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Legal Settlement Enables St. Helena to Embrace Density in General Plan

Uzo Ehi on
Jun 3, 2019

The paradox of Napa Valley is that its famous vine-ripened pastoral character, marked by a pleasing mix of small towns and agricultural land, is appealing and prosperous enough to attract more than just wine-tasting day trippers. Indeed, Wine Country has a housing crisis of its own.

That crisis has landed in the City of St. Helena, one of many Napa County towns aiming to accommodate growing populations while remaining small towns. These tensions played out in a general plan update that included outsized controversies for a town of just 6,196.

The St. Helena Planning Commission unanimously voted April 16 to recommend that the city council adopt the revised 2040 General Plan; the council voted to adopt it, 3-1, May 14. The votes came nearly a decade after the commission first recommended adoption of an earlier version of the plan, drafted in 2010. Modifications to that plan dragged on for nearly a decade, in part due to disagreements over the city’s water supply.

The new plan replaces a 1993 update that was adopted when the town had over 1,000 fewer residents.

The updated plan primarily focuses on preserving agricultural lands, improving and enhancing pedestrian and bicycle areas throughout the community, and modernizing policies to maintain the city’s historic buildings and open spaces. It also strives to allow just enough housing to accommodate some new residents without overwhelming the town.

Complicating this provision was a multi-year lawsuit, recently settled, over infill development that demonstrated just how sensitive some St. Helena residents are to even relatively small developments.

“Maintaining the community character while also ensuring enough growth occurs to maintain a healthy community is a top priority of this City Council,” said Noah Housh, Planning & Community Improvement Director. “Adoption of the 2040 General Plan Update is the first step toward modernizing the city’s land use policies to ensure this balance is met.”

The most noticeable proposals in the revised plan suggest extending an avenue and removing plans to rezone land in a residential neighborhood. Planning Commission Chair Lester Hardy recommended that the commission review the plan in coming months.

Some St. Helena residents may not support the city’s ­­­­response to growth pressures, however.

In McCorkle Eastside Neighborhood Group v. City of St. Helena, Citizens filed suit against the city in 2017 after the city invoked an infill exemption to grant an eight-unit project proposal. The council’s action was in keeping with a 2016 update to the city’s housing element and zoning ordinance, making it only necessary for the city to review design aspects for projects intended for the High Density Residential zoning district. Plaintiffs claimed that St. Helena violated the California Environmental Quality Act by not holding the project to stricter environmental review standards. (See prior CP&DR coverage.)

The trial court ruled in favor of St. Helena, and the appellate court upheld the ruling Dec. 18, 2018. Attorneys representing the plaintiffs contended that plaintiffs saw themselves as watchdogs policing the city rather than activists with an ideological agenda.

“The residents of St. Helena were generally supportive of the recent General Plan update,” said Matthew D. Hinks, partner at Jeffer Mangels Butler & Mitchell. “The case was not animated by ‘anti-growth’ sentiments, but rather the actions of various city officials that we continue to believe were unlawful.”

The court dismissed these claims, writing, “There was no improper delegation of the city’s authority under CEQA….[T]he City Council in this case did act—just not in the way that appellants had hoped.”

According to Hardy, however, the rise of anti-growth “hopes” in St. Helena is not a recent development.

“Limiting population growth has been a priority for many residents and voters in St. Helena for the last 30 years or more; this sentiment is always a factor in the city's land use policy decisions, of varying significance depending on the particulars,” said Hardy. “Comparing the 2040 General Plan Update with the 1993 General Plan…I would say that anti-growth sentiment has as much influence today as it did then.”

With the lawsuit settled, the new plan further ingrains the council’s 2016 infill exemption. According to Housh, City Council has made housing development in St. Helena a priority, and the council expects to initiate a citywide housing strategy by mid-summer. The updated General Plan estimates that the city will construct roughly 330 new housing units, increasing housing units by approximately 10 percent.

To maintain the city’s character, to the plan calls for the creation of a mixed-use land use designation and reclassify select properties located in the city’s downtown commercial center.

St. Helena has started drafting the Citywide Design Guidelines, which will offer nuanced direction on the overall architectural and landscape designs in St. Helena. The guidelines should be completed later this year.

These developments amount to a more progressive general plan than the previous version, which has been described as more of a plan for “tourist management” than for true city-building.

* * *

In related Napa Valley planning news, St. Helena’s neighbor and fellow tourist destination Yountville also recently adopted a general plan that gingerly invites growth. Yountville’s previous general plan was also a product of the early 1990s, having been adopted in 1992.

Most notably, the new plan for the town of 2,924 permits the development of three-story buildings in the downtown area for the first time while imposing a limit of two stories on residential properties. The regulations are tighter than the previous 30-foot height limit. To build three stories, developers must prove a public benefit, such as inclusion of affordable housing, storefronts for locally serving businesses, or accommodations for “under-represented” activities. The plan also provides for slightly higher residential densities in certain areas. 

Contacts & Resources

City of St. Helena General Plan

McCorkle Eastside Neighborhood Group v. City of St. Helena: Infill Exemption Upheld for 8-Unit Project

Yountville General Plan

Noah Housh, Planning & Community Improvement Director, NHoush@cityofsthelena.org

Lester Hardy, Commission Chair, lhardy@cityofsthelena.org

Matthew D. Hinks, partner of Jeffer Mangels Butler & Mitchell LLP, MH2@jmbm.com