section D104.3. Reference sections below.

If a fire starts in the creek or an adjacent property, the lack of significant separation between the townhome blocks increases the likelihood that the entire 41-unit community will be involved simultaneously. This density turns a single structure fire into a multi-building conflagration that can quickly exhaust local fire department resources. Under NIST Scenario 3 (SSD less than 25 feet), adjacent structure ignition becomes the primary driver of structure loss, far outweighing the threat of direct wildland flame contact. The physical proximity of Building 5 to the southern boundary makes it a primary target for exposure from the creek corridor.

Agenda Item #11.1.

Wildfire Analysis 11 February 10, 2026
Spring Grove ZCG No. 0126009

4. EMERGENCY EVACUATION ANALYSIS
Emergency evacuation is the foremost life-safety priority for the Spring Grove development. The following analysis evaluates the proposed site plan against City of St. Helena emergency protocols and state/national standards.
a) Site Evacuation Constraints
The Spring Grove subdivision is currently designed with only one primary ingress and egress point (Street A). With an estimated population of 112 to 143 residents and approximately 82 to 93 vehicles, the internal roadway system is prone to total blockage during a egress event. The "flagpole" layout on Street A creates a bottleneck where a single abandoned vehicle, a fallen tree, or an active fire at the entrance would effectively trap the entire population of the 41-unit development.

The impact of a single-exit environment during a smoke-filled emergency often leads to panic driven blockages. In the event of a rapid-onset wildfire, the arrival of fire engines on Street A could simultaneously prevent residents from fleeing while responders are attempting to enter, creating an inherent risk. Case studies of similar high-density WUI areas, such as the 2025 Pacific Palisades fire, show that gridlock can become so severe that residents are forced to abandon their vehicles and flee on foot. In that event, emergency responders had to use bulldozers to plow through abandoned cars to reach the fire front
Agenda Item #11.1.

Wildfire Analysis 12 February 10, 2026
Spring Grove ZCG No. 0126009
b) City of St. Helena Evacuation Protocols
As demonstrated during the June 19, 2024, Citywide Evacuation Drill, St. Helena utilizes specific life-safety markers that the Spring Grove project must integrate:
• Hi-Lo Sirens: In an emergency, the Police Department will utilize "Hi-Lo" sirens to signal an immediate evacuation order. The narrow 26-foot throat of Street A must remain clear of all obstructions to allow these emergency vehicles to navigate while residents are attempting to exit.
• Evacuation Tags: Residents must place designated tags on their homes or doors to signal that the premises have been cleared. This ensures that first responders do not waste critical minutes performing "primary searches" of structures while a fire front is approaching. • Evacuation Meeting Points: Residents of the Spring Grove development (located West of Main Street) are directed to evacuate to St. Helena Primary School at 1701 Grayson Avenue. The evacuation route involves navigating Spring Street to Main Street, a corridor that is historically prone to extreme congestion during regional events. The project must have a formal community evacuation plan that coordinates these actions for the additional population.
c) Site Access (NFPA 1140 & SHMC 15.36.100)
Good engineering practice and NFPA 1140 Table 11.1.4.1(a) mandate that any residential development exceeding 30 households must be equipped with at least two separate fire access routes. The St. Helena municipal code specifically amended the CFC to state: SHMC 15.36.100, Developments of one, two-family or multi family dwellings where the number of dwelling units exceeds thirty (30) shall be provided with two separate and approved fire apparatus access roads, and shall meet the requirements of Section D104.3.

Given the Very High Fire Hazard Severity Zone designation of the Napa Valley floor, a secondary access point is a non-negotiable life-safety requirement. A "remote" access point is defined as being located a distance away from the primary entrance equal to at least half the diagonal dimension of the property. The lack of a secondary exit is the single greatest life-safety liability in the current proposal.
(Left) Schematic illustrating common life safety concerns and stresses affecting the general public, first responders, and the overall transportation network during major wildfire events. (Right) Diagram illustrating the concept of providing separate and independent egress routes from a neighborhood to improve evacuation safety during wildfire conditions.

Agenda Item #11.1.

Wildfire Analysis 13 February 10, 2026
Spring Grove ZCG No. 0126009
d) Staging and Evacuation
During a rapid-fire event, the Fire Department must stage apparatus (engines and aerial trucks) to perform structure protection while residents are simultaneously attempting to evacuate. The lack of on-site staging areas in the current proposal means that a fire truck parked on Street B to protect Building 1 would physically block the only evacuation path for residents in Buildings 2 through 6.

This creates a trap where emergency response activity directly inhibits the life-safety of the residents. Strategic planning requires that access roads be wide enough to allow for apparatus flow and simultaneous resident egress.

Agenda Item #11.1.

Wildfire Analysis 14 February 10, 2026
Spring Grove ZCG No. 0126009

5. REGIONAL TRAFFIC AND EVACUATION ANALYSIS
A review of regional data indicates that the Spring Grove development's egress challenges are reflective of a broader, systemic risk within California's WUI communities.

National and State Context: According to traffic analytics from StreetLight Data, California contains 14 of the top 100 communities in the United States with the most limited emergency escape routes. This analysis, which focused on towns with populations under 40,000, highlights that St.

Helena is part of a high-risk group where the "Paradise" scenario, residents being trapped or forced to abandon vehicles, is a statistically significant possibility. The 2018 Camp Fire, which killed 86 people, remains the primary reference point for how fast-moving blazes can overwhelm rural towns with limited exit capacity (ATTACHMENT 1).

St. Helena Specific Constraints: St. Helena currently supports approximately 4000 housing units (ATTACHMENT 3). Local safety reviews have emphasized the need for a cumulative exit evacuation analysis that accounts for current and projected populations. The addition of 41 highdensity units at Spring Grove increases the pressure on a road network that is already classified as having a high fire severity risk. Growth management in this context is a "public health and safety matter" because the existing evacuation infrastructure has finite capacity. Without a cumulative analysis, the city risks creating an environment where regional gridlock prevents residents from even reaching the main arterial roads like Highway 29.

Operational Risk and Case Studies: The 2025 Pacific Palisades "Evacuation Disaster" provides a modern parallel to the risks inherent at Spring Grove. In that incident, despite years of requests for detailed fire preparation plans, the community experienced total gridlock. Residents were stuck in vehicles as flames approach nearby, ultimately leading to an order for people to abandon their cars on Sunset Boulevard. The use of bulldozers to clear abandoned cars to make way for emergency crews demonstrates that a single-exit or single-road strategy (like Street A) can result in a total failure of both life-safety and suppression efforts. This case highlights that "orderly" evacuation is often a fallacy in rapid-onset events where panicked residents abandon vehicles when traffic stops moving (ATTACHMENT 9).

Evacuation Behavioral Modeling and Bottlenecking: Research from the University of California, Berkeley Institute of Transportation Studies (ATTACHMENT 2) indicates that wildfire evacuation decision-making and departure timing are complex variables. Modeling suggests that infrastructure limitations often lead to "bottlenecking" where the physical capacity of the road cannot handle the simultaneous departure of even a small percentage of the population. Specifically:
• Infrastructure Capacity: Infrastructure capacity is often the primary bottleneck, regardless of how quickly residents receive alerts.
• Phased Evacuation Challenges: While "phased" evacuations can theoretically reduce peak demand, they are often impossible to coordinate during high-intensity fires that threaten multiple zones simultaneously.
• Resident Behavior: Data suggests that joint-choice making and resident panic can lead to non-linear departure times, causing sudden surges in traffic that the existing road network cannot absorb.

The Spring Grove project, by adding 41 units with only one exit point, essentially creates a localized bottleneck that feeds into a larger, regional bottleneck, significantly increasing the risk of entrapment during a fire event.

Agenda Item #11.1.

Wildfire Analysis 15 February 10, 2026
Spring Grove ZCG No. 0126009

6. CONSTRUCTION IN WILDFIRE PRONE AREAS
Regulation of structures in Wildland Urban Interface (WUI) zones focuses on creating a "defensible structure" that can survive the passage of a fire front without direct human intervention. Per the latest data, homes built under California's Chapter 7A WUI codes are three times more likely to survive than older structures. The Spring Grove project shall consider these standards not just as a code requirement, but as a core design philosophy.
a) Construction
The Spring Grove subdivision can improve structural hardening to withstand intense ember storms and radiant heat by incorporating the following elements:
• Roofing: Constructed with Class A fire-rated materials, such as composite shingles, metal, clay, or concrete tile. Class A roofing is the first line of defense against overhead ember ignition. Any roof-mounted solar arrays must be installed such that they do not create "debris traps" where leaves and twigs can collect under the panels. • Ember-Resistant Vents: Attic, eave, and crawlspace vents should demonstrate the ability to resist the intrusion of flame and embers. Vents must be screened with corrosion-resistant, noncombustible wire mesh with openings not to exceed 1/8 inch, complying with ASTM E2886. This specific mesh size is proven to block up to 80% of hazardous firebrands while still allowing necessary airflow.
• Exterior Siding and Walls: Exterior vertical walls of noncombustible or ignition-resistant materials such as fiber-cement siding, brick, stucco, or masonry. Wood-based siding is highly discouraged and at minimum should meet strict 1-hour fire ratings if utilized. The first 6 inches of vertical space above any horizontal surface (decks, soil) should be a noncombustible material to prevent wicking fire into the wall cavity. • Windows and Doors: Exterior windows and glass within doors should be dual-pane tempered glass. This resists the intense radiant heat that causes single-pane glass to shatter, which would otherwise allow embers to enter and ignite the home's interior. Exterior doors must be solid-core or fire-rated for at least 20 minutes. • Decks and Overhangs: Walking surfaces of decks and porches must be constructed of noncombustible materials. All eaves and overhanging projections must be "boxed-in" (soffited) with ignition-resistant materials to prevent embers from finding weak areas in the roof-to-wall junction. Wood decks attached to homes act as "fuses," carrying ground fire directly to the structure's siding and eaves.

Agenda Item #11.1.

Wildfire Analysis 16 February 10, 2026
Spring Grove ZCG No. 0126009
b) NIST Hazard Mitigation Methodology (HMM)
The National Institute of Standards and Technology (NIST) is an agency of the U.S. Department of Commerce. NIST’s Engineering Laboratory, specifically its Fire Research Division, provides the scientific basis for fire codes and standards through advanced research on Wildland Urban Interface (WUI) fire behavior. NIST research (specifically Technical Note 2205) indicates that in high-density developments like Spring Grove, the primary fire threat transitions from wildland embers to adjacent structure exposure.
• High Structure Density Risk: NIST findings state that "one structure ignition leads to large losses in high-density communities. Spacing between homes affects community survivability. In this 41-unit configuration, complete structure and parcel hardening are essential for the survivability of the entire community. If Building 3 ignites, its radiant heat will likely ignite Building 4 unless both are fully hardened. • Projections and Appendages: Fences, patio covers, and other attached structures must meet 1-hour fire ratings. Noncombustible "breaks" must be installed in any continuous fencing that connects buildings to one another. Wood-to-wood contact between fences and homes shall be evaluated and approved.

Agenda Item #11.1.

Wildfire Analysis 17 February 10, 2026
Spring Grove ZCG No. 0126009

7. WILDFIRE MITIGATION
a) Defensible Space
Per NFPA 1140 Section 26.1 and SHMC 15.36.080, a mandatory 100-foot defensible space is required, focusing on the "Home Ignition Zone" (HIZ). Priority must be given to the area 100 to 200 feet from the structures:

1. Zone 0 (The Ember-Resistant Zone, 0–5 feet): This is the most critical zone. It must be entirely noncombustible (rock, stone, or concrete). No mulch, firewood, furniture, woody shrubs, or overhanging branches are permitted. This zone prevents smoldering material from igniting the building at the sill plate. Any vegetation in this zone must be limited to sparse, low-growing succulents with extreme water content.

2. Zone 1 (The Lean, Clean, and Green Zone, 5–30 feet): Remove all dead plants, pine needles, and surface litter. Prune trees to a height of 6–10 feet from the ground to eliminate "ladder fuels." Ensure horizontal separation between tree crowns (minimum 10 feet) to prevent fire spread across the canopy.

3. Zone 2 (The Reduced Fuel Zone, 30–100 feet): Create vertical and horizontal spacing between shrubs and trees. Mow grass to a maximum height of 4 inches to reduce flame length and intensity. This zone serves to slow the fire down before it reaches the structures.

Agenda Item #11.1.

Wildfire Analysis 18 February 10, 2026
Spring Grove ZCG No. 0126009
b) Vegetation and Maintenance
A formal Vegetation Management Plan (VMP) must be a condition of approval. Per NFPA 1140 Section 26.2.2, all live vegetation must be maintained annually before the start of the summer fire season. Maintenance must include the removal of ladder fuels to preclude ground fires from spreading into the tree canopy. The developer must comply with the City’s annual Weed Abatement Program to reduce community-wide risk. The City Manager’s "Fire Resilience" strategy emphasizes that "each person is responsible for making their own property as fire resistant as possible." c) Irrigation Strategies
A high-efficiency, permanent, and automated irrigation system must be maintained for all Zone 1 vegetation. Research indicates that keeping landscape moisture content high significantly reduces the probability of spot-fire ignition from flying embers. The system should be designed to allow the Fire Department to pre-wet the perimeter during a high-wind event and must remain operational even if municipal power is lost through the use of backup power or gravity-fed systems. Smart controllers that shut off during high-wind events to preserve pressure should be avoided in favor of manual overrides for fire staff.
d) Relative Water Content (RWC)
We recommend the exclusive use of "fire-wise" plants. Species with high Relative Water Content (RWC) do not contain flammable resins, oils, or waxes. Deciduous trees (Oaks, Maples) are preferred over coniferous species (Pines, Junipers), which act as standing fuel. A formal list of approved species with high RWC must be incorporated into the project’s final landscape design to ensure compatibility with the Wildland Urban Interface (WUI) environment. Non-native, highly flammable species like Eucalyptus or Acacia must be strictly prohibited.

Agenda Item #11.1.

Wildfire Analysis 19 February 10, 2026
Spring Grove ZCG No. 0126009
e) Soil Maintenance
Foundations must be kept clear of excessive organic mulch or surface litter. In Wildland Urban Interface (WUI) fires, structures are often lost because organic mulch smolders for hours after the fire front passes, eventually igniting the wood-frame structure. Noncombustible soil covers (gravel, rock, or bare soil) are required within the first 5 feet of each building. Additionally, soil stabilization is required to prevent post-fire erosion and debris flow from the western slopes, which can damage structures after the fire is extinguished.
f) Tank and Hydrant Systems
A formal fire water analysis is required per SHMC 15.36.090. The system must confirm that the GPM and pressure are sufficient for a high-density Type V-B subdivision. • Hydrant Staging: Per NFPA 1140 Section 15.3, fire hydrants must be placed so apparatus can stage and connect without blocking the only access road. • Bollard Protection: Mandatory for the hydrant on Street C to ensure that the water supply is not disabled by an accidental vehicle impact during an evacuation. • Main Looping: We recommend looping the internal water mains to ensure a redundant supply to every building. A dead-end main on Street B could lead to pressure loss if the single supply line is compromised.
g) Evacuation Road
The single access road (Street A) is a "single point of failure" and a primary life-safety concern. • Capacity: 41 high-density units represent approximately 143 residents and dozens of vehicles attempting to exit via one 26-foot road.
• NFPA 1140 Table 11.1.4.1(a) and SHMC 15.36: Requires at least two separate and remote access routes for developments over 30 units.
• Operational Hazard: Lessons from Southern California and the 2024 St. Helena drills prove that single-access communities face significantly higher mortality risks during rapid-onset fires. A secondary, remote evacuation route is a life-safety necessity to avoid gridlock.

Without this redundancy, the project introduces a material health and safety concern that cannot be mitigated through building hardening alone.

Agenda Item #11.1.

Wildfire Analysis 20 February 10, 2026
Spring Grove ZCG No. 0126009

8. CONCLUSION
Based on SHMC Chapter 15.36, the 2025 CAL FIRE maps, and the "Major Risk" Fire Factor assessment, the Spring Grove subdivision faces a material and high risk of wildfire danger. The combination of dense Type V-B wood construction, a single point of access, and proximity to highintensity fuels creates an inherent risk that minimum building codes do not fully mitigate. Recent fire history, including the 2020 LNU Lightning Complex and Glass Fire, proves the reality that fire in the Napa Valley frequently outpaces standard suppression capabilities.

The protection of the existing and future residents depends on a design that prioritizes ignition resistance and evacuation redundancy. By implementing a defensible space strategy, hardening homes against embers, and providing a secondary evacuation route, the developer can mitigate the material health and safety risks inherent to this project. Failure to address the access redundancy and site constraints will result in a community that is fundamentally vulnerable to the next regional fire.

Please don’t hesitate to contact our office if you have any questions or would like to discuss our comments in further detail.

ZARI CONSULTING GROUP, INC. ZARI CONSULTING GROUP, INC.

Duran Muniz Joseph P. Zari, PE
Project Manager Principal
Agenda Item #11.1.

Feb 10, 2026
City of St. Helena
1088 College Avenue
St. Helena, CA 94574
By email: [email protected]; [email protected]; [email protected]; [email protected]; [email protected]
Cc: [email protected]; [email protected]; [email protected]; [email protected]; Re: Proposed Housing Development Project at 1447-1515 Spring St Dear St. Helena City Council,
The California Housing Defense Fund (“CalHDF”) submits this letter to remind the City of its obligation to abide by all relevant state laws when evaluating the proposed 41-unit housing development project at 1447 Spring Street, 1515 Spring Street, and 1505 Spring Street, which includes 8 moderate-income units. These laws include the Housing Accountability Act (“HAA”), the Density Bonus Law (“DBL”), and AB 130.

The HAA provides the project legal protections. It requires approval of zoning and general plan compliant housing development projects unless findings can be made regarding specific, objective, written health and safety hazards. (Gov. Code, § 65589.5, subd. (j).) The HAA also bars cities from imposing conditions on the approval of such projects that would render the project infeasible unless, again, such written findings are made. (Ibid.) As a development with at least two-thirds of its area devoted to residential uses, the project falls within the HAA’s ambit, and it complies with local zoning code and the City’s general plan.

Increased density, concessions, and waivers that a project is entitled to under the DBL (Gov.

Code, § 65915) do not render the project noncompliant with the zoning code or general plan, for purposes of the HAA (Gov. Code, § 65589.5, subd. (j)(3)). The HAA’s protections therefore apply, and the City may not reject the project except based on health and safety standards, as outlined above. Furthermore, if the City rejects the project or impairs its feasibility, it must conduct “a thorough analysis of the economic, social, and environmental effects of the action.” (Id. at subd. (b).)
2201 Broadway, PH1, Oakland, CA 94612
www.calhdf.org
Agenda Item #11.1.

CalHDF also writes to emphasize that the DBL offers the proposed development certain protections. The City must respect these protections. In addition to granting the increase in residential units allowed by the DBL, the City must not deny the project the proposed concessions and waivers with respect to side setback, private ground floor open space, landscape area, paved area, distance to drive aisle, curb cuts, full height recesses, attached rowhouse block standards, entry design, recreation space visibility, and bicycle parking. If the City wishes to deny requested waivers, Government Code section 65915, subdivision (e)(1) requires findings that the waivers would have a specific, adverse impact upon health or safety, and for which there is no feasible method to satisfactorily mitigate or avoid the specific adverse impact. If the City wishes to deny requested concessions, Government Code section 65915, subdivision (d)(1) requires findings that the concessions would not result in identifiable and actual cost reductions, that the concessions would have a specific, adverse impact on public health or safety, or that the concessions are contrary to state or federal law.

The City, if it makes any such findings, bears the burden of proof. (Gov. Code, § 65915, subd. (d)(4).) Of note, the DBL specifically allows for a reduction in required accessory parking in addition to the allowable waivers and concessions. (Id. at subd. (p).) Additionally, the California Court of Appeal has ruled that when an applicant has requested one or more waivers and/or concessions pursuant to the DBL, the City “may not apply any development standard that would physically preclude construction of that project as designed, even if the building includes ‘amenities’ beyond the bare minimum of building components.” (Bankers Hill150 v. City of San Diego (2022) 74 Cal.App.5th 755, 775.) Furthermore, the project is eligible for a statutory exemption from environmental review pursuant to section 21080.66 of the Public Resources Code. Caselaw from the California Court of Appeal affirms that local governments err, and may be sued, when they improperly refuse to grant a project a CEQA exemption or streamlined CEQA review to which it is entitled. (Hilltop Group, Inc. v. County of San Diego (2024) 99 Cal.App.5th 890, 911.) As you are well aware, California remains in the throes of a statewide crisis-level housing shortage. New housing such as this is a public benefit: it will provide important homeownership opportunities; it will increase the city’s tax base; it will bring new customers to local businesses; and it will reduce displacement of existing residents by reducing competition for existing housing. While no one project will solve the statewide housing crisis, the proposed development is a step in the right direction. CalHDF urges the City to approve it, consistent with its obligations under state law.

CalHDF is a 501(c)(3) non-profit corporation whose mission includes advocating for increased access to housing for Californians at all income levels, including low-income households. You may learn more about CalHDF at www.calhdf.org. 2 of 3
Agenda Item #11.1.

Sincerely,
Dylan Casey
CalHDF Executive Director
James M. Lloyd
CalHDF Director of Planning and Investigations
3 of 3
Agenda Item #11.1.

Agenda Report to the City Council
Agenda Section: NEW BUSINESS
Department: Recreation
DATE: February 10, 2026
FROM: Ashley Sylvester, Director of Community Services
SUBJECT: City of St. Helena Public Art Project

RECOMMENDED
ACTION:

Receive direction from the City Council related to the
public art project.

PREVIOUS COUNCIL
ACTION:

In November 2020, City Council approved an Acceptance
of Donations and Charitable Gifts to the City Policy, which provides a framework for accepting donations to the City in various forms and dollar amounts.

In August 2023, City Council adopted Resolution 2023-105 allowing for the implementation of a pilot Mural Permit Application and Public Art Donation Installation Policy.

STATEMENT OF THE
PURPOSE:

To seek City Council's support for the installation of public art to St. Helena. The Art Pieces being presented will be on loan to the City of St. Helena.

FINANCIAL IMPACT: Public Works staff and artist representatives will perform the installation with a total cost of less than $10,000.

BACKGROUND:

There is great community interest in having more public art in St. Helena, and there have been sporadic attempts to explore opportunities for more art of various kinds in the public sphere. So, the current effort to install art capitalizes on the opportunity and will hopefully generate community interest and investment of time and money into public art.

This project additionally aligns and is consistent with General Plan Implementation Action AC1.C “Adopt an Art in Public Places program and ordinance to ensure that public art projects occur efficiently and in a way that meets citywide objectives.” DISCUSSION:

As this opportunity to obtain about 11 art pieces has presented itself, staff has been working very hard to prepare for the installation. As part of this effort, staff is collaborating with the local artist to develop up to ten (11) temporary public art installations proposed for placement within the City of St. Helena. Some of the installations will occur in public spaces and a few may be installed on private property with owner's consent along Hwy 29. Each of the art pieces is over 8 feet in height. Final locations will be determined in the next couple of weeks.

Agenda Item #13.1.

Staff is working in consultation with the City Attorney to evaluate potential liability, insurance, indemnification, and risk management considerations associated with the installation, display, and maintenance of the proposed art pieces. Agreements with private and public property owners may be necessary and if so will be executed prior to installation.

Installation will be overseen by Public Works staff in collaboration with representatives of the artist. The proposed installation method includes anchoring each art piece to concrete slabs or sidewalk, subject to final engineering, safety, and accessibility review.

Installation is anticipated to occur in early-March, in advance of the City’s 150th Birthday Celebration.

As mentioned earlier, there is much to be done before the loaned art can be installed including contract for the loan of art with the artist, ensuring insuring coverage for the art, planning for the transportation and installation, and obtaining permission from two public agencies and two private property owners to install art pieces.

This effort will serve as a continuation of the Public Art Pilot Program previously presented to the City Council in August 2023. Staff views this phase as an opportunity to further evaluate implementation practices, maintenance considerations, processes to gain property owner agreement, and gauge public response. Staff anticipates returning to the City Council in the coming months with a comprehensive policy and committee structure to support the increase of public art in St. Helena and also to explore potential funding strategies to support future projects.

ENVIRONMENTAL REVIEW:

There is no environmental impact with the presented project. Each artwork proposal will continue to be individually reviewed for environmental and site impacts.

GOAL:

Goal 4: Provide Effective Community Information & Opportunities for Engagement Goal 5: Enhance Quality of Life
Agenda Item #13.1.

City of St. Helena Public Art Project
February 10, 2026
City Staff: Ashley Sylvester, Director of Community Services Agenda Item #13.1.

Award-winning Napa-based artist Gordon
Huether specializes in large-scale public art
installations and private art commissions.

Projects have included art installations for
private corporations, airports, transportation
centers, parking garages, hotels,
universities, hospitals, recreation centers,
civic buildings, libraries, and museums.

I have spent my career exploring the power of public
art: how it can engage communities and elevate the
mundane to the memorable, creating lasting
impressions in the viewer.
“
”
Agenda Item #13.1.

Agenda Item #13.1.

Agenda Item #13.1.

Agenda Item #13.1.

Agenda Item #13.1.

Lyman Park Hwy 29 / Main Street Corridor City Hall Vineyard Hand of the Land
Barrel Rings
Reflections
Agenda Item #13.1.

LOCATION MAP
Agenda Item #13.1.

LOCATION MAP
Agenda Item #13.1.

INSTALLATION...
2’ X 2’ Pad 4’ x 4’ Pad 6’ x 6’ Pad
Agenda Item #13.1.

Staff Next Steps…
• Loan agreement with Artist
• MOU with private properties for placement of art
pieces
• Site visit for each piece to be installed on private
property sites
• Staff and artist work together for timeline of each
piece being installed
• Site Prep done of concrete pads
• Installation of pieces
• Final inspection done
Agenda Item #13.1.

Thank you
~
Questions?
Item 13.1- City of St. Helena Public Art Project
Receive direction from the City Council related to the presented public art project.

Agenda Item #13.1.

Agenda Report to the City Council
Agenda Section: NEW BUSINESS
Department: Administration
DATE: February 10, 2026
FROM: Andrew Bradley, Program Manager
SUBJECT: Consideration and proposed approval of a resolution for the City Council appointment of applicants to fill the Library Board of Trustees vacancy.

RECOMMENDED
ACTION:

Approve a resolution appointing one applicant to the
Library Board of Trustees.

PREVIOUS COUNCIL
ACTION:

None.

STATEMENT OF THE
PURPOSE:

Appoint an applicant to the vacant Library Board of
Trustees position.

FINANCIAL IMPACT: There is no financial impact associated with this report.

BACKGROUND:

Library Board of Trustees Member Jonathan Furuta provided his resignation on December 19, 2025. The vacant Library Board of Trustees position has a term ending June 30, 2027.

The City Clerk's Division conducted a recruitment and received three applications for consideration for the Library Board of Trustees. The City Council will conduct a special meeting on February 10, 2026, to interview applicants and make the appointment during the regular meeting.

DISCUSSION:

The City held a recruitment for the Library Board of Trustees vacancy (1 vacancy) and received three applications for consideration.
 Becky St. Clair
 Kristina Skinner
 Vanessa Chase
DOCUMENTS ATTACHMENTS:

Resolution Appointing one member to Library Board of Trustees Library Board of Trustees Application - Vanessa Chase - 02 Feb 2026_Redacted Library Board of Trustees Application - Kristina Skinner - 26 Jan 2026_Redacted Library Board of Trustees Application - Becky St. Clair - 26 Jan 2026_Redacted Agenda Item #13.2.

CITY OF ST. HELENA
RESOLUTION NO.

Appointing applicant to the Library Board of Trustees

RECITALS
A. There is one vacant position on the Library Board of Trustees due to a resignation; and
B. Applications have been received from community members; and C. Per City Council Rules of Procedure appointments shall be made by interview and the Mayor shall nominate applicant with the appointments subject to approval by the majority of Council; and
D. An applicant interview meeting is scheduled to be held on February 10, 2025 at 4:30 p.m.

RESOLUTION
NOW, THEREFORE, the City Council of the City of St. Helena resolves as follows:

Library Board of Trustees

1. ______________ is appointed to the St. Helena Library Board of Trustees to fill vacant position that expires on June 30, 2027.

Approved at a Regular Meeting of the St. Helena City Council on February 10, 2025, by the following vote:

Mayor Dohring:

Vice Mayor Deasy:

Council Member Barak:

Council Member Spadarotto:

Council Member Summers:

APPROVED: ATTEST:
________________________ ________________________
Paul Jamison Dohring, Mayor Andrew Bradley, City Clerk
Agenda Item #13.2.

Agenda Item #13.2.

THIS DOCUMENT AND ALL ATTACHMENTS ARE AVAILABLE FOR PUBLIC INSPECTION Have you ever attended a meeting of the Commission to which you are applying? I have not.

What is your understanding of the role and responsibility of this Commission? My understanding is that the library staff will present the commission with policies that either need updating, revision or need changing in order to get community input. My role would be to provide the input of the community. Also, public works would be addressing the condition of the building, location of the library and it's future. I would also help with programming, support and promotion for the library.

What would be your goal(s) as a Commissioner?
My goal would be to strengthen the programs available to the youth of the community. I know many kids enjoy going to the library especially after school. I would love to see more things for the kids to do in order to foster a love of reading. I would also like to help provide more activities for adults to help them to make friends and use the resources available at the library.

Have you previously served, or do you currently serve, on a St. Helena Commission or Committee? If yes, which one(s) and for what period of time?
No I have not.

Is there anything else you would like us to consider when reviewing your application? I would like to thank you for this opportunity and look forward to serving on the library board.

I agree that all of the information contained in my responses to the questions on this application are true and accurate to the best of my knowledge. I further agree that, by checking the box below and submitting this application, online or otherwise, I am affixing my digital signature to this form as of the date submitted. I also agree that if appointed, I will serve on the Commission/Committee for which I have submitted this application.
☒ I AGREE
Vanessa Chase January 28, 2026
Agenda Item #13.2.

Vanessa Chase
St, Helena, CA 94574

OBJECTIVE
Seeking a substitute teaching position that allows me to utilize my curriculum planning skills and provides opportunities to work with culturally and linguistically diverse students in grades K-8.

PROFESSIONAL SKILLS AND KNOWLEDGE
▪ Establishing and enforcing expectations for behavior and procedures for maintaining order among the students for whom they correspond to.
▪ Developing and executing daily and unit lesson plans. ▪ Administering assessments, tracking and analyzing class performance. ▪ Conducting group and one-on-one math, reading and writing activities. ▪ Fostering a classroom environment conducive to learning and promoting excellent student engagement. ▪ Developing excellent rapport with students ▪ Participating in faculty and parent conferences.

TEACHING EXPERIENCE
2025-2026 St. Helena Unified School District St. Helena, CA Substitute Teacher TK-12th grade
2012-2017 Almond Acres Charter Academy San Miguel, CA
Third Grade Teacher
2011-2012 Galt Joint Union School District Galt, CA
Substitute Teacher Preschool-8th grade
2011- 2012 San Juan Unified School District Sacramento, CA Substitute Teacher Preschool-8th grade
2011-2011 Cameron Ranch Elementary School Carmichael,
CA
Student Teacher 2nd grade
2010-2011 Clayton B Wire Elementary School Sacramento, CA Student Teacher 4th grade
2009- 2009 Cameron Ranch Elementary School Carmichael, CA Teacher’s Assistant 2nd/3rd grade combo

EDUCATION
California State University Sacramento Sacramento, CA
• Bachelor of Science- Exercise Science/Kinesiology
• SB 2042 Multiple Subject Credential Program – Bilingual Multicultural Education Department • Single Subject Teaching Credential-Science
• Supplementary Authorizations in Science and Physical Education American River Junior College Sacramento, CA
• A.A. Liberal Studies
Trainings:
• Enhanced English Language Acquisition (45 hours)
• Daily 5/ CAFÉ Conferences (2 years)
Agenda Item #13.2.

• CREEC training
• NWEA training
• Thinking Maps training
• NGSS Webinars
• Discovery ED training
• GLAD training
• SPBL training
• TEFL certification
Agenda Item #13.2.

Agenda Item #13.2.

THIS DOCUMENT AND ALL ATTACHMENTS ARE AVAILABLE FOR PUBLIC INSPECTION Have you ever attended a meeting of the Commission to which you are applying? No
What is your understanding of the role and responsibility of this Commission? The commission provides strategic planning, governance, and advocates for the community to make sure the needs are being met. They also have subcommittees that tackle a specific duty that commissioners are interested in such as social media and youth engagement.

What would be your goal(s) as a Commissioner?
I want to give a voice to more of the underrepresented communities in St. Helena and to expand on opportunities given to our youth at the library, making the space welcoming and full of fun services the youth can take advantage of.

Is there anything else you would like us to consider when reviewing your application? In my current position as youth advocate at LGBTQ+ Connection, we also partner with the library in providing a monthly movie night for both St. Helena High and Calistoga Jr./Sr. High School's GSAs (gender and sexuality alliance club) where they can get to know each other, eat snacks, and have a safe space to be themselves.

I agree that all of the information contained in my responses to the questions on this application are true and accurate to the best of my knowledge. I further agree that, by checking the box below and submitting this application, online or otherwise, I am affixing my digital signature to this form as of the date submitted. I also agree that if appointed, I will serve on the Commission/Committee for which I have submitted this application.
☒ I AGREE
Kristina Skinner January 26, 2026
Agenda Item #13.2.

Kristina Skinner
St. Helena, CA 94574

Education:

University of Portland, Portland, OR May 2023
B.A. Psychology, Minor in Gender, Women, and Sexualities Studies, GPA: 3.71 Social Justice UP Study Abroad Program in London, England June-August 2022 Awards:

Volunteer of the Year Award, City of American Canyon, Spring 2025 Work Experience:

Circulation Assistant, Clark Library, Portland, OR Winter 2022- Spring 2023 ● Shelve and organize books
● Provide a positive and welcoming environment by checking in/out books ● Attend to patron questions and help locate books for them to check out Customer Service Rep, Caymus Vineyards, Rutherford, CA Fall 2023- Summer 2024 ● Answer customer questions both online and over the phone ● Book reservations for customers through Tok software
● Fulfill online orders of merchandise over the phone for customers using Commerce 7 Youth Advocate, LBGTQ Connection, Napa, CA Fall 2024- Present ● Assist the Youth Programs Coordinator in engaging youth and outreach efforts for socials, health services, and support groups.
● Schedule one on one meetings with youth participants and co-lead youth leadership teams at wellness center sites.
● Collaborate on community projects focusing on LGBTQ+ awareness and activism driven by youth input.

Internship Experience:

Social Media Intern, Community Leaders Coalition, Napa, CA Winter 2024-Spring 2024 ● Create content for social media posts and post to CLC’s various platforms ● Conduct outreach with CLC contacts for voter education, ‘Get out the Vote,’ voter registration, etc.
● Build a Youth Voter Outreach Program in high schools, colleges and youth engagement programs across Napa County
DEI Intern, Vitidore Inc., Davis, CA Fall 2022
● Work remotely for a startup to advance Diversity Equity and Inclusion efforts in the company ● Create work climate survey to measure employee satisfaction in the company ● Lead a company wide DEI meeting within the internship time frame on resources that provided an inclusive work environment
● Provide periodic training on DEI topics with resources such as podcasts and reading clubs HR Intern, City of St. Helena, St. Helena, CA Winter 2024-Spring 2024 ● Create a work climate survey for all City employees to measure employee satisfaction ● Design the HR page on the City website page
● Build content/pages for the City’s new Intranet page
Agenda Item #13.2.

Kristina Skinner
St. Helena, CA 94574

Solicia Aguilar
Director
LGTBQ Connection

Michele Grupe
Director
Community Leaders Coalition
Elvia Najera Santiago
Field Operations Specialist
Vitidore Inc.

Agenda Item #13.2.

THIS DOCUMENT AND ALL ATTACHMENTS ARE AVAILABLE FOR PUBLIC INSPECTION City of St. Helena

COMMISSION/COMMITTEE APPLICATION
Received Date: January 23, 2026
Application Type: Library Board of Trustees
CA-26-001
NAME: Becky St. Clair
ADDRESS: , Angwin, CA, 94508
PHONE: 269-605-3438
EMAIL ADDRESS:

LENGTH OF RESIDENCY: Angwin
EMPLOYER: Director, Paulin Center for the Arts; Freelance Writer and Editor EMPLOYMENT STATUS: Employed
REASON FOR APPLYING: I absolutely love the SHPL. They were my saving grace when I was going through depression and needed to get out of the house, when I needed reading material for my entire family during Covid, and when I needed somewhere cooler to take my kids in the summer. We've played taiko drums, built gingerbread houses, watched puppet shows, watched concerts and movies, enjoyed history presentations, and put together LEGOs at the library.

I worked for the SHPL in 2018-2019 and was so excited to be part of bringing library services and events to the community. I got to meet people from all walks of life from our community, and saw the positive impact the library had on their lives. I had many, many ideas, and was passionate about learning more about how the SHPL operates. I currently volunteer a small number of hours for the SHPL, and am honored to be able to support them in whatever way I can.

In addition, I am an avid reader and my husband is a librarian. I grew up visiting the library at least once a week, and have had a library card for as long as I can remember, wherever I've lived. Libraries are part of the fabric of my being, and the SHPL is special to me. I want to see it flourish, and I want to help even more people recognize the library's value, as well. If my service on the board will be part of accomplishing those things, I'm all in.

EDUCATIONAL BACKGROUND: Gem State Academy (Idaho)
Walla Walla University (Washington State) - BA in English; minor in music University College London - semester study abroad - culture, theater, history, government
Andrews University (Michigan) - MA in Communications (one class away from finishing)
Pacific Union College (California) - MA in Strategic Communications (in progress) OTHER RELEVANT EXPERIENCE: Employed by SHPL 2018-2019
Served on a school board for six years
Significant engagement with libraries and their systems Agenda Item #13.2.

Agenda Item #13.2.

THIS DOCUMENT AND ALL ATTACHMENTS ARE AVAILABLE FOR PUBLIC INSPECTION I agree that all of the information contained in my responses to the questions on this application are true and accurate to the best of my knowledge. I further agree that, by checking the box below and submitting this application, online or otherwise, I am affixing my digital signature to this form as of the date submitted. I also agree that if appointed, I will serve on the Commission/Committee for which I have submitted this application.
☒ I AGREE
Becky St. Clair January 26, 2023
Agenda Item #13.2.

Agenda Item #13.2.

Agenda Item #13.2.

Agenda Item #13.2.