10/20/2022 Planning Commission Special Agenda Packet
Special Planning Commission Agenda
October 20, 2022
6:00 P.M.
PLANNING COMMISSION MEMBERS
Chair: Manny Bhandal:
manny.bhandal@cityofgilroy.org
Vice Chair: Annedore Kushner:
annedore.kushner@cityofgilroy.org
Commissioners:
▪ Joan Lewis:
joan.lewis@cityofgilroy.org
▪ Adilene Jezabel Moreno:
adilene.moreno@cityofgilroy.org
▪ Stefanie Elle:
stefanie.elle@cityofgilroy.org
▪ Adriana Leongardt:
adriana.leongardt@cityofgilroy.org
THIS MEETING WILL BE CONDUCTED PURSUANT TO THE PROVISIONS OF ASSEMBLY BILL 361.
MEETING MATERIAL IS AVILABLE ON THE COUNTY WEBSITE www.cityofgilroy.org.
Pursuant to California Assembly Bill 361, a local legislative bode is authorized to hold public meetings
remotely and to make those meetings accessible to all members of the public seeking to observe and
to address the local legislative body by remote means only via a technology solution. As such, the City
will provide various options for the public to participate in the conduct of the meeting, as indicated in
detail below on this coversheet.
Written comments can be submitted by email to planningdivision@cityofgilroy.org. Please note that
written comments will not be read out loud, but will be part of the written record.
Comments by the public will be taken on any agenda item before action is taken by the Planning
Commission. Persons speaking on any matter are asked to state their name and address for the
record. Public testimony is subject to reasonable regulations, including but not limited to time
restrictions on particular issues and for each individual speaker. A minimum o f 12 copies of materials
should be provided to the Clerk for distribution to the Commission and Staff. Public comments are
limited to no more than 3-minutes, at the Chair’s discretion.
Comments on any agenda item may be emailed to the Planning Division a t
planningdivision@cityofgilroy.org or mailed to the City of Gilroy, Community Development
Department at City Hall, 7351 Rosanna Street, Gilroy, CA 95020. Comments received by the
Planning Division by 1 p.m. on the day of a Planning Commission meeting will be distributed to the
City Council prior to or at the meeting and available for public inspection with the agenda packet
located in he lobby of Planning Division at City Hall, 7351 Rosanna Street pr ior to the meeting. Any
correspondence received will be incorporated into the meeting record. Items received after the 1 p.m.
deadline will be provided to the Planning Commission as soon as practicable.
In compliance with the American Disabilities Act (ADA), the City will make reasonable arrangements
to ensure accessibility to this meeting. If you need special assistance to participate in this meeting,
please contact the City Clerk 72 hours prior to the meeting at (408) 846-0491. A sound enhancement
system is available in the City Council Chambers.
If you challenge any planning or land use decision made at this meeting in court, you may be limited
to raising only those issues you or someone else raised at the public hearing held at this meeting, or
in written correspondence delivered to the Planning Commission at, or prior to, the public hearing.
Please take notice that the time within which to seek judicial review of any final administrative
determination reached at this meeting is governed by Section 1094.6 of the California Code of Civil
Procedure.
Persons who wish to speak on matters set for Public Hearing will be heard when the presiding officer
calls for comments from those persons who are in support of or in opposition thereto. After persons
have spoken, the hearing is closed and brought to the Planning Commission level for discussion and
action. There is no further comment permitted from the audience unless requested by the Planning
Commission.
A Closed Session may be called during this meeting pursuant to Government Code Section
54956.9(b)(1) if a point has been reached where, in the opinion of the legislative body of the City on
the advice of its legal counsel, based on existing facts and circumstances, there is a significant
exposure to litigation against the City.
Materials related to an item on this agenda submitted to the Planning Commission after distribution of
the agenda packet are available for public inspection with the agenda packet in the lobby of
Administration at City Hall, 7351 Rosanna Street during normal business hours. These materials are
also available with the agenda packet on the City website at www.cityofgilroy.org
I. OPENING
II. PLEDGE OF ALLEGIANCE
III. REPORT ON POSTING THE AGENDA AND ROLL CALL
IV. PUBLIC COMMENTS: (Three-minute time limit). This portion of the meeting is reserved for
persons desiring to address the Planning Commission on matters not on the agenda. The
law does not permit the Planning Commission action or e xtended discussion of any item
not on the agenda except under special circumstances. If Planning Commission action is
requested, the Planning Commission may place the matter on a future agenda. Comments
on any agenda item may be emailed to the Planning D ivision at
planningdivision@cityofgilroy.org or mailed to Community Development Department at City
Hall, 7351 Rosanna Street, Gilroy, CA 95020. Comments received by the Planning Division
by 1:00pm on the day of a Planning Commission meeting will be distributed to the Planning
Commission prior to or at the meeting and available for public inspection with the agenda
packet located in the lobby of Planning Division at City Hall, 7351 Rosanna Street prior to
the meeting. Any correspondences received will be incorporated into the meeting record.
Items received after 1:00pm deadline will be provided to the Planning Commission as soon
as practicable. All statements that require a response will be referred to staff for reply in
writing.
PUBLIC HEARINGS FOR RELATED PROJECT APPLICATIONS WILL BE HEARD CONCURRENTLY AND
ACTION WILL BE TAKEN INDIVIDUALLY. COMPANION PROJECTS UNDER NEW BUSINESS WILL BE
TAKEN UP FOR ACTION PRIOR TO, OR IMMEDIATELY FOLLOWING THE RELATED PUBLIC HEARING.
THIS REQUIRES DEVIATION IN THE ORDER OF BUSINESS AS NOTED WITHIN THE AGENDA.
V. PUBLIC HEARINGS
A. Review of the Draft Housing Element
1. Staff Report: Cindy McCormick, Customer Service Manager
2. Open Public Hearing
3. Close Public Hearing
4. Planning Commission Disclosure of Ex-Parte Communications
5. Possible Action:
Accept the report and provide direction to staff on the Draft Housing Element.
VI. ADJOURNMENT to the Next Meeting of November 3, 2022 at 6:00 P.M.
Community Development
Department
7351 Rosanna Street, Gilroy, California 95020-61197
Telephone: (408) 846-0451 Fax (408) 846-0429
http://www.cityofgilroy.org
DATE: October 20, 2022
TO: Planning Commission
FROM: Cindy McCormick, Customer Service Manager
SUBJECT: Review of the Draft Housing Element
RECOMMENDATION:
Accept the report and provide direction to staff on the Draft Housing Element.
PROJECT DESCRIPTION:
The Housing Element is one of several requ ired chapters (“elements”) in the General
Plan. All jurisdictions in California are required to update their Housing Elements every
eight years. The City of Gilroy’s 2023 – 2031 Housing Element goals, policies, and
programs aim to: encourage the development of a variety of housing opportunities and
provide adequate sites to meet the 2023 – 2031 Regional Housing Needs Allocation
(RHNA); assist in the development of housing to meet the needs o f lower- and
moderate-income households; address and, where appropriate and legally possible,
remove governmental constraints to housing development; conserve, preserve, and
improve the condition of the existing affordable housing stock; and promote equal
housing opportunity for all residents to reside in the housing of their choice. These
objectives are required by and delineated in State law (California Code Section 65583
[c][1]).
BACKGROUND:
The Draft 2023-2031 Housing Element has been prepared in compliance with the State
of California Government Code Section 65302 and in conformance with the Housing
Element Guidelines as established by the California Department of Housing and
Community Development (HCD). HCD requires cities to update their Housing Elements
every eight years. The current (5th) Housing Element covers the planning cycle from
January 2015 to January 2023. The 6th planning cycle is from 2023 to 2031. The update
process is an opportunity to reflect on Gilroy's changing needs, resources, and
conditions. An effective housing element provides the necessary conditions for
developing and preserving an adequate supply of housing, including housing affordable
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to seniors, families, and low-income workers. While the Housing Element must address
specific state requirements, it is ultimately a local plan and should reflect the priority of
the community.
Housing Element Update History: On June 21, 2021, staff provided the Council with
an update on the City’s Regional Housing Needs Allocation (RHNA) for the 2023 -2031
planning cycle and discussed next steps regarding an update to the City’s Housing
Element. On October 11, 2021, the City Council awarded a Contract to Michael Baker
and Associates in the amount of $306,155 for preparation of the 2023 -2031 Housing
Element. On October 25, 2021, the City Council recommended that staff include
programs to explore an inclusionary housing policy and affordable housing incentives
policy in the 2023-2031 Housing Element. Desired programs included bonus
concessions beyond state law and incentives for accessory dwelling units, micro -units,
and missing middle housing. The Council also wanted to consider anti -displacement
standards to protect city residents. Details for each of these programs will be explored
following adoption of the 2023-2031 Housing Element. In addition to the community
outreach efforts discussed at the end of this staff report, the City Council held a bilingual
joint study session with the Planning Commission on August 29, 2022. The study
session included an update on the work completed to date, a discussion of pending and
proposed RHNA sites, and a high-level overview of the proposed goals and programs to
be included in the draft housing elem ent. Multiple members of the public spoke during
the meeting and the Council and Commission had an opportunity to ask questions and
provide feedback on the housing element work. On October 17, 2022, the City Council
is holding a public hearing to receive comments from the public on the draft and to also
provide staff with direction on any desired amendments prior to sending the draft to the
California Department of Housing and Community Development (HCD).
Environmental Assessment: Given that no rezoning is needed, City staff and the
consultant anticipate that the 2023-2031 Housing Element can be adopted with a
(Mitigated) Negative Declaration (M/ND) or an Addendum to the 2040 General Plan
Environmental Impact Report (GP EIR) which already analyzed the growth anticipated
during the 2023 to 2031 planning period.
DISCUSSION AND ANALYSIS:
Housing Element Overview: The Housing Element is one of seven required chapters
(“elements”) in the General Plan. The City's Housing Element outlines Gilroy’s goals,
policies, and implementation programs for the preservation, conservation, improvement,
and production of housing. The Housing Element also identifies the specific actions the
City will take to address existing and future housing needs. The Housing Element
contains six chapters: Review of Past Accomplishments; Housing Needs Assessment;
Affirmatively Furthering Fair Housing; Constraints on Housing; Housing Sites and
Resources; and Housing Goals, Policies, and Programs. The Housing Element also
contains three appendices: Appendix A: Sites Inventory Map; Appendix B: Sites
Inventory List; and Appendix C: Outreach.
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Review of Past Accomplishments: California Government Code Section 65588(a)
requires that each jurisdiction review its housing element as frequently as is appropriate
and evaluate: the appropriateness of the housing goals, objectives, and policies in
contributing to the attainment of the state housing goal; the effectiveness of the housing
element in attainment of the community’s housing goals and objectives; and the
progress in implementation of the housing element. According to the State HCD, the
review is a three-step process: review the quantitative and qualitative results of the
previous element’s goals, objectives, and programs; compare what was projected or
planned in the previous element to what was actually achieved; and describe how the
goals, objectives, policies, and programs in the updated element are being changed or
adjusted to incorporate what has been learned from results of the previous element.
Each year, City staff prepares a General Plan Annual Report, which includes the
Housing Element Annual Progress Report, summarizing the City’s progress towards
meeting Gilroy’s RHNA and the City’s efforts to implement the programs listed in the
Housing Element. This report also includes a summary of calendar year activities that
show progress towards implementation of Gilroy’s General Plan. The Annual Report is
reviewed by the Council in March and then forwarded to the Governor’s Office of
Planning and Research (OPR) and the State Department of Housing and Community
Development (HCD), prior to the April 1 due date every year.
Housing Needs Assessment: The housing needs assessment section discusses the
varied needs of all segments of the community. Components that dictate housing need
are population trends, demographics, employment trends, household characteristics,
housing stock characteristics, housing inventory and market conditions, and
preservation of at-risk units. The assessment also analyzes housing needs of various
special needs groups, including elderly persons, large households, female -headed
households, persons with disabilities (including developmental disabilities),
homeless/unhoused persons, farmworkers, and extremely low-income households. The
needs assessment guides the identification of appropriate goals, policies, and programs
for the City to implement during the 2023–2031 Housing Element Cycle.
California General Plan law requires that each city and county have land zoned to
accommodate its fair share of the regional housing need. The California Department of
Housing and Community Development (HCD) determines the projected housing need
for each region. The Association of Bay A rea Governments (ABAG) is responsible for
assessing each Bay Area jurisdiction’s Regional Housing Needs Allocation (RHNA).
Housing unit allocations are divided into four income categories: very low, low,
moderate, and above moderate. Gilroy’s 2023-2031 RHNA is a total of 1,773 units, as
shown below.
Gilroy RHNA, 2023–2031
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Income Group % of County AMI Units % of Units
Very Low* 31–50% 669 37.7%
Low 51–80% 385 21.7%
Moderate 81–120% 200 11.3%
Above Moderate > 120% 519 29.3%
Total - 1,773 100%
Source: Regional Housing Needs Allocation, ABAG, 2023-2031.
*Note: Pursuant to AB 2634, local jurisdictions are also required to project the needs of
extremely low-income households (0–30% of AMI). The projected extremely low-income
need can be assumed as 50 percent of the total need for the very low-income
households.
Affirmatively Furthering Fair Housing (AFFH): Assembly Bill (AB) 686 requires a
jurisdiction’s housing element to provide an analysis of contributing factors to fair
housing issues and to commit to actively and meaningfully affirmatively further fair
housing. This analysis includes an assessment of fair housing enforcement, outreach
activities, integration and segregation, racially and ethnically concentrated areas of
affluence and poverty, disparities in access to opportunities, disproportionate housing
needs, and any other contributing factors that serve as impediments to fair housing. The
assessment also analyzes the extent to which the identified RHNA sites affirmatively
further fair housing.
The City has adopted goals and actions that specifically address the contributing factors
identified in the AFFH analysis. While the City views all contributing factors as an
important priority to address, higher priority was given to factors that limit fair housing
choice and or negatively impact fair housing, per Government Code section
65583(c)(10)(A)(iv). The Draft Housing Element includes a summary (Table 49) of the
identified fair housing issue, contributing factor, actions taken to address the
contributing factor, and priority level for each issue. Relevant programs are referenced
in the action column for each contributing factor.
Constraints on Housing: There are a wide variety of factors that influence whether,
where, when, how, and what type of housing is constructed. While many factors enable,
guide and even incentivize housing construction, almost all also pose some sort of
limitation or constraint as well. Our land use policies and regulations are necessary but,
by definition, establish limits on growth and development. These limits work with,
influence and are balanced by market forces. There are generally two types of
constraints: governmental and non-governmental. Governmental constraints include the
policies, regulations and procedures that directly affect housing. This includes the goals,
policies and programs of the General Plan and the development standards and
requirements of the zoning code and other land use ordinances. Non -governmental
constraints include those factors that are beyond the direct control and authority of the
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City. The Constraints section of the Housing Element identifies and evaluates those
factors that may pose significant constraints or burdens that may limit or constrain the
production of housing to meet our local and regio nal housing needs and the goals and
objectives of the General Plan. Such constraints, particularly those that limit the
construction of or fair access to affordable housing must be addressed with clear,
measurable and timely programs.
Housing Sites and Resources: This section of the Housing Element addresses
resources available for the development, rehabilitation, and preservation of housing in
Gilroy. It provides an overview of available land resources and residential sites for future
housing development and evaluates how these resources can work toward satisfying
future housing need. The financial and administrative resources available to support
affordable housing are also discussed. California General Plan law requires that a
community plan for an adequate number of sites to allow for and facilitate production of
its share of the regional housing need. Each jurisdiction must identify “adequate sites” to
determine whether that jurisdiction has sufficient land to accommodate its share of
regional housing needs for each income level. As defined under California Government
Code Section 655839(c)(1), adequate sites are those with appropriate zoning and
development standards, and with services and facilities to encourage and provide for
the development of a variety of housing for all income levels. As illustrated previously,
Gilroy’s RHNA for the 2023-2031 (6th cycle) planning period is 1,773 units including 669
very low-, 385 low-, 200 moderate-, and 519 above-moderate units.
The City has enough existing residentially zoned land with near-term development
potential to meet its RHNA and a 15 -20 percent buffer. Gilroy’s existing zoning has
capacity to meet the RHNA without rezoning1 through pending projects, ADUs, and both
vacant and non-vacant sites, as shown in Table 72 of the Draft Housing Element.
Appendix B includes a list of proposed sites to help meet the City of Gilroy’s RHNA.
Additional detail on the sites, including their development potential, is discussed near
the end of the Housing Sites and Resources section.
Housing Goals, Policies, and Programs: The Housing Element outlines the City of
Gilroy’s goals, policies, and implementation programs for the preservation,
conservation, improvement, and production of housing for the 2023 – 2031 planning
period. The goals, policies, programs, and quantified objectives are designed to help
ensure housing opportunities for all existing and future residents of the community. The
following seven (7) broad goals are included in the Housing Element along with a serie s
of policies that include general commitments, strategies, and approaches to
accomplishing the goals.
1 California Government Code Section 65583.2 (c) states that cities must have a program to facilitate by -
right approval for projects that include at least 20% of the units for lower-income housing on rezone low-
income sites. The City of Gilroy is not rezoning any sites to meet the RHNA. Thus, this provision is not
applicable to the RHNA sites inventory for Gilroy.
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1. Housing Production: Provide adequate residential sites to accommodate projected
housing needs and encourage the production of a variety of housing types
2. Removal of Government Constraints: Remove or reduce governmental
constraints to the development, improvement, and maintenance of housing where
feasible and legally permissible.
3. Housing Preservation and Rehabilitation: Maintain and conserve the existing
housing stock in a sound, safe, and sanitary condition.
4. Housing Assistance to Meet the Needs of All Income Levels: Encourage and
support the provision of a variety of affordable housing types.
5. Special Housing Needs: The City shall increase access to decent and suitable
housing for Gilroy residents with special housing needs.
6. Fair Housing: Ensure equal housing opportunities for all Gilroy residents regardless
of race, color, religion, sex, sexual orientation, marital status, national origin,
ancestry, familial status, disability, or source of income.
7. Education and Outreach: Increase awareness of and participation in housing
programs.
The Housing Element programs describe specific actions the City will carry out over the
eight-year planning period to satisfy the community’s housing needs and meet the
requirements of State law. The programs are organized by the seven major housing
goals, as follows, and further described in the Draft Housing Element.
Housing Production Programs:
A - 1 No Net Loss Monitoring
A - 2 Surplus Lands/Affordable Housing on City-Owned/Successor Agency Sites
A - 3 By-Right Approval of Projects with 20 Percent Affordable Units, “Reused”
RHNA Sites
A - 4 Publicize Residential Sites Inventory
A - 5 Revise Neighborhood District Policy
A - 6 ADU Tracking and Monitoring
A - 7 ADU Preapproved Plans
A - 8 Monitor Permit Requirements, Processing Procedures and Land Use
Controls
A - 9 Facilitate Missing Middle / Middle Income Housing
A - 10 Inclusionary Housing Policy
A - 11 Density Bonus Beyond State Law
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A - 12 Coordination with California High Speed Rail Authority
Removal of Government Constraints Programs:
B - 1 Residential Development Ordinance Removal
B - 2 Zoning and General Plan Densities
B - 3 SB 35 Permit Processing
B - 4 Public Fees, Standards, and Plans Online
B - 5 Permit Streamlining
B - 6 Objective Standards
B - 7 Zoning Code Cleanup
Housing Preservation and Rehabilitation Programs:
C - 1 Monitoring of Units At-Risk of Converting to Market Rate
C - 2 Housing Rehabilitation
C - 3 Code Enforcement Program
C - 4 Resale Control on Owner-Occupied Below Market Rate Units
C - 5 Resale Control on Rental Below Market Rate Units
C - 6 Identification and Preservation of At-Risk Units
Housing Assistance to Meet the Needs of All Income Levels Programs:
D - 1 Permanent Local Housing Allocation Fund
D - 2 Funding Sources to Assist Homeownership
D – 3 Housing Choice Voucher Referrals
D - 4 Pursue Funding for Affordable Housing
D - 5 Community Development Block Grant Program
Special Housing Needs Programs:
E - 1 Priority Water and Sewer Service for Affordable Housing Developments
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E - 2 Zoning to Encourage and Facilitate Single-Room Occupancy Units
E - 3 Emergency Shelter Standards
E - 4 Low Barrier Navigation Centers
E - 5 Incentivize Micro-Units
E - 6 Reduced Parking Requirements for Senior Housing
E - 7 Development and Conservation of Housing for Farmworkers
E - 8 Consistency with the Employee Housing Act
E - 9 Priority for Gilroy
Fair Housing Programs:
F - 1 Source of Income Protection
F - 2 Fair Housing Counseling
F - 3 Place-Based Improvements
F - 4 Housing Mobility and Choice in Higher Opportunity Areas
F - 5 Displacement Prevention Policy
Education and Outreach Programs:
G - 1 Collaboration with Development Community
G - 2 Community Outreach and Inclusion in the Decision-Making Process
G - 3 ADU Education
G - 4 Increased Outreach in Downtown Areas
G - 5 Housing Outreach and Information
In addition to providing more detail on each of the above prog rams, the Draft Housing
Element includes a timeline for implementation, funding source (e.g., General Fund),
and responsible party (typically Community Development). For example, Program A – 4
(Publicize Residential Sites Inventory) must be posted on the C ity’s website within 6
months of Housing Element adoption and then updated annually, or as needed (e.g.,
after a site gets developed). Programs A-5 (Revise Neighborhood District Policy) and A
– 7 (ADU Preapproved Plans) must be implemented within three yea rs of Housing
Element adoption. Program A – 9 (Facilitate Missing Middle / Middle Income Housing)
and Program A – 11 (Density Bonus Beyond State Law) must be implemented within 2
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years of Housing Element adoption, while Program A -10 (Inclusionary Housing Policy)
must be implemented by the end of 2024.
Appendices: The final section of the Draft 2023 – 2031 Housing Element includes three
appendices; Appendix A: Sites Inventory Map; Appendix B: Sites Inventory List; and
Appendix C: Outreach. The Outreach appendix includes a summary of survey results as
of September 8, 2022, broken down into English responses and Spanish responses.
The appendix also includes a robust list of open-ended general comments received
from English and Spanish speaking survey participan ts. Two individuals raised
concerns that some people may be taking the survey several times; however the
consultant checked the survey respondent data and determined that there were no IP
Addresses repeats.
Conclusion: The Draft Housing Element is the result of a year-long effort that included
several community outreach efforts. Based on the lengthy adoption process for the
Southern California region2, it is anticipated that the Draft Housing Element will be
revised up to three times prior to its final ad option. Although the consultant and staff are
striving for a January 2023 adoption and HCD certification, staff does not anticipate
significant consequences of a late adoption because the City does not anticipate the
need for any rezoning to accommodate RHNA. The attached memo from ABAG outlines
the consequences of late adoption (Attachment 2).
Next steps: In addition to fixing typographical errors, the September 12, 2022 draft will
be revised based on comments received from the public, the City Counci l, and the
Planning Commission. The revised draft will then be sent to HCD for initial comments
and published on the City’s website. City staff will also continue to meet with the local
community and housing stakeholders during the 90-day HCD review period. Based on
the experiences of other cities, staff anticipates meeting with HCD (virtually)
approximately one week prior to receiving their comments. Staff will update the
Planning Commission and City Council once the formal comments are received.
PUBLIC NOTICING / OUTREACH
Comments received through October 12, 2022 (the end of the Draft Housing Element
30-day review and comment period) are included in the attachments. Staff will continue
to accept public comments until the Housing Element is adopted by the City Council in
2023. All comments have been forwarded to the Housing Element consultant, and
recommendations have been considered and included in the Housing Element where
appropriate and feasible to accomplish in the 8-year planning period. The Planning
Commission meeting was noticed in the Dispatch on Friday October 7th. Public outreach
also consisted of a dedicated housing element update website with a description of the
housing element update process, how to provide input, workshop dates and materials, a
link to the Housing Element update survey, and FAQs. A bilingual online community
survey was heavily promoted through email list notification, project website, flyers,
2 In the Southern California Association of Governments (SCAG) region, the due date for Housing
Elements, October 15, 2021 (extended to 10/15/22), has passed, and most jurisdictions are still working
with HCD to receive certification.
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social media, stakeholder interviews, community workshops, and handed out in person.
Four focus groups were held on March 29, April 5, April 7 and April 12, 2022, to gather
input from community members and housing service providers. The City also held
several public meetings including bilingual virtual community workshops on March 30,
2022 and June 28, 2022; an Equity Advisory Group Meeting on August 23, 2022, a
bilingual joint study session with the Planning Commission and City Council on August
29, 2022; and one additional virtual community meeting on September 27, 2022.
Attachments:
1. Draft Housing Element 9-12-22
2. ABAG Memo Timing Requirements for Housing Element Adoption
3. Public Comments through 10-12-22
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CITY OF GILROY
HOUSING ELEMENT
6TH CYCLE
2023 – 2031
Public Review Draft
September 9, 2022
5.A.a
Packet Pg. 14 Attachment: Draft Housing Element 9-12-22 (4016 : Review of the Draft Housing Element)
Table of Contents ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan i
Table of Contents
INTRODUCTION .............................................................................................................................. 1
Purpose and Content ....................................................................................................................... 1
Relationship to Other Elements and Plans ................................................................................... 1
Public Participation .......................................................................................................................... 1
Summary of Comments Received .............................................................................................. 2
REVIEW OF PAST ACCOMPLISHMENTS ......................................................................................... 5
Housing Production ......................................................................................................................... 5
No Net Loss and Adequate Sites ................................................................................................ 6
Effectiveness at Assisting Special Needs Populations ................................................................. 6
Accessibility Improvements ........................................................................................................ 7
Seniors and Residents with Disabilities ..................................................................................... 7
At-Risk Youth Services ................................................................................................................. 8
Homeless Outreach ..................................................................................................................... 8
Farmworkers ................................................................................................................................. 9
2015 – 2023 (5th Cycle) Housing Element Programs .................................................................. 10
HOUSING NEEDS ASSESSMENT ................................................................................................... 28
Projected Housing Needs .............................................................................................................. 29
Existing Housing Need ................................................................................................................... 29
Demographic Characteristics.................................................................................................... 29
Employment Trends .................................................................................................................. 34
Household and Housing Stock Characteristics ....................................................................... 37
Overpayment .............................................................................................................................. 44
Overcrowding ............................................................................................................................. 46
Housing Inventory and Market Conditions ............................................................................. 47
Preservation of Assisted Units At Risk of Conversion ............................................................ 51
Special Needs Groups .................................................................................................................... 55
Persons with Disabilities............................................................................................................ 56
Elderly Persons ........................................................................................................................... 58
Large Households ...................................................................................................................... 61
Female-Headed Households .................................................................................................... 63
Homeless/Unhoused Population ............................................................................................. 63
Farmworkers ............................................................................................................................... 65
Extremely Low-Income Households ........................................................................................ 67
Summary of Housing Needs ......................................................................................................... 68
5.A.a
Packet Pg. 15 Attachment: Draft Housing Element 9-12-22 (4016 : Review of the Draft Housing Element)
Table of Contents ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan ii
AFFIRMATIVELY FURTHERING FAIR HOUSING ............................................................................ 70
Introduction, Outreach, and Assessment ................................................................................... 70
Introduction ................................................................................................................................ 70
Public Outreach .......................................................................................................................... 70
Findings ....................................................................................................................................... 73
City Overview .................................................................................................................................. 73
Integration and Segregation ......................................................................................................... 75
Race and Ethnicity ...................................................................................................................... 75
Income ......................................................................................................................................... 79
Familial Status ............................................................................................................................. 84
Persons with Disabilities............................................................................................................ 87
Findings ....................................................................................................................................... 90
Racially and Ethnically Concentrated Areas of Poverty and Affluence .................................... 91
R/ECAPs ....................................................................................................................................... 91
Racially Concentrated Areas of Affluence ............................................................................... 94
Disparities in Access to Opportunities ......................................................................................... 95
California Tax Credit Allocation Committee (TCAC) ............................................................... 95
Access to Opportunities, Regional Comparisons ................................................................ 101
Transportation ......................................................................................................................... 103
CalEnviroScreen 4.0 ................................................................................................................ 105
Findings .................................................................................................................................... 106
Disproportionate Housing Needs ............................................................................................. 107
Substandard Housing ............................................................................................................. 107
Overcrowding .......................................................................................................................... 109
Homelessness ......................................................................................................................... 111
Displacement ........................................................................................................................... 114
Findings .................................................................................................................................... 116
Other Contributing Factors ........................................................................................................ 116
Historic Immigration and Land Use Patterns ...................................................................... 116
Affordability and Location Within Santa Clara County ....................................................... 117
Fair Housing Issues, Contributing Factors, and Meaningful Action ...................................... 118
CONSTRAINTS ON HOUSING ..................................................................................................... 136
Governmental Constraints ......................................................................................................... 136
Land Use Controls ................................................................................................................... 136
Providing for a Variety of Housing Types ............................................................................. 145
Residential Development Ordinance .................................................................................... 150
Urban Growth Boundary and Urban Service Area .............................................................. 151
Development Review and Permitting Procedures .............................................................. 152
Housing for Persons with Disabilities ................................................................................... 162
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Table of Contents ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan iii
Building Code........................................................................................................................... 163
Code Enforcement .................................................................................................................. 163
On- and Off-Site Improvement Requirements .................................................................... 163
Nongovernmental Constraints .................................................................................................. 165
Requests to Develop Below the Anticipated Density .......................................................... 165
Land Costs ................................................................................................................................ 165
Construction Costs .................................................................................................................. 165
Financing Availability ............................................................................................................... 166
Federal and State Programs .................................................................................................. 167
Environmental and Infrastructure Constraints ................................................................... 167
HOUSING SITES AND RESOURCES ............................................................................................ 173
Land Inventory............................................................................................................................. 173
Housing Allocation .................................................................................................................. 173
Realistic Capacity ..................................................................................................................... 174
Assumed Affordability ............................................................................................................ 176
Environmental and Infrastructure Constraints ................................................................... 177
Entitled and Pending Projects ................................................................................................ 181
Accessory Dwelling Units (ADUs) ........................................................................................... 182
Ability to Meet the RHNA ........................................................................................................ 183
Site Details ................................................................................................................................... 184
Vacant ....................................................................................................................................... 184
Non-Vacant Sites ..................................................................................................................... 185
R4 Northern Cluster ................................................................................................................ 186
Monterey Cluster 1 (Downtown Expansion District) ........................................................... 188
Monterey Cluster 2 (Gateway/ Downtown Expansion District) ......................................... 190
Monterey Cluster 3 (Gateway District) .................................................................................. 192
Monterey Cluster 4 (Downtown Expansion District) ........................................................... 193
Commercial Services and Other ............................................................................................ 196
Financial Resources .................................................................................................................... 198
Countywide Programs ............................................................................................................ 198
Department of Housing and Urban Development Grants ................................................. 199
Statewide Resources ............................................................................................................... 203
Administrative Resources ...................................................................................................... 204
HOUSING GOALS, POLICIES, AND PROGRAMS ......................................................................... 206
Housing Production .................................................................................................................... 206
Removal of Governmental Constraints .................................................................................... 206
Housing Preservation and Rehabilitation ................................................................................ 207
Housing Assistance to Meet the Needs of All Income Levels ................................................ 207
Special Housing Needs ............................................................................................................... 208
Affirmatively Furthering Fair Housing ....................................................................................... 208
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Table of Contents ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan iv
Education and Outreach ............................................................................................................ 209
Quantified Objectives ............................................................................................................. 209
Programs ...................................................................................................................................... 209
APPENDIX A: SITES INVENTORY MAP ........................................................................................ 236
APPENDIX B: SITES INVENTORY LIST ......................................................................................... 238
APPENDIX C: OUTREACH ........................................................................................................... 242
List of Figures
Figure 1: Population Age Distribution, 2019 ................................................................................... 32
Figure 2: Regional Racial/Ethnic Composition, 2019 ...................................................................... 34
Figure 3: Regional Employment by Industry, 2019 ........................................................................ 36
Figure 4: Regional Home Prices Over Time, 2001–2020 ................................................................ 41
Figure 5: Disability by Type, 2019 ..................................................................................................... 57
Figure 6: Developmental Disability by Type Served by San Andreas Regional Center, 2020.... 58
Figure 7: Census Tracts and RHNA Sites, 2022 ............................................................................... 74
Figure 8: Racial and Ethnic Majority, 2010 ...................................................................................... 76
Figure 9: Percent of the Population that is Non-White, 2018 ....................................................... 77
Figure 10: Percent non-White Comparison of RHNA Units ........................................................... 78
Figure 11: Dissimilarity Index for Race ............................................................................................ 79
Figure 12: Low to Moderate Income Population and RHNA Sites, 2011-2015 ........................... 81
Figure 13: Low to Moderate Income Population Comparison of RHNA Units ............................ 82
Figure 14: Poverty Status, 2010-2014 and 2015-2019 ................................................................... 83
Figure 15: Housing Choice Vouchers ............................................................................................... 84
Figure 16: Children in Female-Headed Households and RHNA Sites .......................................... 85
Figure 17: Female Headed Households Comparison of RHNA Units .......................................... 86
Figure 18: Children in Married-Couple Households ...................................................................... 87
Figure 19: Disability Characteristics, Gilroy, 2019 .......................................................................... 88
Figure 20: Population with a Disability, 2010-2014 and 2015-2019 ............................................. 89
Figure 21: Population with a Disability Comparison of RHNA Units ............................................ 90
Figure 22: R/ECAPs in the City and Vicinity ...................................................................................... 93
Figure 23: RHNA Sites by R/ECAP ..................................................................................................... 94
Figure 24: RCAAs Vicinity and RHNA Sites ....................................................................................... 95
Figure 25: TCAC Economic Score, 2021 ........................................................................................... 97
Figure 26: TCAC Education Score ..................................................................................................... 98
Figure 27: TCAC Environmental Score ............................................................................................. 99
Figure 28: TCAC Composite Score and RHNA Sites ..................................................................... 100
Figure 29: TCAC Designation Comparison of RHNA Units ......................................................... 101
Figure 30: Transit Route Map ........................................................................................................ 104
Figure 31: CES Percentile and RHNA Sites ................................................................................... 105
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City of Gilroy Housing Element ▐ 6th Cycle Housing Plan v
Figure 32: CalEnviroScreen Percentile Comparison of RHNA Units .......................................... 106
Figure 33: Housing Problems by Tenure and Race/Elderly/Housing Size ................................ 108
Figure 34: Cost Burden by Tenure and Race/Elderly/Housing Size........................................... 108
Figure 35: Overpayment by Owners ............................................................................................. 109
Figure 36: Overpayment by Renters ............................................................................................. 109
Figure 37: Overcrowded Households ........................................................................................... 110
Figure 38: Communities Vulnerable to Displacement ................................................................ 115
Figure 39: Gilroy Land Use Map .................................................................................................... 137
Figure 40: Gilroy Special Flood Hazard Areas .............................................................................. 179
Figure 41: Gilroy Wildland Urban Interface Areas ....................................................................... 180
List of Tables
Table 1: 5th Cycle RHNA Progress ....................................................................................................... 6
Table 2: Review of 2015 – 2023 (5th Cycle) Housing Element Programs ...................................... 11
Table 3: Gilroy RHNA, 2023–2031 .................................................................................................... 29
Table 4: Regional Population Trends, 2010–2020 .......................................................................... 30
Table 5: Average Annual Population Growth Rate ......................................................................... 30
Table 6: Population Age Distribution, Gilroy ................................................................................... 31
Table 7: Racial and Ethnic Composition, Gilroy .............................................................................. 33
Table 8: Employment Trends, Gilroy ............................................................................................... 35
Table 9: Major Employers, 2021 ....................................................................................................... 37
Table 10: Change in Households, 2000–2019 ................................................................................. 38
Table 11: Regional Average Household Size ................................................................................... 38
Table 12: Household Size Distribution, 2019 .................................................................................. 38
Table 13: Median Household Income by Tenure, 2019 ................................................................. 39
Table 14: Income Range by Affordability Level Based on State Area Median Income, 2022 .... 39
Table 15: Household Income by Tenure, 2018 ............................................................................... 40
Table 16: Zillow Home Value Index, 2020 and 2021 ...................................................................... 42
Table 17: Average Monthly Rent by Unit Size, Gilroy, 2021 .......................................................... 42
Table 18: Income Needed to Afford Market Rate Rent, Santa Clara County .............................. 43
Table 19: Maximum Affordable Monthly Rent by Income Category............................................ 43
Table 20: Occupancy Rates ............................................................................................................... 44
Table 21: Housing Cost as a Percentage of Household Income, 2018 ........................................ 44
Table 22: Overcrowded Households, 2019 ..................................................................................... 47
Table 23: Housing Units, 2000–2019 ............................................................................................... 47
Table 24: Unit Size by Tenure, Gilroy, 2019..................................................................................... 48
Table 25: Housing Inventory by Unit Type ...................................................................................... 48
Table 26: Unit Type by Tenure, 2019 ............................................................................................... 49
Table 27: Tenure by Housing Age .................................................................................................... 50
Table 28: Units Lacking Plumbing or Complete Kitchen Facilities, 2019 ..................................... 51
Table 29: Potential Units at Risk of Conversion .............................................................................. 53
Table 30: Replacement Cost ............................................................................................................. 53
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Table of Contents ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan vi
Table 31: Householders by Age ........................................................................................................ 59
Table 32: Median Household Income for Elderly Households, 2019 ........................................... 59
Table 33: Income Distribution, Elderly Households ....................................................................... 60
Table 34: Elderly People with Disabilities ........................................................................................ 60
Table 35: Elderly Households by Housing Problems and Tenure, 2018 ..................................... 61
Table 36: Large Households by Tenure, 2019 ................................................................................ 62
Table 37: Large Households by Housing Problems and Tenure, 2018........................................ 63
Table 38: Female-Headed Households by Tenure, Gilroy, 2019 .................................................. 63
Table 39: Regional Homeless Population ........................................................................................ 64
Table 40: Homeless Facilities in Gilroy ............................................................................................ 65
Table 41: Number of Santa Clara County Farmworkers and Farms, 2017 ................................. 66
Table 43: Extremely Low-Income Households with Housing Problems, 2018 ........................... 68
Table 44: Dissimilarity Index for Income ......................................................................................... 80
Table 45: Opportunity Indicators .................................................................................................. 103
Table 46: Overcrowding, 2019 ....................................................................................................... 111
Table 47: Homeless Facilities in Gilroy ......................................................................................... 112
Table 48: Regional Point in Time Count, 2019 ............................................................................. 113
Table 49: Permanent Local Housing Allocation Funds for FYs 2022-2024 ............................... 114
Table 50: Contributing Factors ...................................................................................................... 118
Table 51: AFFH Actions Matrix ....................................................................................................... 120
Table 52: Neighborhood District Target Densities ...................................................................... 140
Table 53: Downtown Specific Plan Development Standards ..................................................... 141
Table 54: Existing Residential Standards ...................................................................................... 143
Table 55: Existing Residential Parking Standards ....................................................................... 144
Table 56: Residential Use Table ..................................................................................................... 147
Table 57: Permit Processing Time ................................................................................................. 155
Table 58: Permit Processing Time, Months, Regional Comparison .......................................... 156
Table 59: Planning Related Fees .................................................................................................... 157
Table 60: Development Impact Fees ............................................................................................ 159
Table 62: Total Fees per Unit, Regional Comparison .................................................................. 159
Table 63: Fees as Percentage of Total Development Costs, Regional Comparison ................ 160
Table 65: Recent Vacant Lot Sales in Gilroy ................................................................................. 165
Table 66: Disposition of Home Loans, 2020 ................................................................................ 167
Table 67: 2023–2031 RHNA ........................................................................................................... 173
Table 68: No Net Loss Buffer ......................................................................................................... 174
Table 69: Recent Multifamily Project Densities ........................................................................... 175
Table 70: Assumed Yields .............................................................................................................. 176
Table 71: Densities, Affordability, and Implementing Zones ..................................................... 177
Table 72: Entitled and Pending Projects ....................................................................................... 181
Table 73: ADUs Toward the RHNA ................................................................................................ 182
Table 74: ADU Affordability Assumptions .................................................................................... 182
Table 75: Housing Capacity ............................................................................................................ 183
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Table of Contents ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan vii
Table 76: Lower-Income RHNA Capacity ...................................................................................... 184
Table 77: Residential Vacant Land Capacity ................................................................................. 185
Table 78: Non-Vacant Site Capacity .............................................................................................. 186
Table 79: CDBG Funded Agencies ................................................................................................. 200
Table 80: CARES Act Funds ............................................................................................................. 200
Table 81: Permanent Local Housing Allocation Funds for FYs 2022-2024 ............................... 202
Table 82: Total Quantified Objectives, 2023 – 2031 .................................................................... 209
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Introduction ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 1
Introduction
Purpose and Content
The City of Gilroy’s 2023-2031 6th Cycle Housing Element has been prepared in compliance with
the State of California Government Code Section 65302 and in conformance with the Housing
Element Guidelines as established by the California Department of Housing and Community
Development (HCD). This Housing Element sets forth the City’s overall housing objectives in
the form of goals, policies, and programs.
Relationship to Other Elements and Plans
This Housing Element identifies goals, policies, and programs that guide housing policy for the
City for 2023 – 2031. The goals, policies, and programs are consistent with the direction of the
other General Plan elements, specifically the Land Use Element, Potential Hazards Element,
and the Environmental Justice Element. Each goal is followed by one or more policies that are
designed to provide direction to the policy makers that will enable progress toward the goals.
Consistency will be reviewed as part of the annual General Plan implementation progress
report as required under Government Code Section 65400. Listed after a discussion of the
goals and policies are the programs designed to implement the specific goals and policies.
The Housing Element goals, policies, and programs aim to:
Encourage the development of a variety of housing opportunities and provide
adequate sites to meet the 2023 – 2031 Regional Housing Needs Allocation
(RHNA).
Assist in the development of housing to meet the needs of lower- and moderate-
income households.
Address and, where appropriate and legally possible, remove governmental
constraints to housing development.
Conserve, preserve, and improve the condition of the existing affordable housing
stock.
Promote equal housing opportunity for all residents to reside in the housing of their
choice. These objectives are required by and delineated in State law (California
Code Section 65583 [c][1]).
Public Participation
The City of Gilroy made a diligent effort to encourage public participation in the development
of the Housing Element. Outreach for the Housing Element update began in 2021, starting with
City Council public meetings to introduce the housing element update process and to get initial
feedback on potential programs for inclusion in the housing element. The City of Gilroy also
participated in a regional (virtual) outreach meeting through the Santa Clara County
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Introduction ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 2
Collaborative that included residents and stakeholders from Gilroy, Morgan Hill, and the
County of Santa Clara; approximately 20 attendees participated in the Gilroy breakout room.
Targeted outreach began in January 2022. This involved engaging a diverse group of people in
the planning process, including community members, stakeholders, service providers,
educators, and the Planning Commission and City Council in identification of Gilroy’s Housing
Element housing issues. The public participation program included:
Website. An interactive housing element update website, launched in February
2022 and accessed through the City’s webpage, that included a description of the
project, how to provide input, workshop dates and materials, a link to the Housing
Element update survey, and FAQs.
Surveys. A bilingual (Spanish) online community survey was heavily promoted
through email list notification, project website, flyers, stakeholder interviews,
community workshops, and handed out in person.
Stakeholder Interviews. Four focus groups were held on Tuesday, March 29 at 1:00
p.m.; Tuesday, April 5 at 1:00 p.m.; Thursday, April 7 at 1:00 p.m.; and Tuesday, April
12 at 10:00 a.m. to gather input from community members and housing service
providers.
Community workshops. Two virtual community workshops were held on
Wednesday, March 30, 2022 at 6:00 PM, and Tuesday, June 28, 2022 at 6:00 PM. The
website was updated to include information about the community meetings and
the project planner sent emails to notify individuals on the mailing list which
included stakeholders, community service providers, and members of the public.
The links to the presentation video recording were posted on the Housing Element
Update website.
Study Session. One joint study session with the Planning Commission and City
Council was held on August 29, 2022 at 6:00 PM. All the efforts of notifying the public
that were made for the two community meetings were repeated for the joint study
session. The links to the presentation video recording were posted on the Housing
Element Update website. The joint study session focused primarily on RHNA site
strategy, housing issues, and proposed programs included in the Housing Element.
It included a robust discussion of housing issues and responsive programs to meet
the needs of all Gilroy residents.
Summary of Comments Received
During the outreach process the City heard comments ranging from difficulty paying rent,
mortgage, or down payment, homelessness, and insufficient housing supply including
affordable housing, farm-worker housing, and preference on locations for future housing.
Many of the programs proposed as well as the RHNA sites inventory in the Housing Element
Update reflect the community input. In summary, the community engagement and input
yielded the following themes and feedback:
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Introduction ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 3
Affordability: Participants expressed the difficulties to afford homes and rent in
Gilroy and the larger region; specifically identifying first time home buyers, farm
workers and seniors as key impacted groups. Participants expressed concern that
Gilroy incomes are lower comparatively to the regional median; therefore, housing
that may be affordable for the surrounding region may not be for Gilroy residents.
Program A - 10 consists of the development of an Inclusionary Housing Policy to
establish inclusionary housing requirements so that new developments reserve a
percentage of the total units for lower- and moderate-income households.
Importance of Investment in East Gilroy: Participants noted a disparity in housing
and quality of infrastructure and amenities between the east side and west side of
the City. Participants noted the importance of investing in downtown to provide
access to necessary resources and adequate infrastructure concurrently with
housing development. Program F - 3 is included to ensure place-based investments
and improvements are occurring in east Gilroy, especially in the downtown area.
Education and Outreach: Participants expressed a lack of community engagement
and education on affordable housing, ADUs, housing services and programs that
are available, and housing policy. Programs G - 2, G - 3, and G - 5 implement
outreach and education strategies to increase community awareness about ADUs,
housing resources, and. available fair housing support. Program G - 4 provides
focused outreach in the downtown area.
Prioritizing Extremely Low-Income Housing: Participants addressed the need for
prioritizing development of extremely low-income units. Additionally, residents
expressed the need to prioritize the allocation of these extremely low-income units
to existing Gilroy residents. Program E - 9 is included to develop a priority system
for the allocation of extremely low-income units, including prioritizing current
residents of Gilroy.
Disparity of income between the City and the larger Region. The large difference
between the median income in the City and the regional AMI was frequently noted
in outreach. The difference was $33,871 (24%) in 2020. Participants expressed the
inability to afford lower-income units based on the AMI category income limits.
Program E - 9 is included to develop a priority system for the allocation of extremely
low-income units, including prioritizing current residents of Gilroy.
A summary of outreach is also provided in the Affirmatively Furthering Fair Housing chapter.
For complete survey results and additional detail on outreach see APPENDIX C: OUTREACH
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4
CITY OF GILROY
HOUSING ELEMENT
6TH CYCLE
REVIEW OF PAST ACCOMPLISHMENTS
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Review of Past Accomplishments ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 5
Review of Past Accomplishments
California Government Code Section 65588(a) requires that each jurisdiction review its housing
element as frequently as is appropriate and evaluate:
The appropriateness of the housing goals, objectives, and policies in contributing to
the attainment of the state housing goal.
The effectiveness of the housing element in attainment of the community’s housing
goals and objectives.
The progress in implementation of the housing element.
According to the State HCD, the review is a three-step process:
Review the results of the previous element’s goals, objectives, and programs. The
results should be quantified where possible but may be qualitative where
necessary.
Compare what was projected or planned in the previous element to what was
actually achieved. Determine where the previous housing element met, exceeded,
or fell short of what was anticipated.
Based on the above analysis, describe how the goals, objectives, policies, and
programs in the updated element are being changed or adjusted to incorporate
what has been learned from results of the previous element.
Housing Production
The City of Gilroy had a total RHNA allocation of 1,088 units in the 5th Cycle. As of December
2021, 2,367 units have been permitted during the 5th Cycle, exceeding the overall allocation by
1,279 units. About 60 percent of these new units were affordable to above-moderate incomes.
The City produced four (4) times the low income allocation, approximately 40% of its moderate
income allocation, and approximately 66% of its very-low income allocation. There is a
remaining RHNA need of 80 very low income units and 127 moderate income units.
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Review of Past Accomplishments ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 6
Table 1: 5th Cycle RHNA Progress
Very Low Low Moderate Above
Moderate Total
5th Cycle RHNA
Allocation 236 160 217 475 1,088
Constructed 156 686 90 1,435 2,367
Remaining
Requirement 80 - 127 - 207
No Net Loss and Adequate Sites
The 2015-2023 Housing Element identified adequate capacity for its 5th cycle allocation of units,
identifying a surplus of 1,088 lower-income units, 637 moderate-income units, and 1,713
above moderate- income units. Additionally, in 2020, the City updated its General Plan to
increase densities for specified land use designations, and allow mixed-use residential along
the First Street commercial corridor. These amendments increased zoned capacity for all
income levels in Gilroy.
The City reviewed its 5th cycle sites, past approvals, and the zoning code and determined that
it has maintained adequate sites to meet the RHNA for all income levels throughout the 2015
to 2023 planning cycle.
Effectiveness at Assisting Special Needs Populations
This section reviews the City’s progress on assisting populations with special housing needs
during the 5th Cycle. The City has received and allocated funding to improve access to needs
that improve the quality of life among seniors, the homeless, and extremely low-income
households during the 2015 to 2023 planning cycle.
Funding during the 5th Cycle was allocated through the Housing Trust Fund (HTF). Recently,
the City Council approved the replacement of the HTF with the Permanent Housing Allocation
(PLHA) Fund, making more funds available for public service addressing homeless basic need
programs as well as programs that focus on homelessness prevention. The PLHA Fund will
continue to be used to cover consulting services for current affordable rental and ownership
agreements as well partially funding a staff position. Funding allocations were based on
priorities identified in the City’s consolidated plan. High priority items identified in the plan
include special needs services for the elderly, special need services for youth, homeless
supportive services, and rehabilitation of existing affordable housing.
In the 2022 – 2023 fiscal year (FY), the City allocated $237,000 in Permanent Local Housing
Allocation Fund (PLHA) funds for services related to homelessness, fair housing, and special
needs, such as persons with disabilities. Another $237,000 for the same services are allocated
for the 2023-2024 fiscal year.
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Review of Past Accomplishments ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 7
The City also allocated $613,154 in CDBG CARES ACT-Corona Virus (CDBG-CV) Funds towards
programming that would address the impacts resulting from the COVID-19 pandemic,
including rental assistance, small business assistance, and food delivery.
For the 2021 – 2022 fiscal year funding cycle, the City allocated $287,380 in Community
Development Block Grant (CDBG) funds toward community service needs, including senior
services, youth services, and home repair and accessibility modification. For the 2022 – 2023
fiscal year, the City allocated $205,452 in Community Development Block Grant (CDBG) funds
towards senior services, youth services, and home repair.
In general, these programs have been successful at providing new opportunities, resources,
and procedures to assist special needs populations. The City is committed to furthering fair
housing and supporting special needs populations and has included several programs in its
6th Cycle Element to further address the housing needs of all groups.
Accessibility Improvements
The need to revitalize older City infrastructure, particularly accessibility for elderly persons and
persons with disabilities is identified as a top priority in the City’s 2020 – 2025 Consolidated
Plan and 2020 – 2021 Annual Action Plan1. The Consolidated Plan further identifies accessibility
improvements such as wheelchair ramps, curbing, and sidewalks as one solution to this need.
In November 2021, the City awarded $70,592 in CDBG funding to a consultant to design and
prepare construction documents for property located at 6500 Monterey Road, in front of
Gateway Senior affordable Apartments. The scope of work included design of standalone
HAWK (High-Intensity Activated Crosswalk) system for safe pedestrian crossing, design of two
ADA compliance curb ramps and minor concrete work, and design of new striping for
pedestrian crossing and safety. The full construction cost of the CIP project is estimated to be
$314,400. For the 2022-2023 fiscal year funding cycle, the City also allocated $145,090 in
Community Development Block Grant (CDBG) funds toward improving sidewalks and curb
ramps throughout the City.
Seniors and Residents with Disabilities
The City also identifies supportive services for seniors and persons with disabilities under the
Special Needs section of the 2020-2025 Consolidated Plan. The Consolidated Plan discussed
“assisting special needs population” in the summary section of this chapter. As noted above,
the City allocated a portion of the CDBG funds and a portion of the PLHA funds towards senior
services and residents with disabilities. This included $18,560 for the Live Oak Day adult day
care program, $20,000 for the Silicon Valley Independent Living Center Housing Services for
Gilroy Residents with Disabilities program, and $27,000 for the Health Trust Meals on Wheels
food service program. This service provides access to hot meal deliveries 5 days per week to
people with disabilities and seniors who are unable to leave the house. Similarly, $100,359 of
1 City of Gilroy 2020-2025 Consolidated Plan and 2020-2021 Annual Action Plan.
https://www.cityofgilroy.org/DocumentCenter/View/11526/City-of-Gilroy-2020-2025-Consolidated-Plan-and-AAP-FINAL
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Review of Past Accomplishments ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 8
the CDBG-CV funds were allocated towards the local YMCA’s food distribution program for
homebound seniors which was impacted by the COVID-19 pandemic and shelter in place
orders.
The Recreational Division at City Hall provides access to free food at the following locations:
Box Lunches to go for Seniors at the Gilroy Senior Center, 7371 Hanna Street.
Second Harvest Food Bank Brown Bag Drive Thru Program at the Gilroy Library on 350
W 6th Street
Free groceries from the Second Harvest Food Bank at San Ysidro Park on 7700
Murray Avenue.
At-Risk Youth Services
The 2020 – 2025 Consolidated Plan also identified Gilroy’s at-risk youth as a priority need for
the City. Over the 2021 – 2023 (two-year) fiscal year, a portion of the CDBG funds discussed
above were allocated towards Gilroy’s at-risk youth. The Community Agency for Resources
Advocacy and Services (CARAS) RYSE (Reaching our Young people to Succeed and Empower
with Unlimited Potential) program received $8,500 to provide support to young girls who are
at-risk through crime prevention, gang intervention, youth empowerment, and recreational
activities. The Boys and Girls Club Ochoa Clubhouse CORE Enrichment Program received
$8,500 to empower kids and teens to excel in school, become good community members, and
lead healthy, productive lives through education, learning, the arts, health and wellness,
character and leadership, sports and recreation, and workforce readiness. The Gilroy Youth
Center received $76,904 for engaging high-risk youth and their families with social,
recreational and educational programs that support and enhance their quality of life through
community-based recreation. The Gilroy Youth Center is a free program for income eligible
residents, providing an after-school program during the school year and a day camp during
the summer.
Homeless Outreach
A portion of the PLHA funds and CDBG-CV funds discussed above was allocated towards
homelessness prevention. The following agencies received PLHA Funding for FY 22-23 and FY
23-24: St. Joseph's Family Center, Homeless Prevention Services received $55,000; South
County Compassion Center, Outreach for the Unhoused received $40,000; Community Agency
for Resources Advocacy and Services (CARAS) Homeward Bound Homeless Prevention
Services Program received $20,000; and St. Joseph's Family Center, Gilroy Street Team
program received $35,000. Through its CDBG-CV1 and CDBG-CV2 funds, the City provided
$287,309 in support to Saint Joseph's Family Center's Rental Assistance program. This program
is designed to prevent homelessness through emergency rental assistance and deposits. The
funds helped very-low income tenants who have been impacted by COVID-19 with paying a
portion of their rents to avoid eviction. The Program benefited an estimated 231 low income
individuals.
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Review of Past Accomplishments ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 9
Farmworkers
There are 184 dwelling units to meet the permanent and seasonal housing needs of extremely
low-income and low-income farmworkers in Gilroy. Due to the seasonal nature of farm work,
many households have a difficult time securing safe, habitable, and affordable housing. There
are existing support and services for the farmworker population in the City. The Santa Clara
County Housing Authority (SCCHA) has provided housing assistance through the Ochoa
Migrant Center located in Gilroy. The center serves as a migrant camp 8 months out of the
year and has 100 units available for farmworkers and their families. There are 33 three-
bedroom apartments and 67 two-bedroom apartments.
There are 4 housing developments for farmworkers located in Gilroy, which are owned and
managed by Eden Housing. These properties are:
The Trees, with 14 units
Aspen Grove, with 24 units
Maple Gardens with 18 units
Monterra Village, with 28 units
5.A.a
Packet Pg. 30 Attachment: Draft Housing Element 9-12-22 (4016 : Review of the Draft Housing Element)
Review of Past Accomplishments ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 10
2015 – 2023 (5th Cycle) Housing Element Programs
This section illustrates the City of Gilroy’s accomplishments and status in implementing the
housing programs identified for the 2015-2023 5th Cycle, as well as the continued
appropriateness of each program for the 2023-2031 6th Cycle. Programs that have been
successfully completed or that consist of routine staff functions are marked as “remove,” as
these programs are no longer necessary for the 6th Cycle. Previous programs that are
continued with no or minor modifications are marked as “continue.” Finally, programs marked
as “modify” or “consolidate” are programs that will be continued, but have updated goals and
metrics, and may involve combining multiple existing programs into a single 6th Cycle program
for ease of use and streamlining.
5.A.a
Packet Pg. 31 Attachment: Draft Housing Element 9-12-22 (4016 : Review of the Draft Housing Element)
Review of Past Accomplishments ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 11
Table 2: Review of 2015 – 2023 (5th Cycle) Housing Element Programs
5th Cycle
Program
Number
Program Name Objective Time Frame Accomplishments Continued
Appropriateness
6th Cycle
Program
Number
HOUSING PRODUCTION
H-1.A Publicize
Residential Sites
Inventory
The City shall make the residential sites
inventory available to developers by
publicizing it on the City website and
providing copies of the sites to developers.
The City shall update the list of sites annually,
or as projects are approved on the sites.
Post on website
within 6 months
of adoption;
update annually,
or as needed
The Housing Element, which
includes vacant and underutilized
residential sites, is on the City
website.
The most recent Residential Vacant
Land Inventory was completed in
November 2021 and is available on
the City’s website.
Retain – modify to
include clear
objectives and
additional
developer
outreach.
A - 4
H-1.B Residential
Development
Ordinance
The City shall review and revise, as
appropriate, the Residential Development
Ordinance to ensure that it does not pose a
constraint on the maintenance, improvement
and development of housing; and provides
capacity to meet the City’s RHNA need.
Furthermore, the City will encourage the
development of housing that is affordable to
a variety of income groups through the
Residential Development Ordinance by
comparing its features with the
Neighborhood District Ordinance and making
any changes to ensure the two policies are
compatible.
Review of RDO
following
adoption of the
New General Plan
(estimated FY
2015/16)
Senate Bill 330, signed by the
governor in 2019, prohibits a
jurisdiction from implementing any
provision that limits the number of
approvals or permits or puts a cap
on the number housing units that
can be approved or constructed, or
limits population. As a result, the
Residential Development
Ordinance is now null and void and
will be repealed as part of the City's
comprehensive zoning update in
2023.
Retain - modify:
The RDO will be
repealed as a part
of the City’s
comprehensive
zoning update in
2023.
B - 1
5.A.a
Packet Pg. 32 Attachment: Draft Housing Element 9-12-22 (4016 : Review of the Draft Housing Element)
Review of Past Accomplishments ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 12
5th Cycle
Program
Number
Program Name Objective Time Frame Accomplishments Continued
Appropriateness
6th Cycle
Program
Number
H-1.C Variety of
Housing in
Neighborhood
Districts
The City shall review and revise, as
appropriate, the Neighborhood District Policy
to ensure that it encourages the
development of housing that is affordable to
a variety of income groups by comparing its
features with the Residential Development
Ordinance and making any changes to
ensure the two policies are compatible and
designed to reach the same goals.
Review of
Neighborhood
District Policy in
conjunction with
the New General
Plan preparation
(estimated FY
2015/16)
The Residential Development
Ordinance is no longer in effect.
The 2040 General Plan includes a
new higher density Neighborhood
District designation, allowing a
greater range of housing types
from single family detached
dwellings (0-7 du/ac) to higher
density multi-family dwellings (16-
30du/ac).
Retain – modify
the
Neighborhood
District policy to
eliminate any
references to the
RDO (see
discussion above)
and provide
standards related
to the new
density ranges
and affordable
housing
requirements.
A - 5
H-1.D Facilitate Infill
Development
The City shall coordinate efforts with private
and non-profit developers, and other housing
related groups to encourage the construction
of residential development through a menu
of regulatory incentives (e.g., streamlined
review and other methods that will effectively
encourage infill development). The City shall
monitor infill development on a biannual
basis to ensure the effectiveness of programs
to encourage housing development. If, based
on its biannual review, the City finds that
additional programs are needed to facilitate
infill development, the City shall revise
programs as appropriate.
Monitor biennially
starting in 2016
Major Single-Family Developments
approved or occupied in 2020
included 171 single-family homes in
the Glen Loma Ranch Specific Plan
area. Major Multi-Family
Developments approved or
occupied in 2020 included 199
mixed-income townhome units and
475 affordable apartment units
with 75 of those units being
provided for the City’s senior
citizens.
In 2021, the City issued building
permits for 276 units, including 31
condominium units in the Glen
Loma Town Center, 120 apartment
units in the 1st and Kern
development, 97 single-family
Retain – modify
with a program
that will “Facilitate
Missing Middle
Housing” by
streamlining the
entitlement
process with a
ministerial
process for
duplexes,
triplexes and
quadplexes in
specified areas of
the City, that
meet objective
design standards.
A - 9
5.A.a
Packet Pg. 33 Attachment: Draft Housing Element 9-12-22 (4016 : Review of the Draft Housing Element)
Review of Past Accomplishments ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 13
5th Cycle
Program
Number
Program Name Objective Time Frame Accomplishments Continued
Appropriateness
6th Cycle
Program
Number
residential homes, and 27
accessory dwelling units. The City
also approved planning
entitlements for 100 apartment
units, two duplex units, and 115
single-family dwelling units. It is
anticipated that these entitled
projects will be subsequently
submitted for a building permit. All
of these units are considered infill
units.
H-1.E Monitor Permit
Requirements,
Processing
Procedures and
Land Use
Controls
To ensure permit requirements and
processing procedures do not constrain
residential development, the City shall
evaluate current requirements and
procedures on a biannual basis. The City shall
consult builders and other parties engaged in
housing development activities to identify
concerns. If permitting requirements are
determined to be a constraint to residential
development the City shall modify permitting
requirements and/or procedures to address
constraints, as feasible.
Biennial
evaluation
starting in 2016
and implement
changes as
appropriate
In 2020, the City awarded the
contract for the purchase and
implementation of a Land
Management System to Tyler
Technologies for the
implementation of EnerGov to
manage and track land
development applications, business
and professional licenses, special
event permits, code enforcement
cases, and fire prevention/pre-
treatment/ hazardous materials
management. The City and Tyler
teams kicked off the project in
September of 2020 with an
anticipated "go-live" in Spring 2023.
Applicants will be able to check the
status of their permit online and
staff will have greater control over
the workflow. The City also
continues to hold development
stakeholder roundtable meetings
(virtual in 2020) to maintain a dialog
Retain - modify by
splitting into two
programs. One
for the Land
Management
System
Implementation
and one that is
streamlining the
permit process as
a part of the 2023
comprehensive
Zoning Code
update
A - 8 and
B - 5
5.A.a
Packet Pg. 34 Attachment: Draft Housing Element 9-12-22 (4016 : Review of the Draft Housing Element)
Review of Past Accomplishments ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 14
5th Cycle
Program
Number
Program Name Objective Time Frame Accomplishments Continued
Appropriateness
6th Cycle
Program
Number
with the Development Community.
Topics included bicycle parking,
objective design standards, and a
potential update to the City's
Downtown Specific Plan.
H-1.F Zoning to
Encourage and
Facilitate Single-
Room
Occupancy Units
The City shall revise the Zoning Code to
establish explicit definitions for and
regulatory standards addressing single-room
occupancy units.
Review and
Amend Zoning
Code (estimated
FY 2015/16)
following
adoption of the
New General Plan
Not completed. The City will include
a definition for and regulatory
standards addressing single-room
occupancy units as part of the 2023
Zoning Update.
Retain - modify E - 2
H-1.G Study Micro-
Units
The City shall conduct a study of the
appropriateness of “micro-units” in Gilroy
and the existing barriers in the Zoning
Ordinance to the provision of micro-units.
Based on the findings of the study, the City
will make a determination of the
appropriateness of micro-units in Gilroy and,
if determined appropriate, identify methods
for eliminating barriers, and establish
appropriate development standards.
FY 2017/18 Not completed. The City will define
“micro-units” in Gilroy as part of the
2023 Zoning Update in anticipation
of creating a program for micro-
units in the 6th cycle housing
element.
Retain - modify E - 5
AFFORDABLE HOUSING
H.2.A Develop
Affordable
Housing
Incentives
The City shall review and revise, as
appropriate, current incentives and
regulatory concessions available to
developers for the development of affordable
housing throughout the city, and especially
within the Downtown Gilroy Specific Plan
area and Neighborhood District. Incentives
and regulatory concessions may include, but
are not limited to parking reductions, and
Review incentives
within 1-year of
Housing Element
adoption; revise,
as appropriate;
Monitor
effectiveness of
incentives and
regulatory
Partially Complete. The City
continues to monitor development
in the Downtown Specific Plan area
and provide technical assistance as
available.
In 2020, the City of Gilroy was
awarded $150,000 in funding under
the Local Early Action Planning
(LEAP) Grants Program,
Retain - modify A - 10
5.A.a
Packet Pg. 35 Attachment: Draft Housing Element 9-12-22 (4016 : Review of the Draft Housing Element)
Review of Past Accomplishments ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 15
5th Cycle
Program
Number
Program Name Objective Time Frame Accomplishments Continued
Appropriateness
6th Cycle
Program
Number
reduced setbacks. The City shall also provide
technical assistance, as feasible; information
on State and Federal funding opportunities;
and marketing to potential developers.
The City shall continue to monitor
development within the City’s Downtown
area on a biannual basis to ensure the
implementation of the Specific Plan’s policy
on encouraging the development of a mix of
retail, office and higher density residential
uses. The City shall encourage the
development of uses within the area to
closely follow the recommended land use
assumptions contained in the Specific Plan. If,
based on its biannual review, the City finds
that the proportion of residential uses to
non-residential uses are not being developed
as assumed in the Specific Plan, the City shall
investigate additional incentives, concessions
or assistance and revise programs as
appropriate.
concession
biennially, staring
in 2016; Ongoing
monitoring of
development
within Downtown
Specific Plan.
administered by the California
Department of Housing and
Community Development (HCD).
The majority of that grant money
will be used towards the City’s
2023-2031 Housing Element
Update. One of the tasks identified
in the grant application was the
preparation and implementation of
an Affordable Housing Ordinance.
H-2.B Pursue Funding
for Affordable
Housing
The City shall pursue funding from State,
Federal, and regional sources and support
applications for funding to help increase the
supply of affordable housing. Funding
programs may include but are not limited to:
At least biennially,
or as funding
opportunities
become available
The City evaluates funding
opportunities as they arise and
apply as appropriate. The City also
facilitates public hearings on behalf
of private developers who wish to
seek tax credit financing for an
affordable housing project.
Retain D - 4
5.A.a
Packet Pg. 36 Attachment: Draft Housing Element 9-12-22 (4016 : Review of the Draft Housing Element)
Review of Past Accomplishments ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 16
5th Cycle
Program
Number
Program Name Objective Time Frame Accomplishments Continued
Appropriateness
6th Cycle
Program
Number
One Bay Area Grants awarded by the
Association of Bay Area Governments;
HCD Local Housing Trust Fund Program;
HUD Section 811 funding for supportive
housing for extremely low-income
residents;
The state Infill Infrastructure Grant
program, sponsored by the Department
of Housing and Community
Development (HCD); and
The State Multifamily Housing Program
(MHP), sponsored by HCD.
H-2.C Community
Development
Block Grant
Program
The City shall continue to administer the
Community Development Block Grant
Program for all eligible activities, including
acquisition, rehabilitation, home buyer
assistance, economic development, homeless
assistance, public services, and public
improvements. The City shall continue to
inform non-profit organizations of funding
availability through the City’s website and
informational packets at City Hall.
Annually The City continues to administer
the CDBG program and funds
eligible activities as funding allows.
One such activity is a housing
rehabilitation program that helps
low income individuals with
accessibility improvements. The city
has provided a grant to Rebuilding
Together Silicon Valley to operate
and expand the Home Repair,
Rehabilitation and Modification
program in Gilroy. This program
provides a wide range of home
repair, accessibility, mobility and
rehabilitation improvements for
low income homeowners.
Retain D - 5
5.A.a
Packet Pg. 37 Attachment: Draft Housing Element 9-12-22 (4016 : Review of the Draft Housing Element)
Review of Past Accomplishments ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 17
5th Cycle
Program
Number
Program Name Objective Time Frame Accomplishments Continued
Appropriateness
6th Cycle
Program
Number
H-2.D Housing Trust
Fund
The City shall continue to administer the
City’s Housing Trust Fund for all eligible
activities, including new construction,
acquisition, rehabilitation, home buyer
assistance, homeless assistance, public
services related to housing, and preservation
of affordable housing. The City shall continue
to inform non-profit organizations of funding
availability through the City’s website and
informational packets at City Hall.
Annually Completed. During most of the 5th
cycle planning period, the City
allocated Housing Trust funds
towards housing-related activities.
These activities include fair housing
services, tenant landlord
counseling services, and homeless
prevention services. In 2022, the
City replaced the HTF with the
Permanent Housing Allocation
(PLHA) Fund, making more funds
available for public service
addressing homeless basic need
programs as well as programs that
focus on homelessness prevention.
Retain – modify to
reflect funds are
from the PLHA
rather than the
Housing Trust
Fund
D - 1
H-2.E Funding Sources
to Assist
Homeownership
The City shall pursue potential sources of
additional funding for homeownership
assistance, including the availability of State
HCD, CalHFA funds, HOME, and County
funds. The City shall improve public outreach
activities through the compilation of
resources for down payment assistance,
silent second mortgages, and other means of
acquiring a home.
Development of
resources for
public
dissemination by
December 2015;
ongoing review of
additional
funding sources
Partially completed. The City has
posted on its website links to
organizations who offer
homebuyer assistance, including
the Housing Trust of Silicon Valley,
an organization that helps first-time
homebuyers secure Below Market
Rate (BMR) down payment
assistance.
Retain - modify D - 2
H-2.F Section 8
Referrals
The City shall continue to provide Section 8
referral services and information to City
residents. The City shall make information on
the Section 8 voucher program available on
the City website.
Post on website
by January 2016;
provide referral
on an ongoing
basis
Completed. The City has posted on
its website a link to the Housing
Authority of Santa Clara County
website. Here individuals can learn
more about Housing Choice
voucher eligibility and determine if
the current waiting list is accepting
any additional households.
Retain D - 3
5.A.a
Packet Pg. 38 Attachment: Draft Housing Element 9-12-22 (4016 : Review of the Draft Housing Element)
Review of Past Accomplishments ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 18
5th Cycle
Program
Number
Program Name Objective Time Frame Accomplishments Continued
Appropriateness
6th Cycle
Program
Number
H-2.G Development of
Housing for
Extremely Low-
Income
Households
The City shall review and incorporate
appropriate regulatory incentives, financial
incentives, and other policies that encourage
the development of housing units for
extremely low-income households. The City
shall encourage and support the
development of housing for extremely low-
income households within future affordable
housing projects through various strategies
and programs that may include assistance
with entitlement processing; and modifying
development standards and granting
concessions and incentives for projects that
provide housing for lower income families.
Review and
amend Zoning
Code (estimated
FY 2015/16), as
appropriate,
following
adoption of the
New General Plan
Partially completed. The City
continues to encourage developers
to include extremely low-income
units in their housing projects. Staff
are available to meet with
developers and discuss various
incentives and concessions,
consistent with State density bonus
law.
Retain – modify
by including a
density bonus
beyond state law
with incentives
for ELI
households, and
inclusionary
housing policy.
A - 10 and
A - 11
H-2.H Water and Sewer
Service Priority
The City shall review and update every five
years, as necessary, the Water and Sewer
Service Priority Policy to ensure future
affordable projects will receive service
priority.
Review every 5
years, starting
December 2015
Completed. The Gilroy collection
system includes about 140 miles of
sewer mains. Policies in the new
2040 General Plan provide for
reliable sewer service for all
residents and businesses through a
cooperative effort between the City
and SCRWA. The General Plan also
includes policies to ensure the
provision of healthy, safe water for
all users in Gilroy through facilities,
policies, programs, and regulations.
Retain and Modify E - 1
5.A.a
Packet Pg. 39 Attachment: Draft Housing Element 9-12-22 (4016 : Review of the Draft Housing Element)
Review of Past Accomplishments ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 19
5th Cycle
Program
Number
Program Name Objective Time Frame Accomplishments Continued
Appropriateness
6th Cycle
Program
Number
HOUSING PRESERVATION AND REHABILITATION
H-3.A Housing
Rehabilitation
To enhance the quality of existing
neighborhoods, the City shall continue to
implement the City’s Housing Rehabilitation
Program. The City will continue using
Community Development Block Grant (CDBG)
funds to assist in the improvement of
substandard housing.
Ongoing The City currently funds a housing
rehabilitation program that
provides accessibility
improvements to very low income
households. The City has provided
a grant to Rebuilding Together
Silicon Valley to operate and
expand the Home Repair,
Rehabilitation and Accessibility
Modification program in Gilroy.
This program will provide a wide
range of home repair, accessibility,
mobility and limited rehabilitation
improvements for low income
homeowners.
Retain C - 2
H-3.B Code
Enforcement
Program
To ensure continued maintenance of housing
quality, condition, and use, the City shall
continue to enforce building codes to
address existing exterior and interior code
violations. Within current staffing limits, the
City shall contact owners of units identified as
substandard, offering inspection services and
providing information on the City’s
Rehabilitation Loan Program and
landlord/tenant information and mediation
services.
Ongoing The City continues to utilize CDBG
funding to fund housing code
enforcement services in the
Downtown Specific Plan area.
Retain – modify to
set quantified
objective
C - 3
5.A.a
Packet Pg. 40 Attachment: Draft Housing Element 9-12-22 (4016 : Review of the Draft Housing Element)
Review of Past Accomplishments ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 20
5th Cycle
Program
Number
Program Name Objective Time Frame Accomplishments Continued
Appropriateness
6th Cycle
Program
Number
H-3.C Monitoring of
Units At-Risk of
Converting to
Market Rate
The City shall provide for regular monitoring
of deed-restricted units that have the
potential of converting to market rate. In
order to proactively address units at-risk of
conversion, the City shall develop a program
to partner with non-profit housing providers
and develop a preservation strategy. This
strategy will at least include biennial contact
with property owners of affordable units,
identification of funds to purchase and
preserve affordable units, noticing of tenants
and technical assistance with applications for
funds.
Ongoing To date, no multi-family affordable
housing units have converted to
market rate or are at-risk of
conversion. Many of the complexes
have undergone significant
rehabilitation to update and
prolong the longevity of the units.
The city has contracted with
HouseKeys to serve as Program
Administrator of the city's BMR
home ownership and rental
property program. HouseKeys will
continue to evaluate the city's
current multi-family affordable
housing stock to determine if any
developments are at-risk of
conversion.
Retain C - 1
H-3.D Resale Control
on Owner-
Occupied Below
Market Rate
Units
The City shall continue to implement resale
controls on owner-occupied Below Market
Rate (BMR) units to ensure that affordable
units provided through public assistance or
public action are retained for 30 years or
more as affordable housing stock.
Ongoing The City has contracted with
HouseKeys to serve as Program
Administrator of the city's BMR
home ownership and rental
property program.
Retain C - 4
H-3.A Rent and Income
Restrictions on
Rental Below-
Market Rate
Units
The City shall continue to implement rent and
income restrictions on rental Below Market
Rate (BMR) units to ensure that affordable
units provided through public assistance or
public action are retained for 30 years or
more as affordable housing stock.
Ongoing The City has contracted with
HouseKeys to serve as Program
Administrator of the city's BMR
home ownership and rental
property program.
Retain C - 5
5.A.a
Packet Pg. 41 Attachment: Draft Housing Element 9-12-22 (4016 : Review of the Draft Housing Element)
Review of Past Accomplishments ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 21
5th Cycle
Program
Number
Program Name Objective Time Frame Accomplishments Continued
Appropriateness
6th Cycle
Program
Number
HOUSING OPPORTUNITY FOR RESIDENTS WITH SPECIAL NEEDS
H-4.A Housing for
Large Families
The City shall review and revise the Zoning
Code, as appropriate, to incorporate
appropriate regulatory incentives, and other
policies that encourage the development of
rental housing units with three or more
bedrooms to accommodate the needs of
large families. The City shall encourage and
support the development of rental housing
for large families within future affordable
housing projects through various strategies
and programs that may include assistance
with site identification and entitlement
processing; and modifying development
standards and granting concessions and
incentives.
Review and
amend Zoning
Code (estimated
FY 2015/16), as
appropriate,
following
adoption of the
New General Plan
Not completed. The City will
consider the appropriateness of
regulatory incentives and other
policies that encourage the
development of rental housing
units with three or more bedrooms
to accommodate the needs of large
families in Gilroy as part of the
2023 Zoning Update.
Remove and
consolidate with
Density Bonus
Incentives
program
A - 11
H-4.B Development of
Housing for
Seniors
The City shall consider areas for new senior
housing development, including residential
care facilities, that are convenient to public
transit and within walking distance to
shopping and restaurants, and incorporate
appropriate regulatory incentives, financial
incentives, and other policies that encourage
the development of housing for seniors. The
City shall continue to accept Senior only and
Affordable Senior Housing projects through
the RDO Exemption program to encourage
the development of these projects.
Review and
amend Zoning
Code (estimated
FY 2015/16), as
appropriate,
following
adoption of the
New General Plan
Not completed. As noted above,
the Residential Development
Ordinance is no longer in effect.
The City will consider areas for new
senior housing development,
including residential care facilities,
as part of the 2023 Zoning Update.
Retain – modify.
The RDO is no
longer in effect.
Housing for
seniors is a need
that will be
considered and
incorporated into
the density bonus
beyond state law
A - 11
5.A.a
Packet Pg. 42 Attachment: Draft Housing Element 9-12-22 (4016 : Review of the Draft Housing Element)
Review of Past Accomplishments ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 22
5th Cycle
Program
Number
Program Name Objective Time Frame Accomplishments Continued
Appropriateness
6th Cycle
Program
Number
H-4.C Reduced Parking
Standards for
Senior Housing
The City shall conduct a study to determine if
reduced parking standards for senior
housing is appropriate in Gilroy. Based on the
findings of the study, the City may revise the
Zoning Code, as necessary, to reduce parking
standards for senior housing.
Conduct study
and review
Zoning Code
(estimated FY
2015/16) (as
appropriate)
following
adoption of the
New General Plan
Not completed. The City will
consider reduced parking
standards for senior housing as
part of the Zoning Code update,
which will be completed in 2023.
Retain E - 6
H-4.D Development
and
Conservation of
Housing for
Farmworkers
The City shall continue to partner with the
Housing Authority of Santa Clara County and
various non-profit organizations to explore
and implement ways of providing affordable
farmworker housing. The City shall assist with
requests by developers for State and Federal
funding for development of multi-family
housing within city limits.
Outreach to Santa
Clara Housing
Authority and
non-profit
organizations
biennially starting
in 2016, and
identify and
pursue
development, as
appropriate
The City maintains communication
with Santa Clara County and other
organizations regarding the need
for farmworker housing and the
potential for expanding
farmworker housing in Gilroy.
There is currently farm worker
housing in Gilroy, including four
apartment buildings (managed by
Eden Housing) and the Ochoa
Migrant Camp (managed by EAH
Housing). The Ochoa Migrant camp
is seasonal, following the
surrounding harvest season.
During the off season, it is used as
a homeless camp housing un-
housed families.
Retain E - 7
5.A.a
Packet Pg. 43 Attachment: Draft Housing Element 9-12-22 (4016 : Review of the Draft Housing Element)
Review of Past Accomplishments ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 23
5th Cycle
Program
Number
Program Name Objective Time Frame Accomplishments Continued
Appropriateness
6th Cycle
Program
Number
H-4.E Consistency with
the Employee
Housing Act
The City shall update the Zoning Code to be
consistent with the Employee Housing Act
(Health and Safety Code 17021), which
generally requires employee housing to be
permitted by-right, without a CUP, in single-
family zones for less than six persons, and in
all zones that allow agricultural uses with no
more than 12 units or 36 beds.
Review and
amend Zoning
Code (estimated
FY 2015/16)
following
adoption of the
New General Plan
Not completed. The City will update
the Zoning Code to be consistent
with the Employee Housing Act
(Health and Safety Code 17021).
The zoning update will be
completed in 2023.
Retain E - 8
H-4.F Support
Homeless
Service
Providers
The City shall continue to support the efforts
of agencies providing emergency shelter for
homeless residents, including providing
funding when feasible and appropriate.
Ongoing The City provides funding to
homeless service providers
through both its CDBG and
HTF/PLHA programs. Services
include referrals to the Santa Clara
County Continuum of Care
program, case management,
homelessness prevention and
provision of basic need items.
Consolidate with
other programs;
the PLHA and
CDBG funds
includes funding
for homelessness
prevention
services and
homelessness
assistance
D – 1 and
D - 5
H-4.G Home Access
Grants
The City shall continue to administer Home
Access Program to provide very low-income
disabled residents with help in safely entering
and exiting their homes and accessing
essential areas within their homes.
Ongoing This program was eliminated from
the consolidated plan. The City
continues to look at programs that
can help its very-low income
disabled residents, including the
Home Access Program.
Remove and
consolidate with
Housing
Rehabilitation
program
C - 2
H-4.H Coordinate with
the San Andreas
Regional Center
The City shall work with the San Andreas
Regional Center to implement an outreach
program informing residents of the housing
and services available for persons with
developmental disabilities. The City shall
make information available on the City
website.
Initiate
coordinate by
2016
The San Andreas Regional Center
no longer provides services in
Gilroy.
Remove N/A
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5th Cycle
Program
Number
Program Name Objective Time Frame Accomplishments Continued
Appropriateness
6th Cycle
Program
Number
H-4.I Zoning Code
Amendments for
Transitional and
Supportive
Housing
The City shall update the Zoning Code to be
fully compliant with State law and allow
transitional and supportive housing in all
zones that allow residential uses, subject to
the same restrictions that apply to other
residential uses of the same type in the same
zone.
Amend Zoning
Code (estimated
FY 2015/16)
following
adoption of the
New General Plan
Completed. The Zoning Ordinance
allows transitional and supportive
housing in all residential zoning
districts, subject to the same
restrictions that apply to other
residential uses of the same type in
the same zone.
Remove N/A
FAIR HOUSING
H-5.A Fair Housing
Counseling
The City shall continue to provide funds to
and contract with a non-profit agency to
provide fair housing assistance including
landlord/tenant counseling, homebuyer
assistance, and improvement or removal of
identified impediments. The City shall
disseminate information about fair housing
assistance through pamphlets in City-owned
buildings and other public locations (e.g., City
Hall, Library, post office, other community
facilities) and by posting information on the
City website.
Ongoing The City funds fair housing
counseling services through its
Housing Trust/PLHA Fund program.
It also publishes the availability of
both tenant/landlord counseling
and fair housing services via its
website.
Retain F - 2
EXPANDING OUTREACH
H-6.A Interagency
Collaboration for
Lower Cost
Housing
The City shall continue participation in
Countywide housing assistance programs,
and collaborate with other public agencies
and non-profit housing sponsors in the use
of available programs to provide lower-cost
housing in Gilroy.
Ongoing Abode Services provides a direct
subsidy to one individual at the
Cherry Blossom Apartments,
owned by the City, through a
partnership with the City and
Community Solutions. The City also
facilitates TEFRA hearings, as
needed, to allow for the
development and rehabilitation of
affordable housing units
throughout the City.
Consolidate – roll
into programs to
outreach for
developers and a
program to
provide for
rehabilitation of
affordable
housing units.
G - 1 and
C - 2
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5th Cycle
Program
Number
Program Name Objective Time Frame Accomplishments Continued
Appropriateness
6th Cycle
Program
Number
H-6.B Collaboration
with
Development
Community
The City shall continue to establish
relationships with and provide technical
assistance to both for-profit and non-profit
development companies working in the area
of affordable housing, facilitating innovative
partnerships and collaborative approaches to
affordable housing development. The City will
especially utilize the Housing Advisory
Committee to address housing issues and
provide outreach to the development
community.
Ongoing The City continues to establish
collaborative relationships with for-
profit and non-profit development
companies to find innovative
approaches to affordable housing
development in Gilroy. The housing
advisory duties now fall under the
Planning Commission, a decision-
making body with authority to
approve or recommend approval of
housing developments in Gilroy.
This will focus staff and committee
resources to address housing
issues more efficiently in Gilroy.
City staff continue to provide
outreach to the development
community.
Retain and
modify
G - 1
H-6.C Community
Access to
Housing
Information
To ensure the Gilroy community is provided
the highest level of access to information, the
City shall evaluate the effectiveness of
existing outreach and community education
efforts and develop a comprehensive
outreach strategy for the delivery of housing
information. The outreach strategy will
consider various methods of delivery,
including print media, mailers, web-based
information, and other methods that
consider economic and cultural
considerations unique to the City of Gilroy.
Develop housing
information
strategy by June
2016
The City's new 2040 General Plan
includes goals, policies, and
implementation actions regarding
outreach and community
education efforts including various
methods of delivery, such as print
media, mailers, web-based
information, and other methods
that consider economic and
cultural considerations unique to
the City of Gilroy.
Retain G - 5
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5th Cycle
Program
Number
Program Name Objective Time Frame Accomplishments Continued
Appropriateness
6th Cycle
Program
Number
H-6.D Annual Review
of Housing
Element
Pursuant to HCD Requirements, the City shall
conduct an annual implementation review of
the Housing Element. The review will include
the following information: a log of new
residential development permits and
completion reports; inventory of units built in
the Extremely Low-, Very Low- and Low-
Income categories, an update or inventory of
approved projects; an annual estimate of
population from the State Department of
Finance; and available vacant land and zoning
survey.
Annually to HCD The City has submitted Annual
Progress Reports in from 2015
through 2021 and will submit the
2022 annual report to HCD in
March 2023.
Remove N/A
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27
CITY OF GILROY
HOUSING ELEMENT
6TH CYCLE
HOUSING NEEDS ASSESSMENT
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Housing Needs Assessment
The housing needs assessment discusses the varied needs of all segments of the community.
Components that dictate housing need are population trends, demographics, employment
trends, household characteristics, housing stock characteristics, housing inventory and market
conditions, and preservation of at-risk units. The assessment also analyzes housing needs of
various special needs groups, including elderly persons, large households, female-headed
households, persons with disabilities (including developmental disabilities),
homeless/unhoused persons, farmworkers, and extremely low-income households. These
components are presented within the context of Gilroy, Santa Clara County, and other regional
or neighboring areas as appropriate. The needs assessment guides the identification of
appropriate goals, policies, and programs for the City to implement during the 2023–2031
Housing Element Cycle.
The needs assessment uses multiple data sources for analysis. Primary data sources include
the 2019 American Community Survey (ACS), the 2014–2018 Comprehensive Housing
Affordability Strategy (CHAS) published by the US Department of Housing and Urban
Development (HUD), and the 2020 US Census. The CHAS provides information related to
households with housing problems, including overpayment, overcrowding, and those without
complete kitchen facilities and plumbing systems. The CHAS data is based on the 2014–2018
ACS data files but differs from the standard files by including a variety of housing need
variables split by HUD-defined income limits and HUD-specified household types. CHAS data
uses the HUD Area Median Family Income (HAMFI) which does not differ from the area median
income used by HCD, except that it does not utilize the categories described below. Both AMI
and HAMFI use the same median income from the metropolitan statistical area. In Gilroy the
calculation for the San Jose/Sunnyvale/Santa Clara metropolitan statistical area is used. Tables
that use HAMFI instead of AMI are noted.
Note that data from the different sources and different years may have varying estimates for
totals such as population or number of households.
Some of the data is broken down by income group. The California Department of Housing and
Community Development (HCD) uses five income categories to evaluate housing need based
on the area median income (AMI) for each metropolitan statistical area; they are used for both
funding and planning purposes. The categories are as follows:
Extremely low-income households, between 0% and 30% of the AMI
Very low-income households, between 31% and 50% of the AMI
Low-income households, between 51 and 80% of the AMI
Moderate-income households, between 81% and 120% of the AMI
Above moderate-income households, above 120% of the AMI
Extremely low-, very low-, and low-income households may be grouped together for planning
purposes and referred to as “lower-income households.”
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Projected Housing Needs
California General Plan law requires that each city and county have land zoned to
accommodate its fair share of the regional housing need. A local jurisdiction’s “fair share” of
regional housing need is the number of additional housing units needed to accommodate the
forecasted household growth, replace the loss of existing housing units, and achieve vacancy
rates that contribute to a stable and healthy housing market. The California Department of
Housing and Community Development (HCD) determines the projected housing need for each
region. The housing unit need as determined by HCD for the 2023–2031 planning period for
the Bay Area region is 441,176 units. The Association of Bay Area Governments (ABAG) is
responsible for allocating housing needs to each jurisdiction within the Bay Area region, which
includes Gilroy. Housing unit allocations are divided into four income categories: very low, low,
moderate, and above moderate. Gilroy’s RHNA is a total of 1,773 units, as shown in Table 3.
Table 3: Gilroy RHNA, 2023–2031
Income Group % of County AMI Units % of Units
Very Low* 31–50% 669 37.7%
Low 51–80% 385 21.7%
Moderate 80–120% 200 11.3%
Above Moderate > 120% 519 29.3%
Total - 1,773 100%
Source: Regional Housing Needs Allocation, ABAG, 2023-2031.
*Note: Pursuant to AB 2634, local jurisdictions are also required to project the needs of extremely low income households (0–
30% of AMI). The projected extremely low-income need can be assumed as 50 percent of the total need for the very low-income
households.
Existing Housing Need
Demographic Characteristics
Understanding the demographic characteristics and trends in a City is an important facet of
planning for the needs of a community. This section summarizes the population size, age, and
racial/ethnic composition of the City and region.
Population Growth Trends
The City of Gilroy is one of 15 cities in Santa Clara County. Gilroy is the southernmost
incorporated city in Santa Clara County and is surrounded by the unincorporated county. The
2020 US Census estimates that the population of Gilroy is 59,520, an increase of over 10,500
from 2010. Table 4 displays the population trends of Gilroy and surrounding areas, including
both areas in southern Santa Clara County and northern Santa Cruz County. Gilroy’s
population increase was similar to Morgan Hill and Hollister, but more than double the growth
rate of Watsonville and Santa Clara County as a whole.
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Table 4: Regional Population Trends, 2010–2020
City 2010 2020 % Change
Gilroy 48,821 59,520 21.9%
Morgan Hill 37,882 45,483 20.1%
Watsonville 51,199 52,590 2.7%
Hollister 34,928 41,678 19.3%
Santa Clara County 1,781,642 1,936,259 8.7%
Source: US Census, 2010 and 2020.
Both the City of Gilroy and Santa Clara County continue to see steady population growth.
According to the US Census and the California Department of Finance, Gilroy experienced an
average annual growth rate of 1.6 percent between 2010 and 2020, which was higher than the
County’s average annual growth rate (AAGR) of 1 percent, as shown in Table 5. The growth rate
in Gilroy remained steady in comparison to the period from 2000 through 2010, which was 1.7
percent. Table 5 compares the AAGRs of the City and County from 2000 through 2020.
Table 5: Average Annual Population Growth Rate
Jurisdiction
2000 2010 2020 2000–2010 2010–2020
Total Population Population
Increase AAGR Population
Increase AAGR
Gilroy 41,464 48,821 59,520 7,357 1.7% 10,699 1.6%
Santa Clara
County 1,682,585 1,781,642 1,936,259 99,057 0.6% 154,617 1.0%
Source: Decennial Census, 2020
Age Composition
Table 6 summarizes the population’s age distribution and percentage change from 2000 to
2019. Different age groups have varying housing needs that may fluctuate across the stages
of life. Generally, both the young adult (20 to 34 years old) and the elderly (65 years and older)
live in apartments, condominiums, and smaller single-family units. Persons over 65 may also
need accommodations so that they can age in place. Persons between the ages of 35 to 65 are
more likely to live in single-family homes during this stage of life, per the census estimates.2
From 2010 to 2019, the largest increases in population were in age groups from 55 to 84 years
of age. There was a slower rate of growth in the 25 to 34 years age group and a negative change
in the 4 years and younger, and the 85 years and older age group. This data suggests that there
is an increasing need for senior focused housing in Gilroy, which may take the form of age-
2 https://censusreporter.org/data/table/?table=B25125&geo_ids=16000US0629504&primary_geo_id=16000US0629504.
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restricted developments, smaller units, increased support services, and housing with
proximity to healthcare.
Table 6: Population Age Distribution, Gilroy
Age Group 2000 2010 2019 % Change
(2000–2010)
% Change
(2010–2019)
Age 0-4 3,903 4,144 3,738 6.2% -9.8%
Age 5-14 7,550 8,419 9,885 11.5% 17.4%
Age 15-24 6,194 6,934 8,079 11.9% 16.5%
Age 25-34 6,790 6,718 7,006 -1.1% 4.3%
Age 35-44 6,750 7,386 8,439 9.4% 14.3%
Age 45-54 4,919 6,613 7,553 34.4% 14.2%
Age 55-64 2,543 4,509 6,123 77.3% 35.8%
Age 65-74 1,522 2,326 3,656 52.8% 57.2%
Age 75-84 958 1,237 1,756 29.1% 42.0%
Age 85+ 335 535 531 59.7% -0.7%
Source: US Census 2000, 2010, 2019
Figure 1 shows the age distribution of Gilroy and Santa Clara County in 2019. The distribution
is largely similar between the two. Gilroy has a higher percentage of the population that is 24
years or younger, while the County has a larger percentage of the population between 25 and
39 years of age. The County’s population above 45 years of age is also higher than Gilroy.
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Figure 1: Population Age Distribution, 2019
Source: ACS 2019
Race and Ethnicity
An understanding of the racial and ethnic trends in a region contributes to an analysis of
housing demand. Non-White populations occupy multifamily units at a higher rate.3 Race and
ethnicity characteristics also can be associated with income levels. Table 7 summarizes the
racial and ethnic composition of the population in 2010 and 2019. As of 2019, 59 percent of
Gilroy residents of any race were of Hispanic or Latino origin and 41 percent were Non-
Hispanic. Of the Non-Hispanic population, 28 percent were white, and 9.1 percent were Asian
or Pacific Islander. Between 2010 and 2019, the White Non-Hispanic population percentage
declined by 3.4 percent, while the Asian or Pacific Islander population percentage increased
by 2.2 percent, and the Hispanic or Latino population increased by 1.3 percent.
3 ACS Five Year Estimates Table B25032.
0%
1%
2%
3%
4%
5%
6%
7%
8%
9%
10%% of PopulationAge
City of Gilroy Santa Clara County
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Table 7: Racial and Ethnic Composition, Gilroy
Racial/Ethnic Group 2010 2019
Number % Number %
Not Hispanic or Latino
White 15,335 31.4% 15,877 28%
Black 709 1.5% 610 1.1%
American Indian & Alaska Native 180 0.4% 113 0.2%
Asian or Pacific Islander 3,351 6.9% 5,160 9.1%
Some other race alone 58 0.1% 0 0%
Two or more races 974 2.0% 1,460 2.6%
Subtotal 20,607 42.3% 23,220 41%
Hispanic or Latino
White 13,339 27.3% 26,640 46.9%
Black 233 0.5% 262 0.5%
American Indian & Alaska Native 651 1.3% 215 0.4%
Asian or Pacific Islander 208 0.4% 168 0.3%
Some other race alone 12,264 25.1% 4,807 8.5%
Two or more races 1,519 3.11% 1,454 2.6%
Subtotal 28,214 57.7% 33,546 59%
Total 48,821 100% 56,766 100%
Source: ACS 2019 Five Year Estimates.
Figure 2 displays the racial and ethnic makeup of Gilroy, Santa Clara County, and the entire
Bay Area region. The racial and ethnic makeup of Gilroy varies from that of the region.
Comparatively, Gilroy’s Hispanic or Latino population (59 percent) is more than double that of
the County (25 percent) and region (24 percent). Gilroy has a slightly smaller White, non-
Hispanic or Latino population (28 percent) than Santa Clara County (32 percent) and the Bay
Area region (39 percent). Gilroy’s Asian/Pacific Islander population (9 percent) is also much
smaller than the County (37 percent) and the region (27 percent).
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Figure 2: Regional Racial/Ethnic Composition, 2019
Source: US Census Bureau, ACS 2015–2019, Table B03002.
Employment Trends
Employment trends in a region also influence housing needs. Significant employment
opportunities in Santa Clara County have led to a growth in demand for housing in proximity
to jobs. The quality and/or pay of available employment can determine the need for various
housing types and prices.
Table 8 shows the labor force and employment trends in Gilroy in 2010, 2014, and 2019. The
labor force has increased by over 5,000 from 2010 to 2019. The unemployment rate increased
from 2010 to 2014 but decreased from 2014 to 2019. The unemployment rate for Gilroy (3.9
percent) was higher than the County’s unemployment rate (3.5 percent) in 2019, according to
the 2019 census.
9%
37%27%1%
2%
6%28%
32%39%
3%
4%5%59%
25%24%
0.0%
10.0%
20.0%
30.0%
40.0%
50.0%
60.0%
70.0%
80.0%
90.0%
100.0%
Gilroy Santa Clara County Bay AreaPercent of PopulationHispanic or Latinx
Other Race or Multiple Races, Non-Hispanic
White, Non-Hispanic
Black or African American, Non-Hispanic
Asian / API, Non-Hispanic
American Indian or Alaska Native, Non-Hispanic
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Table 8: Employment Trends, Gilroy
Year Labor Force Employment Unemployment Unemployment
Rate
2010 23,354 21,272 2,068 6.2%
2014 26,213 23,272 2,930 7.9%
2019 29,620 27,955 1,665 3.9%
Source: ACS Five Year Estimates, 2010, 2014, 2019.
Figure 3 displays the employment share by industry in Gilroy, Santa Clara County, and the
entire Bay Area region. The employment by industry breakdown is similar between the City,
County, and Bay Area region, with few small differences. Gilroy has a smaller percentage of
workers employed in the financial and professional services than Santa Clara County and the
Bay Area. It has a higher percentage of workers employed in the construction and agriculture
and natural resources industries. Since there are more people in comparatively lower-paying
industries, there may be an increased need for housing for low- and moderate-income
households in Gilroy.
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Figure 3: Regional Employment by Industry, 2019
Source: US Census ACS 2015–2019, Table C24030.
Table 9 shows the major employers in the City of Gilroy. As of 2021, Christopher Ranch is the
largest single employer in Gilroy with 780 employees. Other large employers in Gilroy include
Saint Louise Hospital (535 employees), Gavilan College (450 employees), and Olam
International (400 employees).
3%2%0%
11%5%6%
16%26%26%
30%27%30%
2%5%4%
17%21%17%
13%8%9%
8%6%8%
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
Gilroy Santa Clara County Bay AreaShare of Employed ResidentsPlaceOther
Retail
Manufacturing, Wholesale & Transportation
Information
Health & Educational Services
Financial & Professional Services
Construction
Agriculture & Natural Resources
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Table 9: Major Employers, 2021
Company Number of Employees
Christopher Ranch 780
Saint Louise Hospital 535
Gavilan College 450
Olam International 400
Walmart 360
Community Solutions 323
Costco 272
Rebekah Children Services 240
Monterey Gourmet Foods 230
United Natural Foods Inc 205
Kaiser Permanente 175
Headstart Nursery 165
Source: Gilroy Chamber of Commerce, 2021.
Household and Housing Stock Characteristics
This section describes Gilroy’s household characteristics, including data on household size,
income, median sale prices, rental prices, and vacancy rates. The US Census Bureau defines a
household as all persons living in a single housing unit, whether or not they are related. A
household can be one person, a single family, multiple families, or any group of related or
unrelated persons. The US Census Bureau defines a family as related persons living within a
single housing unit.
As shown in Table 10, the number of households in Gilroy continues to grow at a faster pace
than the County and the State. In 2019, the US Census Bureau reported 16,126 households in
Gilroy, a 13.8 percent increase from 2010. In comparison, total households in Santa Clara
County increased by 6 percent between 2010 and 2019, while total households in California
increased by 3.7 percent.
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Table 10: Change in Households, 2000–2019
Area 2000 2010 2019 % Change
2000-2010
% Change
2010-2019
Gilroy 11,894 14,175 16,126 19.2% 13.8%
Santa Clara
County 565,863 604,204 640,215 6.8% 6.0%
California 11,502,870 12,577,498 13,044,266 9.3% 3.7%
Source: US Census 2000, 2010, 2019.
The average number of persons per household in Gilroy was 3.5 in 2020, an increase from
2010. As shown in Table 11, the average number of persons per household in Gilroy continues
to be higher than the State and County average by 0.5 persons.
Table 11: Regional Average Household Size
Geography 2010 2020
Gilroy 3.4 3.5
Santa Clara County 2.9 3.0
California 2.9 3.0
Source: US Census 2010 SF1, DP-1 and US Census 2020.
Table 12 shows the household size distribution of Gilroy, Santa Clara County, and the Bay Area
region. Gilroy has a lower percentage of one-person households (14.5 percent) than Santa
Clara County (20.3 percent) and the Bay Area Region (24.7 percent). Gilroy’s percentage of 2-
and 3–4 person households is similar to the County and region, while the City’s percentage of
households with 5 or more people (24.3 percent) is nearly twice that of Santa Clara County
(12.4%). The high proportion of large households influences the needs for a variety of larger
unit types and may correlate with some presence of overcrowding.
Table 12: Household Size Distribution, 2019
Geography
1
Person %
2
Person %
3-4
Person %
5
Person
or
More % Total
Gilroy 2,345 14.5% 4,353 27% 5,512 34.2% 3,916 24.3% 16,126
Santa Clara
County 130,090 20.3% 196,510 30.7% 234,061 36.6% 79,554 12.4% 640,215
Bay Area 674,587 24.7% 871,002 31.9% 891,588 32.6% 294,257 10.8% 2,731,434
Source: US Census Bureau, ACS 5-Year Data (2015-2019), Table B11016-H2.
The median household income for Gilroy in 2019 was $101,616, an increase of over $25,000
from the median income of $76,060 in 2012. However, Gilroy’s median household income is
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about $22,439 less than the median income for the County. In the City, the median income for
owner-occupied households ($134,115) was significantly higher than the median income for
renter-occupied households ($60,022) in 2019.
Table 13: Median Household Income by Tenure, 2019
Jurisdiction and Tenure 2019 Median Income
City of Gilroy $101,616
Owner-Occupied Households $134,115
Renter-Occupied Households $60,022
Santa Clara County $124,055
Owner-Occupied Households $155,139
Renter-Occupied Households $91,265
Source: 2019 ACS B25119.
The State of California uses five income categories to determine eligibility for housing
programs based on median family income. Because eligibility is based on the area median
income (AMI) for Santa Clara County, cities such as Gilroy, which have a lower median income
than the AMI, will have more residents that qualify for housing programs. Furthermore, many
low-income families in Gilroy have difficulty paying for housing even with housing subsidies,
which are based on County AMI.
Note that Table 13 shows the median income for Gilroy as less than the County AMI. This
disparity is in part due to the fact that the rest of Santa Clara County is closer to high-paying
technology and finance jobs in the Bay Area and Silicon Valley. Table 14 shows the State-
defined income ranges for each income category based on the 2022 Santa Clara County AMI
of $168,500 for a household of four.
Table 14: Income Range by Affordability Level Based on State Area Median Income, 2022
Affordability Category % of County Median Income Range
Extremely Low Income 30% ≤ $50,550
Very Low Income 31%-50% $50,550 - $84,250
Low Income 51%-80% $84,250 - $131,750
Moderate Income 81%-120% $131,750–$202,200
Above Moderate Income > 120% > $202,200
Source: California Department of Housing and Community Development, 2022.
Table 15 provides a breakdown of income level by tenure in Gilroy, using the 2014–2018 CHAS
data. The table shows that just under 40 percent of households in Gilroy are renter-occupied,
compared to 43.2 percent of households in the County. In Gilroy, 42.5 percent of the
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population falls into the extremely low-, very low-, and low-income categories, highlighting the
need for affordable housing options in the City.
Table 15: Household Income by Tenure, 2018
Income Level Renter-Occupied Owner-Occupied Total Occupied
Housing Units
Number % Number % Number %
City of Gilroy
Less than or equal to 30% of HAMFI 1,995 12.3% 644 4.0% 2,639 16.3%
Greater than 30%
but less than or equal to 50% of
HAMFI
1,340 8.3% 894 5.5% 2,234 13.8%
Greater than 50%
but less than or equal to 80% of
HAMFI
1,040 6.4% 965 6.0% 2,005 12.4%
Greater than 80%
but less than or equal to 100% of
HAMFI
605 3.7% 1,035 6.4% 1,640 10.1%
Greater than 100% of HAMFI 1,420 8.8% 6,259 38.6% 7,679 47.4%
Total 6,400 39.5% 9,797 60.5% 16,197 100.0%
Santa Clara County
Less than or equal to 30% of HAMFI 55,360 8.7% 27,980 4.4% 83,340 13.1%
Greater than 30%
but less than or equal to 50% of
HAMFI
35,920 5.7% 27,635 4.3% 63,555 10.0%
Greater than 50%
but less than or equal to 80% of
HAMFI
34,260 5.4% 32,440 5.1% 66,700 10.5%
Greater than 80%
but less than or equal to 100% of
HAMFI
24,640 3.9% 28,655 4.5% 53,295 8.4%
Greater than 100% of HAMFI 124,680 19.6% 243,955 38.4% 368,635 58.0%
Total 274,860 43.2% 360,665 56.8% 635,525 100.0%
Source: 2014-2018 HUD CHAS data.
Median Home Sales Price
Figure 4 shows the change in home prices in Gilroy, Santa Clara County, and the Bay Area
region from January 2001 to December 2020. While each geography follows the same general
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trend over time, Gilroy home prices are lower than the other two geographies. Notably starting
after 2005, Santa Clara County home prices trend higher than the Bay Area region on average.
After 2007, the housing market slowdown affected home sale prices in Gilroy, which decreased
by approximately 50 percent between mid-2007 and early 2012. Since 2012, the median sales
prices for new and resale homes in Gilroy have steadily increased, with a minor dip at the start
of the COVID-19 pandemic. However, Gilroy home prices remain significantly lower than the
County. The median home price in December 2020 was $837,995, which was $452,982 lower
than the Santa Clara County median of $1,290,977 at the same time. In November 2021, the
median sales price in Santa Clara County ($1,560,000) was 40.5 percent higher than the median
sales price in Gilroy (1,000,000).
Figure 4: Regional Home Prices Over Time, 2001–2020
Source: Zillow.com, 2020.
As shown in Table 16, the median sales price in Gilroy increased by 20 percent ($835,000 to
$1,000,000) between November 2020 and November 2021. Comparatively, the median sales
price in Santa Clara County increased by 15 percent for the same time period. Since a
household can typically qualify to purchase a home that is 2.5 to 3.0 times the annual income
of that household, Gilroy’s median income implies that the median sales price should be
$100,000
$300,000
$500,000
$700,000
$900,000
$1,100,000
$1,300,000
$1,500,000
20012002200320042005200620072008200920102011201220132014201520162017201820192020Bay Area Santa Clara County Gilroy
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around $450,000. The median sales price over $800,000 indicates a high potential of cost
burden in the City.
Table 16: Zillow Home Value Index, 2020 and 2021
Jurisdiction November 2020 November 2021 % Change
Gilroy $835,000 $1,000,000 20%
Campbell $1,420,000 $1,640,000 15%
Santa Clara $1,380,000 $1,560,000 13%
San Jose $1,120,000 $1,330,000 19%
Morgan Hill $1,050,000 $1,260,000 20%
Santa Clara County $1,225,000 $1,405,000 15%
Source: Zillow Housing Market Data, 2021.
Rental Prices and Affordability
Table 17 summarizes the average monthly rent of market-rate housing in Gilroy by unit size in
2021. According to Zumper, the average rental rate for a one-bedroom unit was $1,850; a two-
bedroom unit was $2,285; and a three-bedroom unit was $3,100. Extremely low- and very low-
income groups would not be able to afford a market-rate apartment in Gilroy. Using the
assumption that any rent above 30 percent of household income renders the residents cost-
burdened, the average rents for one-bedroom to three-bedroom units would be affordable to
the low-, moderate-, and above moderate-income groups.
Table 17: Average Monthly Rent by Unit Size, Gilroy, 2021
Unit Size Average Monthly Rent
Studio $1,600
1 bedroom $1,850
2 bedrooms $2,285
3 bedrooms $3,100
4 bedrooms $3,775
Source: Zumper, August 2021.
Table 18 shows the minimum income needed to afford market rate rent in Santa Clara County
(including Gilroy) by the number of bedrooms in the household. Compared to the AMI for
Santa Clara County ($168,500), the AMI in Gilroy is $101,616, which is lower than the $102, 320
income needed to afford a one bedroom apartment. Rents in the City are more affordable
than the average Countywide, indicating that Gilroy is closer to a fair market rent as shown in
the table below. The disparity between incomes and housing costs indicates a need for more
housing options at a variety of sizes available, especially to households below the AMI.
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Table 18: Income Needed to Afford Market Rate Rent, Santa Clara County
Unit Size
Income Needed to Afford
(hourly)
Income Needed to Afford
(annually) Fair Market Rent
Zero Bedroom $42.85 $89,120 $2,228
One Bedroom $49.19 $102,320 $2,558
Two Bedroom $58.67 $122,040 $3,051
Three Bedroom $76.62 $159,360 $3,984
Four Bedroom $88.33 $183,720 $4,593
Source: National Low Income Housing Coalition. Out of Reach 2021.
Table 19 shows the maximum affordable monthly rent by affordability category. While current
average rents in Gilroy would allow a moderate income household to afford a rental unit of
most any size, extremely low income households would likely be cost-burdened in any size
unit.
Table 19: Maximum Affordable Monthly Rent by Income Category
Affordability
Category % of County Median Income Range Maximum Affordable
Monthly Rent
Extremely Low
Income 30% ≤ $49,700 $1,242
Very Low Income 31%-50% $49,700 - $82,850 $2,071
Low Income 51%-80% $82,851 - $117,749 $2,943
Moderate Income 81%-120% $117,750–$181,550 $4,538
Above Moderate
Income > 120% > $181,550 -
Vacancy Rates
Vacancy rates are indicators of housing supply and demand that reflect the degree of housing
choice that is available. Higher vacancy rates can induce downward price pressure, while low
vacancy rates can influence upward price pressures. Low vacancy rates usually indicate high
demand and/or low supply conditions in the housing market. Too low a vacancy rate can force
prices up, making it more difficult for lower- and moderate-income households to find
housing. For rental units, a 7 to 8 percent vacancy rate is considered “healthy,” and a vacancy
rate of 2 percent or below is considered “healthy” for owner occupied housing. In 2013, the
vacancy rate in Gilroy was 4.6 percent, decreasing to 2.9 percent in 2019. Table 20 summarizes
the number of occupied and vacant units in Gilroy from 2013 to 2019.
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Table 20: Occupancy Rates
Occupancy Status 2013 % 2019 %
Occupied Housing Units 14,657 95.4% 16,126 97.1%
Vacant Housing Units 701 4.6% 482 2.9%
Total Housing Units 15,358 100% 16,608 100%
Source: ACS 5 year estimates, 2013 and 2019.
Overpayment
Overpayment is defined as households paying more than 30 percent of their gross income on
housing-related expenses, including rent or mortgage payments and utilities. Severe
overpayment occurs when households pay 50 percent or more of their gross income for
housing. Households paying greater than 30 percent of their gross income on housing-related
expenses are considered to be cost burdened. Higher costs for housing may contribute to
households having a limited ability to cover other everyday living expenses. The impact of
housing costs is more apparent for extremely low-, very low-, and low-income households, and
especially renter households.
Table 21 illustrates housing cost as a percentage of household income by tenure, showing the
number and percentage of households that are experiencing cost burden and severe cost
burden for both Gilroy and Santa Clara County. In 2018, 9,079 Gilroy households, or 56.3
percent, experience some form of overpayment, with 18.1 percent of households experiencing
severe overpayment. This is an increase of 1,769 households from 2012. Gilroy experiences
overpayment at a slightly higher rate than the County, where 50.2 percent of households
experience some sort of overpayment.
Table 21: Housing Cost as a Percentage of Household Income, 2018
Housing Income Range Households
Percentage of Income Spent on Housing
Overpayment
(>30% income on
housing)
Severe Overpayment
(>50% income on
housing)
Number % Number % Number %
City of Gilroy: Owner Households
Less than or equal to
30% of HAMFI 645 4.0% 470 2.9% 400 2.5%
Greater than 30%
but less than or equal
to
50% of HAMFI
895 5.6% 550 3.4% 330 2.0%
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Housing Income Range Households
Percentage of Income Spent on Housing
Overpayment
(>30% income on
housing)
Severe Overpayment
(>50% income on
housing)
Number % Number % Number %
Greater than 50%
but less than or equal
to
80% of HAMFI
975 6.1% 465 2.9% 240 1.5%
Greater than 80%
of HAMFI 7,305 45.4% 1,160 7.2% 165 1.0%
Total 9,820 61.0% 2,645 16.4% 1,135 7.0%
City of Gilroy: Renter Households
Less than or equal to
30% of HAMFI 1,885 11.7% 1,590 9.9% 1,230 7.6%
Greater than 30%
but less than or equal
to
50% of HAMFI
1,339 8.3% 979 6.1% 395 2.5%
Greater than 50%
but less than or equal
to
80% of HAMFI
1,030 6.4% 590 3.7% 165 1.0%
Greater than 80%
of HAMFI 2,029 12.6% 350 2.2% 0 0.0%
Total 6,283 39.0% 3,509 21.8% 1,790 11.1%
Santa Clara County: Owner Households
Less than or equal to
30% of HAMFI 25,960 4.1% 20,765 3.3% 16,670 2.6%
Greater than 30%
but less than or equal
to
50% of HAMFI
27,625 4.4% 15,370 2.4% 9,725 1.5%
Greater than 50%
but less than or equal
to
80% of HAMFI
32,435 5.2% 15,680 2.5% 6,870 1.1%
Greater than 80%
of HAMFI 272,605 43.3% 46,610 7.4% 7,635 1.2%
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Housing Income Range Households
Percentage of Income Spent on Housing
Overpayment
(>30% income on
housing)
Severe Overpayment
(>50% income on
housing)
Number % Number % Number %
Total 358,625 57.0% 98,425 15.6% 40,900 6.5%
Santa Clara County: Renter Households
Less than or equal to
30% of HAMFI 51,035 8.1% 45,275 7.2% 35,590 5.7%
Greater than 30%
but less than or equal
to
50% of HAMFI
35,940 5.7% 29,750 4.7% 15,250 2.4%
Greater than 50%
but less than or equal
to
80% of HAMFI
34,270 5.4% 21,565 3.4% 5,615 0.9%
Greater than 80%
of HAMFI 149,320 23.7% 22,390 3.6% 1,165 0.2%
Total 270,565 43.0% 118,980 18.9% 57,620 9.2%
Source: 2014-2018 HUD CHAS data.
Overcrowding
An overcrowded housing unit is defined by the US Census Bureau as a housing unit occupied
by more than one person per room (excluding bathrooms, kitchen, hallway, and closet space).
Occupancy by more than 1.5 persons per room constitutes severe overcrowding.
Overcrowding can affect public facilities and services, reduce the quality of the physical
environment, and create conditions that contribute to deterioration of the housing stock.
Additionally, overcrowding can indicate that a community does not have an adequate supply
of affordable housing and/or variety of suitable housing units to meet the needs of the
community. Table 22 summarizes overcrowding in Gilroy by tenure. Approximately 1,482
households in Gilroy, roughly 9.2 percent, were experiencing overcrowding in 2019. This
included 347 owners and 1,135 rental households. Instances of overcrowding vary by tenure
with renters experiencing higher levels of overcrowding than owners.
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Table 22: Overcrowded Households, 2019
Persons per Room
Owners Renters Total
Overcrowded
Households
% of
Total
Overcrowded
Households
% of
Total
Overcrowded
Households
% of
Total
City of Gilroy
1.01 to 1.50 285 1.8% 665 4.1% 950 5.9%
>1.50 62 0.4% 470 2.9% 532 3.3%
Total Overcrowded 347 2.2% 1,135 7.0% 1,482 9.2%
Santa Clara County
1.01 to 1.50 7,526 1.2% 21,951 3.4% 29,477 4.6%
>1.50 2,340 0.4% 17,983 2.8% 20,323 3.2%
Total Overcrowded 9,866 1.6% 39,934 6.2% 49,800 7.8%
Source: 2019 ACS B25014.
Housing Inventory and Market Conditions
This section discusses the housing stock and market conditions in Gilroy, including change in
housing units, unit size, unit type, age of housing stock, and housing conditions. By analyzing
past and current housing trends, future housing needs can be assessed.
Table 23 summarizes the number of housing units in the City and County from 2000 to 2019.
In 2000, Gilroy had 12,167 housing units. By 2010, the number of housing units increased to
14,854 and in 2019, the Census reported 16,608 housing units in the City. According to the
California Department of Finance, 2.5 percent of housing units in the County are within Gilroy’s
boundaries, representing an increase of 0.4 percent from 2000 to 2019.
Table 23: Housing Units, 2000–2019
Year Gilroy Santa Clara County Gilroy as % of Total Santa Clara County
Units
2000 12,167 579,329 2.1%
2010 14,854 631,920 2.4%
2019 16,608 672,495 2.5%
Source: US Census 2000 SF3, H1, US Census 2010 SF1, H1, and Department of Finance Table E-5, 2019.
Table 24 summarizes the distribution of unit size by tenure in 2019. The most common unit
size for renter-occupied units was two-bedroom units, followed by three-bedroom units.
Owner-occupied units had more bedrooms, on average, than renter-occupied units.
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Table 24: Unit Size by Tenure, Gilroy, 2019
Unit Size
Owner-Occupied Renter-Occupied Total Occupied Housing Units
Units % Units % Units %
No bedroom 15 0.1% 218 1.4% 233 1.5%
1 bedroom 126 0.8% 972 6% 1,098 6.8%
2 bedrooms 632 3.9% 2,601 16.1% 3,233 20%
3 bedrooms 3,895 24.2% 1,481 9.2% 5,376 33.4%
4 bedrooms 4,016 24.9% 685 4.2% 4,701 29.1%
5 or more bedrooms 1,230 7.6% 255 1.6% 1,485 9.2%
Total 9,914 61.5% 6,212 38.5% 16,126 100%
Source: 2019 ACS B25042.
Table 25 summarizes Gilroy’s housing inventory by unit type from 2000 to 2021. From 2010 to
2021, the number of units for all housing types increased, except for single-family attached
units and mobile homes, which remained the same at 887 and 317 units, respectively. Single-
family attached houses, per the US Census, are defined as houses running together or that are
attached such as townhomes or row houses4. In 2021, single-family detached units comprised
the largest percentage of housing stock, at almost 70 percent at 11,739 units. Multifamily
housing made up 23.1 percent of the housing stock with 3,883 units.
Comparatively, Santa Clara County has fewer detached single-family housing units (51.7
percent) and more multifamily housing units (35.8 percent) in 2021.
Table 25: Housing Inventory by Unit Type
Housing Type 2000 2010 2021
Number % Number % Number %
City of Gilroy
Single family, detached 7,768 63.8% 9,997 67.3% 11,739 69.8%
Single family, attached 742 6.1% 887 6.0% 887 5.3%
Multifamily 3,225 26.5% 3,653 24.6% 3,883 23.1%
Mobile homes 432 3.6% 317 2.1% 317 1.9%
Total Housing Units 12,167 100% 14,854 100% 16,826 100%
Santa Clara County
Single family, detached 323,923 55.9% 344,586 54.5% 351,726 51.7%
4 US Census Appendix A. Subject Definitions and Table Index. https://www2.census.gov/programs-
surveys/ahs/2017/2017%20AHS%20Definitions.pdf
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Housing Type 2000 2010 2021
Number % Number % Number %
Single family, attached 52,736 9.1% 61,517 9.7% 66,146 9.7%
Multifamily 182,999 31.6% 206,779 32.7% 243,502 35.8%
Mobile homes 19,102 3.3% 19,038 3.0% 18,924 2.8%
Total Housing Units 578,760 100% 631,920 100% 680,298 100%
Source: US Census 2000 SF3, H30 and California Department of Finance Table E-5, 2010 and 2021.
Table 26 displays occupied housing units by tenure in Gilroy in 20195. The majority of owner-
occupied housing units were single family detached units (82.3 percent), while renter-occupied
units were predominantly multifamily (96.7 percent).
Table 26: Unit Type by Tenure, 2019
Building Type Owner
Occupied % Renter
Occupied % Total
Detached Single-Family Homes 8,967 82.3% 1,933 17.7% 10,900
Attached Single-Family Homes 398 41.6% 559 58.4% 957
Multifamily Housing 125 3.3% 3,615 96.7% 3,740
Mobile Homes 424 80.2% 105 19.8% 529
Source: 2019 ACS B25032.
Age of Housing Stock
The age of a housing unit is often an indicator of housing conditions. In general, housing that
is 30 years or older may exhibit need for repairs based on the useful life of materials. Housing
over 50 years old is considered aged and is more likely to exhibit a need for major repairs. The
number of housing units in need of repair and replacement is discussed separately in this
chapter. Many federal and state programs use age of housing as one factor to determine
housing needs and the availability of funds for housing and community development.
Table 27 summarizes the age of housing stock by tenure in 2019. Approximately 56.2 percent
of units were built prior to 1990 and 19.9 percent of units were built before 1970. The City has
seen very little rental family housing stock built within the past two decades: only 1,092 rental
units were built between 2000 and 2019, compared to 3,112 new owner-occupied units. This
disparity in building ages by tenure indicates a need for new rental housing options.
5 This excludes vacant housing units.
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Table 27: Tenure by Housing Age
Year Tenure: Owner Tenure: Renter Total
Built 2014 or later 764 4.7% 32 0.2% 796 4.9%
Built 2010 to 2013 383 2.9% 226 1.4% 609 3.8%
Built 2000 to 2009 1,965 12.2% 834 5.2% 2,799 17.4%
Built 1990 to 1999 1,570 9.7% 1,290 8% 2,860 17.7%
Built 1980 to 1989 1,388 8.6% 1,145 7.1% 2,533 15.7%
Built 1970 to 1979 1,887 11.7% 1,428 8.9% 3,315 20.6%
Built 1960 to 1969 724 4.5% 477 2.9% 1,201 7.5%
Built 1950 to 1959 642 3.6% 216 1.3% 858 5.3%
Built 1940 to 1949 223 1.4% 90 0.6% 313 1.9%
Built 1939 or earlier 368 2.3% 474 2.9% 842 5.2%
Total 9,914 61.5% 6,212 38.5% 16,126 100%
Source: 2019 ACS B25036.
Housing Conditions
Housing is considered substandard when conditions are found to be below the minimum
standard of living defined in the California Health and Safety Code. Substandard housing units
include those in need of repair and/or replacement. Households living in substandard
conditions are considered to be in need of housing assistance, even if they are not seeking
alternative housing arrangements, due to threats to health and safety.
A household is considered substandard or to have a housing problem if it has one or more of
the four following housing problems:
Housing unit lacks complete kitchen facilities
Housing unit lacks complete plumbing facilities
Housing unit is overcrowded
Household is cost burdened
In addition to structural deficiencies and standards, the lack of infrastructure and utilities often
serves as an indicator for substandard conditions. Table 28 summarizes the number of units
lacking plumbing or complete kitchen facilities. According to the 2019 ACS three-year
estimates, 47 occupied-units in Gilroy lacked complete plumbing facilities. Of these, 23 were
owner occupied and 24 were renter occupied. A total of 49 units lacked complete kitchen
facilities. Of those, 16 were owner- occupied and 33 were renter-occupied. It should be noted
that there is potential for overlap in the number of substandard housing units, as some units
may lack both complete plumbing and kitchen facilities.
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Table 28: Units Lacking Plumbing or Complete Kitchen Facilities, 2019
Units
Owner
Occupied
% of Total
Units
Renter
Occupied
% of Total
Units Total
% of Total
Units
Lacking Complete
Plumbing Facilities 23 0.2% 24 0.2% 47 0.3%
Lacking Complete
Kitchen Facilities 16 0.1% 33 0.2% 49 0.3%
Source: 2019 ACS B25049 and B25053.
Code enforcement activities in the City of Gilroy are conducted by two Code Enforcement
officers. From July 1, 2021 to June 30, 2022, code enforcement responded to 78 complaints
about substandard housing conditions or other issues reported by residents. A windshield
survey estimates very few housing in need of substantial repair in the City, about 80 units.
The majority of these complaints do not relate to substandard housing conditions.
Neighborhood complaints received by Code Enforcement include:
Person living in an RV
Junk in the front yard
Trash dumped in the alley
Illegal garage conversion
In the 2021–2022 fiscal year, the City allocated $140,000 in CDBG funds to Rebuilding Together
Silicon Valley for the home repair, rehabilitation, and accessibility modification program. The
City allocated $81, 475 in CDBG funds towards rehabilitation of the Cherry Blossom affordable
housing development, $124,090 in competitive awards for services related to homelessness,
affordable housing, and special needs housing and another $54,330 for services addressing
fair housing, tenant-landlord information and referral, foreclosure counseling, Project Sentinel
Fair Housing, and the Gilroy Streets Team.
Preservation of Assisted Units At Risk of Conversion
Jurisdictions are required by state Housing Element Law to analyze government-assisted
housing that is eligible to convert from low-income to market-rate housing over the next 10
years. State law identifies housing assistance as a rental subsidy, mortgage subsidy, or
mortgage insurance to an assisted housing development. Government-assisted housing might
convert to market-rate housing for a number of reasons, including expiring subsidies,
mortgage repayments, or expiration of affordability restrictions.
Qualified Entities
Under Government Code Section 65863.11, owners of federally assisted projects must provide
a Notice of Opportunity to Submit an Offer to Purchase to qualified entities (nonprofit or for-
profit organizations) that agree to preserve the long-term affordability if they should acquire
at-risk projects at least one year before the sale or expiration of use restrictions. Qualified
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entities have first right of refusal for acquiring at-risk units. Qualified entities are nonprofit or
for-profit organizations with the legal and managerial capacity to acquire and manage at-risk
properties that agree to maintain the long-term affordability of projects. The following is a list
of qualified entities from HCD for Santa Clara County that could potentially acquire and
manage properties if any were to be at risk of converting to market rate in the future.
Cambrian Center, Inc.
Charities Housing Development Corp.
Palo Alto Senior Housing Project, Inc.
Mid-Peninsula Housing Coalition
Affordable Housing Foundation
Palo Alto Housing Corp
Satellite Housing Inc.
ROEM Development Corporation
Silicon Valley at Home
L + M Fund Management LLC
Inventory of At-Risk Units
Per government code section 65863.10, assisted housing developments (or at-risk units) are
defined as multifamily, rental housing complexes that receive government assistance under
any of the specified federal, state, and/or local programs.6 There are approximately 1,534
assisted affordable housing units in Gilroy. The City is currently inventorying all of its assisted
housing developments to determine which developments are at risk of conversion. At the time
of publication expiration dates for two projects have not been confirmed. These projects are
shown in Table 29. All other units do not expire before 2031.
The Housing Element Programs includes a timeframe for completing the inventory of
affordable units. Table 29 provides a list of the remaining units that may be at risk of
conversion before 2031. There are 156 units within two Low-Income Housing Tax Credit
(LIHTC) funded projects may be at risk of being converted to market-rate before 2031. Program
C - 6 is included to complete the inventory of assisted units in the City. Should the units expire
during the Cycle, the City will ensure that owners are contacted and advanced notice to tenant
is provided.
6 HCD Building Blocks https://www.hcd.ca.gov/assisted-housing-developments-at-risk-of-conversion
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Table 29: Potential Units at Risk of Conversion
Project Address Total Units Assisted Units
Gilroy Garden Apartments 9250 Wren Ave 74 73
Lilly Garden Apartments 8800 Lilly Ave 84 83
Total 158 156
Source: LIHTC Database, 2022.
Replacement Costs
The California Tax Credit Allocation Committee’s 2020 report provides estimates and data on
the cost of building assisted units. It estimates that the average cost of an assisted unit in the
State of California is $439,827.7 However, the estimated cost in Santa Clara County is higher
than the State with an average per unit cost of $607,463.
Table 30 summarizes the estimated replacement costs per unit using construction cost
estimates from the UC Berkeley Terner Center’s 2018 Construction Cost Index and average
unit sizes in the City of Gilroy from RentCafe. The table assumes both projects with unknown
expiration dates expire during the 6th Cycle. Combined, they provide an estimate for
replacement costs by unit size specific to Gilroy. It ranges from $261,690 for a one-bedroom
unit to $494,520 for a four-bedroom unit. However, construction costs have increased due to
supply issues associated with the COVID-19 pandemic.
Table 30: Replacement Cost
Unit Size
Construction
Cost per Square
Foot
Average Square
Foot/ Unit
Replacement
Cost per Unit
Number of At-
Risk Units
Total
Replacement
Cost
1 bedroom $390 671 $261,690 12 3,140,280
2 bedroom $390 901 $351,390 100 35,139,000
3 bedroom $390 1,091 $425,490 40 17,019,600
4 bedroom $390 1,268 $494,520 6 2,967,120
Total -- -- -- 158 58,266,000
Source: 2018 UC Berkeley Terner Center Construction Cost Index, RentCafe
Financial Resources
A variety of programs exist to assist cities to acquire, replace, or subsidize at-risk affordable
housing units. The following summarizes financial resources available to the City of Gilroy.
7 California Tax Credit Allocation Committee, 2020 Annual Report. https://www.treasurer.ca.gov/CTCAC/2020/annualreport/2020-
TCAC.pdf
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Preservation Strategies
There are many options to preserving units, including providing financial incentives to project
owners to extend low-income use restrictions; purchasing affordable housing units by a
nonprofit or public agency; or providing local subsidies to offset the difference between the
affordable and market rate. Scenarios for preservation will depend on the type of project at
risk.
Tenant-based subsidies could be used to preserve the affordability of housing. The Housing
Authority of Santa Clara and local nonprofit agencies provide Section 8 Housing Choice
Vouchers to lower-income households. These agencies could request funding from the City to
provide vouchers for residents if additional sources of revenue to the City’s Housing Trust Fund
were available.
Federal Programs
Community Development Block Grant (CDBG) – CDBG funds are awarded to cities on a formula
basis for housing activities. The primary objective of the CDBG program is the development of
viable communities through the provision of decent housing, a suitable living environment,
and economic opportunity for principally low- and moderate-income persons. CDBG funds can
be used for housing acquisition, rehabilitation, economic development, and public services.
HOME Investment Partnership – HOME is a flexible grant program and funds are awarded on
a formula basis for housing activities. HOME considers local market conditions, inadequate
housing, poverty, and housing production costs. HOME funding is provided to jurisdictions to
assist rental housing or home ownership through acquisition, construction, reconstruction
and/or rehabilitation of affordable housing.
Section 8 Rental Assistance / Housing Vouchers Program – The Section 8 Rental Assistance /
Housing Vouchers Program provides rental assistance payments to owners of private, market-
rate units on behalf of very low-income tenants.
Section 811/202 Program – Nonprofit and consumer cooperatives can receive no interest
capital advances from HUD under the Section 202 program for the construction of very low-
income rental housing for seniors and persons with disabilities. These funds can be used in
conjunction with Section 811, which can be used to develop group homes, independent living
facilities, and immediate care facilities. Eligible activities include acquisition, rehabilitation, new
construction, and rental assistance.
State Programs
California Housing Finance Agency (CalHFA) Multifamily Programs – CalHFA’s Multifamily
Programs provide permanent financing for the acquisition, rehabilitation, and preservation or
new construction of rental housing that includes affordable rents for low- and moderate-
income families and individuals. One of the programs is the Preservation Acquisition Finance
Program, which is designed to facilitate the acquisition of at-risk affordable housing
developments and provide low-cost funding to preserve affordability.
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Low-Income Housing Tax Credit (LIHTC) – This program provides tax credits to individuals and
corporations that invest in low-income rental housing. The LIHTC program creates affordable
housing opportunities when the developer of a project “sells” the tax credits to an investor or
investors who contribute equity to the development in exchange for an ownership position in
the project.
California Community Reinvestment Corporation – The California Community Reinvestment
Corporation is a multifamily affordable housing lender whose mission is to increase the
availability of affordable housing for low-income families, seniors, and residents with special
needs by facilitating private capital flow from its investors for debt and equity to developers of
affordable housing. Eligible activities include new construction, rehabilitation, and acquisition
of properties.
Program Efforts to Preserve At-Risk Units
Through the Community Development Department, the City monitors the list of affordable
housing units and their eligibility to convert to market-rate housing. Constant monitoring
allows the City to anticipate the time frame by which affordability covenants would expire,
allowing the City to implement various resources to ensure the continued affordability of the
housing units. Through the Consolidated Annual Performance and Evaluation Report, the City
annually checks with the regional HUD division on the status of rental multifamily housing
units that are funded with federal subsidies. To monitor for-sale affordable units, the City’s
BMR Program Administrator annually sends a “Below Market-Rate” pamphlet in English and
Spanish to all property owners under a resale restriction program. The pamphlet reminds the
owners that their home is currently in the program and directs them to contact City staff when
they plan to sell, refinance, or transfer ownership of their property. The City is including
Programs C - 1, C - 2, C - 4, and C - 5 for preservation of at risk and other below market rate
units.
Quantified Objectives
Housing Element law requires that cities establish a maximum number of units that can be
converted over the planning period. Two assisted projects with unknown conversion dates and
a total of 156 units may be at risk of converting to market-rate housing within the planning
period. Program C - 1 and C - 6 are included to confirm the expiration dates and preserve at-
risk units.
Special Needs Groups
Certain segments of the population may have more difficulty finding decent, affordable
housing due to special needs. This section identifies the housing needs for elderly persons,
large households, female-headed households, persons with disabilities (including
developmental disabilities), homeless persons, farmworkers, and extremely low-income
households. People may belong to more than one special needs group. Identifying special
needs groups helps to fully assess Gilroy’s housing needs and develop appropriate programs
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and actions to address them. The City maintains a list on its website of affordable rentals in
Gilroy and what population each property serves.
Persons with Disabilities
The US Census Bureau provides information on the number of persons with disabilities of
varying types and degrees. According to the US Census Bureau, a person is considered to have
a disability if they have difficulty performing certain functions or difficulty with certain social
roles. Affordability of appropriate housing and access, both within the home and to/from the
home site, are the primary challenges for persons with disabilities. Access often requires
specially designed dwelling units. Additionally, housing locations near public facilities and
public transit are important for this special needs group. The 2019 ACS survey estimates that
8 percent of Gilroy, 8 percent of Santa Clara County, and 10 percent of the Bay Area region
have a disability.8
The US Census Bureau provides information on the number of persons with disabilities of
varying types and degrees. The types of disabilities included in the Census are:
Hearing difficulty: deaf or has serious difficulty hearing
Vision difficulty: blind or has serious difficulty seeing even with glasses
Cognitive difficulty: has serious difficulty concentrating, remembering, or making
decisions
Ambulatory difficulty: has serious difficulty walking or climbing stairs
Self-care difficulty: has difficulty dressing or bathing
Independent living difficulty: has difficulty doing errands alone, such as visiting a
doctor’s office or shopping
Figure 5 shows an estimate of the number of Gilroy residents with disabilities by type of
disability and age group. The most prevalent types of disability are cognitive, ambulatory, and
independent living difficulty. Note that individuals may have more than one type of disability.
8 US Census Bureau, American Community Survey 5-year Data (2015–2019), Table B18101
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Figure 5: Disability by Type, 2019
Source: 2019 ACS B18108.
Persons with Development Disabilities
A subgroup of disabled residents is those who are developmentally disabled. Housing Element
law mandates that an analysis of special needs of disabled persons, including persons with
developmental disabilities, be included in Housing Elements. Many developmentally disabled
persons are able to live and work independently. However, more severely disabled individuals
require a group living environment with supervision, or an institutional environment with
medical attention and physical therapy. When developmental disabilities exist before
adulthood, the first housing issue for the developmentally disabled is the transition from living
with a parent/guardian as a child to an appropriate level of independence as an adult.
The San Andreas Regional Center provides service to developmentally disabled individuals
throughout Santa Clara, Santa Cruz, San Benito, and Monterey Counties. According to the
California Department of Developmental Services, as of December 2020, the San Andreas
Regional Center served 17,309 residents with developmental disabilities in the region. Figure
6 displays the breakdown of type of developmental disabilities served at the San Andreas
Regional Center. The largest populations served are those with an intellectual disability (42
percent) followed by autism (31 percent).
0
500
1,000
1,500
2,000
2,500
Hearing
Difficulty
Vision
Difficulty
Cognitive
Difficulty
Ambulatory
Difficulty
Self Care
Difficulty
Independent
Living
DifficultyPopulation by AgeDisability Type
<18 years old 18-64 years old >65 years old
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Figure 6: Developmental Disability by Type Served by San Andreas Regional Center, 2020
Source: California Department of Developmental Service, 2020.
Elderly Persons
Elderly persons are considered a special needs group because they are more likely to have
fixed incomes. Elderly persons are generally defined as people aged 65 years and older. They
often spend a higher percentage of their income on food, housing, medical care, and personal
care compared to non-elderly persons. Elderly persons may have special needs related to
housing location and construction. Because of limited mobility, elderly persons typically need
easier access to medical services, amenities such as shopping, and public transit. In terms of
housing construction, elderly persons may need ramps, handrails, elevators, lower cabinets
and counters, and special security devices to allow for greater self-protection.
According to the 2021 US Census, and as shown in Table 31, Gilroy has a slightly lower
percentage of elderly householders than the County; 19 percent of Gilroy’s residents were
elderly, while 21.3 percent of the County’s residents were elderly.
31%
8%
7%
42%
12%
Disability Type
Autism
Epilepsy
Cerebral Palsy
Intellectual Disability
Other Diagnosis
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Table 31: Householders by Age
Householder Age Gilroy Santa Clara County
Households % Households %
15-24 Years 271 1.7% 15,468 2.4%
25-34 Years 1,990 12.3% 107,194 16.8%
35-64 Years 10,794 66.9% 381,415 59.7%
65-74 Years 1,921 11.9% 74,305 11.6%
75 Plus Years 1,150 7.1% 61,833 9.7%
Total 16,126 100% 640,215 100%
Source: 2019 ACS 5 Year Estimates.
As indicated in Table 32, the 2019 median household income for households with a resident
aged 65 and older was $71,432 in Gilroy and $75,758 in Santa Clara County. This is compared
to the citywide median income of $101,616 and countywide median income of $133,076 in
2019. The lower income is likely because fewer elderly persons are working full-time, and most
income comes from Social Security and/or part-time work.
Table 32: Median Household Income for Elderly Households, 2019
Householder Age City of Gilroy Median Income Santa Clara County Median
Income
65 Years and Older $71,432 $75,758
All Households $101,616 $133,076
Source: 2019 ACS 5 Year Estimates
Based on HUD’s 2014-2018 CHAS data shown in Table 33, 47.4 percent of elderly households
in Gilroy are in one of the lower-income categories. Santa Clara County had a slightly smaller
percentage of elderly households within the lower income categories, at 45.8 percent.
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Table 33: Income Distribution, Elderly Households
Income Gilroy Santa Clara County
Number % Number %
Less than or equal to 30% of HAMFI 980 20.2% 39,300 19.7%
Greater than 30% but less than or equal to 50% of
HAMFI
695 14.3% 26,085 13.1%
Greater than 50% but less than or equal to 80% of
HAMFI
625 12.9% 26,380 13.2%
Greater than 80% of HAMFI 2,555 52.6% 108,105 54.1%
Total 4,855 100% 199,870 100%
Source: 2014-2018 HUD CHAS data.
Table 34 displays the percentage of the elderly population and their disability status. Of people
aged 65 and above, 11.3 percent have one type of disability and 16.5 percent have two or more
disabilities. The City and County have a similar percentage of elderly individuals with
disabilities, at 27.8 and 30.7 percent, respectively.
Table 34: Elderly People with Disabilities
Disability Status
# of Elderly
People with a
Disability
% of
People
Age 65+
# of Elderly
People
with a Disability
% of
People
Age 65+
Gilroy Santa Clara County
With one type of disability 669 11.3% 31,527 12.4%
With two or more types of
disability
978 16.5% 46,455 18.3%
Total, Elderly with a Disability 1,647 27.8% 77,982 30.7%
Source: 2019 ACS C18108.
Table 35 provides a summary of housing problems experienced by elderly households in
Gilroy. According to the 2014-2018 CHAS data, 61.6 percent of all elderly households
experience some type of housing problem. This includes 81.3 percent of elderly renters and
54.5 percent of elderly owners. The increasing number of elderly persons in the population is
creating a demand for more affordable and accessible housing. The City will address the needs
of the elderly population through Program E - 6, which will develop incentives for senior
housing in the City. The Gilroy Senior Center provides access to a variety of support services
at the center, including the YMCA Nutrition program, which serves lunch Monday to Friday;
free legal services through Senior Adults Legal Assistance; and information and assistance with
social security, housing, and employment matters through Sourcewise Community Resources
Solutions. Through CDBG and the Housing Trust/PLHA Funds, the City allocated funds for
Meals on Wheels and Rebuilding Together Silicon Valley’s Rebuilding Home Repair,
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Rehabilitation and Accessibility Modification Program. Santa Clara County owns the Gateway
Senior Apartments, a 75‐unit affordable senior housing complex with approximately half of
the units reserved for special needs seniors.
Table 35: Elderly Households by Housing Problems and Tenure, 2018
Housing Problem Type Renters Owners Total (Elderly Households)
% with any Housing Problem 81.3% 54.5% 61.6%
% with Cost Burden 29.5% 15.7% 19.4%
% with Severe Cost Burden 29.1% 20.0% 22.4%
Total 843 2,350 3,193
Source: 2014-2018 HUD CHAS data.
Large Households
State housing law defines large households as households with five or more members. Large
households are considered a special needs group based on the limited availability of
adequately sized, affordable housing units. Large households may be of lower income, and
could result in the overcrowding of smaller units. Table 36 displays household size by tenure
for both Gilroy and the County. In 2019, there were 3,916 large households, representing 24.3
percent of all households in Gilroy. Compared to the County as whole, Gilroy has almost
double the percentage of large households (24.3 versus 12.4 percent). This may indicate a
need for larger units in Gilroy to accommodate large households.
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Table 36: Large Households by Tenure, 2019
Number of Persons in Unit Owner Occupied % Renter Occupied % Total
Gilroy
Five 1,239 58.6% 876 41.4% 2,115
Six 636 60.7% 412 39.3% 1,048
Seven or more 405 53.8% 348 46.2% 753
Total Large Households 2,280 58.2% 1,636 41.8% 3,916
% of Total Households 23% 26.3% 24.3%
Total Households 9,914 61.5% 6,212 38.5% 16,126
Santa Clara County
Five 26,406 57.9% 19,190 42.1% 45,596
Six 10,802 58.0% 7,822 42.0% 18,624
Seven or more 8,684 56.6% 6,650 43.4% 15,334
Total Large Households 45,892 57.7% 33,662 42.3% 79,554
% of Total Households 12.7% 12.1% 12.4%
Total Households 361,105 56.4% 279,110 43.6% 640,215
Source: 2019 ACS B25009.
Table 37 provides a summary of housing problems experienced by large households in Gilroy
by tenure. As previously noted, the types of housing problems include overcrowding,
overpayment, and housing lacking kitchen or plumbing facilities. CHAS data from 2014- 2018
indicates that 49.2 percent of large households experience at least one of these housing
problems, including 72.4 percent of large renter households and 30.3 percent of large owner
households.
Currently, less than 10 percent of the City’s rental housing stock has four or more bedrooms
(refer to Table 37), resulting in a high percentage of large family households that are forced to
live in overcrowded situations. To address this need, the Housing Element includes Program
A - 11 that will adopt density bonus incentives beyond state law for developments that include
housing for large households.
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Table 37: Large Households by Housing Problems and Tenure, 2018
Renters Owners Total (Large Households)
% with any Housing Problem 72.4% 30.3% 49.2%
% with Cost Burden 23.2% 12.6% 17.4%
% with Severe Cost Burden 24.3% 6.9% 14.7%
Total Large Households 1,360 1,665 3,025
Source: 2014-2018 HUD CHAS data.
Female-Headed Households
Female-headed households are a special needs group because they experience comparatively
low rates of homeownership, lower incomes, and high poverty rates. Table 38 shows the
number of female-headed households by tenure. In 2019, 16.2 percent of households in Gilroy
were female-headed households. Of the 2,616 female-headed households in Gilroy, 1,410 had
children under 18 living with them, while 1,206 had no children present. Gilroy has more
female-headed households than the County by about 6 percent, where 10 percent of
households in the County are female-headed households.
In Gilroy, 33 percent of female-headed households with children under 18 were below the
poverty line; roughly 465 households.9 This is significantly higher than the poverty rate in Santa
Clara County, which is 6.6 percent.
Table 38: Female-Headed Households by Tenure, Gilroy, 2019
Household Type
Owner Occupied Renter Occupied
Total
% of Total
Households
(16,126) Number % Number %
Female householder, no husband
present, with children under 18 377 2.3% 1,033 6.4% 1,410 8.7%
Female householder, no husband
present, without children 639 4% 567 3.5% 1,206 7.5%
Total 1,016 6.3% 1,600 9.9% 2,616 16.2%
Source: 2019 ACS B25115.
Homeless/Unhoused Population
In 2019, the County of Santa Clara, in conjunction with Applied Survey Research (ASR),
conducted the 2019 Santa Clara County Homeless Count. This study is conducted every two
years in the last 10 days of January. Two strategies were used to collect the data for the study:
a point-in-time count (PITC) and a comprehensive qualitative survey administered to
9 US Census Bureau, American Community Survey 5-year Data (2015–2019), Table B17010
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individuals experiencing homelessness after the completion of the 2019 PITC. The PITC and
shelter census identified 9,706 homeless persons in Santa Clara County. Table 39 summarizes
sheltered and unsheltered homeless persons in Santa Clara County jurisdictions. There were
704 homeless persons surveyed in Gilroy, including 359 sheltered and 345 unsheltered
persons. This represents an increase from 2011 (520 surveyed homeless persons).
Table 39: Regional Homeless Population
Homeless Population Sheltered Unsheltered Total
Gilroy 359 345 704
Campbell 0 74 74
Cupertino 0 159 159
Los Altos 0 76 76
Los Altos Hills 0 2 2
Los Gatos 0 16 16
Milpitas 0 125 125
Monte Sereno 0 0 0
Morgan Hill 0 114 114
Mountain View 32 574 606
Palo Alto 14 299 313
San Jose 980 5,117 6,097
Santa Clara 62 264 326
Saratoga 0 10 10
Sunnyvale 147 477 624
Source: 2019 Santa Clara County Homeless Census and Survey.
Table 40 lists emergency shelters and transitional housing in Gilroy.
The Countywide services and shelter provider, HomeFirst Services, provides cold weather
shelter at the Gilroy National Guard Armory yearly from November through March. The shelter
provides sleeping accommodations, meals, restrooms, and case management support
services. It has a capacity of 110 persons. In 2017, the County of Santa Clara began using the
Arturo Ochoa Migrant Center as an emergency shelter during the cold weather season from
mid-November through the end of March. It houses up to 35 families and has up to 140 beds.
St. Joseph’s Family Center manages the shelter and referral process. EAH Housing is contracted
for day-to-day property management operations and site security.
The Gilroy National Guard Armory and Arturo Ochoa Migrant Center are only open from late
November through March, and typically do not fill to their capacities. According to
conversations with service providers, if the weather is manageable, unhoused individuals
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express a strong reluctance to use the service. The service providers stress the need for a
permanent emergency shelter as well as shelter or housing for single adults who do not exhibit
mental illness or substance abuse disorders.
The City of Gilroy provides annual funds to homelessness prevention support and services
through the PLHA. Projects funded include:
$55,000 to St. Joseph’s Family Center for Homeless Prevention Services
$35,000 to St. Joseph’s Family Center for the Gilroy Street Team
$40,000 to South County Compassion Center for Outreach for the unhoused
$20,000 to CARAS for the Homeward Bound Program
Table 40: Homeless Facilities in Gilroy
Facility Name Type of Facility Target Population
Number of
Shelter Beds
National Guard Winter
Homeless Shelter Cold Weather Shelter Individuals and
families 110
Arturo Ochoa Migrant
Center Cold Weather Shelter Individuals and
Families 140
La Isla Pacifica Emergency Shelter/Domestic
violence
Women and children
(under 12 years old) 14
Sobrato Apartments Transitional/Emergency
Shelter Families 225
Sobrato Apartments Permanent Supportive
Housing Chronically Homeless 26
Community Solutions Transitional Shelter Single Individuals 20
St. Joseph’s Family Center Transitional Shelter Youth
(some with children) 9
Total 544
Source: City of Gilroy, County of Santa Clara.
Farmworkers
Farmworkers are defined as persons whose primary incomes are earned through seasonal
agricultural work. The demographics on farm laborers in all California markets are collected
and reported on a regional or countywide basis. The data collected includes income,
household status, and length of time the laborers work in each area.
There are generally three classifications:
Migrant workers who move from place to place, planting and harvesting; and
Annual workers who generally work in the same agricultural area year after year for
nine or ten months and spend the rest of the year in their home country; and
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Permanent workers who are employed most of the year in one location and may
collect unemployment for the remainder of the year.
Traditionally, Gilroy has been home to many agricultural businesses and industries; however,
the increase in the retail and service trade and the expansion of the City as a “bedroom
community” for northern Silicon Valley jobs continues to reduce the role of agriculture in
recent years. Many of these farms are located in the southern areas of the County, further
from the tech industry, in the regions surrounding Gilroy. The majority of farmworkers, almost
80 percent, work on farms with more than 10 employees.
The US Department of Agriculture conducts a Census of Agriculture every five years. The 2007
US Department of Agriculture Census of Agriculture counted 5,589 farmworkers in the County.
A 2014 estimate indicated employment on 1,000 farms in Santa Clara County represented
about 8,100 jobs.10
Table 41 shows the 2017 estimates of farmworkers for Santa Clara County. As indicated, there
were an estimated 4,175 farmworkers in the County working on 890 farms. The 2019 ACS
estimates indicate that 2.9 percent of Gilroy is employed in the agriculture and natural
resource industry, a decrease from 4.6 percent in 2012.11
Table 41: Number of Santa Clara County Farmworkers and Farms, 2017
Farm /Worker Type Farmworkers Farms
Farm Size
Farms with less than 10 employees 847 293
Farms with more than 10 employees 3,328 66
Length of Employment of Workers
Workers working 150 days or more 2,418 -
Workers working less than 150 days 1,757 -
Source: 2017 Census of Agriculture, Table 7.
The California Department of Conservation’s Important Farmland Finder12 indicates that the
vicinity to the east and south of the City of Gilroy includes large amounts of prime farmland,
farmland of local or statewide importance, and unique farmland. The presence of such
farmland indicates a need for farmworker housing to support those who work on farmland in
and around the City.
Due to the seasonal nature of agricultural work and relatively low wages, farmworker
households often have a difficult time securing safe, habitable, and affordable housing. To
10 The Economic Contribution of Agriculture to the County of Santa Clara, 2014.
http://ag.sccgov1.acsitefactory.com/sites/g/files/exjcpb456/files/AG_Economic_Report_WEB_Final.pdf.
11 US Census Bureau, American Community Survey (2015–2019), Table C24030.
12 California Department of Conservation. California Important Farmland Finder. https://maps.conservation.ca.gov/DLRP/CIFF/
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provide for the existing farmworkers, EAH Housing operates the Arturo Ochoa Migrant Center
in Gilroy. The center contains 33 three-bedroom and 67 two-bedroom apartments. It functions
as a migrant camp for 180 days each year. Housing at the Ochoa Migrant Center is available
on a seasonal basis for a maximum of 100 families whose primary income is derived from
agricultural-related work.
Eden Housing also manages four housing developments with 84 units for farmworkers:
14 units at The Trees
24 apartments at Aspen Grove
18 units at Maple Gardens
28 units at Monterra
The Rodriguez Migrant Labor Camp, which houses 37 seasonal farmworkers, is privately
owned, and is located outside of the City limits.
The Gilroy Zoning Code makes available zoning to accommodate various housing types to
address the needs of farmworkers. Manufactured and modular homes are permitted by-right
in all residential zoning districts; boarding and rooming houses are allowed in all residential
zoning districts with a conditional use permit; and multifamily units are allowed in the R-3 and
R-4 residential zoning districts by right. Currently, the City’s Zoning Code is not consistent with
the Employee Housing Act;13 therefore, as part of this Housing Element update, the City is
including Program E - 8 to revise the Zoning Code in 2023.
Extremely Low-Income Households
Extremely low-income households in Gilroy are defined as households with income less than
30 percent of the Santa Clara County AMI. The provisions of Government Code Section 65583
(a)(1) require quantification and analysis of existing and projected housing needs of extremely
low-income households. In 2018, 16.1 of Gilroy households were within the extremely low-
income category, a decrease from 18.9 percent in 2012.
Table 42 provides a summary of housing problems experienced by extremely low-income
households in Gilroy. Extremely low-income renter-occupied households experience both
overpayment and overcrowding. According to 2014–2018 CHAS data provided by HUD, 79.7
percent of extremely low-income households experience at least one type of housing problem.
The needs of extremely low-income households include housing units designed for unhoused
persons, multifamily rental housing, factory-built housing, mobile homes, housing for
agricultural employees, supportive housing, single-room occupancy units, and workforce
housing. The City is including Program A - 10 to develop an inclusionary housing policy and
Program A - 11 to develop a density bonus beyond state law to incentivize the creation of
additional units to serve extremely low income households.
13https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=HSC&division=13.&title=&part=1.&chapter=1.&article
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Table 42: Extremely Low-Income Households with Housing Problems, 2018
Income Level Renters % Owners % Total %
Household Income < 30% MFI 1,990 31.1% 625 6.4% 2,615 16.1%
With any Housing Problem 1,610 80.9% 475 76.0% 2,085 79.7%
With a Cost Burden 30-50% 360 18.1% 70 11.2% 430 16.4%
Cost Burden > 50% 1,230 61.8% 400 64.0% 1,630 62.3%
Source: 2014-2018 HUD CHAS data.
Summary of Housing Needs
An analysis of the housing needs in the City of Gilroy reveals a number of trends of housing
needs in the City, such as an increased need for large households and for farmworkers.
Additionally, compared to the County, Gilroy has a lower median income and larger
percentage Hispanic or Latino population.
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69
CITY OF GILROY
HOUSING ELEMENT
6TH CYCLE
AFFIRMATIVELY FURTHERING FAIR HOUSING
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Affirmatively Furthering Fair Housing
Introduction, Outreach, and Assessment
Introduction
Assembly Bill (AB) 686 requires a jurisdiction’s housing element to provide an analysis of
contributing factors to fair housing issues and to commit to actively and meaningfully
affirmatively further fair housing. This analysis includes an assessment of fair housing
enforcement, outreach activities, integration and segregation, racially and ethnically
concentrated areas of affluence and poverty, disparities in access to opportunities,
disproportionate housing needs, and any other contributing factors that serve as impediments
to fair housing. The assessment also analyzes the extent to which the identified Regional
Housing Needs Allocation (RHNA) sites affirmatively further fair housing.
Public Outreach
The City of Gilroy solicited community input throughout the Housing Element update planning
process in a variety of ways. The main strategies to gather public participation are summarized
below.
Outreach Activities
Community members were engaged using the following methods:
Survey available in hard copy and online in both English and Spanish
Stakeholder focus groups
Web page on City website
Email list
City newsletter
Community workshops
Joint City Council/Planning Commission study session
Organizations Contacted and Consulted
Organizations contacted and interviewed included:
Housing & Neighborhood Revitalization Committee
St. Joseph's Family Center
Gilroy Historical Society
Rebuilding Together Silicon Valley
Project Sentinel
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Gilroy Compassion Center
Live Oak Adult Day Services
Silicon Valley at Home
South County Collaborative
League of Women Voters
Aperto Property Management
Housing Choices
Health Trust
Visit Gilroy
MidPen Housing
Garlic World
CARAS South County
Eden Housing
Housing Element Update – City Website
The City created the Housing Element update web page on the City’s website to provide:
Background and information on the Housing Element process;
Link to the Housing Element update survey;
Documents related to the Housing Element;
Recordings of the community workshop presentations in English and Spanish;
Notification to the public of future events; and
Notification and interest sign-up lists and comment and question pathways for
residents to get involved in the process and to provide comments or questions to
the project team or City representatives.
Stakeholder Interviews
The City reached out to 40 individuals who represented service providers, nonprofits, and
other stakeholders to participate in focus group interviews about the housing needs and
issues in Gilroy. Out of the 40 individuals and groups that were contacted, 25 people
participated in the focus groups. Four focus groups were held, on Tuesday, March 29 at 1:00
p.m.; Tuesday, April 5 at 1:00 p.m.; Thursday, April 7 at 1:00 p.m.; and Tuesday, April 12 at 10:00
a.m. Hosting the focus group on four different days provided a variety of times to
accommodate different schedules. The stakeholders who participated discussed a variety of
concerns, including:
Need for incentives to support farmworker housing;
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Need for more education and outreach to inform residents of housing law and
affordable housing;
Need for emergency, short-term stay housing, and senior housing at the extremely
low-income area median income (AMI);
Disparity of housing and quality of infrastructure and amenities between the east
side and west side of the City;
Disparity of incomes between Gilroy and the AMI of the region, which was $33,871
less (24%) in 2020;
Challenges and lack of support for homeownership; and
Need to incentivize accessory dwelling unit (ADU) construction
The participants had varying perspectives informed by their involvement and familiarity with
Gilroy, but a consistent message of increased services, education and support, encourage
equitable development and investment, and a lack of extremely low-income housing were the
most prevalent issues covered.
Public Workshops
The City held two virtual public workshops—Wednesday, March 30, 2022 at 6:00 PM, and
Tuesday, June 28, 2022 at 6:00 PM —to present information on the Housing Element update
and gather public input. Sixty-one members of the community participated in the workshops
and provided feedback via live polling and questions and answers on the Housing Element
update process including housing needs (workshop #1) and the potential RHNA sites, draft
goals, and programs (workshop #2). Presentation slides were in English and Spanish. Live
Spanish interpretation was provided, recorded, and posted on the project webpage for both
workshops.
The public workshops were held at 6:00 p.m. on weekdays to accommodate a typical work
schedule. Materials and video recordings of the presentations in English and Spanish were
made available on the Gilroy Housing Element web page on the City’s website for those who
could not attend, or who wanted to review the materials and meetings at their leisure.
Housing Element Survey
Another component of the outreach effort was the Housing Element survey, posted on the
City’s website from April 2022 through August 2022, and promoted through a myriad of
channels for the furthest outreach. The survey was available in both English and Spanish. As
of August 2, 2022, a total of 350 English and 129 Spanish completed surveys were received,
with 244 (51%) respondents being homeowners, 184 (39%) of respondents being white or
Caucasian, and 215 (46%) being Hispanic or Latino. Responses to the survey primarily revealed
concerns from residents regarding:
Difficulty paying rent, mortgage, or down payment
Homelessness
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Insufficient housing supply including affordable housing
Respondents also believe that the greatest housing needs are lower and middle income
workforce housing and affordable housing. The survey results show strong support for more
affordable housing while some respondents feel the City is growing too much and do not
support more development. Most of the survey and stakeholder responders believe that there
are not enough services or housing to support individuals who fall within the extremely low-
income designation. It was also identified that an inclusionary housing ordinance would be
supported by 481 survey respondents and by the stakeholder interviewees.
Findings
Most focus group attendees and survey respondents support the provision of more
assistance, financial or otherwise, to the extremely low-income population in finding housing.
City Overview
Much of the fair housing analysis is based upon census data provided at the census tract level.
Gilroy has a total of 11 census tracts. Figure 7 displays the census tracts in the City and the
RHNA sites within those census tracts; however, several of the census tracts are not solely in
Gilroy and have large portions in neighboring jurisdictions. As a result, demographic
information for these census tracts reflects neighboring communities, as well as Gilroy. The
west tracts have more open space and agriculture, so the population as a whole is generally
more concentrated in the east, which may skew data perception. Several of the tracts include
more land and more households in adjacent jurisdictions other than in Gilroy. These
households are included in the census data, which may affect the displayed maps.
Until 2018, a large portion of the Downtown Specific Plan area and several properties west of
downtown were designated as a Neighborhood Revitalization Strategy Area by the US
Department of Housing and Urban Development (HUD). A number of capital improvements,
youth activities, neighborhood beautification projects, and other downtown revitalization
efforts were pursued during this time.14 The downtown area in Gilroy is also identified as a
Priority Development Area in ABAG’s Plan Bay Area 2050.
The AFFH section also considers the effects that the selected RHNA sites may have on fair
housing. Selected RHNA sites are primarily in the eastern portion of the City, while pending
projects are more evenly distributed throughout Gilroy. The sites inventory includes a mix of
vacant and non-vacant sites, selected for their access to resources, suitability for multifamily
housing, and proximity to upcoming plans for community revitalization, including the planned
high speed rail station, parking management plan, and Downtown Specific Plan update.
Additionally, non-vacant sites were selected based on their likelihood to develop during the 6th
cycle and the extent to which the existing use may preclude development.
14 Neighborhood Revitalization Strategy Area Renewal Request for 2013-2018.
https://www.cityofgilroy.org/DocumentCenter/View/9045/NRSA-Strategy-Renewal-Request-for-2013-2018
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The City is including Program F - 3 for place-based improvements in the downtown area. The
City is also including programs to encourage ADU development15 in the western portion of the
City to promote housing mobility and increased housing opportunities (Program A - 6). To
encourage a variety of housing types throughout the City, a program to create a ministerial
permit process for duplexes, triplexes, and quadplexes that meet objective design standards
is included (Program F - 4). This program will also encourage the development of missing
middle housing in all areas of the City.
Figure 7: Census Tracts and RHNA Sites, 2022
Fair Housing Enforcement and Outreach Capacity
Project Sentinel provides fair housing counseling services for the City of Gilroy. The City
publishes the availability of both tenant/landlord counseling and fair housing services via its
website. In the fiscal years 2022 – 2023 and 2023-2024, the City of Gilroy allocated $80,000 in
total funds to two Project Sentinel programs: Fair Housing and Landlord/Tenant Counseling
15 ADUs are calculated on a citywide basis and are not represented on the sites maps
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and Dispute Resolution. The funds are provided through the Permanent Housing Allocation
(PLHA) Fund, which is administered by Santa Clara County’s’ Office of Supportive Housing.
Project Sentinel is a non-profit organization that provides a variety of fair housing resources
and services in northern California, including resources for tenants, property managers, and
service providers, dispute resolution, and housing counseling. Annually, Project Sentinel
processes over 10,000 initial contacts, handles over 400 housing discrimination complaints,
over 1,700 landlord tenant and community dispute cases, counsels over 750 homeowners,
and provides monthly workshops on housing topics.
Integration and Segregation
Race and Ethnicity
Figure 8 shows the racial and ethnic majority by census tract in the City of Gilroy. As illustrated,
the western half of the City has a slim (<10%) to sizeable (10 – 50%) White majority, while the
eastern half of the City has areas with sizeable (10 – 50%) to predominant (> 50%) Hispanic
majorities. The tracts with Hispanic majorities have larger low- to moderate-income
populations, and a higher quantity of female-headed households than the majority White
tracts. The area with the predominant Hispanic majority also contains a Racially and Ethnically
Concentrated Area of Poverty (R/ECAP). HUD defines Racially and Ethnically Concentrated
Areas of Poverty (R/ECAP) as areas where the percentage of the population that is non-White
is over 50 percent and the percentage of households with incomes below the poverty line is
over 40 percent. Alternatively, a neighborhood can be a R/ECAP if it has a poverty rate that
exceeds 40 percent or is three or more times the average tract poverty rate for the
metropolitan/micropolitan area, whichever threshold is lower.
Regionally, there is a common correlation between wealth and race, which may help explain
the racial/income concentrations in the City. In comparison to the County as a whole, the City
has a significantly larger Hispanic population (57.6 percent), compared to the County’s 25.1
percent. Gilroy has a much smaller percentage Asian/Asian Pacific Islander (API) population (9
percent), compared to the County (37 percent), and a slightly smaller non-Hispanic White
population (28 percent) compared to the County (32 percent).
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Figure 8: Racial and Ethnic Majority, 2010
Source: HCD AFFH Data Viewer
As shown in Figure 9, there are no census tracts in the City with a non-White population less
than 41 percent. The area with the highest non-White percentage is also the area with the
R/ECAP. In the City, newer developed single-family housing is primarily available in the west,
while the multifamily, more affordable housing opportunities are primarily available in the east
of the City, where there is a larger non-White population. As of 2019, 72 percent of the City was
non-White while 68 percent of the County was non-White, indicating that the overall
distribution of the non-White population is similar between the City and the region as a whole.
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Figure 9: Percent of the Population that is Non-White, 2018
Source: HCD AFFH Data Viewer
Figure 10 compares the RHNA units with the percentage of the population that is non-White.
While many sites are in the downtown area, where there is a large non-White population, this
area is where the City is targeting revitalization, which includes plans for significant investment
and improvements, further economic development, and a future high speed rail station.
The City is including Program F - 5, Displacement Prevention Ordinance, to ensure that existing
residents in sites located in the eastern portion of the City are protected from displacement
including multilingual tenant counseling through Program F - 2, a partnership with Project
Sentinel. The City is also including programs to encourage development opportunities
throughout the City, including Program G - 3 for ADU outreach focused in the western portion
of the City, Program A - 10 for adoption of an inclusionary housing policy, and allowing
duplexes, triplexes, and fourplexes that meet objective design standards to be approved
ministerially in certain zones.
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Figure 10: Percent non-White Comparison of RHNA Units
Dissimilarity Index – Race and Ethnicity
Segregation is defined by the census as the spatial distributions of different groups among
units in a metropolitan area.16 Segregation can be quantified by using the dissimilarity index.
The dissimilarity index measures the distribution of two groups in a city and assigns a score
between 1 and 100. The level of segregation is determined by assessing what percentage of
residents of a census block would have to move for each block to have the exact same
population of said group. A score of zero (0) reflects a fully integrated environment; a score of
100 (or 100%) reflects full segregation. Therefore, a higher dissimilarity index indicates higher
concentrations of the indicated ethnic groups in areas of the City, when compared to the White
population distribution. A lower dissimilarity index implies higher integration, and a more even
distribution of each ethnicity when compared to the White population. The formula for this
calculation is provided by California Department of Housing and Community Development’s
(HCD) AFFH Guidance Document.
16 Measures of Residential Segregation https://www.census.gov/topics/housing/housing-patterns/guidance/appendix-b.html
0%
5%
10%
15%
20%
25%
30%
35%
40%
45%
40-60% 60-80% 80-100%Percent of RHNA UnitsPercent of the Population that is non-White by Block Group
Lower Moderate Above Moderate Mixed
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The categories for the dissimilarity index on a scale of 1-100 are as follows:
<30: Low Segregation
30 – 60: Moderate Segregation
>60: High Segregation
Figure 11 provides the dissimilarity index values in Gilroy, indicating the level of segregation
between White residents and residents who are non-White, Black, Hispanic, or Asian. In 2020,
there was moderate segregation between the Hispanic and White populations and low
segregation between the Black and White populations, and between the Asian and White
populations. The moderate dissimilarity index of 35.41 in the table below means that 35.41
percent of Gilroy’s Hispanic or White residents would need to move to a different census block
to create balanced integration between Hispanic and White residents. Segregation at the City
level is much lower than Santa Clara County as a whole.
Figure 11: Dissimilarity Index for Race
Source: HUD AFFH Data tool.
Income
The dissimilarity index can also be used to calculate income segregation, using the same scale
as above. The segregation between below moderate and above moderate income groups is
moderate. Regionally in the Bay Area, segregation is also moderate.
0
10
20
30
40
50
60
Non-White/WhiteBlack/WhiteHispanic/WhiteAsian/WhiteNon-White/WhiteBlack/WhiteHispanic/WhiteAsian/WhiteGilroy San Jose-Sunnyvale-Santa Clara Region
1990 2000 2010 2020
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Table 43: Dissimilarity Index for Income
2010 2015
Below 80% AMI
/ Above 80%
AMI
Below 50% AMI /
Above 120% AMI
Dissimilarity
Below 80% AMI /
Above 80% AMI
Dissimilarity
Below 50% AMI /
Above 120% AMI
Dissimilarity
Gilroy 31.5 46.2 41.6 53.3
Bay Area 28.7 36.6 27.4 35.1
Source: Association of Bay Area Governments AFFH Data Report.
As shown in Figure 12, the area with a large low-moderate income population is also the area
with a predominant Hispanic majority, and largest non-White population. This area is also
where the R/ECAP is located. There is a large low- to moderate-income population in the area
with more multifamily housing. Income often correlates with housing type—i.e., large single-
family areas generally have higher incomes. Compared to the region, Gilroy has a lower
median income and a higher income disparity.
While a large percentage of the RHNA sites are in the area with the highest concentration of
the low- to moderate-income population, this area also falls within the downtown Gilroy, which
provides residents with close access to resources and employment opportunities. The
anticipated development of the new high speed rail station is also expected to increase
economic investment in the downtown. The Housing Element includes programs to ensure
redevelopment of non-residential sites downtown. No displacement is expected. Programs
include the creation of an inclusionary housing ordinance (Program A - 10), multilingual tenant
support in partnership with Project Sentinel (Program F - 2), and a displacement prevention
policy (Program F - 5).
The City also has an affordable housing portfolio available to lower-income households,
including ownership and rental units. The below market rate units are administered by
HouseKeys through Programs C - 1, C - 4, and C - 5, which include monitoring of Units At-Risk
of Converting to Market Rate and resale/rent control on BMR units. There are over 400 units
in the Below Market Rate (BMR) program.
The City is also including programs to encourage development opportunities in the western
portion of the City that are not captured by the sites inventory, including ADU Tracking and
Monitoring (Program A - 6), adoption of an Inclusionary Housing Policy (Program A - 10), and
allowing duplexes, triplexes, and fourplexes to be approved ministerially in certain zones
(Program A - 9), and through Housing Mobility and Choice in Higher Opportunity Areas
(Program F - 4).
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Figure 12: Low to Moderate Income Population and RHNA Sites, 2011-2015
Source: HCD AFFH Data Viewer
Figure 13 shows the percentage of RHNA units compared to the percent of each block group
that is in the low to moderate income. The lower and moderate income RHNA sites are
proposed in the areas with a larger low-to-moderate income population so as to provide new
housing opportunities without displacing current residents from their neighborhoods.
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Figure 13: Low to Moderate Income Population Comparison of RHNA Units
Figure 14 shows the change in the population under the federal poverty line by census tract
from 2010–2014 to 2015–2019. Poverty is defined by incomes falling below the annually
defined thresholds for family size by the Census. Poverty levels in the east area, where the
downtown specific plan is, decreased significantly over this period. From 2010 to 2014, 30-40%
of households in the eastern downtown R/ECAP area were living in poverty. Between 2015 and
2019, the percentage decreased significantly, with less than 20% and in some cases, less than
10% of residents in this area living in poverty. Similarly, the number of impoverished residents
in southern Gilroy decreased between 2010 and 2019, with less than 10% of these residents
living in poverty. The 2015–2019 map shows lower levels of poverty Citywide, and increased
geographic parity. The 2015–2019 map also shows that pending projects and proposed RHNA
sites are spread throughout the City with more pending projects in the west and proposed
RHNA sites in the east.
0%
5%
10%
15%
20%
25%
30%
35%
40%
0-25% 25-50% 50-75% 75-100%Percent of RHNA UnitsPercent of the Population that is Low to Moderate Income by Block Group
Lower Moderate Above Moderate Mixed
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Figure 14: Poverty Status, 2010-2014 and 2015-2019
Source: HCD AFFH Data Viewer
Figure 15 displays the distribution of housing choice vouchers in the City. The Santa Clara
County Housing Authority (SCCHA) is the regional Public Housing Authority for the City of Gilroy
and administers the Housing Choice Voucher (HCV) program (also known as section 8). The
HCV program is a 100% federally funded rental subsidy for low-income households living in
privately owned rental units. The City does not own any public housing; however, SCCHA owns
and manages affordable housing units in Gilroy and throughout the County of Santa Clara.
Santa Clara County owns the Gateway Senior Apartments, a 75‐unit affordable senior housing
complex with approximately half of the units reserved for special needs seniors. Many of the
seniors in this housing complex use housing choice vouchers. There is little housing choice
voucher use in the west side of the City. The majority of housing choice voucher usage is in the
R/ECAP, where there is more multifamily housing and rental apartments.
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Figure 15: Housing Choice Vouchers
Source: HCD AFFH Data Viewer
Familial Status
Figure 16 shows the percentage of children that are living in female-headed households with
no spouse by census tract. It also shows pending and proposed RHNA sites. In 2019, 2,616
households, or 16.2 percent of the total households in Gilroy, were female-headed
households, which is about 6 percent higher than in the County, at 10 percent. There is no
tract with a significant concentration of children in female-headed households. As shown in
Figure 17, RHNA sites are distributed throughout the City and are not expected to impact fair
housing concerns based on familial status. For example, 32.7 percent of the RHNA units are
located in tracts where 0-20% of children are living in female-headed households with no
spouse.
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Figure 16: Children in Female-Headed Households and RHNA Sites
Source: HCD AFFH Data Viewer
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Figure 17: Female Headed Households Comparison of RHNA Units
As shown in Figure 18, areas with high concentrations of children in married-couple
households are also areas with large numbers of single-family households. In Gilroy, 30.5
percent of households are married-couple households with children present, compared to
26.6 percent countywide. RHNA sites are distributed throughout the City and are not expected
to impact fair housing concerns based on familial status.
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
0-20% 20-40%Percent of RHNA UnitsPercent of Children in Female-Headed Households by Tract
Lower Moderate Above Moderate Mixed
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Figure 18: Children in Married-Couple Households
Source: HCD AFFH Data Viewer
Persons with Disabilities
The US Census Bureau provides information on the number of persons with disabilities of
varying types and degrees. According to the US Census Bureau, a person is considered to have
a disability if they have difficulty performing certain functions or difficulty with certain social
roles. Affordability of appropriate housing and access, both within the home and to/from the
home site, are the primary challenges for persons with disabilities. Access often requires
specially designed dwelling units. Additionally, housing locations near public facilities and
public transit are important for this special needs group. The 2019 American Community
Survey estimates that 8 percent of Gilroy, 8 percent of Santa Clara County, and 10 percent of
the Bay Area region have a disability.17
The US Census Bureau provides information on the number of persons with disabilities of
varying types and degrees. The types of disabilities included in the Census are:
17 US Census Bureau, American Community Survey 5-year Data (2015–2019), Table B18101
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Hearing difficulty: deaf or has serious difficulty hearing
Vision difficulty: blind or has serious difficulty seeing even with glasses
Cognitive difficulty: has serious difficulty concentrating, remembering, or making
decisions
Ambulatory difficulty: has serious difficulty walking or climbing stairs
Self-care difficulty: has difficulty dressing or bathing
Independent living difficulty: has difficulty doing errands alone, such as visiting a
doctor’s office or shopping
Figure 19 shows an estimate of the number of Gilroy residents with disabilities by type of
disability and age group. The most prevalent types of disability are cognitive, ambulatory, and
independent living difficulty. Note that individuals may have more than one type of disability.
Ambulatory issues are the highest reported disability countywide. A large population with
walking difficulty creates a need for single-story housing, elevators, transit access, wheelchair
access, larger homes for live-in help, and proximity to health facilities.
Figure 19: Disability Characteristics, Gilroy, 2019
Source: 2019 ACS B18108.
Figure 20 shows that the disabled population is relatively evenly distributed throughout Gilroy.
There were no significant changes in location or concentration of those with a disability from
2010–2014 to 2015–2019. The area in the east of the City with a larger low- to moderate-
income population and larger non-White population does have a slightly larger disabled
population, though the difference is minimal. There is no area of the City with an extreme
concentration of persons with disabilities. A larger or more concentrated disabled population
0
500
1,000
1,500
2,000
2,500
Hearing
Difficulty
Vision
Difficulty
Cognitive
Difficulty
Ambulatory
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Self Care
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Independent
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DifficultyPopulation by AgeDisability Type
<18 years old 18-64 years old ≥65 years old
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may indicate a greater need for access to health care. However, health care facilities are also
more concentrated in these areas to the east. The west tracts have more open space and
agriculture, so the population as a whole is generally more concentrated in the east, which
may skew data perception.
Figure 20 also shows pending and proposed RHNA sites in the context of persons with a
disability. As shown in Figure 21, the RHNA sites are relatively evenly distributed between areas
with higher and lower concentrations of the disabled population. For example, 51.5 percent of
the RHNA units are located in the area where 0-10% of the population has a disability. As such,
the sites are not expected to cause fair housing concerns as they relate to residents with a
disability.
Figure 20: Population with a Disability, 2010-2014 and 2015-2019
Source: HCD AFFH Data Viewer
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Figure 21: Population with a Disability Comparison of RHNA Units
Findings
Overall, the City of Gilroy has higher concentrations of non-White and low- to moderate-
income residents in the east of the City. This area saw a reduction in households under the
federal poverty level over time from 30-40% in 2010-2014 to under 20% and under 10% in
2015-2019. This area is also where housing choice voucher use primarily occurs. Many of the
pending and proposed RHNA sites are located in this area, which includes the Downtown
Specific Plan and the upcoming high speed rail station.
The City is including programs to encourage redevelopment of sites downtown. The selected
RHNA sites are not anticipated to cause displacement or worsen patterns of segregation.
These programs include an Inclusionary Housing Policy (Program A - 10), multi-lingual tenant
outreach in partnership with Project Sentinel (Program F - 1), a Displacement Prevention
Ordinance (Program F - 5), and Place-Based Improvements in this area (Program F - 3).
The City is also including programs to encourage development opportunities in the western
portion of the City, including an ADU Tracking and Monitoring (Program A - 6), adoption of an
Inclusionary Housing Policy (Program A - 10), and allowing duplexes, triplexes, and fourplexes
meeting objective design standards to be approved ministerially in certain zones (Program
A - 9). Much of the western portions of the Gilroy was developed relatively recently, leaving few
0%
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20%
30%
40%
50%
60%
70%
0-10% 10-20%Percent of RHNA UnitsPercent of the Population with a Disability by Tract
Lower Moderate Above Moderate Mixed
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vacant or underdeveloped sites that meet the size requirements for lower-income units, or
which would likely be redeveloped during the 2023-2031 eight-year planning cycle.
Racially and Ethnically Concentrated Areas of Poverty and Affluence
R/ECAPs
HUD defines Racially and Ethnically Concentrated Areas of Poverty (R/ECAP) as areas where
the percentage of the population that is non-White is over 50 percent and the percentage of
households with incomes below the poverty line is over 40 percent. Alternatively, a
neighborhood can be a R/ECAP if it has a poverty rate that exceeds 40 percent or is three or
more times the average tract poverty rate for the metropolitan/micropolitan area, whichever
threshold is lower.
Gilroy has a R/ECAP in Census Tracts 5126.03 and 5126.04. The tracts are shown in Figure 22
along with the proposed RHNA sites by their income levels. The tracts include the Downtown
Specific Plan area and the future high speed rail station, which will increase access to transit
options and employment centers for potential residents. Existing and proposed transit bring
the opportunity for transit-oriented development to the R/ECAP area. The downtown area has
excellent proximity to commercial and employment resources and opportunities. Additionally,
placing new housing sites in this area allows lower-income residents to stay in their
neighborhood and take advantage of new, high quality housing with new amenities. The
location of RHNA sites in the R/ECAP will not exacerbate or create any additional R/ECAPs.
Figure 23 compares the percent of RHNA sites within the R/ECAP area by their income levels.
The downtown area consists of the older portions of the city with smaller lots and higher
density, while newer areas of Gilroy have developed with low-density single family
communities. Newer large homes are often more expensive than older small homes in the
downtown areas, which correlates with higher income households in these newer areas.
Twenty-five percent (25%) of pending projects and potential RHNA sites are proposed in the
R/ECAP, which represents 10 percent of acreage in Gilroy. This area is also designated for
higher density housing options in a smart growth pattern with access to transit, employment,
and service uses and facilities. Furthermore, planning for more affordable units in this area
will help minimize displacement of existing residents when older properties are redeveloped.
As a part of the 2040 General Plan update, the City adopted an Environmental Justice Element
focused on the eastern portion of the City, including the R/ECAP. The Environmental Justice
Element includes programs to improve the quality of life in the R/ECAP.
The two census tracts that make up the R/ECAP are also qualified Opportunity Zones as
designated by the Tax Cuts and Jobs Act of 2017. Opportunity Zones are designated census
tracts where new investments may be eligible for preferential tax treatment. The Opportunity
Zones designator helps spur economic investment by providing tax incentives that defer or
eliminate federal taxes through a temporary deferral, step-up in basis, or permanent
exclusion. These census tracts are also qualified census tracts in the New Market Tax Credit
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program, which incentivizes community development and economic growth through the use
of tax credits.
The City is including multiple programs to ensure that the sites in the R/ECAP improve
conditions rather than exacerbate existing conditions. These include Place-Based
Improvements (Program F - 3), Displacement Prevention Ordinance (Program F - 5), increased
outreach in downtown Areas (Program G - 4), and fair housing support through partnerships
with Project Sentinel (Programs F - 1 and F - 2).
Recent place-based improvements include the $3.9 million grant through the California
Department of Transportation’s Clean California Local Grant Program for the Historic
Downtown in Gilroy. Improvements anticipated from the grant include:
Gourmet Alley between 4th and 7th: pedestrian and bicycle-friendly markings, new
signage, new benches, new trees, repaving of alley in decorative stamped asphalt,
new trash enclosures and trash receptacles, additional lighting.
Railroad Street between 4th and 7th: pedestrian and bicycle-friendly markings, new
trash receptacles for pedestrians, new signage, additional lighting, new benches,
new fencing
Clean Up and Media Campaign: cleanup days for alleys, anti-littering campaign.
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Figure 22: R/ECAPs in the City and Vicinity
Source: HCD AFFH Data Viewer
As shown in Figure 22 and Figure 23, the majority of the RHNA sites are located in non-R/ECAP
areas. The City is including multiple programs to ensure that the sites that are included in the
R/ECAP improve conditions rather than exacerbate existing conditions.
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Figure 23: RHNA Sites by R/ECAP
Racially Concentrated Areas of Affluence
HUD defines Racially Concentrated Areas of Affluence (RCAAs) as areas where the percentage
of the population in a tract that is White is over 1.25 times the average percentage of the
population that is White in the given COG region and median income is 1.5 times higher than
the COG or State AMI, whichever is lower.
The City of Gilroy has an RCAA area along the west portions of the City. The west tracts have
more open space and agriculture, so the population as a whole is generally more concentrated
in the east, which may skew data perception. Additionally, the included tracts have the majority
of their acreage outside of the City of Gilroy, making it likely that the small portions of the tracts
in the City are not responsible for this overall designation. Newer single family development
primarily occurs in these areas. The City is including an ADU Tracking and Monitoring (Program
A - 6), to encourage ADU development in the western portion of the City to promote housing
mobility and increased housing opportunities.
0%
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30%
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50%
60%
70%
Not a R/ECAP R/ECAPPercent of RHNA UnitsPresence of a R/ECAP by Tract
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Figure 24: RCAAs Vicinity and RHNA Sites
Source: HCD AFFH Data Viewer
Disparities in Access to Opportunities
California Tax Credit Allocation Committee (TCAC)
One tool that can be used to analyze disparities in access to opportunities is the California Tax
Credit Allocation Committee’s (TCAC) Opportunity Area scores. These were prepared by a task
force commissioned by TCAC and HCD to identify areas statewide whose economic,
educational, and environmental characteristics support positive outcomes for low-income
families. The map is updated annually. Opportunity maps are made for three domains:
economic, environmental, and education. Each map uses categorical indicators to determine
its individual score. A composite score and resource designation combining all three
designations is then assigned to each block group.
To determine the final resource category, the top 20 percent of overall scores in a county are
labeled as highest resource and the next 20 percent of scores are labeled as high resource.
Then, any area that is considered segregated and that has at least 30 percent of the population
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living below the federal poverty line is labeled as an area of High Segregation and Poverty. Any
remaining uncategorized areas in the County are evenly divided between moderate resource
and low resource areas. The rationale and metric for each indicator is described in more detail
in current guidance documents for the California TCAC program18. Additional information
regarding these indicators in Gilroy are provided on the following pages.
Economic Indicators
Economic indicators include poverty, adult education, employment, job proximity, and median
home value. The scores for Gilroy are shown in Figure 25. Gilroy has more positive economic
scores in the west, and less positive scores in the east of the City. The less positive scoring area
includes the R/ECAP, while the more positive scoring area contains single-family homes. The
more positive scoring area also has some open space, which may slightly skew results. The
City is located far away from major job regional job centers. For this reason, the City also trends
lower in score when compared to the region as a whole.
18 https://www.treasurer.ca.gov/ctcac/opportunity/2022/2022-hcd-methodology.pdf
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Figure 25: TCAC Economic Score, 2021
Source: HCD AFFH Data Viewer
Education Indicators
Education indicators include math and reading proficiencies of fourth graders, high school
graduation rates, and the student poverty rate. The entirety of Gilroy is served by the Gilroy
Unified School District, which includes 11 elementary schools, 6 middle schools, and 6 high
schools. According to Great Schools, 31 percent of schools in the district are rated below
average, 44 percent are rated average, and 25 percent are rated above average.19
Gilroy Unified School District has a Migrant Education Program which aims to ensure that all
migrant students experience a high-quality education. This program include actions to ensure
migrant children who move among the States are not penalized by disparities among the
States in curriculum, help students overcome language barriers, and more.20
19 Great Schools, Gilroy Unified School District Summary. https://www.greatschools.org/california/gilroy/gilroy-unified-school-
district/#summary_rating
20 Migrant Education Program https://www.gilroyunified.org/departments/educational-services/migrant-education
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As shown in Figure 26, most of the City has below average education scores, with the
northmost areas being slightly above average. Additionally, the above average poverty rates
in the City have a negative effect on TCAC educational scores, as poverty rates are included in
this calculation.
Figure 26: TCAC Education Score
Source: HCD AFFH Data Viewer
Environmental Indicators
The environmental domain utilizes CalEnviroScreen (CES) 3.0 pollution indicators and values
(see below for more discussion on CES). As shown in Figure 27, the scores vary throughout the
City, with environmental outcomes becoming less positive as the tracts move eastward. The
tracts bisected by the 101 Highway have lower outcomes, potentially due to pollution from
freeway proximity. Pesticides, hazardous waste, solid waste, and impaired water are the
highest scoring pollutants in the area, which may be contributions from the large agriculture
industry in the City.
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Figure 27: TCAC Environmental Score
Source: HCD AFFH Data Viewer
TCAC Composite Score
Figure 28 displays the 2022 TCAC composite score for the City. The vast majority of the City is
in the moderate or low resource area. A corner of the City is a part of a large census tract that
is high resource. The portions of this tract in the City contain mostly hillside open space and
the Gilroy Gardens Family Theme Park, along with two single-family neighborhoods. A large
portion of the population in the census tract lives outside of the City. The City is focusing
growth as infill within the downtown area, which has access to regional transit, employment
opportunities, and social resources. As such, the majority of RHNA sites are located in the east
area of the City, which is currently considered a low resource area. However, through the 2040
General Plan and the Downtown Specific Plan, the City is focusing growth and economic
development to revitalize the downtown area, which will include the future construction of a
high speed rail station. Investments in the area are expected to increase access to opportunity
and increase resources in the low resource area of the City. The City is also including programs
to encourage development in moderate resource area of the City. Many of the pending
projects, including the low- and moderate-income programs, are located in the moderate
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resource areas of the City. Programs include targeted ADU outreach to the single-family
neighborhoods (Program A - 6), and ministerial approval of duplexes, triplexes, and fourplexes
in R2 areas of the City (Program A - 9). The City is also adopting an inclusionary housing
ordinance (Program A - 10). Furthermore, the City is including a program to develop density
bonuses beyond state law (Program A - 11).
Figure 28: TCAC Composite Score and RHNA Sites
Source: HCD AFFH Data Viewer
As shown in Figure 29, the majority of RHNA sites in the City are in low or moderate resource
areas, including a large majority of above moderate pending projects. The area of the City with
the highest resource category is about half open space. As the majority of the City is moderate
resource, distributing RHNA Sites of a variety of income in areas of these categories is unlikely
to exacerbate any conditions or make any negative changes to the resource designation. Just
over 30 percent of the City is low resource, and 20 percent of RHNA sites are located in the low
resource area.
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Figure 29: TCAC Designation Comparison of RHNA Units
Access to Opportunities, Regional Comparisons
HUD has developed a series of indices for fair housing analysis to assist cities in identifying
disparities in access to opportunity. The following indicators are scored on a scale from zero
to 10021.
Low Poverty Index: The low poverty index captures poverty at the census tract level.
The higher the score, the less exposure to poverty.
School Proficiency Index: The school proficiency index uses the performance of
fourth-grade students on state exams to describe which areas have higher and
lower performing schools. The higher the score, the higher the school system
quality.
Labor Market Index: The labor market index measures the relative intensity of labor
market engagement and human capital. The index is calculated using employment
levels, labor force participation, and education attainment. The higher the score,
the higher the labor market participation in a neighborhood.
21 HUD Affirmatively Furthering Fair Housing Data and Mapping Tool (AFFH-T) Data Documentation
0%
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40%
50%
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Low Resource Moderate Resource High ResourcePercent of RHNA UnitsTCAC Composite Category by Census Tract
Lower Moderate Above Moderate Mixed
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Transit Index: The transit index is based on estimates of transit trips taken by a
three-person, single-parent family with income at 50 percent of the median income
for renters for the region. The higher the index, the more likely that the residents
use public transit.
Low Transportation Cost Index: The low transportation cost index is calculated
based on estimates for a three-person, single-parent family with income at 50
percent of the median income for renters for the region. More specifically, this
index considers transportation costs as a percent of income for this household
type. The higher the index, the lower the cost of transportation.
Jobs Proximity Index: The jobs proximity index quantifies the accessibility of a given
residential neighborhood as a function of its distance to all job locations within a
region. Larger employment centers are more heavily weighted. The higher the
index, the better access to employment opportunities.
Environmental Health Index: The environmental health index summarizes potential
exposure to a variety of toxins that are harmful to human health. The higher the
index, the less exposure to toxins.
The most variation between different ethnicities is seen in the low poverty index, with the
Hispanic population at 41.0 while the Asian and White populations score 60.1 and 57.7
respectively. The labor market index also shows variation, with the Hispanic population at 43,7,
while the Asian population scores 49.0.
Compared to the wider Santa Clara County region as a whole, Gilroy scores lower in all index
categories for all groups, indicating the City may have less access to resources when compared
to the County as a whole. This means that Gilroy generally has more exposure to poverty and
lower performing elementary school students. Gilroy scores are about the same as the region’s
scores in the low transportation cost index. Gilroy also has a lower score in the environmental
health index, indicating higher exposure to toxins than the region. Additionally, scores in job
proximity are much lower than in the region, which is likely due to the City’s distance from tech
industry jobs in the region; the City is located in the southern portion of the County.
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Table 44: Opportunity Indicators22
Low Poverty Index School Proficiency Index Labor Market Index Transit Index Low Transportation Cost Index Jobs Proximity Index Environmental Health Index Gilroy
White 57.7 59.5 57.8 55.4 88.6 16.4 39.1
Black 54.1 62.5 54.8 55.1 88.8 16.9 39.1
Hispanic 41.0 58.4 43.7 55.3 90.8 21.1 38.9
Asian 60.1 62.4 59.0 55.3 88.3 15.8 39.0
Native American 45.1 59.4 46.8 54.9 90.4 20.9 39.0
Santa Clara County
White 81.1 81.9 82.2 68.1 91.2 52.8 58.8
Black 72.9 74.1 74.2 73.4 93.1 57.1 53.5
Hispanic 65.3 58.9 61.9 64.5 91.3 43.2 54.6
Asian 82.0 85.3 83.3 71.4 91.4 51.7 61.6
Native American 70.9 69.4 68.4 67.2 91.8 50.6 56.7
Source: Decennial Census; American Community Survey; Great Schools; Common Core of Data; School Attendance Boundary
Information System; Local Affordability Index; Longitudinal Employer Household Dynamics; National Air Toxics Assessment
Transportation
Access to adequate transportation and a variety of transit options can help illustrate disparities
in access to opportunities. The Valley Transit Authority (VTA) serves Santa Clara County, and
there is also a commercial shuttle service available from the San Francisco and San Jose
airports. Both public transportation and Highway 101 provide access from Gilroy to north
Santa Clara County. The City is the southernmost stop on the Caltrain which operates
commute service to the Santa Clara Valley, San Francisco Peninsula and San Francisco.
Amtrak’s Capitol Corridor line runs a thruway line from San Jose to Santa Barbara with a stop
in Gilroy. The Monterey-Salinas Transit Line 55 stops in Gilroy and provides rush hour service
between San Jose and Monterey. The San Benito County Express provides intercounty bus
service from Gilroy to Hollister and San Juan Bautista.
Transit routes in Gilroy are shown in Figure 30. The VTA provides service to Gavilan College
with bus lines along Luchessa Avenue and Santa Theresa Boulevard. The City also has a full
network of bike lanes which connect all elementary, middle, and high schools in the area.
22 HUD Affirmatively Furthering Fair Housing. https://egis.hud.gov/affht/
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A new high speed rail station is proposed in downtown Gilroy at the existing Caltrain station
on Monterey Street between 7th and 9th Streets. This station will be a transit hub for Southern
Santa Clara County and provide additional transit access for the community. Many RHNA sites
have been chosen specifically for their proximity to existing and proposed transit.
The City will work with California High Speed Rail to develop a station area plan for the
proposed station through Program A - 12. The existing transit and proposed high speed rail
bring the opportunity to create transit-oriented development in the downtown area.
Figure 30: Transit Route Map
Source: Valley Transportation Authority, 2022
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CalEnviroScreen 4.0
CES 4.0 is a tool that identifies communities in California that are disproportionately burdened
by pollutants. Factors used to identify communities include ozone, particulate matter, drinking
water contaminants, pesticide use, lead, diesel particulates, asthma rates, and linguistic
isolation. A higher score indicates a higher effect of pollutants for the area.
The CES scores for the City of Gilroy in Figure 31 show that highest scores occur in the eastern
half of the City, where the R/ECAP is located. CES scores are lower in the west. The areas
bisected by the 101 Highway have less positive outcomes, potentially due to pollution from
freeway proximity. Pesticides, hazardous waste, solid waste, and impaired water are the
highest scoring pollutants in the area, which may be attributed to both permitted and
unpermitted contributions from the large agriculture industry in the City. The lower density
western portion of Gilroy contains steeply sloped areas and low-density development, and
large open areas that significantly limit development, contributing to higher CES scores.
Figure 31: CES Percentile and RHNA Sites
Source: HCD AFFH Data Viewer.
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As shown in Figure 32, sites are distributed throughout both the lower and higher scoring
areas of the City. For example, 40.2 percent of RHNA units are located in a tract in the 20-30th
CalEnviroScreen Percentile. Although the Downtown Specific Plan area contains the highest
CES scores in the City, RHNA sites in this area will provide potential residents with access to
transit and employment resources, including a new future high speed rail station.
Figure 32: CalEnviroScreen Percentile Comparison of RHNA Units
Findings
Overall, the City of Gilroy is largely of lower and moderate resource. The City has lower scores
in opportunity metrics, compared to the County as a whole. As such, many of the RHNA sites
are located in a low-resource area (see Figure 28), which includes the Downtown Specific Plan
area. The low resource area is also where housing choice voucher use primarily occurs. While
pending projects are more evenly distributed throughout the City, proposed RHNA sites in the
downtown area will provide potential residents the best access to services, employment
resources, and transit including the future high speed rail station.
The City is including Program F - 3 to ensure that the RHNA site selection will improve access
to resources in lower-resource areas. This includes place-based improvements such as the
$3.9 million grant in the historic downtown, a displacement prevention program, tenant
0%
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25%
30%
35%
10-20% 20-30% 30-40% 50-60% 70-80% 90-100%Percent of RHNA UnitsCalEnviroScreen Percentile by Tract
Lower Moderate Above Moderate Mixed
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mediation program, and targeted funding such as CDBG and the Permanent Housing
Allocation (PLHA) Fund.
Additionally, other programs in the Housing Element are intended to spur housing
development in the moderate- and high-resource areas of the City. This includes a program
that geographically targets ADU education (Program G - 3), development of an inclusionary
housing policy (Program A - 10), development of a density bonus program that goes beyond
state law (Program A - 11), and ministerial approval of duplexes, triplexes, and quadplexes that
meet objective design standards (Program A - 9).
Disproportionate Housing Needs
Substandard Housing
Disproportionate housing needs are determined by finding trends in housing problems in the
population by race, household size, or household age. A housing unit is considered
substandard or having a housing problem if it has one or more of the following housing
conditions:
Housing unit lacks complete kitchen facilities
Housing unit lacks complete plumbing facilities
Housing unit is overcrowded
Household is cost burdened
A large household is a household with three or more children, but it is also often calculated as
a household with five or more people. An elderly household is calculated as any household
with a person over 62 years of age. Large and elderly households are often more likely to
experience housing problems.
Black and Native American renters experience housing problems at the highest rate, around
75 percent, while only about 25 percent of both Asian and White owners experience housing
problems. Rates of housing problems for the Hispanic population is relatively comparable
between the City and the County, with 29.8 and 33.9 percent of Hispanic owners in the City
and County respectively, and 58.8 and 55.6 of Hispanic renters in the City and County
respectively experiencing housing problems. In 2018, there was no Pacific Islander population
in the City, which indicates why Figure 33 reads that 0 percent of that population experiences
housing problems.
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Figure 33: Housing Problems by Tenure and Race/Elderly/Housing Size
Source: HUD CHAS Data, 2018
Cost burden is when a household spends more than 30 percent of its monthly income on
housing costs like rent, mortgage, or utilities. Large households have more costs to support
more people and may experience cost burden or a lack of excess of funds to amend housing
problems. Elderly households may be on a fixed income, which affects excess funds necessary
for maintenance in an older home bought before retirement.
Figure 34: Cost Burden by Tenure and Race/Elderly/Housing Size
Source: HUD CHAS Data, 2018
Overpayment by both owners and renters has decreased in Gilroy over time in most areas of
the City. The area with the highest levels of overpayment is the same area that has low
environmental scores and higher levels of poverty. Overpayment in the City occurs at a similar,
though slightly higher level than within the County, with 38 percent of households
0%
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40%
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70%
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90%
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White Black Asian Nat Am Pac
Islander
Hispanic Elderly Large All
Owner-Occupied Renter-Occupied Santa Clara County
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30%
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50%
60%
70%
80%
90%
100%
White Black Asian Nat Am Pac
Islander
Hispanic Elderly Large All
Owner-Occupied Renter-Occupied Santa Clara County
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experiencing a cost burden citywide, compared to 34.2 percent in the County. In both cases,
renters have higher rates of overpayment than owners.
Figure 35: Overpayment by Owners
Source: HCD AFFH Data Viewer
Figure 36: Overpayment by Renters
Source: HCD AFFH Data Viewer
Overcrowding
A household is considered overcrowded when there is more than one person per room,
including living and dining rooms but excluding bathrooms and kitchens. Overcrowding can
affect public facilities and services, reduce the quality of the physical environment, and create
conditions that contribute to deterioration of the housing stock. Additionally, overcrowding
can indicate that a community does not have an adequate supply of affordable housing and/or
variety of suitable housing units to meet the needs of the community.
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In Gilroy, areas with high concentrations of overcrowding are in areas with high levels of
poverty and low economic opportunity, where the R/ECAP is located. Overcrowding is only
slightly more prevalent in Gilroy, at 9.2 percent, than in the County, at 7.8 percent, as a whole.
Overcrowding is more prevalent for renters than owners both in the City and regionwide.
Figure 37: Overcrowded Households
Source: HCD AFFH Data Viewer
Table 45 summarizes overcrowding in Gilroy by tenure. Approximately 1,482 households,
roughly 9.2 percent of all households in Gilroy, were experiencing overcrowding in 2019. This
included 347 owner-occupied households and 1,135 renter-occupied households. Instances of
overcrowding vary by tenure, with renters experiencing higher levels of overcrowding than
owners.
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Table 45: Overcrowding, 2019
Source: HUD CHAS Data, 2018
Homelessness
Table 46 lists emergency shelters and transitional housing in Gilroy.
The Countywide services and shelter provider, HomeFirst Services, provides cold weather
shelter at the Gilroy National Guard Armory yearly from November through March. The shelter
provides sleeping accommodations, meals, restrooms, and case management support
services. It has a capacity of 110 persons. In 2017, the County of Santa Clara began using the
Arturo Ochoa Migrant Center as an emergency shelter during the cold weather season from
mid-November through the end of March. It houses up to 35 families and has up to 140 beds.
St. Joseph’s Family Center manages the shelter and referral process. EAH Housing is contracted
for day-to-day property management operations and site security.
The Gilroy National Guard Armory and Arturo Ochoa Migrant Center are only open from late
November through March, and typically do not fill to their capacities. According to
conversations with service providers, if the weather is manageable, unhoused individuals
express a strong reluctance to use the service. The service providers stress the need for a
permanent emergency shelter as well as shelter or housing for single adults who do not exhibit
mental illness or substance abuse disorders.
As illustrated in Table 48, the City of Gilroy provides annual funds to homelessness prevention
support and services through the PLHA. Projects funded include:
$55,000 to St. Joseph’s Family Center for Homeless Prevention Services
$35,000 to St. Joseph’s Family Center for the Gilroy Street Team
$40,000 to South County Compassion Center for Outreach for the unhoused
$20,000 to CARAS for the Homeward Bound Program
Jurisdiction Persons per
Room
Owners Renters Total
Overcrowded
Households
% of
Total
Overcrowded
Households
% of
Total
Overcrowded
Households
% of
Total
Gilroy
1.01 to 1.50 285 1.8% 665 4.1% 950 5.9%
>1.50 62 0.4% 470 2.9% 532 3.3%
Total
Overcrowded 347 2.2% 1,135 7.0% 1,482 9.2%
Santa Clara
County
1.01 to 1.50 7,526 1.2% 21,951 3.4% 29,477 4.6%
>1.50 2,340 0.4% 17,983 2.8% 20,323 3.2%
Total
Overcrowded 9,866 1.6% 39,934 6.2% 49,800 7.8%
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Table 46: Homeless Facilities in Gilroy
Facility Name Type of Facility Target Population
Number of
Shelter
Beds
National Guard
Winter Homeless
Shelter
Cold Weather Shelter Individuals and
families 110
Arturo Ochoa
Migrant Center Cold Weather Shelter Individuals and
Families 140
La Isla Pacifica Emergency Shelter/Domestic
Violence
Women and children
(under 12 years old) 14
Sobrato Apartments Transitional/Emergency Shelter Families 225
Sobrato Apartments Permanent Supportive Housing Chronically Homeless 26
Community
Solutions Transitional Shelter Single Individuals 20
St. Joseph’s
Family Center Transitional Shelter Youth (some with
children) 9
Total 544
Source: City of Gilroy, County of Santa Clara.
In 2019, the County of Santa Clara, in conjunction with Applied Survey Research (ASR),
conducted the 2019 Santa Clara County Homeless Count. This study is conducted every two
years in the last 10 days of January. Two strategies were used to collect the data for the 2019
study: a point-in-time count (PITC) and a comprehensive qualitative survey administered to
individuals experiencing homelessness after the completion of the 2019 PITC. The PITC and
shelter census identified 9,706 homeless persons in Santa Clara County. Table 47 summarizes
sheltered and unsheltered homeless persons in Santa Clara County jurisdictions. There were
704 homeless persons surveyed in Gilroy in January 2019, including 359 sheltered and 345
unsheltered persons. Planning for the 2023 Point-in-Time Count began in the middle of 2022.
The PITC will be scheduled during the last two weeks of January 2023.
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Table 47: Regional Point in Time Count, 2019
Homeless Population Sheltered Unsheltered Total
Gilroy 359 345 704
Campbell 0 74 74
Cupertino 0 159 159
Los Altos 0 76 76
Los Altos Hills 0 2 2
Los Gatos 0 16 16
Milpitas 0 125 125
Monte Sereno 0 0 0
Morgan Hill 0 114 114
Mountain View 32 574 606
Palo Alto 14 299 313
San Jose 980 5,117 6,097
Santa Clara 62 264 326
Saratoga 0 10 10
Sunnyvale 147 477 624
Source: Analysis of Impediments/Regional PITC Data
Permanent Local Housing Allocation Fund (PLHA)
The City had historically allocated funding for services related to housing and homelessness
through its Housing Trust Fund (HTF). Recently, the City Council approved the replacement of
the HTF with the Permanent Housing Allocation (PLHA) Fund making more funds available for
public service addressing homeless basic need programs as well as programs that focus on
homelessness prevention. Although the HTF will no longer be made available for public service
programs or rehabilitation purposes it will continue to be used to cover consulting services for
current affordable rental and ownership agreements as well partially funding a staff position
until the money is depleted.
The PLHA Fund spans a five-year period and will make available $1.4 million dollars. The City
is contracting with Santa Clara County’s’ Office of Supportive Housing to administer the
programs under the PLHA Consortium Agreement. Table 48 displays funding approved by the
City Council for FY 22-23 and FY 23-24.
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Table 48: Permanent Local Housing Allocation Funds for FYs 2022-2024
Agency Project Funding
Amount
St. Joseph’s Family Center Homeless Prevention Services $55,000
Project Sentinel Fair Housing $20,000
Project Sentinel Landlord/Tenant Counseling and
Dispute Resolution $20,000
Community Agency for Resources
Advocacy and Services (CARAS) Homeward Bound Program $20,000
The Health Trust Meals on Wheels $27,000
St Joseph’s Family Center Gilroy Street Team $35,000
South County Compassion Center Outreach for the Unhoused $40,000
Silicon Valley Independent Living Center Housing Services Program for Gilroy
Residents with Disabilities $20,000
Source: City of Gilroy, 2021.
Displacement
The Urban Displacement Project at University of California, Berkeley, developed a map of
“sensitive communities” where residents may be particularly vulnerable to displacement in the
event of increased redevelopment and drastic shifts in housing cost. Sensitive communities
are defined based on the following set of criteria:
The share of very low-income residents is above 20 percent.
The tract must also meet two of the following criteria:
o The share of renters is above 40 percent.
o The share of people of color is above 50 percent.
o The share of very low-income households (50 percent AMI or below) that are
severely rent burdened is above the county median.
o They, or areas in close proximity, have been experiencing displacement
pressures. Displacement pressure is defined as:
The percentage change in rent in a selected census tract, divided by
county median rent increases OR
Median rent in a selected census tract, minus median rent for all
surrounding tracts, divided by median rent for all tracts in county
(rent gap).
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Figure 38 shows the areas vulnerable to displacement as identified by the Urban Displacement
Project. The center of the City, including the downtown area in the east, is considered
vulnerable to displacement. Areas north and south of the City show similar risk.
The City is attempting to meet its RHNA without displacing existing residents by identifying
vacant and underutilized sites that do not have existing residential uses. Therefore, the City’s
RHNA strategy is not anticipated to exacerbate risk of displacement. Instead, it is expected to
minimize displacement by providing new housing opportunities for all income levels in areas
with greater risk of displacement. It is counteracting this vulnerability by deliberating planning
more housing in these same areas. Additionally, the City is including a Displacement
Prevention Policy (Program F - 5), adopting an Inclusionary Housing Policy (Program A - 10),
and providing multilingual tenant support to further minimize the risk of displacement in the
City.
Figure 38: Communities Vulnerable to Displacement
Source: HCD AFFH Data Viewer
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Findings
Overall, the City of Gilroy experiences housing problems at a similar or lower rate than the
region as a whole, while rates of cost burden or overpayment are higher. However, the percent
of the population experiencing overpayment is decreasing over time. Overcrowding citywide
occurs at a similar rate regionally, but is more prevalent in the R/ECAP area, potentially
indicating a need for larger units or shared multiplexes in the R/ECAP area.
The City is including Program F - 3, a Place-Based Improvement program, to ensure that the
RHNA site selection will improve access to resources in R/ECAP. Primarily vacant sites were
chosen in the R/ECAP to prevent displacement while allowing residents to find available
housing in their own neighborhood.
Other Contributing Factors
Historic Immigration and Land Use Patterns
Historically, other cities in Santa Clara County had racial covenants, which led to thriving
immigrant communities settling in the City of Gilroy. This first included the Chinese population,
which settled in Gilroy after immigrating to the United States to build railroads and work in
gold mines, tobacco fields, and orchards.23 Since the migrations of the Chinese population to
the central county, the Latino population has been largely responsible for the thriving
businesses in Gilroy. Over 50 percent of Gilroy’s current population is Hispanic.
The original City, incorporated in 1870, began development in what is now considered the
downtown area. As is typical, these older areas and older housing naturally are lower cost than
newer areas and newer housing. These older city centers also tend to have the most
multifamily and rental housing as these were the most efficient land use patterns developed
around the civic, transit service, and employment center. As a result, the older areas naturally
have higher proportions of affordable housing without subsidies and lower-income
households. Similarly, today’s new housing will be more affordable than housing built in 10 or
20 years.
The Christmas Hill Park began construction in 1964.24 Several single family homes were built
in the surrounding neighborhoods in the following years, leading to the highest rates of
population growth in the City’s history in the 1970s and 1980s. Portions of the downtown are
designated as the Downtown Historic District, which is intended to foster the historic
downtown as a unique commercial resource. The newer areas of the City are in the moderate
resource category as the infrastructure and housing is more recently developed. The City
continues to expand to the west with the recent Hecker Pass and Glen Loma Specific Plan
areas.
23 Gilroy Dispatch. https://gilroydispatch.com/immigrants-play-big-part-in-gilroy-history/
24 The Mercury News Gilroy Timeline https://www.mercurynews.com/2007/02/05/gilroy-timeline/
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The City has taken multiple steps to encourage economic revitalization and growth in the older,
downtown areas of the City. The two tracts that are designated as Racially or Ethnically
Concentrated Areas of Poverty (R/ECAP) are classified as an Opportunity Zone by the federal
government and are eligible for a number of tax-based incentives. In 2022, Gilroy was awarded
a 3.9 million dollar grant for improvements in the historic downtown area. In 2020 and 2021
the City operated a Downtown Improvement Incentive Program which included reductions on
development fees and a grant to help fund minor façade improvements for businesses
downtown. The City continues to partner with organizations such as Visit Gilroy, the Gilroy
Downtown Business Association, and the Gilroy Chamber of Commerce to promote economic
development in downtown Gilroy.
The City expanded as the agricultural industry expanded, but in the late twentieth century, the
economy shifted from agriculturally based to an urban service-oriented community.25 This
change in economy contributed to the growth of the City.
Affordability and Location Within Santa Clara County
Another contributing factor that is present throughout the AFFH and needs section analyses is
the relative affordability of Gilroy to other areas in Santa Clara County and the larger Bay Area
region. In 2020, the City of Gilroy had a median income of $107,729, $33,871 (24%) less than
the County AMI, which was $141,600 in 2020. The City also had a lower percentage of the
population that is earning greater than 100% of the AMI at 47 percent, compared to the County
which was at 58 percent during the same period. Additionally, the median home price in Gilroy
in 2020 was significantly lower than Santa Clara County. The median home price in December
2020 was $837,995, which was $452,982 lower than the Santa Clara County median of
$1,290,977 at the same time. As mentioned in the needs section, Gilroy has a significantly
higher percentage of the population that is Hispanic, at 59 percent compared to 25 percent in
the County in 2019.
Gilroy has a higher percentage of workers employed in the construction, agriculture, and
natural resources industries and in comparatively lower-paying industries than Santa Clara
County and the Bay Area region as a whole. Gilroy’s location in the southernmost edge of the
County, further from larger employment centers, helps to explain this trend.
Both public transportation and Highway 101 provide access from Gilroy to north Santa Clara
County. Public transportation that connects Gilroy to surrounding areas include Caltrain which
operates commute service to the Santa Clara Valley, San Francisco Peninsula and San
Francisco, Amtrak’s Capitol Corridor which runs a thruway line from San Jose-Santa Barbara
with a stop in Gilroy, the Monterey-Salinas Transit Line 55 which stops in Gilroy and provides
rush hour service between San Jose and Monterey, and the San Benito County Express which
provides intercounty bus service from Gilroy to Hollister and San Juan Bautista. As Gilroy
continues to grow, it may serve as a more affordable option for people who wish to remain in
the area but may be priced out of other areas in the County. However, most of the City remains
25 A Brief History of Gilroy https://www.cityofgilroy.org/381/History-of-Gilroy
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in the moderate and low resource categories according to TCAC, due to its comparison to the
wealthier balance of the county. The economic and employment trends differ from the
remainder of the County. The shifting of Gilroy from a more agrarian to urbanized area helps
to explain these trends relative to the remainder of Santa Clara County.
The difference between the AMI in the County and median income in the City was noted
frequently by the public during outreach efforts. Participants commented that units that may
be considered “affordable” per the AMI category income limits are not necessarily affordable
to Gilroy residents due to the substantial difference between the City’s median income and the
County AMI ($33,871 in 2020).
Fair Housing Issues, Contributing Factors, and Meaningful Action
The City has adopted goals and actions that specifically address the contributing factors
identified in the AFFH analysis. While the City views all contributing factors as an important
priority to address, higher priority was given to factors that limit fair housing choice and or
negatively impact fair housing, per Government Code section 65583(c)(10)(A)(iv).
Table 49 displays the identified fair housing issue, contributing factor, actions taken to address
the contributing factor, and priority level for each issue. Relevant programs are referenced in
the action column for each contributing factor.
Table 49: Contributing Factors
Identified Fair
Housing Issue Contributing Factor Action Priority
Segregation and
Integration
East/west income segregation
Lack of inclusionary housing
policy
Creation of density bonuses
beyond state law (A - 11)
Adoption of inclusionary
housing policy(A - 10)
Source of income protection /
Housing Mobility (F - 1)
Medium
Disproportionate
Housing Needs
Risk of displacement in
downtown
Lack of missing middle
housing
Lack of affordable housing for
special needs groups (large
households, seniors,
farmworkers)
Place-Based economic
investments in downtown
(F - 3)
ADU education targeting high
resource areas (A - 6)
Fair housing counseling (F - 2)
Develop incentives for
housing for seniors,
farmworkers, and large
families (E - 6)
Displacement prevention
ordinance (F - 5)
Permit streamlining (B - 5)
High
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Identified Fair
Housing Issue Contributing Factor Action Priority
Development and Conservation
of Housing for Farmworkers
(E - 7)
Access to
Opportunities
Presence of a R/ECAP
Lower access to opportunities
than the County as a whole
Lack of missing middle /
middle income housing
Place-Based economic
investments in downtown
(F - 3)
Adoption of inclusionary
housing policy (A - 10)
Administerial approval of
duplexes, triplexes and
quadplexes in qualifying
zones (F - 4)
Targeted outreach in higher
resource areas (F - 4)
Source of income protection /
Housing Mobility (F - 1)
Permit streamlining (B - 5)
Density bonus beyond state
law (A - 11)
High
Outreach and
Enforcement
Capacity
Access to materials in
appropriate languages
Lack of education and
outreach in the R/ECAP area
City staff capacity
Targeted outreach in
moderate and high resource
areas (F - 4)
Community access to
housing information program
(G - 5)
Interagency collaboration for
lower cost housing (G - 1)
Fair housing counseling (F - 2)
Low
Table 50 provides a detailed overview of actions included in Housing Element Programs that
are aimed at affirmatively furthering fair housing. The table separates the actions by their
identified fair housing issue and priority level. It summarizes the specific commitment,
timeline, geographic targeting, and metric for each program.
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Table 50: AFFH Actions Matrix
HE Programs or
Other Activities Specific Commitment Timeline Geographic
Targeting 2023 – 2031 Metric
Integration and Segregation
A-11: Density
Bonus Beyond
State Law
Study and consider
adopting a density
bonus ordinance above
and beyond the
minimum requirements
of state law. Specifically
consider additional
incentives for
households with special
housing needs such as
large households,
extremely low income
households, and
farmworkers.
Within 2 years of
Housing Element
adoption
Citywide Adoption of Zoning
Code amendment;
Increased housing
choice and
mobility for special
needs households.
A-10:
Inclusionary
Housing Policy
Conduct an
inclusionary zoning
feasibility study to
identify appropriate
inclusionary
requirements that will
not constrain housing
production. Develop an
affordable housing
policy and amend the
Zoning Ordinance to
establish inclusionary
housing requirements
so that specified new
developments reserve
a percentage of the
total units for lower-
and moderate-income
households. Require in-
lieu fees for qualifying
projects that do not
construct affordable
housing.
By the end of
2024
Citywide Increased
production of
affordable housing
with new planned
housing
developments;
increased housing
choice and
mobility for lower
income
households.
Prioritize use of in-
lieu fees to
develop affordable
housing options in
higher resources
areas of the City.
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HE Programs or
Other Activities Specific Commitment Timeline Geographic
Targeting 2023 – 2031 Metric
F-1: Source of
Income
Protection
Within one year,
coordinate with Project
Sentinel to conduct a
meeting/workshop to
inform residents of
sources of income
protection and state
rent control laws such
as AB 1482.
Continue to coordinate
outreach efforts to
inform landlords and
tenants of recent
changes to state law
that prevent source of
income discrimination,
including allowance of
housing choice
vouchers (HCVs) to
establish a renter’s
financial eligibility.
Informational
outreach within
one year of
Housing Element
adoption.
Annual
education and
outreach to
landlords and
tenants.
Downtown Outreach to 50
landlords or
tenants annually.
Disproportionate Housing Needs
F-3: Place-
Based
Improvements
Develop programs and
strategies to create
place-based
improvements through
investments in the
public right of way.
Specific actions
include:
The City was
awarded a $3.9
million Clean
California Grant
to renovate and
beautify a
portion of
Gourmet Alley
and Railroad
Street within
the downtown
area with:
pedestrian and
Streetscape and
infrastructure
improvements
will be
completed
pursuant to the
City’s CIP
schedule.
The Clean
California Grant
project must be
completed by
June 30, 2024
Construction of
the parking lot
with community
event space
should be
complete by the
end of 2023.
Downtown Construction of
one parking lot
with a community
event space;
Reconstruction of
20 curb ramps
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HE Programs or
Other Activities Specific Commitment Timeline Geographic
Targeting 2023 – 2031 Metric
bicycle-friendly
markings along
each block;
improvements
to the
stormwater
drainage
system;
additional
landscaping
and lighting;
new benches;
cleanup days
for the alleys;
and an anti-
littering
campaign.
As a part of
downtown
revitalization,
the City is also
constructing a
new downtown
parking lot that
will also serve
as a community
resource for a
Farmers Market
and community
events in the
downtown.
As a part of the
CIP, to support
economic
development in
the downtown,
complete
Automall
Parkway
Pavement
Rehabilitation
including
reconstruction
of 20 curb
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HE Programs or
Other Activities Specific Commitment Timeline Geographic
Targeting 2023 – 2031 Metric
ramps, addition
of Class II bike
lanes, and
repair and
replacement of
deteriorated
curb and gutter
(estimated $2.4
million)
As a part of the
CIP, to support
pedestrian
infrastructure
in the DTSP
area, install and
upgrade ADA
curb ramps in
Downtown
Gilroy
A-6: ADU
Tracking and
Monitoring
Continuously track the
number of building
permits issued for
ADUs. If annual
production rates do not
match the estimates
included in the Sites
Inventory of the
Housing Element,
update the RHNA
strategy to ensure that
the City continues to
maintain adequate
capacity for all income-
levels.
The City will review
geographic
distributions of ADUs
biennially.
Track ADU
permits as they
are submitted.
Review ADU
strategies
annually as part
of the Annual
Progress Report
process.
High
Resource
Areas
Increase the
number of new
ADUs permitted in
the City from an
average of
approximately 17.5
(2018-2021) to an
average of
approximately 25.
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HE Programs or
Other Activities Specific Commitment Timeline Geographic
Targeting 2023 – 2031 Metric
F-2: Fair
Housing
Counseling
The City shall continue
to provide funds to and
contract with a non-
profit agency to provide
fair housing assistance
including
landlord/tenant
counseling.
The City shall
disseminate
information about fair
housing assistance
through pamphlets in
City-owned buildings
and other public
locations (e.g., City Hall,
Library, post office,
other community
facilities) and by
posting information on
the City website.
Pamphlets will be made
available in English and
Spanish.
Annual or
biennial award
of funds.
Provision of
pamphlets
within one year
of Housing
Element
adoption.
Downtown Work with Fair
Housing Provider
to track number of
households
assisted in Gilroy
annual. Provide
information to 30
households
annually.
E-6: Reduced
Parking
Requirements
for Senior
Housing
The City shall conduct a
study to determine if
reduced parking
standards for senior
housing is appropriate
in Gilroy. Based on the
findings of the study,
the City may revise the
Zoning Code, as
necessary, to reduce
parking standards for
senior housing.
Within 3 years of
Housing Element
adoption
Citywide Conduct study and
revise Zoning
Code, as necessary
F-5:
Displacement
Prevention
Policy
Adopt a displacement
prevention policy.
Measures that are
being considered for
inclusion in the policy
are “tenant option to
purchase agreements”
Within three
years of Housing
Element
adoption.
Areas
denoted
above as
having
vulnerability
to
displacement
Adopt the policy
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HE Programs or
Other Activities Specific Commitment Timeline Geographic
Targeting 2023 – 2031 Metric
for redevelopment
projects meeting
specified thresholds, a
just cause eviction
policy, and relocation
agreements.
Pursuant to
Government Code
Sections 65583.2(g)(3)
and 65915(c)(3), ensure
that when existing
housing is demolished,
at least an equivalent
number of units at the
same affordability are
created as
replacements.
B-5: Permit
Streamlining
As a part of the 2023
comprehensive Zoning
Code update, the City is
pursuing changes to
streamline the
permitting process,
including but not
limited to:
Creating a
ministerial use
permit process
Creating a
more
transparent
and
streamlined
process for
reviewing and
approving
applications
involving a
historic
resource.
Concurrent with
the
comprehensive
zoning code
update,
anticipated
completion
Spring 2023.
Citywide Shorter permit
processing time.
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HE Programs or
Other Activities Specific Commitment Timeline Geographic
Targeting 2023 – 2031 Metric
E-7:
Development
and
Conservation of
Housing for
Farmworkers
The City shall continue
to partner with the
Housing Authority of
Santa Clara County and
various non-profit
organizations to
explore and implement
ways of providing
affordable farmworker
housing including
identification of State
and Federal funding
opportunities.
Ongoing
throughout
planning period
Citywide Preserve and
maintain the 4
farmworker
housing
developments (84
units) and Ochoa
Migrant Center
(100 units).
E-5: Incentivize
Micro-Units Revise the zoning code
to establish
development standards
for micro-units, create
incentives for micro-
unit production, and
remove barriers to
micro-units
development.
Ensure that provisions
for efficiency units are
consistent with AB 352
(2017).
Within one year
of Housing
Element
adoption.
Citywide Adopt the policy
Access to Opportunities
F-3: Place-
Based
Improvements
Develop programs and
strategies to create
place-based
improvements through
investments in the
public right of way.
Specific actions
include:
The City was
awarded a $3.9
million Clean
California Grant
to renovate and
beautify a
portion of
Streetscape and
infrastructure
improvements
will be
completed
pursuant to the
City’s CIP
schedule.
The Clean
California Grant
project must be
completed by
June 30, 2024
Construction of
the parking lot
Downtown Construction of
one parking lot
with a community
event space;
Reconstruction of
20 curb ramps
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HE Programs or
Other Activities Specific Commitment Timeline Geographic
Targeting 2023 – 2031 Metric
Gourmet Alley
and Railroad
Street within
the downtown
area with:
pedestrian and
bicycle-friendly
markings along
each block;
improvements
to the
stormwater
drainage
system;
additional
landscaping
and lighting;
new benches;
cleanup days
for the alleys;
and an anti-
littering
campaign.
As a part of
downtown
revitalization,
the City is also
constructing a
new downtown
parking lot that
will also serve
as a community
resource for a
Farmers Market
and community
events in the
downtown.
As a part of the
CIP, to support
economic
development in
the downtown,
complete
Automall
with community
event space
should be
complete by the
end of 2023.
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HE Programs or
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Targeting 2023 – 2031 Metric
Parkway
Pavement
Rehabilitation
including
reconstruction
of 20 curb
ramps, addition
of Class II bike
lanes, and
repair and
replacement of
deteriorated
curb and gutter
(estimated $2.4
million)
As a part of the
CIP, to support
pedestrian
infrastructure
in the DTSP
area, install and
upgrade ADA
curb ramps in
Downtown
Gilroy
A-10:
Inclusionary
Housing Policy
Conduct an
inclusionary zoning
feasibility study to
identify appropriate
inclusionary
requirements that will
not constrain housing
production. Develop an
affordable housing
policy and amend the
Zoning Ordinance to
establish inclusionary
housing requirements
so that specified new
developments reserve
a percentage of the
total units for lower-
and moderate-income
households. Require in-
By the end of
2024
Citywide Amend Zoning
Ordinance;
Increased
production of
affordable housing
with new planned
housing
developments;
increased housing
choice and
mobility for lower
income
households.
Prioritize use of in-
lieu fees to
develop affordable
housing options in
higher resources
areas of the City.
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HE Programs or
Other Activities Specific Commitment Timeline Geographic
Targeting 2023 – 2031 Metric
lieu fees for qualifying
projects that do not
construct affordable
housing.
F-4: Housing
Mobility and
Choice in
Higher
Opportunity
Areas
Improve housing
mobility and choice,
especially in higher
opportunity areas of
the City through the
follow actions:
Allow duplexes,
triplexes, and
quadplexes
that meet
objective design
standards to be
approved
ministerially in
specified areas
of the City
(Program A-9.
Adopt a density
bonus beyond
state law to
include
incentives for
special needs
households
(Program A-11)
Adopt an
inclusionary
housing policy
(Program A-10)
Within 3 years of
Housing Element
adoption.
Higher
Opportunity
Areas
Adopt density
bonus and
inclusionary
housing policies
F-1: Source of
Income
Protection
Within one year,
coordinate with Project
Sentinel to conduct a
meeting/workshop to
inform residents of
sources of income
protection and state
Outreach to 50
landlords or
tenants
annually.
Downtown Conduct workshop
with residents
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HE Programs or
Other Activities Specific Commitment Timeline Geographic
Targeting 2023 – 2031 Metric
rent control laws such
as AB 1482.
Continue to coordinate
outreach efforts to
inform landlords and
tenants of recent
changes to state law
that prevent source of
income discrimination,
including allowance of
housing choice
vouchers (HCVs) to
establish a renter’s
financial eligibility.
B-5: Permit
Streamlining
As a part of the 2023
comprehensive Zoning
Code update, the City is
pursuing changes to
streamline the
permitting process,
including but not
limited to:
Creating a
ministerial use
permit process
Creating a
more
transparent
and
streamlined
process for
reviewing and
approving
applications
involving a
historic
resource.
Concurrent with
the
comprehensive
zoning code
update,
anticipated
completion
Spring 2023.
Citywide Shorter permit
processing time.
A-11: Density
Bonus Beyond
State Law
Study and consider
adopting a density
bonus ordinance above
and beyond the
minimum requirements
of state law. Specifically
Within 2 years of
Housing Element
adoption
Citywide Adoption of Zoning
Code amendment;
Increased housing
choice and
mobility for special
needs households.
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HE Programs or
Other Activities Specific Commitment Timeline Geographic
Targeting 2023 – 2031 Metric
consider additional
incentives for
households with special
housing needs such as
large households,
extremely low income
households, and
farmworkers.
Outreach and Enforcement Capacity
D-1: Permanent
Housing
Allocation
Fund
The City shall continue
to utilize the
Permanent Local
Housing Allocation
(PLHA) Fund for all
eligible activities,
including new
construction,
acquisition,
rehabilitation, home
buyer assistance,
homeless assistance,
public services related
to housing, and
preservation of
affordable housing.
The City also contracts
with Santa Clara
County’s’ Office of
Supportive Housing to
administer the
Permanent Housing
Allocation (PLHA) Fund,
which provided
$237,000 in funding
during the FY 22-23 and
FY 23-24 funding period
for homelessness
prevention services, fair
housing, and basic
needs (e.g., meals on
wheels).
The City shall continue
to inform non-profit
The PLHA funds
span a 5-year
basis. Conduct
outreach and
allocate funding
every two years
Downtown Through various
eligible funding
programs, assist
80 households
annually.
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HE Programs or
Other Activities Specific Commitment Timeline Geographic
Targeting 2023 – 2031 Metric
organizations of
funding availability
through the City’s
website and
informational packets
at City Hall.
F-4: Housing
Mobility and
Choice in
Higher
Opportunity
Areas
Improve housing
mobility and choice,
especially in higher
opportunity areas of
the City through the
follow actions:
Allow duplexes,
triplexes, and
quadplexes
that meet
objective design
standards to be
approved
ministerially in
specified areas
of the City
(Program A-9.
Adopt a density
bonus beyond
state law to
include
incentives for
special needs
households
(Program A-11)
Adopt an
inclusionary
housing policy
(Program A-10)
Within 3 years of
Housing Element
adoption.
Higher
Opportunity
Areas
Adopt density
bonus and
inclusionary
housing policies
D-5:
Community
Development
Block Grant
Program
The City shall continue
to utilize the
Community
Development Block
Grant Program for all
eligible activities,
including acquisition,
rehabilitation, home
Administer
funds annually.
Downtown Increase CDBG
related traffic on
the City’s website;
Distribute 50
informational
packets at City Hall
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HE Programs or
Other Activities Specific Commitment Timeline Geographic
Targeting 2023 – 2031 Metric
buyer assistance,
economic
development, homeless
assistance, public
services, and public
improvements. The City
shall continue to inform
non-profit
organizations of
funding availability
through the City’s
website and
informational packets
at City Hall.
The City expects to
receive an estimated
$440,000 in CDBG
funds from the U.S.
Department of Housing
and Urban
Development (HUD)
each year. The primary
objectives of the CDBG
Program include
activities that benefit
low-income
households, aid in the
prevention of slums or
blight, or meet an
urgent community
need.
G-1:
Collaboration
with
Development
Community
The City shall continue
to cultivate
relationships with for-
profit and non-profit
development
companies working in
the area of affordable
housing, facilitating
collaborative
approaches to
affordable housing
development.
Collaboration
with other
agencies on an
annual basis.
Countywide Host an annual
developer
roundtable
meeting.
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HE Programs or
Other Activities Specific Commitment Timeline Geographic
Targeting 2023 – 2031 Metric
Establish new
relationships and
maintain existing
relationships with for-
profit and non-profit
development
companies throughout
the planning period.
F-2: Fair
Housing
Counseling
The City shall continue
to provide funds to and
contract with a non-
profit agency to provide
fair housing assistance
including
landlord/tenant
counseling.
The City shall
disseminate
information about fair
housing assistance
through pamphlets in
City-owned buildings
and other public
locations (e.g., City Hall,
Library, post office,
other community
facilities) and by
posting information on
the City website.
Pamphlets will be made
available in English and
Spanish.
Annual or
biennial award
of funds.
Provision of
pamphlets
within one year
of Housing
Element
adoption.
Downtown Work with Fair
Housing Provider
to track number of
households
assisted in Gilroy
annual. Provide
information to 30
households
annually.
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135
CITY OF GILROY
HOUSING ELEMENT
6TH CYCLE
CONSTRAINTS ON HOUSING
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Constraints on Housing
There are a wide variety of factors that influence whether, where, when, how, and what type
of housing is constructed. While many factors enable, guide and even incentivize housing
construction, almost all also pose some sort of limitation or constraint as well. Our land use
policies and regulations are necessary but, by definition, establish limits on growth and
development. These limits work with, influence and are balanced by market forces.
There are generally two types of constraints: governmental and non-governmental.
Governmental constraints include the policies, regulations and procedures that directly affect
housing. This includes the goals, policies and programs of the General Plan and the
development standards and requirements of the zoning code and other land use ordinances.
Non-governmental constraints include those factors that are beyond the direct control and
authority of the City.
This section identifies and evaluates those factors that may pose significant constraints or
burdens that may limit or constrain the production of housing to meet our local and regional
housing needs and the goals and objectives of the General Plan. Such constraints, particularly
those that limit the construction of or fair access to affordable housing must be addressed
with clear, measurable and timely programs.
Governmental Constraints
Governmental constraints can limit or deter the operations of the public, private, and nonprofit
housing development sectors, make it difficult to meet the demand for housing, and limit
housing supply in a region. Such constraints can limit access to housing mobility and housing
choice, or prevent lower-income segments of the population from having adequate housing
opportunities. Governmental constraints may include, but are not limited to, land use controls,
development standards, local processing and procedures, and permitting fees.
Land Use Controls
General Plan
The City of Gilroy adopted an updated General Plan in November 2020. The Gilroy 2040
General Plan is a comprehensive, long-range general policy document that expresses the
community’s vision and establishes eight guiding principles for development. One of the
guiding principles includes encouraging a mix of housing types to create diverse
neighborhoods to meet the needs of all residents. Among other efforts, the Gilroy 2040
General Plan allows for an increase in housing by creating a new Mixed-Use land use
designation and removing the maximum density specified for the High-Density Residential
land use area. The Land Use Element of the General Plan identifies the location, distribution,
density, and intensity of land use within the City. The Environmental Impact Report (EIR) for
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the 2040 General Plan analyzed the development potential of the plan for up to 6,477 new
housing units and an additional population of 19,756.26
Figure 39: Gilroy Land Use Map
There are seven residential land use designations in the Gilroy General Plan, as follows:
Hillside Residential (HR): This designation is generally applied to developable hillside
areas with slopes of 10 percent to 30 percent. Developments in these areas must
follow special design and siting criteria to preserve the sensitive hillside
environment together with the views and vistas of surrounding hillsides, hilltops,
and ridgelines. The permitted density is 0 to 4 dwelling units per net acre (du/ac).
The implementing zone is the RH district.
Low Density Residential (LDR): This is the most common residential land use
designation in Gilroy. It is applied to areas of predominantly single-family detached
dwellings, with typical lot sizes ranging from 5,000 square feet to 7,000 square feet.
Appropriate residential uses include single-family detached homes and secondary
(“accessory”) dwelling units that comply with City standards. The permitted density
is 3–8 du/ac. The implementing zones are R1 and R2.
26Final Gilroy 2040 General Plan EIR. http://www.gilroy2040.com/wp-content/uploads/2020/09/Gilroy-2040-General-Plan_Final-
EIR.pdf
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Medium Density Residential (MDR): This designation is intended primarily for
multifamily attached structures (townhomes, condominiums, and apartment
buildings). Buildings are typically two to three stories tall. This designation is
typically applied to transition areas between lower-density neighborhoods and
higher-density developments or commercial areas. The permitted density is 8–20
du/ac. The implementing zone is R3. While the R3 zone currently only allows 8–16
du/ac, it will be updated in the comprehensive zoning update to allow for 8–20
du/ac (Program B - 2).
High Density Residential (HDR): This designation allows higher density attached
housing types (apartments and condominiums), often within walking distance of
commercial areas. The predominant housing type is multifamily dwellings, such as
apartments or condominiums, with buildings typically comprising two or more
stories. The permitted density is 20+ du/ac, with no maximum density or floor area
ratio (FAR) requirements. The implementing zone is R4. The R4 zone currently
allows for 20–30 du/ac, and the upper limit will be removed in the ongoing
comprehensive zoning code update to ensure consistency with the General Plan,
see Program B - 2.
Mixed Use (MU): The purpose of this designation is to encourage a mix of retail,
office, and high-density residential uses. Street-level frontage of mixed-use projects
shall be developed with pedestrian-oriented, typically commercial, uses. Residential
uses can be integrated on the same site with other uses in either a vertical or
horizontal design. The permitted density is a minimum of 20 and a maximum of 30
du/ac. The implementing zones are within the Downtown Specific Plan area and the
mixed-use corridor along 1st Street. As a part of its comprehensive code update, the
City is in the process of creating a zoning district for the mixed-use 1st street corridor
with the anticipated completion of Spring 2023 (Program B - 2). Any mixed-use
development within the 1st Street mixed-use corridor will be entitled in accordance
with the development standards set forth in the Zoning Ordinance and the density
allowance per the 2040 General Plan. The design of projects will be subject to the
City’s existing objective development design standards until the 1st Street Corridor
mixed-use design and development standards are adopted.
Rural County (RC): The purpose of this designation is to preserve rural residential,
hillside, and productive agriculture land uses located outside areas planned for
urban development. Allowed uses include rural residential, grazing, active
agricultural production, associated agricultural processing, sales, and support uses.
Typical building types include low-intensity structures associated with farming and
agricultural processing and sales. One single dwelling unit per parcel is allowed. The
implementing zone is RR.
Neighborhood District (ND High, ND Low): The purpose of these designations is to
encourage compact, complete, neighborhood-style development. Traditional
single-family uses will comprise a substantial portion of these districts. Commercial
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and medium- to high-density residential uses should be clustered to form
neighborhood centers. Neighborhood District High and Low may use a
Neighborhood Commercial (NC) designation to designate land in neighborhood
centers to encourage low-intensity commercial uses that cater directly to residents
in the immediate neighborhood. The 0–7 du/ac category is intended for single-
family detached dwellings with varying lot sizes. The 7–9 du/ac category is intended
for a combination of two-family and some single-family detached dwellings. The 9–
16 du/ac category is intended to accommodate a combination of small-lot and
attached single-family dwellings, as well as multifamily dwelling options. The 16–30
du/ac category is intended to provide a variety of attached single-family and
multifamily residential styles of development. The implementing zone is ND.
o The ND land use designation is generally applied to vacant land that is currently
outside the City’s Urban Service Area but within the City’s Urban Growth
Boundary (UGB) area. The UGB area applies to land within the Planning
Boundary/Sphere-of-Influence that is intended for urbanization at some point
in the future. There are two designated neighborhood districts, one in the north
and one in the south, that are currently outside of the Urban Service Area. The
City is in the process of requesting approval from the Santa Clara County Local
Agency Formation Commission (LAFCO) to bring approximately 54 acres of
unincorporated county land into the City’s Urban Service Area (USA). The land is
located just outside City limits to the north. If the USA is amended and the land
is eventually annexed into the City (a lengthy two-step process), the property
would be subject to the City’s inclusionary policies for the Neighborhood
District.
o Each Neighborhood District (ND) development is required to construct a
minimum of fifteen percent (15%) of its units at affordable prices. Specific
requirements regarding the level of affordability were contained in the City’s
Residential Development Ordinance (RDO) policy. However, this policy is no
longer in effect due to state legislation (e.g., SB330). To ensure compliance with
State law, and provide more comprehensive affordability benchmarks, Program
A - 5 is included to review and revise the Neighborhood District Policy. Another
program will include analyzing potential adoption of an Inclusionary Housing
Policy that could apply to properties outside the Neighborhood District planning
area.
o Table 51 displays the target densities for both low and high Neighborhood
District designations. Neighborhood Districts include the Hecker Pass Specific
Plan area and the Glen Loma Ranch Specific Plan area. The rows denote the
maximum or minimum percentages of the land area within this land use
designation that must fall within the specified density.
o Neighborhood District target densities and inclusionary requirements may act
as a potential constraint to housing; however, the City has found that they do
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not discourage development. Development of two Neighborhood Districts, the
Hecker Pass Specific Plan area and Glen Loma Ranch Specific Plan area, is
currently underway. As a part of Program A - 5, the City is revising Neighborhood
District standards to no longer rely on the RDO and is updating the ND’s
inclusionary housing policy.
Table 51: Neighborhood District Target Densities
0-7 du/ac 7-9 du/ac 9-16 du/ac 16-30 du/ac
Low 82% max. 5% min. 10% min. 3% min.
High 60% max. 5% min. 25% min. 10% min.
Source: City of Gilroy 2040 General Plan.
Hecker Pass Specific Plan
The Hecker Pass Specific Plan projects the development of 521 housing units. The Specific Plan
designates three “clusters” for residential development: North Cluster (57 units), West Cluster
(205 units), and East Cluster (259 units). The Specific Plan aims to provide for a variety of
housing types in each cluster, but offers some flexibility in how that variety is achieved. The
Specific Plan gradually transitions the intensity of development from the Village Green project
into the Specific Plan area, with more intensive development on the eastern side of the plan
as it moves from rural to urban. The Hecker Pass Specific Plan was approved before
inclusionary housing policies were adopted, and thus was not subject to the inclusionary
housing requirement.
Glen Loma Ranch Specific Plan
The Glen Loma Ranch Specific Plan area is approximately 392 acres located between Santa
Teresa Boulevard and the Uvas Creek corridor. The project includes a maximum of
approximately 1,693 residential units in up to 17 neighborhoods comprising detached single-
family residences, attached townhomes, apartments, and senior-only units. Under the
Neighborhood District policy, 15.1 percent of units will be affordable to very low-, low-, and
moderate-income households.
Downtown Specific Plan
The Downtown Specific Plan contains six districts with the purpose of creating a pedestrian-
oriented and economically vibrant downtown. Adopted in 2005, the Downtown Specific Plan
anticipated potential for development of 1,576 new residential units over 20 years. Mixed uses
and residential development above the ground floor are encouraged in the Downtown Specific
Plan.
Residential dwelling units are permitted by right in all Downtown Specific Plan districts. In the
Downtown Historic District and the Downtown Expansion District, residential units are
permitted by right on the second story or above. A conditional use permit is required for
residential uses on the first floor. In the Civic/Cultural Arts District, residential units may be
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allowed on the ground floor if they are located between Eigleberry Street and Church Street
and behind a business.
Table 52 displays the FAR and density requirements in each of the Downtown Specific Plan
districts. The FARs only apply to the commercial uses within a mixed-use development. The
residential densities allow for high density, with a minimum 20 units an acre and no maximum
density in some cases, as illustrated below. The districts also generally have very permissive
development standards, including zero-foot minimum setbacks, and height limits of 50 feet or
4 stories in all areas not fronting Railroad Street.
The Downtown Specific Plan area also has lower parking requirements than other residential
areas in the City. The parking requirements for residential units are 1 space per unit and 1
guest space per 6 units for units that are less than or equal to 800 square feet, and 1.5 spaces
per unit and 1 guest space per 4 units for units that are greater than 800 square feet. These
requirements are not excessive for a suburban area. Parking standards are often a potential
constraint to development. However, in Gilroy, they appear to be appropriate and reasonably
accommodated as part of new high-density developments with below market rate units in the
Downtown Specific Plan Area.
Table 52: Downtown Specific Plan Development Standards
Zone Commercial FAR Residential Density (du/ac)
Downtown Historic District (DHD) 2.5 20 (minimum)
Downtown Expansion District (DED) 2.5 20 (minimum)
Civic/Cultural Arts District (CCA) 1.5 or 1.0 n/a
Transitional District (TD) 1.5 20 (maximum)
Cannery District (CD) 2.0 20 – 40
Gateway District (GD) 0.75 30 (stand-alone residential maximum)
Source: City of Gilroy Zoning Code.
Zoning Ordinance
The Zoning Ordinance, Chapter 30 of the Gilroy City Code, is the primary tool for implementing
the land use designations in the Gilroy 2040 General Plan. The Zoning Ordinance provides
controls over land use. In conformance with the 2040 General Plan and current state housing
law, a comprehensive update of the zoning code is anticipated to be complete by the end of
2023. As such, some standards identified in this analysis will be updated with the new Zoning
Ordinance. Such instances are noted and the appropriate programs are referenced. Existing
residential development standards are shown in Table 53.
The City’s General Plan allows for a range of densities and housing types to meet the needs of
all income levels. Assembly Bill (AB) 2348 established “default” density standards. If a local
government has adopted density standards consistent with the established population
criteria, sites with those density standards are accepted as appropriate for accommodating
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the jurisdiction’s share of regional housing need for lower-income households. Pursuant to AB
2348 and the 2020 decennial census, Gilroy is considered a “jurisdiction within a metropolitan
county” with a “default” density for affordable units of 30 du/ac. Densities of at least 30 du/ac
are allowed in the High-Density Residential zone and Neighborhood District. Densities of 30
du/ac are also allowed in the 1st Street mixed-use corridor and Downtown Specific Plan
designations, described above.
Height Limits
The City has two types of height limits in residential districts: a maximum height measured in
stories and an absolute height. Height limits in the R3 zone, which has a density of 8–16 du/ac,
are 3 stories or 45 feet. For the R4 zone, which allows densities from 20–30 du/ac, the height
limits are 6 stories or 75 feet, whichever is less. Parking garages that are aboveground would
count toward the story limit, while those that are belowground do not. The height limits do not
constrain development from reaching their prescribed General Plan densities.
Setbacks
All residential zones have setbacks, which are the minimum distances between a structure and
a lot line. Setbacks in Gilroy are largely uniform between the residential zones, with 26-foot
front setbacks, 6- to 12-foot interior side setbacks, 21-foot street side setbacks, and 15-foot
rear setbacks. While all setbacks reduce the amount of land that is developable on a site, the
setbacks do not constrain projects from reaching the maximum housing density in a zone.
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Table 53: Existing Residential Standards
District
Lot Requirements
Lot Size in Square
Feet (Lots Using
Street Standards
Adopted in
February 2006)1
Yard Requirements
(Minimum Setbacks in Feet. Property Lines Adjacent to Streets Measured from the
Face of Curb)
Height
Requirements Density
Front
Front (Lots on
Bulb of Cul-de-
sac)
Side
(Adjacent to
a Street)
Side (All
Other Side
Yards)
Rear
Rear (Yards
Backing onto
Street)
Feet Stories Maximum Density Units per
Acre
A1 20 acres 262 222 21 12 156 26 35 2 Maximum of one dwelling unit per lot
RR 2.5 acres 262 222 21 12 156 26 30 2 Maximum of one dwelling unit per lot
R1 6,660 sf 262 222 21 63 156 26 35 2 Maximum of one dwelling unit
per lot 3 – 7 ¼
R2 8,8804 sf 262 222 21 63 156 26 35 2
One dwelling unit per 4,000 square
feet of land to a maximum of two
units per lot
3 – 9
R3 8,880 sf 262 222 21 12 156 26 455 3 One dwelling unit per two 2,722
square feet of lot area 8 – 16
R4 13,320 sf 262 222 21 12 156 26 755 6
One dwelling unit per 1,452 square
feet up to a maximum site area of
2,178 square feet per unit.
20 – 30
ND* * * * * * * * * * * *
Source: Gilroy City Code Chapter 30.
1 See Zoning Code for lot size requirements for lots using street standards adopted prior to 2006
2 Garage vehicular entrances shall be set back from the property line such that they have a minimum eighteen (18) foot long driveway measured from the back of the sidewalk
3 For dwellings located within new subdivisions (after the effective date of the ordinance codified in this chapter), containing five (5) or more lots, the total width of the two (2)
side yards for any one (1) lot in an R1 or R2 district must equal twelve (12) feet. For structures in existence on the effective date of the ordinance codified in this chapter, a six (6)
foot side yard setback shall be maintained, unless a smaller side yard has been allowed by a variance, planned unit development, or preexisting, nonconforming use.
4 Seven thousand (7,000) sq. ft. for preexisting lots created prior to September 15, 1983; and six thousand (6,000) sq. ft. for one (1) single-family dwelling.
5 For R3 and R4 lots proposed to be developed with one (1) single-family residence as the primary use, the height of the residential dwelling unit shall not exceed two (2) stories
and thirty-five feet (35) feet.
6 Rear yard setbacks may be reduced to ten (10) feet to accommodate a five (5) foot encroachment for rear yard patio covers.
* Residential site and building requirements shall be established by the master plan or specific plan for the neighborhood district area in which the property is located.
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Parking
The provision of parking is a significant cost for all forms of development. High parking
requirements reduce the potential land available for development and increase the cost of
development. Table 54 displays the parking requirements for residential developments in
Gilroy. The parking requirements often pose a potential constraint on development. However,
construction of recent developments, including below market rate units, demonstrate that
Gilroy’s existing parking requirements are appropriate and are not an unreasonable
constraint.
In addition to these minimum standards, Gilroy also has a maximum parking requirement. Per
Gilroy City Code Section 30.31.30 (a), the maximum parking requirement is 10 percent above
those listed in the parking schedule, and any parking spaces beyond the 10 percent must be
offset with an equal amount of landscaping.
Table 54: Existing Residential Parking Standards
Type of Residential Development Required Parking Spaces (off street)
Single- and two-family dwellings Two (2) stalls per dwelling unit, one (1) of which shall be a covered
carport or garage (each space must be at least ten (10) feet by
twenty (20) feet).
Multiple family dwellings One and one-half (1 1/2) stalls per one (1) bedroom or two (2)
bedroom dwelling unit and two (2) stalls for each unit having three
(3) or more bedrooms or rooms which could be used as bedrooms,
plus one (1) stall for every four (4) units for guests. One (1) stall for
each unit shall be covered with a garage or carport.
Accessory dwelling units (detached) One (1) stall per unit
Downtown Specific Plan Residential Parking Requirements
Residential units < or equal to 800 sq. ft One space per unit plus one guest space per six units
Residential units > 800 sq. ft. 1.5 spaces per unit plus one guest space per four units
Source: Gilroy City Code Chapter 30.
Cumulative Effect of Development Standards
The cumulative effect of development standards is not likely to constrain the ability of
developers to achieve densities on site development. The City of Gilroy has permissive
standards for development, especially in its Downtown Specific Plan area. The development
standards do not constrain the ability for projects to meet the densities in each zone.
Additionally, many recent projects have been developed at the City’s standards that are able
to achieve moderate and high densities. Recently proposed or approved developments
include:
A four-story, 120-unit affordable development on 3.4-acre parcel in the R-4 zone (35
du/acre)
A 100-unit affordable development on a 3.9-acre parcel in the R-4 zone (25 du/acre)
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A 75-unit development on a 1.86-acre parcel in the Gateway District in the
Downtown Specific Plan (40 du/acre)
A 120-unit development on a 3.9-acre parcel in the R4 zone (30.8 du/acre)
A 268-unit development in the Downtown Expansion District in the Downtown
Specific Plan on 6.8 acres (38.7 du/acre)
A 94-unit affordable development in the Downtown Gateway District on 2.9 acres
(32.4 du/acre)
These and other entitled and pending projects include a total of 62 very low, 407 low, and 38
moderate units.
Density Bonus
California Government Code Sections 65915 through 65918, known as the density bonus law,
were enacted to encourage developers to build affordable housing by requiring local
governments to provide meaningful incentives in exchange for those affordable units.
The City addresses the density bonus requirement through the implementation of Section
30.46.40 of the Gilroy City Code. This section of the Gilroy City Code references and
incorporates the state density bonus law. The City is fully compliant with density bonus law,
and knows how to properly implement it if requested by a developer. Multiple recent and
ongoing projects have utilized the density bonus including the Jemcor Apartments (130 units),
the Hecker Pass Apartments (100 units), and the 1st and Kern Apartments (120 units).
The City is including Program A - 11 to study and adopt a density bonus ordinance beyond
what required by state law to further encourage development of affordable housing. The
program will specifically consider additional incentives for households with special needs such
as large households, extremely low-income households, and farmworkers.
Providing for a Variety of Housing Types
Table 55 shows the allowed uses within residential zones in the zoning code. As discussed in
the following section, accessory dwelling units and junior accessory dwelling units are allowed
in all residential zoning districts under Section 30.54 of the City’s Zoning Ordinance. Single-
family residential zoning includes four districts: A1, RR, HR, and R1. Single-family units are
permitted as a matter of right in all single-family residential districts. Single-family dwellings
are permitted as a matter of right in all multifamily residential districts, except for mixed-use
zones in the Downtown Specific Plan area. Single family development in the R3, R4 and RH
zones has the potential to prevent the achievement of the planned densities.
Multifamily residential zoning includes R2, R3, and R4, districts. Duplexes are permitted as a
matter of right in R2, R3, and R4 district; they are also allowed in the R1 district on corner lots
of a certain size, when meeting certain conditions. Condominiums and townhouses are
permitted as a matter of right in the R3 and R4 districts; they are also permitted in the HR
district when conforming to the density limits through clustering. Multiple family buildings are
permitted as a matter of right in R3 and R4 districts.
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The City of Gilroy has also established a Neighborhood District zone. Land in the
Neighborhood District may be used as specified by a Master Plan or Specific Plan adopted for
each Neighborhood District area. In addition to including 15% of the units as affordable, each
development must provide compatible uses such as parks, schools, and neighborhood-serving
commercial facilities.
The City is including several programs in the Housing Element to further encourage a variety
of housing types across the City. One of these programs includes adoption of an affordable
housing policy to encourage and incentivize development of affordable housing (Program
A - 11). Another program may incentivize missing middle housing, by allowing ministerial
approvals for duplexes, triplexes, and fourplexes, in specified zones, that comply with the City’s
objective design standards (Program A - 9). Additionally, the City is considering a program to
incentivize micro-units (Program E - 5).
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Table 55: Residential Use Table
Housing Types Permitted A1 RR R1 R2 R3 R4 RH ND
Accessory Dwelling Unit1 -- X X X X X X *
Condominiums -- -- -- -- X X X *
Duplex -- -- X2 X X X -- *
Mobile Home Park -- -- C C X X -- *
Multi-Family Building -- -- -- -- X X -- *
Residential Care Homes (> 6 Residents) -- C C C C C C *
Residential Care homes (≤ 6 residents) -- X X X X X X *
Single-Family Dwelling or Modular Home X4 X X X X X X *
Townhouse** -- -- -- -- X X X *
Emergency Shelters C C C C C C C *
Supportive and Transitional Housing3 X X X X X X X *
Source: City of Gilroy Zoning Ordinance, Section 11. 10.
Notes:
X = Unconditionally Permitted; C = Permitted only with conditional use permit granted by planning commission;
* = Refer to master plan or specific plan adopted for the neighborhood district area in which the property is located.
**= Program B - 7 is included to remove reference of condominium ownership in the definition of Townhome.
1 Accessory dwelling unit(s) and/or junior accessory dwelling units may be allowed subject to compliance with the regulations prescribed in Article LIV.
2 A duplex dwelling is permitted when all of the following conditions are met:
(a) The duplex dwelling shall be located on a corner lot only; and
(b) The corner lot shall have a minimum area of eight thousand (8,000) square feet and be so designated for a duplex unit on a tentative and final map; and
(c) The duplex shall not increase the overall density within any given land subdivision beyond the maximum of seven and one-fourth (7 1/4) dwelling units per net acre
3 Supportive and/or transitional housing that serves more than six (6) individuals, provides on-site services and is licensed by the state as a group home shall only be allowed
upon the granting of a conditional use permit.
4 One (1) residential dwelling unit may be permitted on an A1 zoned parcel that has a minimum size of twenty (20) acres or more. Subdivision of land for further development is
not permitted without rezoning to another zoning district that implements the general plan land use map.
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Accessory Dwelling Units
Accessory dwelling units (ADUs) provide additional housing opportunities for people of all ages
and economic levels. The City of Gilroy permits ADUs on any residential parcel in any zoning
district that permits residential or mixed-use development and which contains an existing or
proposed primary single-family residential use.
The City has previously submitted its ADU ordinance to the state and worked with the state to
ensure its compliance with state law. The City will continue to update the ADU ordinance as
necessary and work with the state to ensure compliance with state law (e.g., Government Code
Section 65852.2).
The City is also including multiple programs to monitor, incentivize and encourage
ADU development across the City. This includes monitoring and tracking ADUs and their
affordability (Program A - 6), adopting a set of preapproved plans (Program A - 7), and
encouraging the development of ADUs through education and marketing (Program G - 4).
Senate Bill 9
Effective January 1, 2022, Senate Bill (SB) 9 requires ministerial approval of a housing
development with no more than two primary units in a single-family zone, the subdivision of
a parcel in a single-family zone into two parcels, or both. SB 9 facilitates the creation of up to
four housing units in the lot area typically used for one single-family home. The City adopted
two objective design standard policies for SB 9 projects on December 13, 2021, and revised
them effective April 4, 2022 following additional interpretation by the state. Consistent with
state law, the adopted standards are purely objective in nature, providing property owners
information on the SB 9 process and associated standards in Gilroy. The City’s SB9 2-Unit
Objective Design Standards Policy and the SB9 Lot Split Objective Design Standards Policy both
closely follow state law. The City website has readily available information regarding ADU and
SB 9 applicability and standards.
Emergency Shelters
An emergency shelter is housing with minimal supportive services for unhoused persons that
is limited to occupancy of 180 days or less per calendar year by an unhoused person. No
individual or household may be denied emergency shelter because of an inability to pay.
The City’s emergency shelter requirements are currently provided in the Performance
Standards section of the zoning ordinance. Currently, emergency shelters may be permitted
in any zone with a conditional use permit. Emergency shelters in the agriculture and residential
zoning districts may only serve families. Per City Code, one parking stall shall be provided per
employee and volunteer on the shift with the greatest number of employees and volunteers,
and one parking stall shall be provided for every ten beds in the shelter.
The number of beds per single room in a shelter is limited to 50, unless a larger number is
approved on a temporary basis in advance by the planning manager and police chief. A shelter
must include an indoor intake area that is of sufficient size to accommodate the maximum
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number of clients anticipated to request sheltering at any given time, as well as an exterior
area for clients waiting for the shelter to open. The waiting area must be physically separated
and visually screened from the public right-of-way.
Additional requirements for emergency shelters include a management plan to address
experience, neighbor issues, transportation, client supervision, screening of clients, food
services, security, training, counseling, and treatment programs. The plan requires approval
by the planning manager and police chief prior to operation of the emergency shelter. The
plan must include a floor plan that demonstrates compliance with the physical standards of
the City’s code. The operator of each emergency shelter is required to annually submit the
management plan with updated information for approval.
Current City emergency shelter standards do not meet state law requirements (Government
Code Section 65583). The City will amend its zoning code to comply with all portions of state
law (Government Code Section 65583). The City will ensure that other development standards
that apply to emergency shelters are consistent with other uses in the underlying zone
(Program E - 3).
Program E - 3 is included to update emergency shelter standards to comply with state law to
allow for an emergency shelter as a by-right use in the R4 zone and set parking based on the
rate of staff only. The R4 zone is appropriate for emergency shelters due to their access to
nearby resources such as transit and supportive services. There are 10.81 vacant or
underutilized acres in the R4 zone available to accommodate emergency shelters. The R-4
zone includes sufficient capacity to accommodate the needs of unhoused individuals identified
in the most recent Point in Time Count (345). Program B - 2 includes zoning amendments to
remove the maximum density in the R4 zone, such that there is no limit to the number of beds
in an emergency shelter in the City. Emergency shelters will continue to be allowed in all zones
with a CUP, which increases the amount of land available for emergency shelters beyond what
is required by state law.
Low Barrier Navigation Centers
Low barrier navigation centers (LBNC) are service-enriched shelters that are focused on
moving individuals into more permanent housing. LBNCs provide temporary housing while
case managers connect individuals experiencing homelessness to shelter, public benefits, and
health services. Under the Housing for Homeless Act (2019), local governments are required
to allow LBNCs by right in areas zoned for mixed uses and nonresidential zones that permit
multifamily uses.
Gilroy does not currently explicitly allow LBNCs in any zone, though this would not prevent
their development if an application for one were received. Per Program E - 4, the City will
amend its zoning code pursuant to Government Code Section 65583 to allow for LBNCs by
right in areas zoned for mixed uses and nonresidential zones that permit multifamily uses.
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Modular Homes
The permitting of modular, or manufactured, housing on foundations is subject to the same
development standards as conventional single-family units, consistent with Government Code
Section 65852.3. The City of Gilroy permits modular homes by right in all residential zones that
permit single-family dwellings by right.
Transitional and Supportive Housing
Supportive or transitional housing that serves up to six individuals is allowed by right in all
residential zones. Supportive or transitional housing that serves more than six individuals,
provides on-site services, and is licensed by the state as a group home, is allowed in any zone
upon the granting of a conditional use permit. While the conditional use permit may be a
potential constraint on the development of group homes with more than six residents, the City
has objective standards for these homes to add certainty to the development process. As a
part of Program B - 6, the City’s objective standards will be reviewed and modified as necessary
to ensure they are purely objective in nature.
Single-Room Occupancy Units
Single-room occupancy (SRO) residences are small, one-room units occupied by a single
individual, and may either have a shared or private kitchen and bathroom facilities. SROs are
rented on a monthly basis, typically without a rental deposit, and can provide an entry point
into the housing market for extremely low-income individuals, formerly unhoused, and
disabled persons. SRO units are not specifically defined or included in the City’s Zoning
Ordinance; however, there is precedence for their allowance within the City.
The City of Gilroy has one SRO development, which opened in 2016. The 26-unit SRO project,
the Gilroy Sobrato Apartments, was added to the Sobrato Transitional Apartments, aimed at
serving the unhoused population in Gilroy. This recent project demonstrates that there are no
actual constraints on the development of SROs in the City.
Residential Development Ordinance
The Residential Development Ordinance (RDO) was first established in 1979 to monitor the
amount of residential growth in the City by limiting the number of dwelling units that could be
built in a 10-year period.
The RDO is a potential constraint on development; however, it has been made null by
provisions of SB 330 and SB 8, effective through 2030. The RDO limitations are not currently
utilized by the City and will not be included in the City’s new zoning ordinance, and thus does
not pose a constraint to development. Program B - 1 facilitates the removal of the RDO as a
part of the comprehensive zoning update.
Affordable Housing Policy
The City does not have an inclusionary policy in effect for the whole City. Though the RDO is
no longer in effect, portions of the RDO were set up similarly to an inclusionary housing
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ordinance, by including resale controls and rental price controls for a minimum of 55 or 30
years, and specified a minimum percent of units for different affordability categories. The City
is considering carrying forward portions of the RDO that do not cap development but provide
other incentives for low-income housing development. This includes the study and
development of an inclusionary housing policy or ordinance (Program A - 10). As inclusionary
housing often raises the cost of development by mandating a price subsidy, an inclusionary
housing policy is a potential constraint on development.
The City currently has an inclusionary housing requirement for developments in its
Neighborhood District areas, requiring developments to construct a minimum of fifteen
percent (15%) of its units at affordable prices.
While most provisions of the City’s RDO are null, the affordable housing exemption procedure
provides the following affordability ratios that can be used as a benchmark for any affordable
housing policy adopted by the City:
At least 40% of units affordable to households below 60% of the AMI
At least 15% of units affordable to households between 60% and 80% of the AMI
At least 15% of units affordable to households between 80% and 100% of the AMI
No more than 30% of the units affordable to households between 100% and 120%
of the AMI
Incentives for constructing affordable housing in the Neighborhood Districts include density
bonuses, reduction in City standards (including zero-lot line developments, clustered housing
on smaller lots, and smaller unit sizes), and reduction in road widths. All affordable units must
be developed on-site and there is no option for an in-lieu fee. The lack of an in-lieu fee is a
constraint to development, and does not comply with Government Code Section 65850(g);
Program A - 5 is included to revise the Neighborhood District Policy to ensure it is fully
compliant with state law.
Urban Growth Boundary and Urban Service Area
Per the City’s General Plan, “The Urban Growth Boundary (UGB) applies to land within the
Planning Boundary/Sphere-of-Influence that is intended for urbanization at some point in the
future. The UGB indicates the extent and direction of the City's future urban expansion and
capital improvements planning. Lands outside the UGB are to be preserved for rural and
agricultural uses.”
In 2016, voters passed Measure H, resulting in the UGB. The intent of the UGB is to protect
agriculture and open space in the surrounding areas outside of the UGB. Urban development
is not allowed outside of the UGB; only uses allowed in the open space designation per the
General Plan are allowed. Until December 31, 2040, lands outside the UGB can only be
redesignated by a vote of the people, except for the following exceptions in which the City
Council determines that doing so is necessary to comply with state law regarding the provision
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of housing for all segments of the community and makes each of the following findings based
on substantial evidence, per the General Plan:
That the land proposed to be brought within the UGB and/or re-designated is
immediately adjacent to: (i) the existing UGB; and (ii) available water and sewer
connections; and
That the proposed development will consist primarily of low and very low-income
housing pursuant to the Housing Element of this General Plan;
That there is no existing vacant or undeveloped residentially designated land within
the UGB to accommodate the proposed development and it is not feasible to
accommodate the proposed development by re-designating lands within the UGB
for low- and very low-income housing; and
That the proposed development is necessary to comply with State law
requirements for the provision of low- and very low-income housing and the area
of land within the proposed development will not exceed the minimum area
necessary to comply with State law.
An analysis by the City attorney at the time of the vote estimated that this would yield a
reduction of 2,929 potential units compared to the City’s previous General Plan and 4,344 units
to the draft General Plan update at the time.27
The City also has an Urban Service Area (USA). The USA is the land to which the City is
committed to providing basic infrastructure and services for urban development. The USA is
generally coterminous with the UGB. The City accepts applications for USA modifications in the
month of July only. The USA is reviewed and amended by the Local Agency Formation (LAFCO)
if desired by the City. The USA acts as a potential constraint to development by limiting the
area in which the City provides infrastructure. Despite this potential constraint, the City has
capacity for new housing within the USA and UGB, and has increased residential densities in
the Gilroy 2040 General Plan to accommodate any capacity lost under Measure H.
The UGB does not restrict the number or timing of permits within the USA or UGB.
Development Review and Permitting Procedures
The efficiency and timing of a jurisdiction’s processes for review and approval of residential
development has a significant impact on the amount and pace of housing construction. The
procedures for development review and permitting in the City of Gilroy are described below.
Permit Processing Procedure
The requirements of the permit processing procedure have the potential to act as a constraint
to the development of housing. The time and uncertainty of the review and revision cycle can
27City Attorney’s Impartial Analysis of Measure H. https://sccvote.sccgov.org/sites/g/files/exjcpb1106/files/E110%20-
%20Measure%20H.pdf
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contribute significantly to the overall cost of the project, ability to obtain and maintain funding,
and the cost of each dwelling unit. Certainty and consistency in permit processing procedures
and reasonable processing times are important to ensure that the developmental review and
approval process does not act as a constraint to development by adding excessive costs or
discouraging housing development.
In 2020, the City awarded a contract to Tyler Technologies for the purchase and
implementation of a Land Management System. The Land Management System helps to
manage land development applications, business and professional licenses, special event
permits, code enforcement cases, and fire prevention/pre-treatment/hazardous materials
management. The City began configuring the system in 2021 and intends to “go live” with the
public in spring 2023. This Land Management System will modernize the City's application
processes by allowing online application submittals and coordinated digital plan review. The
system will automate many steps in the existing permitting process and help mitigate potential
constraints caused by a lengthy permitting process. Applicants will be able to check the status
of their permit online and staff will have greater control over the workflow.
The City also continues to hold development stakeholder roundtable meetings (virtual in 2020
and 2021) to maintain a dialog with the development community. Recent topics discussed at
the roundtable included bicycle parking, objective design standards, and a potential update to
the City's Downtown Specific Plan. The City evaluates its permitting and processing procedures
biannually. It consults builders and other parties engaged in housing development activities to
identify concerns and potential constraints in the permit processing procedure. In 2021, the
City began a comprehensive update of the City's Zoning Ordinance to ensure that it is
compliant with the 2040 General Plan. Updates will include changes to help streamline the
permit process, including but not limited to creating an administrative use permit process, as
currently all use permits require a public hearing before the Planning Commission. City staff is
also recommending a more transparent and streamlined process for reviewing and approving
applications involving a historic resource (e.g., residential additions). Program B - 5 includes
the above changes to streamline the permitting process.
The typical planning permit process follows the steps below.
1. Optional Pre-Application Submittal Meeting
2. Application Submittal
3. Input from Other Departments
4. Status Letter to Applicant
5. Plan Revision (if yes, return to Step 2)
6. Planning Staff Analysis
7. Project Decision, including conditions of approval if applicable
The project decision may be appealed, which would result in project review by either the
Planning Commission or City Council, depending on the permit.
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Permit Processing Time
The processing time needed to obtain development permits and required approvals can act
as a constraint to development and contribute to the high cost of housing. Permit processing
times are partially dependent on the number of staff available to review projects. When
staffing levels drop due to attrition (e.g., voluntary termination) or cutbacks (e.g., layoffs),
permit processing times increase. In 2017, the City hired Management Partners to complete
an organizational review of the Community Development Department, including
recommended staffing levels. Many of the report’s recommendations, such as over-the-
counter plan checks, were implemented to reduce permit processing times. The report also
recommends that the City reevaluates staffing levels on a regular basis to determine when
additional staff resources are needed to meet service demand.
The permit processing times for various permits are shown in Table 56. The level of project
review depends on the type of project. Most single-family projects require only a zoning
clearance from the Planning Department as part of the building permit process. Single-family
residential hillside projects can be approved by planning staff through an Architectural and
Site Review permit. Similarly, most multi-family (no subdivision map) commercial, industrial,
and professional office projects can be approved administratively. These staff level
discretionary planning projects typically take three to six months (depending on application
completeness) to obtain planning entitlements, while applications for building permits take
another three to four months. Projects that require a tentative subdivision map require
Planning Commission review and City Council approval. The subdivision review and approval
process typically takes approximately one year to complete, depending on the required
California Environmental Quality Act (CEQA) documentation. Once final maps are recorded,
building permit applications may be filed, which typically takes another three to four months
for approval.
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Table 56: Permit Processing Time
Permit Type Length of
Approval Approval Body
Building Permit 3-4 months Issued by Building and Safety Division
Conditional Use Permit 3-4 months Planning Commission
Variance 3-4 months Planning Commission
Zone Change / Zoning
Amendment
6-12 months City Council
General Plan Amendment 6-12 months City Council
Architecture and Site Review 3-6 months Community Development Director (or
designee)
Planned Unit Development 6-9 months City Council
Tentative Tract Map 6-9 months City Council
Negative Declaration 6-9 months Same as project approval body
Environmental Impact Report 12 months Same as project approval body
Final Subdivision Map 2-4 months City Council
Parcel Map 1-2 months City Council
Source: City of Gilroy, 2022
The Cities Association of Santa Clara County Planning Collaborative collected data through a
survey to provide a regional comparison of permit processing times for jurisdictions across
the County. Table 58 displays the permit processing time in months for various types of
residential permits. Gilroy has similar or slightly quicker processing times as jurisdictions
across County for most permits. The City has a shorter processing time on discretionary
permits that go to City Council (5 – 6 months) than all jurisdictions except two.
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Table 57: Permit Processing Time, Months, Regional Comparison
Jurisdiction ADU
Process
Ministerial
By-Right
Discretionary
By-Right
Discretionary
(Hearing
Officer if
Applicable)
Discretionary
(Planning
Commission)
Discretionary
(City Council)
Gilroy 1 - 2 1 - 2 2 – 4* N/A 4 - 5 5 - 6
Campbell 1 1 3 N/A 5 8
Cupertino 1 - 3 1 - 6 2 - 4 2 - 4 3 - 6 6 - 12
Los Altos Hills 1 - 2 0.5 - 2 2 - 3 3 - 4 4 - 6 5 – 8
Los Gatos N/A 1 - 2 1 - 2 2 - 4 4 - 6 6 - 12
Milpitas 1 - 3 1 - 3 2 - 4 3 - 4 4 - 6 6 - 12
Monte Sereno 0.75 0.75 1 1 - 2 1 - 2 1 - 2
Morgan Hill 1 - 2 1 - 2 2 – 3** 2 - 3 4 - 6 4 - 6
Mountain View 3 - 5 4 - 6 2 - 3 6 – 18** N/A 12 - 24
San Jose 2 1 - 3 7 7 7 - 11 5 - 12
Santa Clara 0 - 1 0 - 1 0 - 3 4 - 9 6 - 9 6 - 12
Saratoga 1 1 - 2 2 - 3 N/A 4 - 6 6 - 12
Sunnyvale 1 - 3 1 - 3 3 - 6 6 - 9 9 - 18 9 - 18
Unincorporated
County 4 - 6 6 - 8 9 - 12 12 - 15 15 - 18 15 - 18
Source: Cities Association of Santa Clara County, Planning Collaborative. 2022.
*Gilroy does not have "discretionary by-right" permits This timeline represents "Discretionary (Staff)”. This timeline also depends
on level of CEQA review.
**Entitlements only
Objective Design Standards Policy
In October 2021, the City of Gilroy adopted the Mixed-use Residential and Multi-Family
Residential Objective Design Standards Policy. The Objective Design Standards were created
to ensure the City’s compliance with the Housing Accountability Act. The Objective Design
Standards apply to residential projects that are multifamily or mixed-use. Consistent with state
law, the standards are purely objective in nature. The objective design standards are also
intended to increase consistency in decision making, minimize applicant delays, better utilize
limited staff resources, and promote good design principles that help ensure that Gilroy is an
attractive place to live and visit.
The City is including Program A - 9 to incentivize missing middle housing by allowing ministerial
approval of duplexes, triplexes, and quadplexes, in specified zones, that meet these objective
standards.
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Planning, Building, and Development Impact Fees
Housing developments are typically subject to three types of fees: planning-related fees,
building permit fees, and development impact fees. The fees are charged by the City and other
agencies to cover administrative processing costs associated with development and help
ensure the provision of adequate services.
Fees vary based on the type of application necessary for project approvals. The processing
fees are typically recouped through the rent or sales price, so excessive fees may ultimately
affect the affordability of housing. It is best practice to periodically conduct user fee studies to
ensure the City is recouping the cost of providing services in areas for which fees apply. In May
2022, the City completed a Comprehensive User Fee Study to update the City’s user fees
schedule, which was last updated and adopted in 2014. Following community meetings and
public hearings with the City Council, a new fee schedule was adopted, effective August 1,
2022. The most current fee schedule is available on the City’s website. Planning related fees
for the City of Gilroy are shown in Table 58.
Table 58: Planning Related Fees
Applications Fee
Annexation $16,632 + actual attorney fees
Architectural Site Review – Residential
New Construction $8,294/first lot + $592/additional flat land tract plan +
$1,203/additional hillside lot
New Hillside Lot - SFD $4,532
Additions $2,648
Development Agreement $19,081 minimum deposit (hourly rate invoiced against initial
deposit, plus $10,000 deposit for attorney fee)
Environmental
Categorical Exemption $536.00
Initial Study/ND/MND, non-complex project
(Staff Review)
$12,113.17 (minimum)
Environmental Impact Report (staff review) $23,739.79 (minimum)
EIR/MND/Initial Study (Consultant Contract) Actual contract cost plus 15% of contract cost + 15% staff
review + 10% contingency
General Plan Map Amendment $15,604/first 10 acres + $150/each additional 10 acres, plus
attorney fees and publishing costs
Planned Unit Development $16,203
Tentative Parcel Map $10,253 (up to 4 lots), plus publishing
Tentative Tract Map $19,036/(5-12 lots) + $302/additional flat land lot +
$877/additional hillside lot, plus publishing costs
Urban Service Area Extension $29,188/first 10 acres + $423/each additional 10 acres +
publishing3 + LAFCO fees
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Variance $5,470, plus attorney fees and publishing costs
Zoning Map Amendment $11,884/first 10 acres + $150/each additional 10 acres, plus
attorney fees and publishing costs
Source: City of Gilroy. Effective August 1, 2022.
3. For those projects involving multiple public hearing applications, the publication costs will be reduced to a single charge when
it is determined, and reasonably possible, that the public-hearing applications can be processed together.
The City of Gilroy Public Works Department provides a fee schedule for the development
impact fees per unit. The current fee schedule runs from July 1, 2022, to June 30, 2023. This fee
schedule was recently updated to reflect the fees adopted as part of the 2022 Comprehensive
User Fee Study discussed above. Development impact fees add to the cost of residential
development; however, they can be a cost-effective mechanism for financing the new
infrastructure (e.g. water, sewer, roads) required to support new development. The fees allow
for the consolidation of infrastructure projects when it is more cost-effective to do so and, by
law, must be linked to the actual impact of the specific project.
The City of Gilroy imposes a number of development impact fees, including for public facilities,
sewer development, storm development, traffic, and water development. Typically, fees per
unit for high-density residential are lower than fees per unit for low-density residential.
Development fees for the City of Gilroy are shown in Table 59. The City also charges a
development impact fee of $15.82 per square foot for ADUs that are greater than 750 square
feet.
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Table 59: Development Impact Fees
Fee Type Fee
Public Facilities Impact Fees
Residential – Low Density $22,617/unit
Residential – High Density $19,028/unit
Sewer Development Impact Fees
Residential – Low Density $13,262/unit
Residential – High Density $7,176/unit
Storm Development Impact Fees
Residential – Low Density $598/acre
Residential – High Density $940/acre
Traffic Impact Fees
Residential – Low Density $13,012/unit
Residential – High Density $10,548/unit
Water Development Impact Fees
Residential – Low Density $4,556/unit
Residential – High Density $1,843/unit
ADUs ADU impact fees are not assessed for the first 750 square feet. Any floor
area above 750 square feet will be assessed an impact fee of
$15.82/square foot
Source: City of Gilroy. Fees to Build Effective July 1, 2022.
The Cities association of Santa Clara County Planning Collaborative collected data through a
county-wide survey to provide a regional comparison of fees for different types of
development. Total fees per unit for single-family, small multi-family, and large multi-family
are shown in Table 60. Generally, Gilroy has fees that are comparable to the region. For single-
family fees, Gilroy is the sixth least expensive of the thirteen jurisdictions with listed fees. For
small multi-family units Gilroy is sixth of twelve, and for large multi-family Gilroy is eighth of
twelve.
Table 60: Total Fees per Unit, Regional Comparison
Jurisdiction Single-Family Small Multi-Family Large Multi-Family
Gilroy $69,219 $40,195 $39,135
Campbell $72,556 $20,599 $18,541
Cupertino $136,596 $77,770 $73,959
Los Altos Hills $146,631 N/A N/A
Los Gatos $32,458 $5,764 $3,269
Milpitas $77,198 $74,326 $59,740
Monte Sereno $33,445 $4,815 $4,156
Morgan Hill $55,903 $41,374 $36,396
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Jurisdiction Single-Family Small Multi-Family Large Multi-Family
Mountain View $90,423 $69,497 $82,591
San Jose $9,919 $23,410 $23,410
Santa Clara $72,034 $7,299 $3,048
Saratoga $64,272 $17,063 $15,391
Sunnyvale $133,389 $126,673 $98,292
Source: Cities Association of Santa Clara County Planning Collaborative. 2022.
Table 61 displays a regional comparison of fees a percentage of total development costs.
Gilroy's single-family fees (1.5 percent of total development) rank sixth least expensive out of
fourteen jurisdictions listed. For small multi-family fees, Gilroy ranks seventh out of twelve (5.3
percent), and for large multi-family fees, Gilroy is eighth of the twelve jurisdictions listed (5.6
percent).
Table 61: Fees as Percentage of Total Development Costs, Regional Comparison
Jurisdiction Single-Family Small Multi-Family Large Multi-Family
Gilroy 1.5% 5.3% 5.6%
Campbell 2.6% 2.7% 2.6%
Cupertino 2.9% 10.3% 10.5%
Los Altos Hills 3.1% N/A N/A
Los Gatos 1.2% 0.8% 0.5%
Milpitas 2.8% 9.8% 8.5%
Monte Sereno 0.7% 0.6% 0.6%
Morgan Hill 2.0% 5.5% 5.2%
Mountain View 3.3% 9.2% 11.8%
San Jose 0.4% 3.1% 3.3%
Santa Clara 2.6% 1.0% 0.4%
Saratoga 1.4% 2.3% 2.2%
Sunnyvale 4.8% 16.8% 14.0%
Unincorporated County 0.9% N/A N/A
Source: Cities Association of Santa Clara County Planning Collaborative. 2022.
On average, fees are comparable to surrounding jurisdictions in Santa Clara County. Fees may
represent a barrier to the construction of housing as they increase the minimum cost of
development for a dwelling unit and may be passed onto the purchaser or renter. However,
the City’s fees are not excessive and do not constitute actual constraints on the production of
housing, as the City has seen robust housing production during the 5th Cycle.
School Fees
In addition to the costs above, the Gilroy Unified School District charges development fees.
The entirety of Gilroy is served by the Gilroy Unified School District. As of 2018, the residential
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development fees for the school district are $3.79 per square foot.28 The City does not have
control over these fees, but the fees have not constrained the development of housing in
recent years.
Transparency of Development Standards
The City of Gilroy provides its development standards on the City website. The Gilroy City Code,
General Plan, permit and development fees, affordability requirements, and zoning maps can
all be accessed on the City’s website. This includes the most recent Comprehensive User Fee
Study. City staff are available to assist applicants or interested parties that do not have internet
access. The City is in compliance with requirements set forth in AB 1483.
SB 35 Approval Procedure
SB 35 (2017) requires a Streamlined Ministerial Approval Process for developments in
jurisdictions that have not made sufficient progress towards their Regional Housing Needs
Allocation. Program B - 3 establishes and implements expedited permit processing for
qualifying affordable housing projects, pursuant to SB 35 and SB 330.
As of August 2022, the City of Gilroy has not received an SB 35 application. If the City were to
receive an SB 35 application, it would follow state law procedure. The following permitting
procedure that the City will follow is from the Streamlined Ministerial Approval Process
guidelines outlined by HCD.
After receiving a notice of intent from the applicant intending to submit an application for a
Streamlined Ministerial Approval Process, the following steps must occur:
1. The City will complete the tribal consultation process outlined in Government Code
Section 65913.4(b) prior to accepting an application for a Streamlined Ministerial
Approval process.
2. Once the tribal consultation process is complete, the City will begin processing the
submitted application for a Streamlined Ministerial Approval process.
3. The City will perform a determination of consistency with regard to objective zoning,
subdivision, and design review standards.
4. The City will perform a determination of consistency with density requirements.
5. The City will complete the design review within the following timeline, following
acceptance of the application in item #2 above:
Within 60 calendar days of submittal of the application to the City if the
development contains 150 or fewer housing units.
28 Gilroy Unified School District. Developer Fee Justification Study. 2018.
https://resources.finalsite.net/images/v1529100379/gusdk12caus/qszb2awtcdnj2lpzxcc8/DeveloperFeeJustificationStudy.pdf.
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Within 90 calendar days of submittal of the application to the City if the
development contains more than 150 housing units
6. The City will determine whether the application for Streamlined Ministerial Approval
complies with all applicable requirements, and will approve or deny the application,
within the following timeline:
Within 90 calendar days of submittal of the application to the City if the
development contains 150 or fewer housing units
Within 180 calendar days of submittal of the application to the City if the
development contains more than 150 housing units.
Housing for Persons with Disabilities
The US Census Bureau defines persons with disabilities as those with a long-lasting physical,
mental, or emotional condition. Certain conditions affect a person’s housing choices, whether
it creates a need for accessibility, living spaces for caretakers, transit access, or other.
Reasonable Accommodation Procedures
The City of Gilroy has a Reasonable Accommodation Procedure adopted in 2014 outlined in
Section 30.50.23 of the Zoning Ordinance. A request for reasonable accommodation may be
made by any person with a disability, their representative or any entity, when the application
of a zoning law or other land use regulation, policy or practice acts as a barrier to fair housing
opportunities.
Requests for reasonable accommodation shall be reviewed by the Community Development
Director or their designee if no other approval is sought. Requests for reasonable
accommodation submitted for concurrent review with another discretionary land use
application shall be reviewed by the authority responsible for reviewing the discretionary land
use application, in conjunction with that application. The written decision to approve or deny
a request for reasonable accommodation shall be based on consideration of the following
factors:
Whether the housing will be used by a disabled individual.
Whether the request for reasonable accommodation is necessary to make specific
housing available to an individual with a disability.
Potential impact on surrounding uses.
Physical attributes of the property and structures.
Alternative accommodations which may provide an equivalent level of benefit.
Whether the requested accommodation would impose an undue financial or
administrative burden on the City.
Whether the requested accommodation would require a fundamental alteration of
a City program.
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The reviewer must make a written determination within 45 days of receipt of a complete
application and either approve, approve with modifications, or deny a request for reasonable
accommodation.
Definition of Family
The Gilroy City Code defines family as “one (1) or more persons, occupying premises and living
together as a single housekeeping unit, as distinguished from a group occupying a hotel, club,
fraternity, or sorority.” This definition is consistent with state law and does not pose a
constraint on the development of housing for persons with disabilities.
Building Code
The City of Gilroy has adopted the 2019 California Building Code, adopted from the 2018
International Building Code, with local amendments. The modifications and changes were
adopted with recommendation by the City of Gilroy chief building official. Modifications and
changes are reasonable and necessary due to local climactic, geological, or topographical
conditions or are otherwise permitted by state law. Local amendments to the building code
can be found in Gilroy City Code Chapter 6, Article II, Section 6.7. Amendments are minor
changes, and no modifications pose constraints to development. The City will adopt the 2022
California Building Code with local amendments on January 1, 2023, following public meetings
with the City Council in the last quarter of the 2022 calendar year.
Code Enforcement
The City’s Code Enforcement staff responds to potential violations of the Gilroy City Code.
There are two code enforcement officers. Code enforcement is reactive and officers respond
to complaints reported by residents. Common violations include abandoned or dangerous
buildings, blighted property and maintenance concerns, unsafe living conditions, land
use/zoning permits, and illegal tree removal.
The City utilizes Community Development Block Grant (CDBG) funding to partially fund
housing code enforcement services within the US Department of Housing and Urban
Development approved Neighborhood Revitalization Strategy area. The program provides
accessibility improvements to very low-income households. The City has provided a grant to
Rebuilding Together Silicon Valley to operate and expand the Home Repair, and Accessibility
Modification program in Gilroy.
On- and Off-Site Improvement Requirements
The City requires on- and off-site improvements for new developments, which are intended to
meet health and safety requirements of the community. Residential developers are
responsible for constructing road, water, sewer, and storm drainage improvements on new
housing sites. The City’s General Guidelines for development were most recently updated in
August 2014. They include local street rights-of-way and curb-to-curb widths, sanitary sewer
and storm drainage lines, street lighting, erosion control, landscaping, and easements.
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Notably, all streets must be designed in accordance with accepted engineering principles and
conform to the design standards, the standard details, and the complete streets resolution
approved by City Council. All exceptions to the general guidelines must be approved by the
City Engineer prior to the approval of a tentative map. These requirements are similar to those
of other jurisdictions and are not considered a constraint on development.
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Nongovernmental Constraints
Requests to Develop Below the Anticipated Density
Requests to develop housing at densities below those anticipated in the Housing Element act
as a potential constraint to housing development. Over the last housing cycle, the City has not
received any requests to develop below densities anticipated.
One of the low-income sites identified in the previous housing element (LI-4) is developing
above the anticipated density identified in the previous housing element. The site was
projected for 78 units and has 120 units pending for a surplus of 42 units.
Land Costs
Land costs have a demonstrable influence on the cost and availability of affordable housing.
Land prices are determined by numerous factors, most important of which are land availability
and permitted development densities. As land becomes less available, the price of land
increases.
The scarcity of adequate housing opportunities in northern Santa Clara County have
influenced upward pressure on land and housing costs in Gilroy.
The price of land varies depending on a number of factors, including size, location, the number
of units allowed on the property, and access to utilities. Vacant land sales (in early 2022) are
shown by cost and acreage in Table 62. The price ranges from $1.80 to $9.69 per square foot,
with an average price of $6.75 per square foot (or $293,843 per acre). The City has little control
over land costs, which can pose a constraint to development.
Table 62: Recent Vacant Lot Sales in Gilroy
Acreage Land Cost Cost per sq. ft. Date Sold
7.34 $3 million $9.38 2/28/2022
1.26 $335,000 $6.10 2/18/2022
13.11 $1.03 million $1.80 2/15/2022
7.67 $900,000 $2.69 2/11/2022
1.14 $400,000 $8.06 2/1/2022
2.38 $985,000 $9.50 1/5/2022
1.09 $460,000 $9.69 1/4/2022
Source: Zillow.com, 2022
Construction Costs
Construction costs include the cost of materials and labor. Materials costs include the cost of
building materials (wood, cement, asphalt, roofing, pipe, glass, and other interior materials),
which vary depending on the type of housing being constructed and amenities provided. In
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general, construction costs can be lowered by increasing the number of units in a
development, until the scale of the project requires a different construction type that has a
lower cost per square foot.
One indicator of construction costs is Building Valuation Data, compiled by the International
Code Council (ICC). The unit costs compiled by the ICC include structural, electrical, plumbing,
and mechanical work, in addition to interior finish and normal site preparation. The data are
national and do not account for regional differences, nor include the price of the land upon
which the building is built. The most recent Building Valuation Data, dated August 2021,
reports the national average for development costs per square foot for apartments and single-
family homes as follows:
Residential Multifamily: $136.73 to $203.34 per square foot
Residential One- and Two-Family Dwelling: $148.33 to $189.34 per square foot
Residential Care/Assisted Living Facilities: $172.87 to $240.35 per square foot
California building costs tend to be higher than national levels. A 2020 study by the Berkeley
Terner Center noted that construction costs in the state are highest in the Bay Area, and
reached more than $380 per square foot in 2018.29
Financing Availability
Interest rates affect homeownership opportunities throughout the City. In August 2022,
Freddie Mac’s primary mortgage market survey listed interest rates on home loans at 5.55
percent on a 30-year fixed-loan rate. While low interest rates are expected to prolong the
availability of financing, low housing inventory can create competition among potential
homebuyers, especially for first-time homebuyers. The sales price of housing is typically
adjusted for changes in mortgage rates. The Housing Trust of Silicon Valley administers the
Santa Clara County Empower Homebuyers First Time Homebuyer Loans and HELP for
Homebuyers programs.
Table 63 displays the number of loan applications received in 2020 for the purpose of
purchasing a home in the San Jose-Sunnyvale-Santa Clara metropolitan statistical area, which
includes the City of Gilroy. Specifically, the table provides the number of total applicants, the
number of loans originated, the number of applications that were approved but not accepted
by the applicant, and the number of applications denied across various types of loans.
29 Terner Center for Housing Innovation. The Hard Costs of Construction: Recent Trends in Labor and Materials Costs for
Apartment Buildings in California. Marc 2020. https://ternercenter.berkeley.edu/wp-
content/uploads/2020/08/Hard_Construction_Costs_March_2020.pdf
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Table 63: Disposition of Home Loans, 2020
Loan Type Total
Applicants Originated
Approved
Not
Accepted
Denied Withdrawn /
Other
Conventional Purchase 24,691 15,660 644 1,942 6,445
Government Backed
Purchase 1,879 986 71 138 684
Home Improvement 5,206 2,998 165 961 1,082
Refinance 41,117 21,078 1,208 5,930 12,901
Total 72,893 40,722 2,088 8,971 21,112
Source: lendingpatternslite.com, 2020
Federal and State Programs
There is limited funding available for housing assistance programs from the state and federal
governments. For the 2021-2022 and 2022-2023 fiscal years, the City of Gilroy allocated
approximately $440,000 each year in CDBG funds from the US Department of Housing and
Urban Development. The CDBG program aims to support activities that benefit low-income
households, aid in the prevention of slums or blight, or meet an urgent community need,
through grants for eligible activities.
For the 2022 – 2023 and 2023-2024 fiscal years, the City also allocated $237,000 (each year) in
Permanent Local Housing Allocation Fund (PLHA) funds for services related to homelessness,
fair housing, and special needs, such as persons with disabilities.
Environmental and Infrastructure Constraints
Environmental hazards affecting housing units include geologic and seismic conditions, soil
conditions, flood risk, vegetation and wildlife habitat, toxic and hazardous waste, fire hazards,
noise levels, and preservation of agricultural lands. In Gilroy, seismic hazards provide the
greatest threat to the built environment. Infrastructure constraints include the availability and
cost of water and sewer services. The following hazards may impact future development of
residential units in the City and can pose a potential constraint to housing development.
Environmental Constraints
Seismic Hazards
The topography of Santa Clara County consists of three principal geologic features: the Santa
Clara Valley, the Santa Cruz Mountains, and the Diablo Range. The area is dominated by a
complex system of faults associated with motion between the Pacific and North American
plates. The most significant fault is the San Andreas Fault. The area is seismically active and
includes other major, active strike-slip faults, including the Calaveras Fault, as well as active
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folding and thrust faulting. The Sargent Fault, northeast of the City of Gilroy, has significant
potential to cause seismic shaking.
Soils
The soils in the Gilroy area consist of gravel, silt, and clay that are often poorly drained with
flooding and deposition occurring along the major streams. Because these soils exhibit site-
specific properties, site-specific studies should be completed at the project design stage to
characterize the suitability and behavior of soil for specific development applications.
Flooding
The City of Gilroy area lies within two major watersheds: the Uvas Creek watershed and the
Llagas Creek watershed. The City of Gilroy Flood Plain Management Ordinance was updated
in 2016 to adopt regulations designed to promote public health, safety, and general welfare.
The standards require all new developments in the 100-year floodplain, regardless of project
size, to develop a base flood elevation in areas without a determined base flood elevation.
Vegetation and Wildlife Habitat
Vegetation and wildlife habitat within the Gilroy area include both developed and natural
areas. Developed areas include urban and agricultural land. Natural communities include
annual grassland, coastal oak woodland, and valley foothill riparian habitat.
The 2040 General Plan includes policies aimed at protecting sensitive communities, including
wetlands and waterways (including associated freshwater marsh vegetation and riparian
corridor habitats), serpentine rock formations that support native species, and native oak
woodlands, from urban development, in-stream capital projects, and in-stream operations
and maintenance.
Toxic and Hazardous Wastes
Hazardous waste management in Gilroy includes three areas: control of production, control
of disposal, and control of transportation of hazardous waste. A limited number of hazardous
materials are produced in the City. Among those produced by point sources are waste oil,
antifreeze, solvents, x-ray solutions, and materials associated with graphic design. Hazardous
wastes associated with non-point sources include waste oil, antifreeze, and other pollutants
associated with motorized vehicles. The City of Gilroy’s Hazardous Materials Specialists and
Pretreatment Inspectors and the County Health Department regularly inspect activities that
store and/or use hazardous materials. Regular inspections and monitoring help ensure
compliance with local, state, and federal regulations and help reduce the risks associated with
the use and handling of hazardous materials and waste.
Fire Hazards
The City of Gilroy receives fire protection from the Gilroy Fire Department. The areas outside
the City are under the jurisdiction of the South Santa Clara County Fire Protection District. The
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two jurisdictions have a mutual aid agreement that allows reciprocal aid to be provided on an
as-needed basis during major emergencies.
High Fire Hazard (or “Mutual Threat Zones”) areas are designated by the district. These include
much of the hillsides on the western boundary of the City. The City of Gilroy Fire Department
has in place a hazard (weed) abatement program. The City’s Hillside Development Guidelines
contain policies relating to fire hazards.
Noise
One of the primary noise sources in the Gilroy area is traffic on local roadways, primarily the
result of tire noise on the road surface and the Union Pacific Railway line. Other typical noise
sources, as in all suburban areas, include construction, barking dogs, children playing, industry,
and recreational activities. Overflying aircraft are also occasionally audible in the Gilroy area.
These sources are not significant compared to the noise produced by the dominant
transportation sources.
The City is responsible for evaluating noise impacts as part of the review and approval process
for new discretionary project proposals. Project approval may include conditions to mitigate
noise levels for project occupants and nearby neighbors. There is no noise impact fee. The cost
of construction, as well as maintenance of noise mitigation measures, is borne by the
developer. The City of Gilroy aims to buffer residential areas from sources of noise pollution
through appropriate zoning wherever possible (e.g., locating commercial uses between
residential uses and light industrial uses).
Agricultural Lands
To protect and preserve agricultural land, the City of Gilroy adopted an Agricultural Mitigation
Policy. The policy was adopted in 2004 and revised in 2016. The California Environmental
Quality Act (CEQA) requires all feasible mitigation for significant unavoidable impacts. Upon
certification of the City’s General Plan EIR, the City Council established the Agricultural
Mitigation Policy to implement the mitigation measures identified in the 2020 General Plan EIR
for loss of agricultural lands. Therefore, significant impacts as determined under CEQA would
be subject to the City’s Agricultural Mitigation Policy. The policy establishes the criteria for
determining when mitigation would be required and what lands are acceptable for
preservation. The policy requires mitigation for the conversion of agricultural lands to urban
uses at a 1:1 replacement ratio. Mitigation may be accomplished with one of two options and
the options shall include all costs to cover program administration, monitoring and
management of established easements as outlined in the Policy.
The policy established a preferred area for the preservation of agricultural lands. This area is
located within the City’s Sphere of Influence and outside the General Plan 20-year boundary,
east of Highway 101 and south of Masten Avenue. At the time the map was created in 2004,
this area contained the greatest concentration of “Prime” and “Statewide Important” farmland
remaining in south Santa Clara County.
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All lands located within one thousand (1,000) feet of any agricultural lands deemed for
preservation shall be subject to the placement of a “right to farm” deed restriction that
conforms with both Santa Clara County restrictions as well as the State of California real estate
transfer disclosure requirements as a condition of approval for any discretionary permit. The
policy requires new developments to establish a minimum of 150 feet for an agricultural buffer
adjacent to permanent agricultural and open space areas. This applies only to a few areas in
the City, and would aim to reduce potential conflicts between agricultural and non-agricultural
uses.
The policy allows for certain exemptions from the 1:1 mitigation ratio as follows:
Up to 100 feet in width of a permanent agricultural buffer area;
Public facilities established in the City’s General Plan or Parks Master Plan; and
Lands dedicated for public rights-of-way that service the overall community, not just
the specific development.
The Agricultural Mitigation Policy poses a potential constraint to development.
Infrastructure Constraints
Water
The Llagas Basin Aquifer serves as Gilroy’s potable water source for most residential,
municipal, industrial, and agricultural land uses. It is estimated that the municipal demand will
increase to 53,000 acre-feet per year by 2040.
The City depends solely on local groundwater from wells for its water supply. Currently, there
are 15 active wells that serve three water pressure zones. The City’s water supply system relies
on well pumping from dispersed sources to supply system pressures in areas of lower
elevation during peak demand conditions. Gilroy will continue to meet its future demands
through its 2020 Urban Water Management Plan.
Sewer
The City sewer collection system consists of approximately 162 miles of 3-inch through 48-inch
diameter sewers. The system consists of trunk sewers that convey the collected wastewater
flows to the Wastewater Treatment Plant (WWTP). The WWTP, operated by the South County
Regional Wastewater Authority (SCRWA), treats the collected wastewater from the City.
During dry weather conditions, the maximum day and peak wastewater hour flows from the
City are 2.8 million gallons per day (mgd) and 5.4 mgd, respectively. During wet weather
conditions, the maximum day and peak wastewater hour flows from the City are 6.6 mgd and
20 mgd, respectively.
According to the City’s Sanitary Sewer Master Plan, the existing system was well planned to
meet the needs of existing customers. In anticipation of future growth, the City has planned
and constructed sewer facilities in conjunction with new street construction. Some project
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improvements in the master plan will mitigate flows caused by infiltration and inflows that
occur during significant storm events.
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172
CITY OF GILROY
HOUSING ELEMENT
6TH CYCLE
HOUSING SITES AND RESOURCES
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Housing Sites and Resources
Land Inventory
This section of the Housing Element addresses resources available for the development,
rehabilitation, and preservation of housing in Gilroy. It provides an overview of available land
resources and residential sites for future housing development and evaluates how these
resources can work toward satisfying future housing need. The financial and administrative
resources available to support affordable housing are also discussed.
Housing Allocation
As discussed in the needs section, California General Plan law requires that a community plan
for an adequate number of sites to allow for and facilitate production of its share of the
regional housing need. Each jurisdiction must identify “adequate sites” to determine whether
that jurisdiction has sufficient land to accommodate its share of regional housing needs for
each income level. As defined under California Government Code Section 655839(c)(1),
adequate sites are those with appropriate zoning and development standards, and with
services and facilities to encourage and provide for the development of a variety of housing
for all income levels. As shown in Table 64, Gilroy’s RHNA for the 2023-2031 (6th cycle) planning
period is 1,773 units. Broken down by income level, the allocation is 669 very low-, 385 low-,
200 moderate-, and 519 above-moderate units.
Table 64: 2023–2031 RHNA
Very Low Income Low Income Moderate
Income
Above Moderate
Income Total
RHNA 669 385 200 519 1,773
Source: Regional Housing Needs Allocation, ABAG, 2023-2031.
*Note: Pursuant to AB 2634, local jurisdictions are also required to project the needs of extremely low income households (0–
30% of AMI). The projected extremely low-income need can be assumed as 50 percent of the total need for the very low-income
households.
No Net Loss Buffer
Recent changes to state law require jurisdictions to continually maintain adequate capacity in
their site inventories. In the event that a site is developed below the anticipated density or at
a different income level than projected in the Housing Element, the City must still have
adequate sites available to accommodate the remaining balance of the RHNA. Alternatively,
the City may identify new sites or rezone sites to continue to accommodate the remaining
need. For this reason, the City is including a buffer of 15 percent above the RHNA in each
category. So, the City is planning for a capacity of 2,039 units, including 1,212 very low- and
low-income units, as shown in Table 65.
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Table 65: No Net Loss Buffer
Very Low
Income
Low
Income
Moderate
Income
Above
Moderate
Income
Total
RHNA 669 385 200 519 1,773
Buffer (20% of allocation) 100 58 30 78 266
Total 769 443 230 597 2,039
Realistic Capacity
State law requires that a jurisdiction project realistic estimates for housing capacity on its
RHNA sites. The realistic capacity of sites may be calculated using recent project history, a
minimum density, or other methods. As a majority of growth is expected to take the form of
multifamily housing, recent multifamily projects constructed were reviewed to understand
and establish historical trends for multifamily housing development in the City.
Multifamily developments in the City have had success in meeting the densities allowed by the
zoning ordinance. Recent projects in multifamily zones, their land uses, zones, and densities
are shown in Table 66. Seven (7) of the eleven (11) recent projects have achieved a yield over
100 percent of the maximum density. The average of all of these yield percentages is 111
percent, suggesting that most developments are able to meet the maximum density, or in the
case of zones with no maximum density, a density of at least 30 dwelling (du)/acre. For projects
in zones that allow densities of up to or greater than 30 du/acre, the average density of recent
projects is 33.1 du/acre. Three (3) of these recent projects utilized density bonuses; the JEMCOR
apartments, Hecker Pass apartments, and the 1st and Kern apartments.
The Cannery Apartments project yields a noticeably lower percentage of the maximum density
than the other projects on the list. This is due to an environmental constraint as Miller Slough
runs through the northern part of the parcel. There was also a homeless encampment within
the upper Miller Slough drainage channel which separates the Forest Park single-family
development from the Cannery development. Accordingly, there is an “Easement, Joint Use
and Maintenance Agreement” encumbering these three developments. Disregarding the
Miller Slough on the northern portion of the parcel, the yield is closer to 70%.
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Table 66: Recent Multifamily Project Densities
Project Land Use Zoning
Project
Density
Number
of Units
Max
Density
Yield
Percentage
The Cannery
Apartments
Cannery District
DTSP CD 21.1 104 40 53%
Cantera
Commons Mixed-
Use Apts
Downtown
Expansion District
DTSP
DED 34.5 10 N/A* 115%
Alexander Station
Apts
Downtown
Expansion District
DTSP
DED 38.7 263 N/A* 129%
Monterey/Gilroy
Gateway Apts
Gateway District
DTSP GD 40.3 75 30 134%
Kern Ave Apts LD R3 13.7 27 16 86%
Royal Way
Townhomes
(proposed)
MD R3 13.4 45 16 83%
Hecker Pass Apts MD R3 26.2 100 16 164%
Gurries Duets MD R3 17.4 4 16 109%
Gurries
Townhomes MD R3 21.1 4 16 132%
JEMCOR Apts HD R4 30.8 120 30 103%
Harvest Park Apts ND ND 35.2 81 30** 117%
Source: City of Gilroy.
* The DED district in the Downtown Specific Plan has no maximum density. As such, a maximum density of 30 was used to
ensure suitability for low-income development per HCD guidelines.
** The ND designation has a variety of densities within the designation, and there is no one maximum density for the zone.
Table 67 shows the assumed yields for higher density zones in the City. The yields were
determined based on recent multifamily trends and development standards assessed in the
constraints section. Though recent projects suggest that most projects in Gilroy are achieving
the maximum, or close to the maximum, density on sites, conservative yields were assumed
for the purposes of RHNA projection. For example, recent multifamily projects in the DED and
DHD zones have been developed at densities of 34.5, 38.7, and 40.3 du/acre. Although the DED
and DHD districts do not have maximum densities, the yield was conservatively assumed at
100 percent of 30 du/acre.
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Table 67: Assumed Yields
Zone Maximum Density Yield Estimated Yield Density
R3 20 du/acre 100% 20 du/acre
R4 30 du/acre 80% 24 du/acre
CD 40 du/acre 70% 28 du/acre
DED 30 du/acre* 100% 30 du/acre
DHD 30 du/acre* 100% 30 du/acre
GD 30 du/acre 80% 24 du/acre
Mixed-Use Corridor 30 du/acre 70% 21 du/acre
* The DED and DHD districts have no maximum density.
Assumed Affordability
Density
The California Government Code states that if a local government has adopted density
standards consistent with the population-based criteria set by the state, then HCD must accept
sites with those density standards as appropriate for accommodating the jurisdiction’s share
of lower-income units. For Gilroy, this density is 30 du/acre. Per Government Code Section
65583.2(c)(3)(B), the R4 zone, mixed-use corridor on 1st Street, and CD, DED, DHD, and GD
districts in the Downtown Specific Plan meet this requirement. Table 68 shows the income
levels, densities, and their implementing zones in Gilroy.
Moderate-income housing can be accommodated through medium- and higher-density
zones, with maximum densities ranging from 15 to 30+ du/ac. These densities support a
variety of multifamily housing typologies, including townhomes and garden-style apartments,
which may be affordable to moderate-income households. Above moderate-income housing
needs may be met through lower-density, single-family typologies, typically in the 0 to 15 du/ac
range.
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Table 68: Densities, Affordability, and Implementing Zones
Income Density Range (du/acre) Gilroy Implementing Zone
Above
Moderate 0–15 RH, LDR, RR, ND
Moderate 15-30 MDR, ND, TD, DHD, DED, TD, CD, GD, R3, R4
Low 30+ HDR, MU, ND, DHD, DED, CD, GD, R4
Very Low 30+ HDR, MU, ND, DHD, DED, CD, GD, R4
Size
Pursuant to state law, RHNA sites accommodating lower-income units must have areas
between 0.5 and 10 acres, regardless of allowed density. The identified RHNA sites for lower-
income units meet these criteria. Sites that may otherwise meet the 30 du/ac default density
but are smaller than 0.5 acres are presumed to be affordable to moderate-income
households.
The exception to this is one 0.49-acre vacant parcel in the mixed-use corridor. The site is a part
of a cluster of three vacant sites in the 1st Street mixed-use corridor (APNs: 790 39 019, 790 39
029, and 70 39 030). It is anticipated that this site could be developed together with the two
other sites, which have acreages of 0.55 and 0.97. Even if the site is developed on its own, the
0.49-acre site is functionally the same as a 0.5-acre site for the purposes of its development.
Environmental and Infrastructure Constraints
The site inventory analysis takes into consideration any environmental constraints such as
habitat, flood, noise hazards, and steep slopes, among others. Any environmental constraints
that would lower the potential yield (e.g., steep slopes) have already been accounted for in the
site/unit capacity analysis. In general, the deductions in the yield from the maximum will cover
and accommodate any reductions in site capacity due to environmental constraints.
Flooding
Portions of Gilroy fall into flood hazard zones as defined by the Federal Emergency
Management Agency (FEMA). The City has been a participating community in the National
Flood Insurance Program since August 1, 1980. Figure 40 displays the special flood hazard
areas in Gilroy. The northern part of the City falls into flood zone X, which has a 0.2 percent
annual chance of flooding; these areas are not subject to special standards. The large majority
of the City has some amount of flood risk.
The southeast portion of the City is within the AH flood zones, which indicate areas that are
subject to inundation by 1 percent annual chance of shallow flooding. Seven sites located along
Monterey Street are within this zone, including three of which have a proposed low-income
development on the site. The City has adopted a set of standards for development in the
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identified flood areas, most recently updated in 2016.30 The City allows for residential
development within its floodplains, provided mitigating strategies and design choices are
made to ensure safety and limit flood damage. In ”A“ flood zones, the construction must be
elevated to or above the base flood elevation and the lowest floor must be elevated at least
one foot above the base flood elevation. While the requirements for floodplain development
may act as minor constraints to housing production, they are not expected to reduce
development yields or preclude new housing production in general. Most of the recent and
pending projects that are not a part of the Hecker Pass or Glen Loma specific plans are located
in a flood zone. This includes the Cannery apartments, 1st and Kern apartments, Harvest Park
apartments, and JEMCOR apartments.
The City does not have any RHNA sites within floodways, which is a water channel that directly
conveys stormwater and experiences rapid velocities during wet weather events.
30 City of Gilroy Floodplain Ordinance. https://ca-gilroy.civicplus.com/DocumentCenter/View/6324/Gilroy-Flood-Ordinance-
Update?bidId=
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Figure 40: Gilroy Special Flood Hazard Areas
Source: Federal Emergency Management Agency.
Fire
The City of Gilroy does not have any areas identified as very high fire severity zones. The City
does have identified Wildland Urban Interface (WUI) areas, which are high fire risk areas, as
shown in Figure 41. The City recommends that people living in the WUI areas prepare for
wildfires by maintaining adequate defensible space around their property, hardening their
home by using building materials and installation techniques that increase resistance to heat,
flames, and embers, and having a pre-evacuation plan prepared in the event of a wildfire and
subsequent evacuation orders. The majority of the WUI is zoned for open space, Residential
Hillside RH (areas with 10%–30% slopes), R-1, and the Hecker Pass Special Use District. None
of the RHNA sites are within the WUI areas.
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Figure 41: Gilroy Wildland Urban Interface Areas
Source: City of Gilroy.
Infrastructure
Full urban-level infrastructure services are available throughout the City and to the sites in the
RHNA inventory. Specifically, water and sewer are available to all of the RHNA sites. Program
E - 1 ensures that the City will work with public service providers to ensure there is the
prioritization of services to housing developments serving lower income households in an
adopted, written procedure. All sites are located within the Urban Service Area, which is the
area of land that could potentially be developed in the next five years and where the City is
committed to providing basic infrastructure services for urban development. The City has
enough capacity to accommodate the development in the RHNA site inventory.
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Entitled and Pending Projects
The City has approved or received multiple applications for housing developments in the City.
Entitled and pending projects are shown in Table 69. The projects were grouped by the type
of development. In Gilroy, above moderate-income pending projects include 253 townhomes
in four different projects, 27 units in three mixed-use projects, and 846 units in other
subdivisions and single-family projects. There are enough pending and entitled projects to fully
meet the above moderate-income RHNA category (519 units), with a surplus of 606 units.
Other entitled and pending projects include 42 very low-, 334 low-, and 37 moderate-income
units. Lower- and moderate-income housing unit counts were based on City entitlements, and
agreements or discussions with the property developers about stated intent.
All of the lower income units identified in Table 72 are deed restricted for a period of 55 years.
The 1st and Kern and Hecker Pass apartments are both density bonus projects that are deed
restricted for 55 years. The Glen Loma Apartment Project is subject to the 15% affordable units
under the neighborhood district policy and has a 55-year regulatory agreement.
Table 69: Proposed, Entitled, and Pending Projects
Entitled and Pending Projects Very Low Low Moderate Above Moderate Total
JEMCOR Development, 1st
and Kern 12 107 1 - 120
Various Townhome
Developments - - - 253 253
JEMCOR Development,
Hecker Pass and Santa
Teresa
30 69 1 - 100
Glen Loma Apartment
Project - 158 - - 158
Various Mixed-Use Projects - - - 27 27
Other Single Family Homes,
Subdivisions, and Caretaker
Units
- - 1 650 651
Rocky Knoll Multi-family - - 34 - 34
Proposed Monterey Street
Affordable Housing Project* 20 73 1 - 94
Total 62 407 38 930 1,437
Source: City of Gilroy.
*Proposed project, not yet pending.
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Accessory Dwelling Units (ADUs)
The City of Gilroy has seen the number of ADU permits increase over recent years. A section
of the City website is dedicated to ADU information, including FAQs, links to helpful resources,
required documents, and the template to deed-restrict ADUs and Junior ADUs. Table 70
displays the recent ADU development trends in Gilroy. Based on the average number of
building permits for ADUs in the last four years (17.5), the City is conservatively projecting 140
ADUs over the 2023 – 2031 6th cycle. The City is not relying heavily on ADUs to meet its RHNA.
The City is including Programs A - 6, A - 7, and G - 3 to incentivize and specifically facilitate ADU
construction for lower income households per California Government Code section
65583(c)(7).
Table 70: ADUs Toward the RHNA
Year # of ADUs
2018 7
2019 16
2020 20
2021 27
Average 17.5
Source: City of Gilroy.
Assumed Affordability
The levels of affordability assumed for the 140 ADUs projected during the 6th cycle period is
based off of the ABAG affordability survey data.31 The study allocated 30 percent of ADUs in
each of the very low-, low-, and moderate-income categories, respectively, and the remaining
10 percent in the above moderate-income category. Table 71 displays the assumed
affordability and projected number of ADUs in each income category.
Table 71: ADU Affordability Assumptions
Percent Income Category # of ADUs
30% Very Low 42
30% Low 42
30% Moderate 42
10% Above Moderate 14
Source: ABAG ADU Technical Assistance Memo, City of Gilroy.
31 ABAG ADU Technical Assistance Memo. https://abag.ca.gov/sites/default/files/documents/2022-03/ADUs-Projections-Memo-
final.pdf
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Ability to Meet the RHNA
The City has enough existing residentially zoned land with near-term development potential
to meet its RHNA and 20 percent buffer. The existing zoning has capacity to meet the RHNA
without rezoningTable 72 through pending projects, ADUs, and both vacant and non-vacant
sites, as shown in Table 72. The development considered in this table takes into consideration
the community character as well as development constraints when evaluating each site’s
development potential. To meet the RHNA for lower-income households, the Housing Element
Sites Inventory relies on sites with densities that allow for at least 30 du/acre. To meet the
RHNA for moderate-income households, the inventory relies on sites zoned for up to 20
du/acre in the medium density General Plan land use category. In addition, smaller sites (< 0.5
acres), zoned for up to and greater than 30 du/acre, may be suitable for moderate-income
households. Housing for the above moderate-income group can be accommodated by
approved and pending projects, with a surplus of 411 above moderate units in the pipeline.
California Government Code Section 65583.2 (c) states that cities must have a program to
facilitate by-right approval for projects that include at least 20% of the units for lower-income
housing on rezone low-income sites. The City of Gilroy is not rezoning any sites to meet the
RHNA. Thus, this provision is not applicable to the RHNA sites inventory for Gilroy.
Table 72: Housing Capacity
Category Very Low Low Moderate Above
Moderate Total
Pending Projects 62 407 38 930 1,437
ADUs 42 42 42 14 140
Vacant Site Capacity 405 - 82 - 487
Non-Vacant Site Capacity 270 - 79 - 349
Total Capacity 779 449 241 944 2,683
Total Requirements (RHNA + 15%
Buffer) 769 443 230 597 2,039
Surplus/(Deficit) 10 6 11 347 -
Source: City of Gilroy.
Lower Income Capacity
Government Code Section 65583.2 (g) (2) states that housing elements relying on non-vacant
sites for greater than 50 percent of its lower-income households need to demonstrate that the
existing use does not constitute an impediment to additional residential development. This
section does not apply to Gilroy, since the City meets the 85 percent of the 1,054 unit RHNA
through vacant sites, pending projects, and ADUs, as shown in Table 73.
The City has low-income capacity through ADUs, pending projects, and vacant sites. The City is
entirely meeting its low income RHNA of 385 with proposed and pending projects and ADUs.
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In addition, the City has a projected excess of 64 units over the low-income RHNA, for a total
of 449 projected low-income units.
Fifty percent of the lower-income RHNA is 527 units. Only 15 percent of the lower-income
RHNA in Gilroy is met through the use of non-vacant sites. The City has 489 lower-income units
in proposed or pending projects and projected ADUs. It also has capacity on vacant sites for
405 additional lower-income units, for a total of 894 units (85% of the 1,054 lower-income
RHNA) on vacant, pending sites, or ADUs. These 894 units exceed the 50 percent (527 units)
threshold by 367 units, in conformance with Government Code Section 65583.2 (g) (2).
Table 73: Lower-Income RHNA Capacity
Category Units Percent of LIH RHNA
Lower Income RHNA 1,054 100%
50% of Lower Income RHNA 527 50%
Lower Income Capacity: ADU & Pending
Entitlements 489 46%
Lower Income Capacity: Vacant Sites 405 38%
Total Non-Vacant Site Capacity 894 85%
Non-Vacant Sites for LIH RHNA 160 15%
Source: City of Gilroy.
Site Details
The site selection process examined zoned capacity, existing uses, and recent development
trends to determine which parcels to include to meet the RHNA. Both vacant and non-vacant
sites are included in the RHNA.
For a detailed analysis of the sites as they relate to affirmatively further fair housing, see the
Affirmatively Furthering Fair Housing chapter.
Vacant
A portion of the RHNA will be met on vacant land that is zoned for residential use. Per HCD’s
Housing Element Sites Inventory Guidebook, a vacant site is one “without any houses, offices,
buildings, or other significant improvements […] or structures on a property that are
permanent and add significantly to the value of the property.”32 Table 74 displays the capacity
of residentially zoned vacant sites included in the inventory. A total of 487 lower- and
moderate-income units can be accommodated with currently vacant, residentially zoned land.
32 HCD Housing Element Sites Inventory Guidebook. https://www.hcd.ca.gov/community-development/housing-
element/docs/sites_inventory_memo_final06102020.pdf.
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Table 74: Residential Vacant Land Capacity
Zone/Site Capacity
1st Street Mixed-Use Corridor 30
Downtown Specific Plan – CCA 7
Downtown Specific Plan – CD 101
Downtown Specific Plan – DED 70
Downtown Specific Plan – DHD 15
Downtown Specific Plan – GD 47
Downtown Specific Plan – TD 4
Neighborhood District 31
R-3 9
R-4 173
Total 487
Non-Vacant Sites
As shown in Table 73, 894 (85%) of the 1,054 lower-income RHNA units will be met by the
pending entitlement sites, projected ADUs and vacant RHNA sites. This includes the entirety of
the 385 low-income RHNA units, with an excess of 64 units. The remaining 15% (160/1,054)
lower income RHNA units will be met on non-vacant sites in the 1st Street mixed-use corridor,
R4 zone, and Downtown Specific Plan areas.
The non-vacant sites in these areas were selected based on their existing uses, capacity for
residential redevelopment, and their high potential for short term redevelopment. Land-
improvement ratios were also calculated and considered in site selection. The comparison of
assessed values for land and improvements (land-improvement ratios) is a reliable indicator
of whether and to what extent sites are utilized. Typically, a newly improved site will have a
ratio of well under 0.2, or where the improvements are valued at five times the value of the
land.
The City has seen recent interest in redevelopment of non-vacant sites for affordable and
market rate housing. This includes a recently proposed project for a 94-unit 100% lower-
income project on three parcels in the Gateway District in the Downtown Specific Plan. Current
uses on these parcels include a two-story office building, multiple single-story commercial
structures, and their paved parking areas. This site was previously identified as a RHNA site. It
should be noted that the proposed development provides 25 more units (36%) than had been
projected – increasing our total yield and RHNA buffer of lower-income units.
Another project proposed on a non-vacant site includes the development of an affordable
housing project on land owned by Santa Clara County that currently consists of four large
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structures. While proposed for 57 units for households less than 80% of AMI, this project is not
included in RHNA projections.
The City has also received interest in developing market-rate housing from the owner of a
parcel that includes a car dealership in Downtown. These projects demonstrate the viability
and interest and plans to redevelop non-vacant sites, including active uses, for both affordable
and market-rate housing in Gilroy. These sites have similar zoning and other characteristics to
the proposed RHNA sites and therefore demonstrate the strong likelihood of meeting the
projected construction of units within the next 8 years.
Table 75 summarizes the capacity of non-vacant sites included to meet the RHNA broken down
by their existing General Plan use. The realistic capacity of non-vacant sites is 487 moderate
and low-income units.
Table 75: Non-Vacant Site Capacity
Existing GP Use Capacity
1st Street Mixed-Use Corridor 12
Downtown Specific Plan – DED 143
Downtown Specific Plan – DHD 9
Downtown Specific Plan – GD 70
R-3 8
R-4 86
PF 21
Total 349
Source: City of Gilroy.
R4 Northern Cluster
The parcels at 8985, 8955, and 8915
Monterey Road are all R-4 zoned sites
adjacent to one another, which provides an
opportunity for consolidation. There are no
existing residential uses on the sites. Their
combined acreage is 3.59 acres. The
combined realistic capacity for these sites
is 86 lower-income units. The northern and
central buildings were built prior to 1956.
8985 Monterey Road (R4 High Density)
The 0.80-acre site at 8985 Monterey Road
is currently occupied by a preschool and day care center. More than half of the lot is a parking
lot and is underutilized relative to its potential under the current zoning. It is located in the
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center of an existing residential community, making this site optimal for further residential
development. The site is near several restaurants and gyms, as well as a large park and a
grocery store, which provide necessary resources for residents. The land-improvement ratio
for this site is 1.05. The realistic capacity for this site is 19 units.
8955 Monterey Road (R4 High Density)
The 2.05-acre site at 8955 Monterey Road is currently occupied by
A church
A closed commercial building, formerly the office of a general contractor
Several storage containers
Commercial structures on the lot are single story, while the church is partially two stories.
Approximately half the site is used for parking or vehicle access. It is located in the center of
an existing residential community, making this site optimal for further residential
development. There is potential for partial redevelopment of the site, on the western portion
of the site, which could maintain some of the existing uses during redevelopment. The site is
near several restaurants and gyms, as well as a large park and a grocery store, which provide
necessary resources for residents. The assessor data did not provide a value for improvements
on this parcel so the land-improvement ratio could not be calculated. The realistic capacity for
this site is 49 units. It may be possible to achieve this capacity while maintaining some of the
existing uses, specifically the church.
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8915 Monterey Road (R4 High Density)
The 0.74-acre site at 8915 Monterey Road is currently occupied by a used car sales lot. It is
located in the center of an existing residential community, making this site optimal for further
residential development. The site is near several restaurants and gyms, as well as a large park
and a grocery store, which provide necessary resources for residents. It is nearly all surface
parking, with no expensive or modern permanent structures that would preclude
redevelopment. The land-improvement ratio for this site is 19.01. The realistic capacity for this
site is 18 units.
Monterey Cluster 1 (Downtown Expansion District)
The parcels at 7191, 7161, 7141, and 7121
Monterey Street are all adjacent to one
another, which provides an opportunity for
a larger moderate-income residential
community. The sites are near several
restaurants, a grocery store, and a train
station, which provide necessary resources
for residents. Their combined acreage is
1.32 acres. The combined realistic capacity
for these sites is 40 units.
7191 Monterey Street (Downtown Expansion
District)
The 0.34-acre site at 7191 Monterey Street is currently partially occupied by a vacant single-
story office space. More than half of the lot is a parking lot or for vehicle access and is
underutilized land. It is adjacent to an existing residential community, making this site optimal
for further residential development and potential lot consolidation. The land-improvement
ratio for the site is 0.64. The realistic capacity for this site is 10 moderate-income units.
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7161 Monterey Street (Downtown Expansion District)
The 0.32-acre site at 7161 Monterey Street is currently partially occupied by a small plumbing
and auto sales office that was built in 1930 (non-historic). More than half of the lot is parking
for the used cars being sold by the dealer. It is adjacent to an existing residential community,
as well as to several other RHNA sites, making this site optimal for further residential
development and lot consolidation. The land-improvement ratio for this site is 1.90. The
realistic capacity for this site is 10 moderate-income units.
7141 Monterey Street (Downtown Expansion District)
The 0.30-acre site at Monterey Street is currently entirely used as a parking lot or for the used
cars being sold by the auto dealer on the adjoining parcel. Redevelopment of this site would
benefit the community as its single level use as a parking lot renders the land underutilized
and below its zoning potential. It is adjacent to an existing residential community, making this
site optimal for further residential development and lot consolidation. The assessor data did
not provide a value for improvements on this parcel so the land-improvement ratio could not
be calculated. The realistic capacity for this site is 9 moderate-income units.
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7121 Monterey Street (Downtown Expansion District)
The 0.36-acre site at 7121 Monterey Street is currently a little less than half occupied by a
seafood restaurant with some outdoor dining spaces. More than half of the lot is a parking lot
or for vehicle access and is underutilized land. It is adjacent to an existing residential
community, making this site optimal for further residential development and lot consolidation.
The land-improvement ratio is 1.24. The realistic capacity for this site is 11 moderate-income
units.
Monterey Cluster 2 (Gateway/ Downtown Expansion District)
The parcels at 6790, 6620, and 6920
Monterey Street are all Gateway District
zoned sites adjacent to one another in
the General Plan defined Downtown
Specific Plan, which provides an
opportunity for a larger residential
community and a potential for lot
consolidation. 6920 Monterey Road is
included in this group of sites but is
currently Downtown Expansion District
zoned. The sites are near several
restaurants, a bulk grocery store, and a
high school, which provide necessary
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resources for residents. These sites all have high land-improvement ratios indicating strong
potential for redevelopment. These sites are adjacent to a proposed project located at 6730,
6630, and 6680 Monterey Street, which are denoted with a crosshatch in the aerial above. The
City has received a conceptual plan for 94 affordable units on the three parcels. Their
combined acreage is 3.28 acres. The combined realistic capacity for these sites is 78 units.
6920 Monterey Road (Downtown Expansion District)
The 1.69-acre site at 6920 Monterey Road is currently about two-thirds underutilized vacant
lot, with the only building being a permanently closed furniture store. It is adjacent to an
existing residential community, making this site optimal for further residential development.
The site has a land-improvement ratio of 0.81. The realistic capacity for this site is 51 lower-
income units.
6790 Monterey Road (Gateway District)
The 0.39-acre site at 6790 Monterey Road currently has an electric company building
occupying about 25 percent of the parcel, while the large majority of the site is an underutilized
surface parking lot. It is adjacent to an existing residential community, making this site optimal
for further residential development. The site has a land-improvement ratio of 2.37. The
realistic capacity for this site is 9 moderate-income units. It is possible these units could be
built without displacing the existing use.
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6620 Monterey Road (Gateway District)
The 0.53-acre site at 6620 Monterey Road is currently almost all parking lot and vehicle access,
with a small commercial construction building. It is adjacent to an existing residential
community, making this site optimal for further residential development. The site has a land-
improvement ratio of 3.33. The realistic capacity for this site is 13 lower-income units.
Monterey Cluster 3 (Gateway District)
The parcels at 6320, 6470, and 6380
Monterey Street are all adjacent to
one another in the General Plan
defined Downtown Specific Plan,
which provides an opportunity for a
larger residential community and lot
consolidation. The sites are near a
park, a school, and a grocery outlet,
which provide necessary resources
for residents. Their combined
acreage is 2.06 acres. The combined
realistic capacity for these sites is 49
units.
6320 Monterey Road (Gateway District)
The 0.55-acre site at 6320 Monterey Road is currently occupied by a single-family home and a
permanently closed hardware store. Half of the parcel is an underutilized empty lot, making
this site optimal for further residential development. The land-improvement ratio for the site
is 0.87. The realistic capacity for this site is 13 lower-income units.
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6380 and 6470 Monterey Road (Gateway District)
The 0.77- and 0.74-acre sites at 6380 and 6470 Monterey Road are currently an unoccupied
former lumber yard and associated buildings. The majority of the parcels are vacant and
underutilized. They are adjacent to an existing residential community, making these sites
optimal for further residential development. The land-improvement ratio for these sites is 1.25
and 22.52, respectively. The realistic capacity for each site is 18 lower-income units.
Monterey Cluster 4 (Downtown Expansion District)
The parcels at 7780, 7760, and 7700 Monterey Street are
all adjacent to one another in the General Plan defined
Downtown Specific Plan, which provides an opportunity
for a larger residential community and lot consolidation.
The sites are near multiple schools and a grocery store,
which provide necessary resources for residents. Their
combined acreage is 1.75 acres. The combined realistic
capacity for these sites is 52 units.
7780 Monterey Street (Downtown Expansion District)
The 0.44-acre site at 7780 Monterey Road is currently occupied by a single-story office space
and a small shed. About 25 percent of the parcel is an underutilized surface lot. Businesses
that occupy the site seem to have limited hours, which may eliminate the need for an office
space. There is also the possibility for a mixed-use development without displacement of
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existing businesses. The assessor data did not provide a value for improvements on this parcel
so the land-improvement ratio could not be calculated. The realistic capacity for this site is 13
moderate-income units.
7760 Monterey Street (Downtown Expansion District)
The 0.7-acre site at 7760 Monterey Road is currently occupied by a single-story strip mall that
includes a restaurant and a window tinting business. About 75 percent of the parcel is an
underutilized surface lot and vehicle access both in front of and behind existing businesses.
Development without displacement of existing businesses is possible. The land-improvement
ratio for the site is 0.70. The realistic capacity for this site is 21 moderate-income units.
7700 Monterey Street (Downtown Expansion District)
The 0.61-acre site at 7700 Monterey Road is currently occupied by a single story small office
park. Over half the site is underutilized lot and vehicle access. It is adjacent to several other
RHNA sites. The land-improvement ratio for the site is 0.75. The realistic capacity for this site
is 18 lower-income units.
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7310 Monterey Street (Downtown Historic District)
The parcel at 7310 Monterey Street is
currently an underutilized parking
lot. The parcel is 0.29 acres and is
adjacent to an existing residential
community, making this site optimal
for further residential development.
The site is near a grocery store,
daycare center, and a library, which
provide necessary resources for
residents. The assessor data did not
provide a value for improvements on
this parcel so the land-improvement
ratio could not be calculated. The
realistic capacity for this site is 9 moderate-income units.
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Commercial Services and Other
401 E 8th Street (R3)
The 0.58-acre site at 401 E 8th Street is currently half
occupied by a storage facility. The remaining half of
the lot is an underutilized surface parking lot. It is
located in the center of an existing residential
community, making this site optimal for further
residential development. The site is near several
restaurants, a grocery store, an elementary school,
and a daycare center, which provide necessary
resources for residents. The land-improvement
ratio for the site is 1.20. The realistic capacity for this
site is 8 moderate-income units.
880 Sunrise Drive (PF)
The 1.98-acre site at 880 Sunrise Drive is
currently two-thirds occupied by a fire
station. The remainder of the site is
vacant. The PF zone permits all facilities
owned or leased, or operated or used by
the City or other governmental agencies
on the site. It is located in the center of
an existing residential community in a
higher resource area of the City, making
this site optimal for further residential
development. The site is near several
schools and a daycare center, which
provide necessary resources for residents. The assessor data did not provide a value for
improvements on this parcel so the land-improvement ratio could not be calculated. The
realistic capacity for this site is 21 lower-income units on the vacant land and parking lot
portions of the site, while retaining the existing fire station.
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1355 1st Street (1st Street mixed-use corridor)
The 0.55-acre site is adjacent to two
vacant parcels also listed on the sites
inventory, with strong potential for
redevelopment of all three parcels.
This lot is currently occupied by a two-
story commercial building which
includes a dental care office and a
permanently closed pregnancy
resource center. The lot is currently for
sale. The building was built between
1968 and 1980. The site has a land-improvement ratio of 0.50. Existing uses are not expected
to preclude development of this site. The realistic capacity for this site is 12 lower-income units.
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Financial Resources
Countywide Programs
2016 Measure A – Affordable Housing Bond
In November 2016, Santa Clara County voters approved Measure A, the $950 million
affordable housing bond. The housing bond provides the County with an unprecedented
opportunity to partner with cities, residents, and the affordable and supportive housing
community to significantly address the housing needs of the community’s poorest and most
vulnerable residents. It will provide affordable housing for vulnerable populations including
veterans, seniors, the disabled, low- and moderate-income individuals or families, foster
youth, victims of abuse, homeless persons, and individuals suffering from mental health or
substance abuse illnesses. The bond proceeds would contribute to the creation and/or
preservation of approximately 4,800 affordable housing units in Santa Clara County.
The housing bond will enhance the County’s ability to achieve its housing priorities which
include:
Increasing the scope and breadth of supportive housing for special needs populations,
including homeless and chronically homeless persons
Increasing the supply of housing that is affordable to extremely low-income
households; and
Improving coordination and collaboration among the County, the cities, other
governmental agencies, and the affordable housing community.
$7.5 million in Measure A funds was used to develop the Monterey Gateway Senior
Apartments, a 75-unit affordable housing complex for low-income seniors that was
constructed in Gilroy in 2020.
MHAS Housing Program
The California Department of Mental Health, the California Housing Finance Agency, and the
County Mental Health Directors Association announced a new housing program under which
$400 million in Mental Health Services Act (MHSA) funds were made available to finance the
capital costs associated with development, acquisition, construction, and/or rehabilitation of
permanent supportive housing for individuals with mental illness and their families, especially
including unhoused individuals. The new MHSA Housing Program, and funds for capitalized
operating subsidies, are included in the $400 million that has been designated for the
program.
This program will serve persons with serious mental illness who are currently unhoused or at
risk of homelessness and who meet the MHSA Housing Program target population
description. Santa Clara County’s allocated amount is $19,249,300, of which $6,416,400 can be
used for capitalized operating subsidies. MHSA funding pays only for housing units designated
to qualified consumers.
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The Sobrato Transitional Apartments is an MHSA housing project in Gilroy. The Sobrato
Transitional Apartments, developed and constructed by South County Housing Corporation
(SCHC), provides 35 single-occupancy studio units in Gilroy for unhoused individuals with
incomes below 30 percent of the area median income (AMI). The SCHC will set aside 17 units
for individuals that are currently unhoused or at risk of becoming homeless due to mental
illness.
Department of Housing and Urban Development Grants
Community Development Block Grant
The City of Gilroy is an entitlement jurisdiction participating in the U.S. Department of Housing
and Urban Development’s (HUD’s) Community Development Block Grant (CDBG) Program. A
requirement of receiving CDBG funds is the City having a five-year Consolidated Plan. The Plan
identifies local community development needs and sets forth a strategy to address these
needs over a five-year period. The City’s current 5-Year Consolidated Plan spans July 1, 2020 –
June 30, 2025.
Developing an Annual Action Plan (AAP) for each of the fiscal years within the Consolidated
Plan is also required. AAP’s program the use of federal funding for their respective fiscal year
by outlining which specific projects or programs will receive funding from the annual
allocation. Funding available for housing assistance programs from the state and federal
governments is extremely limited. The AAP gives a complete breakdown of public service
descriptions and use of funds is available on the City’s website.
For the 2021-2022 and 2022-2023 fiscal years, the City of Gilroy allocated approximately
$440,000 (each year) in CDBG funds from the US Department of Housing and Urban
Development. The CDBG program aims to support activities that benefit low-income
households, aid in the prevention of slums or blight, or meet an urgent community need,
through grants for eligible activities. A breakdown of CDBG funded agencies are listed below:
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Table 76: CDBG Funded Agencies
Activity Name 2020/2021
Entitlement
2021/2022
Entitlement
2022/2023
Entitlement
Program Administration $97,250 $87,874 $87,635
Gilroy Youth Center $38,452 $38,452 $38,452
Rebuilding Home Repair Program $144,364 $140,000 $140,000
Gilroy Compassion Center $16,318 - -
Live Oak Adult Day Care $11,549 $8,560 $10,000
Meals on Wheels - $8,643 -
Community Outreach PREP - $10,250 -
Boys & Girls Club - Core Enrichment - - $8,500
C.A.R.A.S - Ryse Up Program - - $8,500
Cherry Blossom Rehab - $81,475 -
Monterey Gateway Improvements - $70,592 -
Code Enforcement $7,700 - -
Sidewalk / Curb Ramp CIP Project $156,155 - $145,090
Source: City of Gilroy, 2022
CDBG CARES ACT-Corona Virus (CDBG-CV) Funds
CDBG-CV funds were specifically made available for programming that would address the
impacts resulting from the COVID-19 pandemic, and include the following programs:
Table 77: CARES Act Funds
Activity Name Entitlement
CDBG-CV1
St. Joseph’s Rental Assistance $150,000
Small Business Assistance $125,486
CDBG-CV2
Small Business Assistance $100,000
St. Joseph's Rental Assistance $137,309
YMCA Healthy Food Delivery $100,359
Source: City of Gilroy, 2022.
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Rental Assistance/Subsistence Program
The St. Joseph’s Rental Assistance program utilizes CARES Act funding for Gilroy residents
needing rental assistance. Rent relief is provided to persons and households directly affected
by the COVID-19 pandemic.
Small Business Relief Grant Program
The Small Business Assistance Program, originally developed in 2020, includes $435,000 in
professional support for local businesses with processing applications for federal and state
loans/grants. This program aligns with the purpose of the CARES Act to provide small grants
($5,000 to $10,000) to help local businesses cope with the COVID economic downturn by
providing funds needed for working capital that will result in low-income jobs being retained
and/or created. Home Investment Partnerships Program
The HOME Program is federally funded by HUD to provide decent affordable housing to lower-
income households. The HOME Program is administered on behalf of the Urban County cities,
which includes Gilroy.
Housing Trust Fund
The City had historically allocated funding for services related to housing and homelessness
through its Housing Trust Fund (HTF). Recently, the City Council approved the replacement of
the HTF with the Permanent Housing Allocation (PLHA) Fund making more funds available for
public service addressing homeless basic need programs as well as programs that focus on
homelessness prevention. Although the HTF will no longer be made available for public service
programs or rehabilitation purposes it will continue to be used to cover consulting services for
current affordable rental and ownership agreements as well partially funding a staff position.
Permanent Local Housing Allocation Fund (PLHA)
The PLHA Fund spans a five-year period and will make available $1.4 million dollars. The City
is contracting with Santa Clara County’s’ Office of Supportive Housing to administer the
programs under the PLHA Consortium Agreement. The following agencies were approved by
the City Council for FY 22-23 and FY 23-24:
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Table 78: Permanent Local Housing Allocation Funds for FYs 2022-2024
Agency Project Funding
Amount
Homeless Prevention
St. Joseph’s Medical
Center Homeless Prevention Services $55,000
Project Sentinel Fair Housing $20,000
Project Sentinel Landlord/Tenant Counseling and Dispute Resolution $20,000
Community Agency for
Resources Advocacy and
Services (CARAS)
Homeward Bound Program $20,000
Basic Needs
The Health Trust Meals on Wheels $27,000
St Joseph’s Family Center Gilroy Street Team $35,000
South County
Compassion Center Outreach for the Unhoused $40,000
Silicon Valley
Independent Living
Center
Housing Services Program for Gilroy Residents with
Disabilities $20,000
Source: City of Gilroy, 2021.
Housing Choice Voucher Program
The Housing Choice Voucher (HCV) program is a rental assistance program that helps very low-
income families to live in market-rate housing units rather than public housing. Households
are provided with vouchers that are paid to private market-rate landlords, who are then
reimbursed by HUD. In addition to the regular voucher program, Santa Clara County Housing
Authority (SCCHA) administers special housing programs. These programs include the
Veterans Affairs Supportive Housing (VASH) Program, Mainstream Program, and Emergency
Housing Vouchers (EHV).
The VASH Program is for homeless veterans with severe psychiatric or substance
abuse disorders. The Veterans Affairs Palo Alto and SCCHA have partnered to
provide rental vouchers and supportive services to eligible veterans. The veteran
must demonstrate to the VAMC that he/she is homeless (has been living outdoors,
in a shelter, in an automobile, etc.) before being evaluated for this program.
The Mainstream Program is designed to provide assisted housing to persons with
disabilities to enable them to rent suitable and accessible housing in the private
rental market. Mainstream applicants are offered a voucher as allocations become
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available. Applicants must be participating in programs of rehabilitation and/or
support services within the community that are directly related to their disability.
The EHV program is available through the American Rescue Plan Act. Through EHV,
HUD provided SCCHA with 664 housing vouchers to assist individuals and families
who are homeless or at risk of homelessness; fleeing or attempting to flee domestic
violence, dating violence, sexual assault, stalking, or human trafficking; or were
recently homeless or have a high risk of housing instability.
Project-Based Voucher Program
The Project-Based Voucher Program provides rental assistance to households living in specific
housing sites. Because the rental assistance is tied to a particular unit, a family cannot retain
the assistance if they move (voluntarily or through eviction). The Housing Authority
administers different waiting lists by bedroom size for each project-based housing site. These
housing sites are either multifamily or senior housing developments.
Statewide Resources
There are a variety of statewide programs and resources available. The City receives regular
notification regarding state and federal funding and grant opportunities. Additionally, the City
pursues grants on a programmatic and project basis for active programs and projects in Gilroy.
Senate Bill 2 (SB2) Grant. In 2020, the City was awarded $160,000 in SB2 grant funding to create
and adopt objective design standards for mixed-use and multi-family residential projects in
Gilroy. The City also used the funding to create and adopt objective design standards for
Senate Bill 9 projects. The project implements the SB2 Objective Design and Development
Standards Policy Priority Area criteria to be eligible for SB2 funding. The goal of the project was
to create objective design standards that would: increase consistent decision making;
minimize applicant delays; better utilize staff resources; and promote/require good design
principles in Gilroy to help ensure that housing development projects conform to the City’s
minimum design expectations.
Local Early Action Planning (LEAP) Grant. In 2020, the City was awarded $150,000 in LEAP grant
funding. A portion (or potentially all) of the funding will be used to help supplement
preparation of the 2023-2031 Housing Element. Funds must be expended by December 2023.
If there is sufficient time and resources available before the end of 2023, the funds may also
be used to prepare an affordable housing policy (a 2023-2031 Housing Element program) and
update the Downtown Gilroy Specific Plan as it relates to residential or mixed-use projects. All
three of these projects were identified in the grant application as potential uses of the funds.
Regional Early Action Planning (REAP) Grant. In 2021, the City was awarded $32,603 in REAP
grant funding to further supplement costs associated with preparation of the 2023-2031
Housing Element.
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Sites and Resources ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 204
The No Place Like Home Program
The No Place Like Home Program provides loans to eligible counties to acquire, design,
construct, rehabilitate, and/or preserve permanent supportive housing for persons who are
experiencing homelessness or chronic homelessness, or who are at risk of chronic
homelessness, and who need mental health services. Projects funded through this must be
apartment complexes of five or more units.
Administrative Resources
The City of Gilroy’s Community Development Department consists of the Housing and
Community Development (HCD) Division, the Planning Division and the Building and Safety
Division which includes code enforcement. The Community Development Department helps
implement several of the programs outlined in this Housing Element with the help of the City’s
HCD Technician. The Community Development Director manages the City’s Housing and
Community Development program and administers the Community Development Block Grant
(CDBG) funds, the City's Permanent Housing Allocation (PLHA) Fund, and the former Housing
Trust fund. The Planning Division reviews land-use entitlement applications and is responsible
for the implementation of the General Plan, Zoning Ordinance, and adopted specific plans.
The Building and Safety division processes and issues building permits, conducts plan reviews,
conducts building inspections, and resolves land-use related violations through Code
Enforcement.
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205
CITY OF GILROY
HOUSING ELEMENT
6TH CYCLE
HOUSING GOALS, POLICIES, AND PROGRAMS
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Goals, Policies, and Programs ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 206
Housing Goals, Policies, and Programs
The section of the Housing Element outlines the City of Gilroy’s goals, policies, and
implementation programs for the preservation, conservation, improvement, and production
of housing for the 2023 – 2031 planning period. The goals, policies, programs, and quantified
objectives are designed to help ensure housing opportunities for all existing and future
residents of the community.
Housing Production
Goal 1
HOUSING PRODUCTION
Provide adequate residential sites to accommodate projected housing needs
and encourage the production of a variety of housing types
Policy 1.1: The City shall encourage the provision of a variety of housing options for Gilroy
residents.
Policy 1.2: The City shall strive to ensure adequate land is available at a range of densities to
meet Gilroy’s existing and projected housing needs.
Policy 1.3: The City shall encourage the provision of new affordable housing.
Policy 1.4: The City shall encourage partnerships between non-profit and for-profit housing
developers to encourage affordable housing production.
Policy 1.5: The City shall continue to implement the Downtown Specific Plan and encourage
and coordinate activities with Downtown stakeholders.
Policy 1.6: The City shall support the development of workforce housing to enable the
manufacturing workforce to live in the community.
Removal of Governmental Constraints
Goal 2
REMOVAL OF GOVERNMENT CONSTRAINTS
Remove or reduce governmental constraints to the development,
improvement, and maintenance of housing where feasible and legally
permissible.
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Goals, Policies, and Programs ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 207
Policy 2.1: Periodically review City regulations, ordinances, permitting processes, and
residential fees to ensure that they do not constrain housing development and are
consistent with State law.
Policy 2.2: The City shall continue to provide individuals with disabilities reasonable
accommodation through flexibility in the application of land use or zoning, when necessary
to eliminate barriers to housing opportunities.
Policy 2.3: The City shall consider the development of single-room occupancy units, studio
apartments, micro-units, and other similar unit types that are affordable to extremely low-
income residents in higher-density areas of the City.
Housing Preservation and Rehabilitation
Goal 3
HOUSING PRESERVATION AND REHABILITATION
Maintain and conserve the existing housing stock in a sound, safe, and
sanitary condition.
Policy 3.1: The City shall strive to preserve the affordability of existing below market rate
housing units.
Policy 3.2: The City shall promote the maintenance and rehabilitation of structures in poor
condition and take action to prevent poorly maintained properties from further
deterioration.
Policy 3.3: The City shall encourage the retention and rehabilitation of older homes in and
near the historic City Center and ensure that rehabilitation activities are sensitive to the
historic character of the building and/or site.
Housing Assistance to Meet the Needs of All Income Levels
Goal 4
HOUSING ASSISTANCE TO MEET THE NEEDS OF ALL INCOME LEVELS
Encourage and support the provision of a variety of affordable housing
types.
Policy 4.1: The City shall continue to participate in programs that assist lower- and moderate-
income households to secure affordable housing, such as the County’s Mortgage Credit
Certificate program, Housing Choice Voucher programs, and Silicon Valley’s assistance
programs.
Policy 4.2: The City shall support homeownership opportunities for low- and moderate-income
households.
Policy 4.3: The City shall provide incentives for affordable housing, including but not limited to
the density bonus ordinance and expedited project review.
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Goals, Policies, and Programs ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 208
Special Housing Needs
Goal 5
SPECIAL HOUSING NEEDS
The City shall increase access to decent and suitable housing for Gilroy
residents with special housing needs.
Policy 5.1: The City shall encourage housing opportunities for special needs groups, including:
seniors; persons with disabilities, including developmental disabilities; the homeless; large
households; single female-headed households; and farmworkers.
Policy 5.2: The City shall encourage the development, rehabilitation, and preservation of
affordable and market-rate housing for seniors, particularly in neighborhoods that are
accessible to public transit, commercial services, and health and community facilities.
Policy 5.3: The City shall support efforts to provide emergency shelter, transitional housing,
and permanent supportive housing for unhoused persons and those at risk of homelessness.
Policy 5.4: The City shall support the development of permanent and seasonal farmworker
housing in appropriate areas of the City.
Policy 5.5: The City shall encourage affordable housing developments to include units that can
accommodate large households of five or more.
Policy 5.6: The City shall encourage the development and maintenance of housing accessible
to people with disabilities, including developmental disabilities.
Affirmatively Furthering Fair Housing
Goal 6
FAIR HOUSING
Ensure equal housing opportunities for all Gilroy residents regardless of
race, color, religion, sex, sexual orientation, marital status, national origin,
ancestry, familial status, disability, or source of income.
Policy 6.1: The City shall promote fair housing standards and comply with State laws.
Policy 6.2: The City shall refer discrimination complaints to Project Sentinel or other
organizations that address housing discrimination.
Policy 6.3: The City shall prioritize economic investment and opportunity in the Downtown
Specific Plan area, especially the Racially/Ethnically Concentrated Areas of Poverty (R/ECAP)
and the Equity and Engagement District (EED), which is the focus of the City’s Environmental
Justice goals, policies, and programs.
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Goals, Policies, and Programs ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 209
Education and Outreach
Goal 7 EDUCATION AND OUTREACH
Increase awareness of and participation in housing programs.
Policy 7.1: The City shall consolidate and disseminate housing related resources to provide
better access to information on available housing programs and affordable housing units.
Policy 7.2: The City shall encourage the production of secondary units in single family districts
through outreach and educational materials.
Policy 7.3: The City shall provide information on resources available to assist residents facing
foreclosure.
Policy 7.4: The City shall encourage involvement of all Gilroy neighborhoods in the public
decision-making process.
Quantified Objectives
Government Code Section 65583 (b) requires that quantified objectives be developed with
regard to new construction, rehabilitation, conservation, and preservation activities that will
occur during the eight-year Housing Element cycle. The quantified objectives set a target goal
for Gilroy to achieve based on needs, resources, and constraints. State law recognizes that the
total housing needs identified by a community may exceed available resources and the
community’s ability to satisfy this need. Table 79 summarizes Gilroy’s quantified objectives for
the 6th Cycle.
Table 79: Total Quantified Objectives, 2023 – 2031
Target
Extremely
Low
Income
Very
Low
Income
Low
Income
Moderate
Income
Above
Moderate
Income Total
New Construction 334 335 385 200 519 1,773
Rehabilitation 80 - 80
Conservation/Preservation 156 - - 156
Total 2,009
Programs
The programs in this section of the Housing Element describe specific actions the City will carry
out over the eight- year Housing Element cycle to satisfy the community’s housing needs and
meet the requirements of State law. The programs are organized by the following seven major
housing goals:
Housing Production
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Goals, Policies, and Programs ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 210
Removal of Governmental Constraints
Housing Preservation and Improvement
Housing Assistance
Special Housing Needs
Affirmatively Furthering Fair Housing
Education and Outreach
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Goals, Policies, and Programs ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 211
A. Housing Production
Number Title Action Responsible
Party
Funding
Source Timeline
A - 1 No Net Loss
Monitoring
To ensure that the City monitors its compliance with SB
166 (No Net Loss), the City will develop a procedure to and
will track:
Unit count and income/affordability assumed on
parcels included in the sites inventory.
Actual units constructed and income/affordability
when parcels are developed.
Net change in capacity and summary of
remaining capacity in meeting remaining RHNA.
Quantified Objective: No net loss of capacity below the
RHNA requirement during the planning period.
CDD General
Fund
Adopt procedure
within one year
of Housing
Element
Adoption.
Review RHNA site
status twice
yearly and as
development
proposals are
submitted.
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Goals, Policies, and Programs ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 212
Number Title Action Responsible
Party
Funding
Source Timeline
A - 2 Surplus
Lands/Affordable
Housing on City-
Owned/Successor
Agency Sites
Assess City-owned properties for their potential
redevelopment or development for residential uses that
include housing for extremely low-income households and
those with special needs such as seniors and persons with
disabilities.
Implement the Surplus Lands Act to annually review city-
owned parcels and provide affordable housing developers
the first priority for designated surplus lands as applicable
per Government Code section 54227.
CDD General
Fund
Annual review in
conjunction with
the review of
Surplus Lands.
A - 3 By-Right Approval
of Projects with
20 Percent
Affordable Units
on “Reused”
RHNA Sites
Pursuant to the statutory requirements of Government
Code sections 65583.2(h) and (i), amend the Zoning
Ordinance to require by-right approval of housing
development that includes 20 percent of the units as
housing affordable to lower-income households on sites
being used to meet the 6th Cycle RHNA that represent
“reuse sites” previously identified in the 4th and 5th cycles
Housing Element.
CDD General
Fund
Within one year
of Housing
Element adoption
A - 4 Publicize
Residential Sites
Inventory
The City shall make the residential sites inventory available
to developers by publicizing it on the City website and
providing copies of the sites to developers.
The City shall update the list of sites annually, or as
projects are approved on the sites.
Quantified Objective: Maintain accurate and publicly
available residential site inventory throughout the
planning period.
CDD General
Fund
Post on website
within 6 months
of adoption;
update annually,
or as needed.
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Goals, Policies, and Programs ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 213
Number Title Action Responsible
Party
Funding
Source Timeline
A - 5 Revise
Neighborhood
District Policy
The City will revise the Neighborhood District policy so it
does not rely on the RDO. Revisions to the policy include:
Studying and adopting an inclusionary housing
policy and in-lieu fee for Neighborhood District
areas
Updating the Neighborhood District Target
Densities, consistent with the Gilroy 2040 General
Plan.
Adopting standards related to the distribution of
units across the levels of affordability (e.g., 30%
of the 15% affordable units shall be designated
for low income).
Adopting standards related to the term of
affordability (e.g., rental units shall be restricted
as affordable for a minimum of 55 years).
CDD General
Fund
Within three
years of Housing
Element
Adoption
A - 6 ADU Tracking and
Monitoring
Continuously track the number of building permits issued
for ADUs. If annual production rates do not match the
estimates included in the Sites Inventory of the Housing
Element, update the RHNA strategy to ensure that the City
continues to maintain adequate capacity for all income-
levels.
The City will review geographic distributions ADUs
biennially.
Quantified Objective: Increase the number of new ADUs
permitted in the City from an average of approximately
17.5 (2018-2021) to an average of approximately 25.
CDD General
Fund
Track ADU
permits as they
are submitted.
Review ADU
strategies
annually as part
of the Annual
Progress Report
process.
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Goals, Policies, and Programs ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 214
Number Title Action Responsible
Party
Funding
Source Timeline
A - 7 ADU
Preapproved
Plans
The City will develop an ADU program that includes pre-
approved, “model” plans for ADUs that meet zoning,
building, and fire codes, including designs that are ADA
accessible. The program may be modeled after successful
programs implemented in other cities.
The City will work with the Santa Clara County Housing
Collaborative on the option of creating a sub-regional
program of pre-approved ADU plans that can be available
to all residents and cities in Santa Clara County.
Quantified Objective: Increase the number of new ADUs
permitted in the City from an average of approximately
17.5 (2018-2021) to an average of approximately 25.
CDD General
Fund
Within 3 years of
Housing Element
adoption
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Goals, Policies, and Programs ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 215
Number Title Action Responsible
Party
Funding
Source Timeline
A - 8 Monitor Permit
Requirements,
Processing
Procedures and
Land Use
Controls
Implement the Land Management System for Tyler
Technologies with a "go-live" date in Spring 2023 and hold
an outreach meeting to educate users on how to utilize
the new permitting system. To assess the effectiveness of
the new Land Management System, the City will survey
users 6 months after its launch.
The City will also create metrics that track time to process
permits. These metrics can be compared year-to-year to
determine if process and procedural changes are
successful.
As a part of the City’s annual developer’s roundtable
meetings, the City shall consult builders and other parties
engaged in housing development activities to identify
potential constraints in the City’s permit requirements,
processing procedures and land use controls, and analyze
potential streamlining where feasible.
Quantified Objective: Increase the percentage of permits
that are processed online. Decrease the time it takes to
process permits.
CDD General
Fund
Spring 2023;
survey 6 months
after “go-live”
date.
Annual outreach
to builders and
developers
through the City’s
annual
Developer’s
Roundtable
meetings.
A - 9 Facilitate Missing
Middle / Middle
Income Housing
Amend the City Code to allow duplexes, triplexes, and
fourplexes to be approved ministerially in designated
zones so long as the project complies with objective
design standards.
Quantified Objective: Increased production and reduced
permitting time and cost for duplexes, triplexes, and
fourplexes.
CDD General
Fund
Within 2 years of
Housing Element
adoption
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Goals, Policies, and Programs ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 216
Number Title Action Responsible
Party
Funding
Source Timeline
A - 10 Inclusionary
Housing Policy
Conduct an inclusionary zoning feasibility study to identify
appropriate inclusionary requirements that will not
constrain housing production. Develop an affordable
housing policy and amend the Zoning Ordinance to
establish inclusionary housing requirements so that
specified new developments reserve a percentage of the
total units for lower- and moderate-income households or
pay an in-lieu of housing fee for projects below the
threshold for inclusionary housing such as smaller
projects that cannot feasibly construct affordable housing.
Quantified Objective: Increased production of affordable
housing within the City, including housing choice and
mobility for lower income households. Prioritize use of in-
lieu fees to develop affordable housing options in higher
resources areas of the City.
CDD General
Fund
By the end of
2024
A - 11 Density Bonus
Beyond State Law
Study and consider adopting a density bonus ordinance
above and beyond the minimum requirements of state
law. Specifically consider additional incentives for
households with special housing needs such as large
households, extremely low income households, and
farmworkers.
Quantified Objective: Increased housing choice and
mobility for special needs households.
CDD General
Fund
Within 2 years of
Housing Element
adoption
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Goals, Policies, and Programs ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 217
Number Title Action Responsible
Party
Funding
Source Timeline
A - 12 Coordination with
California High
Speed Rail
Authority
Continue to coordinate with the California High Speed Rail
Authority so that the Station Area Plan includes the
development of a mix of affordable and market-rate
housing and commuter parking on the parcels associated
with the High Speed Rail Station.
Quantified Objective: To develop a specific commitment to
housing development, set objective targets for the
development of affordable and market-rate housing on
the High Speed Rail site.
CDD,
California
High Speed
Rail
Authority
General
Fund
Within 2 years of
Housing Element
Adoption
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Goals, Policies, and Programs ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 218
B. Constraint Removal
Number Title Action Responsible
Party
Funding
Source Timeline
B - 1 Residential
Development
Ordinance
Removal
Repeal the Residential Development Ordinance.
The City's Residential Development Ordinance has been
made null and void by SB 330 (2019). The RDO will be
repealed as a part of the City's comprehensive zoning
update
CDD General
Fund
Concurrent with
the
comprehensive
zoning code
update,
anticipated
completion
Spring 2023.
B - 2 Zoning and
General Plan
Densities
Amend the Zoning Ordinance to ensure that the Gilroy
2040 General Plan maximum densities are achievable in
the implementing zones (Housing Accountability Act/AB
3194).
Changes include:
Increase the maximum density in the R-3
(medium density) zone from 16 to 20 du/ac;
Remove the maximum density in the R-4 (high
density) zone
Create a zoning district for the mixed-use 1st
street corridor with a density range from 20-30
dwelling units per net acre.
Create Neighborhood District High and
Neighborhood District Low zoning designations
with density allowances that are consistent with
the 2040 General Plan
CDD General
Fund
Concurrent with
the
comprehensive
zoning code
update,
anticipated
completion
Spring 2023.
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Goals, Policies, and Programs ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 219
Number Title Action Responsible
Party
Funding
Source Timeline
B - 3 SB 35 Permit
Processing
Establish and implement expedited permit processing for
qualifying affordable housing projects, pursuant to SB 35
and SB 330.
Add information regarding the expedited permit process
on the City’s website.
CDD General
Fund
Within 2 years of
Housing Element
adoption
B - 4 Public Fees,
Standards, and
Plans Online
Pursuant to AB 1483, the City will compile all development
standards, plans, fees, and nexus studies in an easily
accessible online location. The City will continue to provide
a high-quality, parcel-specific zoning map and general plan
map online.
CDD General
Fund
Within 1 year of
Housing Element
adoption
B - 5 Permit
Streamlining As a part of the 2023 comprehensive Zoning Code update,
the City is pursuing changes to streamline the permitting
process, including but not limited to:
Creating a ministerial use permit process
Creating a more transparent and streamlined
process for reviewing and approving applications
involving a historic resource (e.g., residential
addition).
Quantified Objective: Decreased permit processing time.
CDD General
Fund
Concurrent with
the
comprehensive
zoning code
update,
anticipated
completion
Spring 2023.
B - 6 Objective
Standards Review and revise development standards, design
guidelines, and findings to ensure they are objective and
facilitate development of properties at their maximum
densities.
CDD General
Fund
Within 3 years of
Housing Element
adoption
B - 7 Zoning Code
Cleanup The City will revise the definition of Townhouse to be
consistent with state law.
CDD General
Fund
Within 2 years of
Housing Element
adoption
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Goals, Policies, and Programs ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 220
C. Housing Preservation and Rehabilitation
Number Title Action Responsible
Party
Funding
Source Timeline
C - 1 Monitoring of
Units At-Risk of
Converting to
Market Rate
Continue to provide regular monitoring of deed-restricted
units that have the potential of converting to market rate.
The City currently contracts with HouseKeys to serve as the
BMR Program Administrator of the City’s below market
rate home ownership and rental property program and
monitor these units. The BMR Program Administrator will
continue to evaluate the city's current multi-family
affordable housing stock to determine if any developments
are at-risk of conversion.
Together with the BMR Program Administrator, implement
strategies to preserve projects identified as being at risk of
converting to market-rate housing. Strategies include:
Monitoring affordable housing term expiration
status annually.
Notifying property owners annually about
compliance with the extended noticing
requirement (three year, one-year, and 6 month
Notice of Intent) under state law.
Including preservation as an eligible use in Notices
of Funding Availability.
If below-market rate units appear to be at risk of
conversion, work with qualified operators, HCD,
and the property owners to preserve the housing
for lower-income households.
Biennial contact with property owners of
affordable units
Identification of funding opportunities to purchase
and preserve affordable units
CDD and
Program
Administrator
(e.g.,
HouseKeys)
General
Fund Annually review
affordable
housing term
expirations.
Noticing as
needed with
expiration of
covenants.
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Goals, Policies, and Programs ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 221
Number Title Action Responsible
Party
Funding
Source Timeline
Noticing of tenants and technical assistance with
applications for funds
Quantified Objective: Preservation of below-market rate
units.
C - 2 Housing
Rehabilitation
To enhance the quality of existing neighborhoods, the
City shall continue utilize Community Development Block
Grant (CDBG) funds, as available, to assist in the
improvement of substandard housing. For example, the
City has provided CDBG grants to the Rebuilding Together
Silicon Valley Home Repair, Rehabilitation and
Accessibility Modification program which provides a wide
range of home repair, accessibility, mobility and limited
rehabilitation improvements for low-income homeowners
in Gilroy.
The City will facilitate TEFRA hearings throughout the
planning period to allow for the development and
rehabilitation of affordable housing units throughout the
City.
Quantified Objective: Provide assistance to 100
households. Target 25% in the R/ECAP and DTSP area.
CDD General
Fund Annually
evaluate
progress and
review contract.
C - 3 Code
Enforcement
Program
Within current staffing limits, the City shall contact owners
of units identified as substandard, offering inspection
services and providing information on the Rebuilding
Together Program (or similar) and landlord/tenant
information and mediation services.
Quantified Objective: Provide information regarding the
Rebuilding Together (or similar) and landlord/tenant
information and mediation services to 240 households.
CDD General
Fund
Ongoing
throughout
planning period.
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Goals, Policies, and Programs ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 222
Number Title Action Responsible
Party
Funding
Source Timeline
C - 4 Resale Control
on Owner-
Occupied
Below Market
Rate Units
The BMR Program Administrator shall continue to
implement resale controls on owner-occupied Below
Market Rate (BMR) units to ensure that affordable units
provided through public assistance or public action are
retained per the term specified in the affordable housing
agreement (e.g., 30 years) as affordable housing stock.
Quantified Objective: Maintain all affordable units
throughout the planning period or as specified in the
affordable housing agreement.
CDD and BMR
Program
Administrator
(e.g.,
HouseKeys)
General
Fund
Annual
assessment of
units at risk of
conversion.
C - 5 Resale Control
on Rental
Below Market
Rate Units
The BMR Program Administrator shall continue to
implement resale controls on renter-occupied Below
Market Rate (BMR) units to ensure that affordable units
provided through public assistance or public action are
retained per the term specified in the affordable housing
agreement (e.g., 30 years) as affordable housing stock.
Quantified Objective: Maintain all affordable units
throughout the planning period or as specified in the
affordable housing agreement.
CDD and BMR
Program
Administrator
(e.g.,
HouseKeys)
General
Fund
Annual
assessment of
units at risk of
conversion.
C - 6 Identification
and
Preservation of
At-Risk Units
The City will complete its ongoing effort to create an
inventory of below market rate units.
In the event that the City identifies units with restrictive
covenants that expire during the 6th Cycle, the City will
ensure that owners of the properties are contacted,
encouraged to extend or renew the rent or sales price
restrictions, and ensure appropriate advanced notice of
conversion to tenants is provided.
CDD General
Fund
Within one year
of Housing
Element
adoption
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Goals, Policies, and Programs ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 223
D. Housing Assistance
Number Title Action Responsible
Party
Funding
Source Timeline
D - 1 Permanent
Local Housing
Allocation Fund
The City shall continue to utilize the Permanent Local
Housing Allocation (PLHA) Fund for all eligible activities,
including new construction, acquisition, rehabilitation,
home buyer assistance, homeless assistance, public
services related to housing, and preservation of affordable
housing.
The City also contracts with Santa Clara County’s’ Office of
Supportive Housing to administer the Permanent Housing
Allocation (PLHA) Fund, which provided $237,000 in funding
each year during the FY 22-23 and FY 23-24 funding periods
for homelessness prevention services, fair housing, and basic
needs (e.g., meals on wheels).
The City shall continue to inform non-profit organizations of
funding availability through the City’s website and
informational packets at City Hall.
Quantified Objectives: Through various eligible funding
programs, assist 80 households annually.
CDD Permanent
Local
Housing
Allocation
Fund
The PLHA funds
span a 5-year
basis. Conduct
outreach and
allocate funding
every two years
D - 2 Funding Sources
to Assist
Homeownership
The City shall pursue potential sources of additional funding
for homeownership assistance, including the availability of
State HCD, CalHFA funds, HOME, and County funds.
The City shall improve public outreach activities through the
compilation of resources for down payment assistance and
other means of acquiring a home.
Quantified Objectives: The City will annually pursue funding
for down payment assistance and increase awareness as
new funding is available.
CDD General
Fund
Pursue funding
and conduct
research
annually.
5.A.a
Packet Pg. 244 Attachment: Draft Housing Element 9-12-22 (4016 : Review of the Draft Housing Element)
Goals, Policies, and Programs ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 224
Number Title Action Responsible
Party
Funding
Source Timeline
D – 3 Housing Choice
Voucher
Referrals
The City shall provide information to City residents on the
Santa Clara County Housing Authority Housing Choice
Voucher program. This information shall also be available
on the City website.
The City shall notify interested residents and provide
technical assistance to residents who need help applying to
the Housing Choice Voucher program.
The City shall refer residents that experience discrimination
based on source of income (including vouchers) to Project
Sentinel.
Quantified Objective: Assist or refer 40 individuals annually.
CDD General
Fund
Immediately
upon opening
of HCV waitlist.
Technical
assistance to
residents as
needed. Annual
education and
outreach to
landlords.
D - 4 Pursue Funding
for Affordable
Housing
The City shall pursue funding from State, Federal, and
regional sources and support applications for funding to
help increase the supply of affordable housing. Funding
programs may include but are not limited to:
One Bay Area Grants awarded by the Association of
Bay Area Governments;
HCD Local Housing Trust Fund Program;
HUD Section 811 funding for supportive housing for
extremely low-income residents;
The state Infill Infrastructure Grant program,
sponsored by the Department of Housing and
Community Development (HCD); and
The State Multifamily Housing Program (MHP),
sponsored by HCD.
CDD General
Fund
Pursue funding
sources
annually.
5.A.a
Packet Pg. 245 Attachment: Draft Housing Element 9-12-22 (4016 : Review of the Draft Housing Element)
Goals, Policies, and Programs ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 225
Number Title Action Responsible
Party
Funding
Source Timeline
D - 5 Community
Development
Block Grant
Program
The City shall continue to utilize the Community
Development Block Grant Program for all eligible activities,
including acquisition, rehabilitation, home buyer assistance,
economic development, homeless assistance, public
services, and public improvements. The City shall continue
to inform non-profit organizations of funding availability
through the City’s website and informational packets at City
Hall.
The City expects to receive an estimated $440,000 in CDBG
funds from the U.S. Department of Housing and Urban
Development (HUD) each year. The primary objectives of
the CDBG Program include activities that benefit low-
income households, aid in the prevention of slums or blight,
or meet an urgent community need.
CDD General
Fund
Administer
funds annually.
5.A.a
Packet Pg. 246 Attachment: Draft Housing Element 9-12-22 (4016 : Review of the Draft Housing Element)
Goals, Policies, and Programs ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 226
E. Special Housing Needs
Number Title Action Responsible
Party
Funding
Source Timeline
E - 1 Priority Water
and Sewer
Service for
Affordable
Housing
Developments
Pursuant to Government Code 65589.7, work with public
service providers to ensure prioritization of services to
housing developments serving lower-income households is
adopted in a written procedure.
CDD General
Fund
Within one year
of Housing
Element
adoption.
E - 2 Zoning to
Encourage
and Facilitate
Single-Room
Occupancy
Units
As a part of the comprehensive zoning code update, the City
shall revise the Zoning Code to establish explicit definitions
for and regulatory standards addressing single-room
occupancy units.
CDD General
Fund
Concurrent with
the
comprehensive
zoning code
update,
anticipated
completion
Spring 2023.
E - 3 Emergency
Shelter
Standards
Amend the Zoning Ordinance to modify the requirements
for emergency shelters in compliance with Government
Code section 65583(a)(4).
The City will modify its zoning code to ensure that
emergency shelters are allowed by right in the City’s high
density residential zoning districts.
CDD General
Fund
Within one year
of Housing
Element
adoption.
E - 4 Low Barrier
Navigation
Centers
Pursuant to SB 48, amend the Zoning Ordinance to allow
low-barrier navigation centers, meeting specific objective
requirements, by-right in areas zoned for nonresidential
uses, including mixed-use zones and multi-family zones.
CDD General
Fund
Within one year
of Housing
Element
adoption.
5.A.a
Packet Pg. 247 Attachment: Draft Housing Element 9-12-22 (4016 : Review of the Draft Housing Element)
Goals, Policies, and Programs ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 227
Number Title Action Responsible
Party
Funding
Source Timeline
E - 5 Incentivize
Micro-Units Revise the zoning code to establish development standards
for micro-units, create incentives for micro-unit production,
and remove barriers to micro-unit development.
Ensure that provisions for efficiency units are consistent with
AB 352 (2017).
CDD General
Fund
Within one year
of Housing
Element
adoption.
E - 6 Reduced
Parking
Requirements
for Senior
Housing
The City shall conduct a study to determine if reduced
parking standards for senior housing is appropriate in Gilroy.
Based on the findings of the study, the City may revise the
Zoning Code, as necessary, to reduce parking standards for
senior housing.
CDD General
Fund
Within 3 years of
Housing Element
adoption
E - 7 Development
and
Conservation
of Housing for
Farmworkers
The City shall continue to partner with the Housing Authority
of Santa Clara County and various non-profit organizations
to explore and implement ways of providing affordable
farmworker housing including identification of State and
Federal funding opportunities.
Quantified Objective: Preserve and maintain the 4
farmworker housing developments (84 units) and Ochoa
Migrant Center (100 units).
CDD General
Fund
Ongoing
throughout
planning period.
5.A.a
Packet Pg. 248 Attachment: Draft Housing Element 9-12-22 (4016 : Review of the Draft Housing Element)
Goals, Policies, and Programs ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 228
Number Title Action Responsible
Party
Funding
Source Timeline
E - 8 Consistency
with the
Employee
Housing Act
As a part of the 2023 comprehensive Zoning Code Update,
the City shall update the Zoning Code to be consistent with
the Employee Housing Act (Health and Safety Code 17021).
This act generally requires by-right approval of employee
housing for agricultural employees (i.e., farmworker housing)
as follows:
Less than six persons: by-right in all zones allowing
single-family residential uses.
No more than 12 units or 36 beds: by-right in all
zones allowing agricultural uses.
CDD General
Fund
Concurrent with
the
comprehensive
zoning code
update,
anticipated
completion
Spring 2023.
E - 9 Priority for
Gilroy The City will develop a system to prioritize occupancy of
existing and future affordable units to the specific needs that
originate in the City of Gilroy. The City will determine how to
weigh the factors and develop a process for priority. The City
will amend the zoning code to require affordable units in
Gilroy to be sold or leased with priority given to special
needs households for:
Residents of Gilroy
Individuals working within the City of Gilroy
CDD General
Fund
Within two years
of Housing
Element
adoption
5.A.a
Packet Pg. 249 Attachment: Draft Housing Element 9-12-22 (4016 : Review of the Draft Housing Element)
Goals, Policies, and Programs ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 229
F. Affirmatively Furthering Fair Housing
Number Title Action Responsibl
e Party
Funding
Source Timeline
F - 1 Source of
Income
Protection
Within one year, coordinate with Project Sentinel to conduct
a meeting/workshop to inform residents of sources of
income protection and state rent control laws such as AB
1482.
Continue to coordinate outreach efforts to inform landlords
and tenants of recent changes to state law that prevent
source of income discrimination, including allowance of
housing choice vouchers (HCVs) to establish a renter’s
financial eligibility.
Quantified Objective: Outreach to 50 landlords or tenants
annually.
CDD General
Fund
Informational
outreach within
one year of
Housing Element
adoption. Annual
education and
outreach to
landlords and
tenants.
F - 2 Fair Housing
Counseling
The City shall continue to provide funds to and contract with
a non-profit agency to provide fair housing assistance
including landlord/tenant counseling. The City shall
disseminate information about fair housing assistance
through pamphlets in City-owned buildings and other public
locations (e.g., City Hall, Library, post office, other
community facilities) and by posting information on the City
website. Pamphlets will be made available in English and
Spanish.
Quantified Objective: Work with Fair Housing Provider to
track number of households assisted in Gilroy annually.
Provide information to 30 households annually.
CDD General
Fund
Annual or biennial
award of funds.
Provision of
pamphlets within
one year of
Housing Element
adoption.
5.A.a
Packet Pg. 250 Attachment: Draft Housing Element 9-12-22 (4016 : Review of the Draft Housing Element)
Goals, Policies, and Programs ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 230
Number Title Action Responsibl
e Party
Funding
Source Timeline
F - 3 Place-Based
Improvements
Develop programs and strategies to create place-based
improvements through investments in the public right of
way. Specific actions include:
As part of the $3.9 million Clean California Grant,
the City will renovate and beautify a portion of
Gourmet Alley and Railroad Street within the
downtown area with: pedestrian and bicycle-
friendly markings along each block; improvements
to the stormwater drainage system; additional
landscaping and lighting; new benches; cleanup
days for the alleys; and an anti-littering campaign.
As a part of downtown revitalization, the City will
construct a new downtown parking lot that will also
serve as a community resource for a Farmers
Market and community events in the downtown.
As a part of the CIP, to support economic
development in the downtown, complete Automall
Parkway Pavement Rehabilitation including
reconstruction of 20 curb ramps, addition of Class II
bike lanes, and repair and replacement of
deteriorated curb and gutter (estimated $2.4
million)
As a part of the CIP, to support pedestrian
infrastructure in the DTSP area, install and upgrade
ADA curb ramps in Downtown Gilroy
CDD, Public
Works
General
Fund Streetscape and
infrastructure
improvements will
be completed
pursuant to the
City’s CIP schedule.
The Clean
California Grant
project must be
completed by June
30, 2024
Construction of
the parking lot
with community
event space
should be
complete by the
end of 2023.
5.A.a
Packet Pg. 251 Attachment: Draft Housing Element 9-12-22 (4016 : Review of the Draft Housing Element)
Goals, Policies, and Programs ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 231
Number Title Action Responsibl
e Party
Funding
Source Timeline
F - 4 Housing
Mobility and
Choice in
Higher
Opportunity
Areas
Improve housing mobility and choice, especially in higher
opportunity areas of the City through the follow actions:
Allow duplexes, triplexes, and quadplexes that meet
objective design standards to be approved ministerially
in specified zones (Program A-9)
Adopt a density bonus beyond state law to include
incentives for special needs households (Program A-11)
Adopt an inclusionary housing policy (Program A-10)
CDD General
Fund
Within 3 years of
Housing Element
adoption.
F - 5 Displacement
Prevention
Policy
Adopt a displacement prevention policy. Measures that are
being considered for inclusion in the policy are “tenant
option to purchase agreements” for redevelopment projects
meeting specified thresholds, a just cause eviction
ordinance, and relocation agreements.
Pursuant to Government Code Sections 65583.2(g)(3) and
65915(c)(3), ensure that when existing housing is
demolished, at least an equivalent number of units at the
same affordability are created as replacements.
CDD General
Fund
Within three years
of Housing
Element adoption.
5.A.a
Packet Pg. 252 Attachment: Draft Housing Element 9-12-22 (4016 : Review of the Draft Housing Element)
Goals, Policies, and Programs ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 232
G. Education and Outreach
Number Title Action Responsible
Party
Funding
Source Timeline
G - 1 Collaboration
with
Development
Community
The City shall continue to cultivate relationships with
for-profit and non-profit development companies
working in the area of affordable housing, facilitating
collaborative approaches to affordable housing
development.
Establish new relationships and maintain existing
relationships with for-profit and non-profit
development companies throughout the planning
period.
Quantified Objective: Host an annual developer
roundtable meeting.
CDD General
Fund
Annual developer
roundtable meeting.
G - 2 Community
Outreach and
Inclusion in
the Decision
Making
Process
To implement Goal EJ 1 from the City's 2040 General
Plan Environmental Justice Element, the City will
encourage involvement of all Gilroy neighborhoods
in the public decision-making process through the
use of various methods of delivery, such as print
media, mailers, web-based information, accessible
meetings, and other methods that consider
economic and cultural considerations unique to the
City of Gilroy.
Provide all pamphlets and communications in
English and Spanish
Geographic Targeting: R/ECAP and Downtown
Specific Plan area
CDD General
Fund
Ongoing throughout
General Plan
implementation.
5.A.a
Packet Pg. 253 Attachment: Draft Housing Element 9-12-22 (4016 : Review of the Draft Housing Element)
Goals, Policies, and Programs ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 233
Number Title Action Responsible
Party
Funding
Source Timeline
G - 3 ADU
Education Develop and implement a comprehensive marketing
program to advertise the benefits of ADUs and
process for constructing ADUs.
The City will provide educational pamphlets on the
City website and at City Hall with detailed
information on the ADU process as well as basic
responsibilities and legal requirements of being a
landlord. The pamphlets will be provided in both
English and Spanish.
The City will focus outreach and education in the
higher opportunity areas of the City to expand
housing mobility and choice. Upon biennial review of
geographic ADU distribution, the City will review and
adjust promotion and outreach strategies to ensure
ADUs are being marketed in high resource areas
that are seeing less ADU construction.
Quantified Objective: Increase the number of new
ADUs permitted in the City from an average of
approximately 17.5 (2018-2021) to an average of
approximately 25.
CDD General
Plan
Develop marketing plan
within one year of Housing
Element adoption;
implement marketing
program within two years
of Housing Element
adoption. Biennial review of
ADU geographic
distribution.
5.A.a
Packet Pg. 254 Attachment: Draft Housing Element 9-12-22 (4016 : Review of the Draft Housing Element)
Goals, Policies, and Programs ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 234
Number Title Action Responsible
Party
Funding
Source Timeline
G - 4 Increased
Outreach in
Downtown
Areas
To implement Policies EJ 1.3 and EJ 1.5 from the
City's 2040 General Plan Environmental Justice
Element, the City will consult with local community
leaders in the Downtown Specific Plan Area to
ensure community priorities are being addressed.
The City will consider the viewpoints and concerns of
all neighborhoods within Gilroy when drafting the
High Speed rail Station Area Plan and when updating
the Downtown Specific Plan.
Geographic Target: R/ECAP and Downtown Specific
Plan area
CDD General
Fund
Upon receiving funding and
availability of adequate
staffing resources to
complete these area plans.
5.A.a
Packet Pg. 255 Attachment: Draft Housing Element 9-12-22 (4016 : Review of the Draft Housing Element)
Goals, Policies, and Programs ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 235
Number Title Action Responsible
Party
Funding
Source Timeline
G - 5 Housing
Outreach and
Information
The City shall provide information about housing
assistance, fair housing, housing resources, and
housing programs through a wide variety of
outreach methods such as:
Disseminating information about fair housing in
City-owned buildings and other public locations
(e.g., City Hall, Library, post office, other
community facilities) and by posting information
on the City website. Pamphlets will be made
available in English and Spanish.
Advertising housing assistance information on
the City website, through the compilation of
resources for rental assistance, down payment
assistance, and other means of retaining existing
housing or acquiring a new home.
Promoting housing resources at an
informational booth at four community events a
year, such as the Farmer’s Market in the DTSP
area.
Coordinating with the City’s Fair Housing Service
Provider to provide resources and information at
a housing resources event in the DTSP area.
Geographic Targeting: Annual housing event in the
DTSP area.
Quantified Objective: Provision of housing resources
and information through at least three different
mediums. All information made available in English
and Spanish. Annual housing event in the DTSP.
Outreach with 150 households annually.
CDD General
Fund
Update the City website
with housing information
as new resources become
available.
Annual housing event in
the DTSP area
Presence at 4 community
events annually
5.A.a
Packet Pg. 256 Attachment: Draft Housing Element 9-12-22 (4016 : Review of the Draft Housing Element)
APPENDIX A ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 236
APPENDIX A: SITES INVENTORY MAP
5.A.a
Packet Pg. 257 Attachment: Draft Housing Element 9-12-22 (4016 : Review of the Draft Housing Element)
APPENDIX A ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 237
5.A.a
Packet Pg. 258 Attachment: Draft Housing Element 9-12-22 (4016 : Review of the Draft Housing Element)
APPENDIX B ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 238
APPENDIX B: SITES INVENTORY LIST
5.A.a
Packet Pg. 259 Attachment: Draft Housing Element 9-12-22 (4016 : Review of the Draft Housing Element)
APPENDIX B ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 239
APN Address Zip
Code
Size
(Acres)
Existing
Zone
Existing General
Plan Max. Density Existing Units Very Low Income
Capacity
Moderate
Income
Capacity
Total
Capacity Existing Use Infrastructure Publicly
Owned 4th Cycle 5th Cycle
783 20 050 880 Sunrise Dr 95020 1.98 PF Low Density 15 0 21 0 21 Public Facilities Yes Yes
790 14 025 8955 Monterey Rd 95020 2.05 R-4 High Density 30 0 49 0 49 Commercial
Services Yes Yes Yes
790 14 075 8915 Monterey Rd 95020 0.74 R-4 High Density 30 0 18 0 18 Commercial
Services Yes Yes Yes
790 14 091 8985 Monterey Rd 95020 0.80 R-4 High Density 30 0 19 0 19 Commercial
Services Yes Yes Yes
790 32 052 620 Broadway 95020 0.06 R-3 Medium Density 20 0 0 1 1 Vacant Yes
790 32 053 622 Broadway 95020 0.06 R-3 Medium Density 20 0 0 1 1 Vacant Yes
790 32 054 626 Broadway 95020 0.06 R-3 Medium Density 20 0 0 1 1 Vacant Yes
790 32 055 624 Broadway 95020 0.06 R-3 Medium Density 20 0 0 1 1 Vacant Yes
790 37 003 8020 Monterey Road
Route 2 95020 1.95 GD Downtown Specific
Plan Area 30 0 47 0 47 Vacant Yes
790 39 019 1375 1st St 95020 0.97 C-3 Mixed Use Corridor
High 30 0 20 0 20 Vacant Yes Yes
790 39 029 1335 1st St 95020 0.55 C-3 Mixed Use Corridor
High 30 0 12 0 12 Commercial
Services Yes
790 39 030 1355 1st St 95020 0.49 C-3 Mixed Use Corridor
High 30 0 10 0 10 Vacant Yes
799 03 054 7733 Monterey St 95020 0.10 DED Downtown Specific
Plan Area 30 0 0 3 3 Vacant Yes
799 03 055 7711 Monterey St 95020 0.20 DED Downtown Specific
Plan Area 30 0 0 6 6 Vacant Yes
799 04 008 7601 Monterey St 95020 0.51 DHD Downtown Specific
Plan Area 30 0 15 0 15 Vacant Yes
799 04 016 7660 Eigleberry St 95020 0.18 DED Downtown Specific
Plan Area 30 0 0 5 5 Vacant Yes
799 08 039 7355 Monterey St 95020 0.06 CCA Downtown Specific
Plan Area 20 0 0 1 1 Vacant Yes Yes
799 08 040 7353 Monterey St 95020 0.07 CCA Downtown Specific
Plan Area 20 0 0 1 1 Vacant Yes Yes
799 08 041 7347 Monterey St 95020 0.13 CCA Downtown Specific
Plan Area 20 0 0 2 2 Vacant Yes Yes
799 09 028 7273 Eigleberry St 95020 0.13 TD Downtown Specific
Plan Area 20 0 0 2 2 Vacant Yes
799 10 033 7191 Monterey St 95020 0.34 DED Downtown Specific
Plan Area 30 0 0 10 10 Commercial
Services Yes
5.A.a
Packet Pg. 260 Attachment: Draft Housing Element 9-12-22 (4016 : Review of the Draft Housing Element)
APPENDIX B ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 240
APN Address Zip
Code
Size
(Acres)
Existing
Zone
Existing General
Plan Max. Density Existing Units Very Low Income
Capacity
Moderate
Income
Capacity
Total
Capacity Existing Use Infrastructure Publicly
Owned 4th Cycle 5th Cycle
799 10 034 7161 Monterey St 95020 0.32 DED Downtown Specific
Plan Area 30 0 0 10 10 Commercial
Services Yes
799 10 042 7101 Eigleberry St 95020 0.16 TD Downtown Specific
Plan Area 20 0 0 2 2 Vacant Yes
799 10 048 7141 Monterey St 95020 0.30 DED Downtown Specific
Plan Area 30 0 0 9 9 Used Car Lot Yes
799 10 049 7121 Monterey St 95020 0.36 DED Downtown Specific
Plan Area 30 0 0 11 11 Commercial
Services Yes
799 17 052 7390 Dowdy St 95020 0.22 CCA Downtown Specific
Plan Area 20 0 0 3 3 Vacant Yes Yes
799 34 036 80 W 10th St 95020 0.89 DED Downtown Specific
Plan Area 30 0 27 0 27 Vacant Yes
808 01 024 1440 Ponderosa Dr 95020 7.22 R-4 High Density 30 0 173 0 173 Vacant Yes Yes
808 21 009 10 W Luchessa Ave 95020 0.57 ND Neighborhood
District 30 0 12 0 12 Vacant Yes
808 49 078 6031 Monterey Rd 95020 0.92 ND Neighborhood
District 30 0 19 0 19 Vacant Yes
841 01 064 8340 Swanston Ln 95020 0.17 R-3 Medium Density 20 0 0 2 2 Vacant Yes
841 02 058 7840 Monterey St 95020 0.43 DED Downtown Specific
Plan Area 30 0 0 13 13 Vacant Yes
841 04 018 7700 Monterey St 95020 0.61 DED Downtown Specific
Plan Area 30 0 18 0 18 Office Building Yes
841 04 019 7760 Monterey St 95020 0.70 DED Downtown Specific
Plan Area 30 0 21 0 21 Commercial
Services Yes
841 04 020 7780 Monterey St 95020 0.44 DED Downtown Specific
Plan Area 30 0 0 13 13 Commercial
Services Yes Yes
841 08 048 7310 Monterey St 95020 0.29 DHD Downtown Specific
Plan Area 30 0 0 9 9 Parking Lot Yes
841 11 075 430 Old Gilroy St 95020 0.21 R-3 Medium Density 20 0 0 3 3 Vacant Yes
841 11 076 401 E 8th St 95020 0.58 R-3 Medium Density 20 0 0 8 8 Storage Structure Yes
841 13 022 110 Old Gilroy St 95020 3.62 CD Downtown Specific
Plan Area 40 0 101 0 101 Vacant Yes
841 14 001 7050 Monterey Hwy 95020 0.55 DED Downtown Specific
Plan Area 30 0 16 0 16 Vacant Yes
841 14 006 6790 Monterey Rd 95020 0.39 GD Downtown Specific
Plan Area 30 0 0 9 9 Commercial
Services Yes
841 14 015 6320 Monterey Rd 95020 0.55 GD Downtown Specific
Plan Area 30 1 14 0 13 Single Family
Home Yes
5.A.a
Packet Pg. 261 Attachment: Draft Housing Element 9-12-22 (4016 : Review of the Draft Housing Element)
APPENDIX B ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 241
APN Address Zip
Code
Size
(Acres)
Existing
Zone
Existing General
Plan Max. Density Existing Units Very Low Income
Capacity
Moderate
Income
Capacity
Total
Capacity Existing Use Infrastructure Publicly
Owned 4th Cycle 5th Cycle
841 14 036 6470 Monterey Rd 95020 0.74 GD Downtown Specific
Plan Area 30 0 18 0 18
Unoccupied
Commercial
Services
Yes
841 14 037 6380 Monterey Rd 95020 0.77 GD Downtown Specific
Plan Area 30 0 18 0 18
Unoccupied
Commercial
Services
Yes
841 14 081 6620 Monterey Rd 95020 0.53 GD Downtown Specific
Plan Area 30 0 13 0 13 Commercial
Services Yes
841 14 083 6920 Monterey Rd 95020 1.69 DED Downtown Specific
Plan Area 30 0 51 0 51
Unoccupied
Commercial
Services
Yes
5.A.a
Packet Pg. 262 Attachment: Draft Housing Element 9-12-22 (4016 : Review of the Draft Housing Element)
APPENDIX C ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 242
APPENDIX C: OUTREACH
September 8, 2022
Survey results for the City of Gilroy as of September 8, 2022
English Responses: 363
Spanish Responses:136
Total Reponses: 499
Q1. Please identify your relationship with the City of Gilroy. (Choose all that may apply)
Total: Answers = 495; Skipped = 4
English: Answered = 362; Skipped = 1
Spanish: Answered = 133; Skipped = 3
Q2. How long have you associated yourself with Gilroy?
Total: Answers = 490; Skipped = 9
English: Answered = 360; Skipped = 3
Spanish: Answered = 130; Skipped = 6
1%
38%
1%
7%
12%
5%
15%
3%3%5%3%2%5%
0%
66%
1%
7%6%4%
18%
7%3%
9%5%3%
8%
3%
10%
1%
17%
44%
11%
27%
0%4%2% 2%2%3%
0%
10%
20%
30%
40%
50%
60%
70%
Total Responses English Spanish
1%3%
15%18%
63%
2%2%
15%14%
68%
0%3%
15%
20%
62%
0%
10%
20%
30%
40%
50%
60%
70%
80%
Not Applicable Less than one year 1 to 4 years 5 to 10 years 10 years or more
Total Responses Spanish English
5.A.a
Packet Pg. 263 Attachment: Draft Housing Element 9-12-22 (4016 : Review of the Draft Housing Element)
APPENDIX C ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 243
Q3. Based on the map above, please indicate in which part of Gilroy you live, work, or spend the
most your time in. (Select one)
Total: Answers = 470; Skipped = 29
English: Answered = 357; Skipped = 6
Spanish: Answered = 113; Skipped = 23
Q4. Please share your age.
Total: Answers = 494; Skipped = 5
English: Answered = 360; Skipped = 3
Spanish: Answered = 134; Skipped = 2
5%
10%10%
9%
18%18%
10%
6%
7% 7%
0%
2%
15%
9%
13%
14%
7%
9%
18%
12%
6%
13%
9% 9%
19%19%
10%
6%
4%
6%
0%
2%
4%
6%
8%
10%
12%
14%
16%
18%
20%
1 2 3 4 5 6 7 8 9 10
Total Responses Spanish English
3%
16%
28%
18%17%
9%
5%4%
7%
16%
37%
20%
14%
4%
1% 1%
1%
16%
25%
16%
18%
11%
6%5%
0%
5%
10%
15%
20%
25%
30%
35%
40%
18-24 25-34 35-44 45-54 55-64 65-74 75+ Prefer not to say
Total Responses Spanish English
5.A.a
Packet Pg. 264 Attachment: Draft Housing Element 9-12-22 (4016 : Review of the Draft Housing Element)
APPENDIX C ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 244
Q5. Please share your race/ethnicity. (Choose all that apply)
Total: Answers = 491; Skipped = 8
English: Answered = 360; Skipped = 3
Spanish: Answered = 131; Skipped = 5
English Responses
White/mexican
American
Mexican/German
Asian Indian
White/hispanic
American
Mixed
Southeast Asian
Q6. Please specify the primary language and any other secondary languages spoken in your
household:
Total: Answers = 481; Skipped = 18
English: Answered = 354; Skipped = 9
Primary Language: English 335, Spanish 17, Chinese 1, Thai 1
Secondary Language: Ahmaric 1, English 23, Filipino 1, French 2, Hindi 1, Italian 1, Kutchi 1, Portuguese 1, Punjabi 1, Spanish 71, Tagalog 1, Thai
1, Urdu 1, Vietnamese 1
Spanish: Answered = 127; Skipped = 9
Primary Language: English 13, Spanish 113, Amuzgo 1
Secondary Language: English 49, Spanish 13
Q7. How many people including yourself live in your household?
Total: Answers = 489; Skipped = 10
English: Answered = 361; Skipped = 2
Spanish: Answered = 128; Skipped = 8
36%
1%
6%
43%
2%1%
11%
2%
53%
1%
8%
28%
2%1%
15%
2%1%0%1%
95%
2%0%1%0%
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
White or Caucasian Black or African
American
Asian or Asian
American
Hispanic or Latino
Another race
American Indian or
Alaska Native
Native Hawaiian or
other Pacific
Islander
Prefer not to say Other (please
specify)
Total Responses English Spanish
5.A.a
Packet Pg. 265 Attachment: Draft Housing Element 9-12-22 (4016 : Review of the Draft Housing Element)
APPENDIX C ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 245
Q8. Please select all that apply to you:
Total: Answers = 493; Skipped = 6
English: Answered = 360; Skipped = 3
Spanish: Answered = 133; Skipped = 3
Q9. Please share the total annual household income for all adults in your household:
Total: Answers = 491; Skipped = 8
English: Answered = 360; Skipped = 3
Spanish: Answered = 131; Skipped = 5
7%
20%21%
23%
14%
8%
4%
3%
9%
25%
23%
22%
10%
5%3%3%
0%
7%
14%
26%
25%
20%
7%
1%
0%
5%
10%
15%
20%
25%
30%
1 2 3 4 5 6 7 or more Prefer not to answer
Total Responses English Spanish
3%
11%10%
7%
3%2%
17%
35%
5%3%3%2%
19%
9%9%
5%4%
17%
66%
6% 6%
3%
12%
6%
29%
13%
3%
0%
44%
8%10%
1%
7%
0%
10%
20%
30%
40%
50%
60%
70%
None apply to
me
I am a senior
(65 years or
over)
I live in a
household of
more than 5
people
I am a single-
parent with
children at
home
I am disabled I am a veteran I am a renter I am a
homeowner
I am a student I have been
homeless
Prefer not to
answer
Total Responses English Spanish
26%
12%
15%14%14%
19%
12%10%
18%19%19%22%
65%
15%
8%
1% 1%
11%
0%
10%
20%
30%
40%
50%
60%
70%
Less than $45,999 $46,000 to $75,999 $76,000 to $120,999 $121,000 to $180,999 $181,000 or more Prefer not to answer
Total Responses English Spanish
5.A.a
Packet Pg. 266 Attachment: Draft Housing Element 9-12-22 (4016 : Review of the Draft Housing Element)
APPENDIX C ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 246
Q10. Please select up to three (3) of the following groups who have the greatest need for housing
and related services in the Gilroy.
Total: Answers = 449; Skipped = 50
English: Answered = 322; Skipped = 41
Spanish: Answered = 127; Skipped = 9
English Responses
The rest of everyone on this list……….
Three choices are not enough
people who make too much for low income and not enough for regular housing market. (having to make 3x the rent in
order to rent)
People who already live in Gilroy
People of all ages and income
Those working at least part time, with good credit.
Survivors of Gender Based Violence
Persons with mental health disorders.
High end housing
We are overpopulated and not enough community infrastructure and commercial retail space is available. Should be
spending money to fix the roads and cleanup the town. Make the city and downtown area more representable, modern
and safe… rather than continuing to build home and low income housing. Gilroy needs to establish a worth and community
value, not just cram everyone into the city and let it go downhill
I am not qualified to accurately answer this question
disabled mental health
Homeless
Homelessness doesn't discriminate. Homelessness occurs within every group.
Middle income families
People who already live here
Spanish Responses
Family making less than 80,000
12%
8%6%6%8%
17%
10%9%7%
3%3%
11%
1%
37%
16%
21%
12%
24%
45%
33%36%
16%
11%
5%
39%
5%
35%
41%
12%
34%
23%
62%
18%
5%
27%
3%
20%
16%
1%
0%
10%
20%
30%
40%
50%
60%
70%
Total Responses English Spanish
5.A.a
Packet Pg. 267 Attachment: Draft Housing Element 9-12-22 (4016 : Review of the Draft Housing Element)
APPENDIX C ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 247
Q11. Please select up to three (3) of the following groups who have the greatest need for housing
and related services in the Gilroy.
Total: Answers = 459; Skipped = 50
English: Answered = 323; Skipped = 40
Spanish: Answered = 126; Skipped = 10
English Responses
Builder / developer price gouging
Lack of town center in GLR
Affordable rent.
No infrastructure to support
Section 8
Over developing in areas not intended. Housing causing traffic congestions
Home prices
Getting too crowded in Gilroy. Have enough housing. Not enough services and infrastructure to support current growth let
alone future growth. Don’t want to become another San Jose. Keep open spaces and rural community.
city services and infrastructure stretched with current housing being built
parking
Irresponsible development outpacing water and services budget supply
substance abuse, mental health issues
no opinion
Unrealistic costs. Cost of housing compared to income.
poorly planned neighborhoods
Landlords that don't follow laws
Single story
Homeless encampments
Lack of funding from the State for Section 8
Dining/entertainment for residents
Too many homes are being built in the city and we are getting overpopulated. But only is there too many homes being built
causing overpopulation and causing major traffic, it enough retail and commercial areas/plazas and schools are being built
to compensate for the increasing population. Too much new homes being built and too much low income housing being
built. Too
Literally all those plus more. I can be considered to "make enough" but that doesn't reflect the responsibilities or hardships
we are all going thru and I've had to choose do I pay rent or pay my cell phone bill or put food on the table for my dying
grandparents. rent prices are terrible and can be increased at anytime and if u fight about it u lose your home
16%
23%
13%
2%
7%4%7%7%
18%
4%
37%
58%
36%
5%
15%
8%
20%22%
56%
14%
57%
77%
34%
4%
27%
18%13%14%
40%
3%
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
Total Responses English Spanish
5.A.a
Packet Pg. 268 Attachment: Draft Housing Element 9-12-22 (4016 : Review of the Draft Housing Element)
APPENDIX C ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 248
No help for domestic violence victims with kids
Too many affordable housing units being built
Renting with no dogs
No enough infrastructure to support new and existing housing
lack of creative solution
Too many condos/apts/townhomes being built
South Gilroy housing units explosive growth is straining the necessary retail support needs for grocery and pharmacy needs
to support all the new market rate housing coming on line not to mention the infrastructure of roads, water, sewer and
electrical grids. We continue to experience PG & E outages because of the service grid not keeping up with expansion
Lack of affordable housing
insufficient planning for current and future water scarcity
Allowing housing with little or no open space. Inadequate roads/highway to support the number of cars already on the
road.
Lack of ELI affordable housing
Infrastructure
Education and resources.
Shopping center / grocery stores
Undocumented folks who can’t get a job
We need affordable housing - not selling the dream of homeownership. The developers are using loopholes to
overabundance us with housing in categories well above the 2040 quotas by throwing in a few token BMR units so the
development can't be denied. They should NOT be able to build in categories above quota when the other categories are
under 100%.
Inadequate water supply; Deficit growth with housing boom; Loss of open space and farm land
Low income housing is abused by many people who abuse the system & have no intention in finding employment. Many
of these same people bring crime into our neighborhoods and make it dangerous for everyone else living in the city. I think
low income housing should be available to people who are carefully screened to verify they don’t have a history of living in
low income housing. They should only be allowed 6 months to 1 year and then be off the system. There are too many jobs
available to be unemployed or underemployed. People who abuse the system take away from people who actually need
the assistance and do not want to stay in assistance.
Price
Mentally Ill, drug addicted
This is America. Capitalism works. Stop interfering.
Permanently parked motor homes in side streets.
Cost of housing
Spanish Responses
I would like to see the city of Gilroy working more to fix the problem with the high cost of rent.
very expensive rent
Very demanding owner
More accessible costs
5.A.a
Packet Pg. 269 Attachment: Draft Housing Element 9-12-22 (4016 : Review of the Draft Housing Element)
APPENDIX C ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 249
Q12. In your opinion, please note which of the following housing types are missing or most needed
in Gilroy. (Select all that apply)
Total: Answers = 445; Skipped = 54
English: Answered = 320; Skipped = 43
Spanish: Answered = 125; Skipped = 11
Q13. Select your top three (3) programs to improve housing access in Gilroy.
Total: Answers = 422; Skipped = 77
English: Answered = 302; Skipped = 61
Spanish: Answered = 120; Skipped = 16
18%
15%
23%
11%11%
15%
7%
33%
40%
63%
24%25%
39%
21%
70%
29%
41% 41%
29% 29%
4%
0%
10%
20%
30%
40%
50%
60%
70%
80%
Extend resale, rental,
and ownership price
controls on existing
affordable units
Provide incentives to
housing developers
that restrict a portion
of units to be
affordable
Require affordable
housing units in new
developments
Allow more higher-
density (multi-family)
housing
Simplify the process to
approve projects (e.g.,
rely less on public
hearings to approve
housing projects)
Provide access to low-
cost pre-designed
plans for Accessory
Dwelling Units
Other (please specify)
Total Responses English Spanish
8%
4%5%4%3%
7%
4%6%6%5%
9%8%8%7%9%8%
30%
19%19%19%
9%
30%
14%
18%
26%
12%
43%
40%43%
32%
39%37%
42%
17%
22%
16%19%
28%
21%
46%
28%
50%
28%
13%
19%
23%
36%
20%
0%
10%
20%
30%
40%
50%
60%
Total Responses English Spanish
5.A.a
Packet Pg. 270 Attachment: Draft Housing Element 9-12-22 (4016 : Review of the Draft Housing Element)
APPENDIX C ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 250
English Responses
Housing for extremely low salaries
More Senior Housing and middle-income (not low-income) housing options
replace single houses by townhouses or at least duplexes, need more green spaces around buildings for trees
Rent control
On city owned land install a "tiny" homes project.
Less residents
Convert large single family homes to group homes and halfway houses
Section 8
Over charging on rent. Should be based on gross income
choices are too one-sided. what about current residents??
Honestly housing numbers fine just need to lower prices and build more business for local jobs and fix downtown and add
community center like MH to add revenue
Don’t need more housing unless to help young adults getting started.
tiny house communities
Workshops/incentives to ad ADU
We don't need to build more houses until we have water.
Stop building! We have too much housing and not enough resources
Standardize process approval for projects by setting community set standards that satisfy community needs
Affordable opportunities should be made for those who work, but cannot afford because it is too expensive (costs, rates,
etc.)
Restrict high density housing and keep low income to a realistic need, not exceed
Promote creation of well-paying jobs for existing residents
Fix the existing roads, why was Santa Teresa not built out to its original design 4 lanes all the way
Provide a safe parking facility
Not to build low income units without adding amenities
Use affordable housing in-lieu fees to offer down payment and mortgage rate assistance.
Offer working middle class financial backing to be able to purchase homes
Collaborate with developers to extend preferences to survivors of gender based violence
Middle income earners are being left out of the conversation. Too much money for affordable housing, but not enough for
a down-payment. What gives?
city-managed subsidies for housing choice
Perhaps landowners of the Outlets and other shopping centers would be willing to redesign the buildings to include living
spaces, since retail is struggling these days. They would have to hire an architect, so that the redesign looks inviting. This
would benefit the businesses as well, since residents would have an easy walk to shopping.
Low income or free help for tenants
incentives' for ADU's
Streamline permitting process for building ADUs
More financial help with rent for low income families
Invest in the community and infrastructure, not more homes. Take care of the town and existing residents, and not lure
more crowds into town and have it be overwhelmed.
The problem is NIMBY and as long as residents are allowed to vote on these projects. We will never reach affordable housing
because it affects their assumed property values. Every California owner only cares about their property value not the status
of their neighbor
Help domestic violence victims with housing
Better plan additional housing to be integrated with essential services like food and transit to reduce traffic congestion
while also increasing housing availability.
improve infrastructure
Gilroy is crowded enough. We don't need more building.
Stop stack-n-pack units. If Gilroy wants to grow, expand the city not put more people in a smaller space.
Build low-cost/high density housing in areas near shopping centers/grocery stores. Building low-cost housing in areas
where one would need a vehicle to get to shopping is just plain dumb and poor planning.
Please do not approve anymore high density housing. We have way to many of these as is.
Prevent landlords to increase rent prices
5.A.a
Packet Pg. 271 Attachment: Draft Housing Element 9-12-22 (4016 : Review of the Draft Housing Element)
APPENDIX C ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 251
Prioritize housing for the homeless
permanent supportive housing in Gilroy
We do not need to build housing in every plot of open land. What makes Gilroy so beautiful and what makes it stand out
are the open areas that are around the city.
Allow BMR owners empty nesters to rent extra rooms in their home without being penalized. Allow them to build ADUs
without adding restrictions.
The city needs more amenities like larger grocery stores. Morgan Hill has 3 large spacious store with 10K less in population
than Gilroy. You are overcrowding the area of First Street, Santa Theresa, and Hecker Pass. Where are the amenities?
smart planning
Create more units and access to "truly" affordable housing, geared at ELI
Education/resources for youth and young adults for homelessness prevention, and housing options from renting
apartments, to roommate living, etc.
Address the homeless encampments and escalating crime
Housing for middle income
Developers need to be required to build in the categories that have not met 2040 quotas before being allowed to build in
categories that are above 100% of 2040 quotas. They need to actually focus on creating affordable housing - rentals before
homeownership - before allowing developers to build homes - they don't build affordable housing as it's not as profitable
as the homes for sale. They also need to be required to build adequate parking along with the developments - our situation
out here at the butt end of the county and being rural has different needs than those in bigger cities - the current criteria
does not fit the needs of Gilroy that most developers and some city council members are pushing for. We do not need more
housing in the categories above 100% of 2040 quotas - we do need more affordable rentals. No more mega monstrosity
developments until there is adequate affordable housing - then the housing developments can start up again. Why is
everything geared to the developers, who already use loopholes to overabundance us with the mega monstrosities??
Attract more good jobs, not more houses!
I think Gilroy has enough housing as is. I would prefer to eliminate low income housing that has a history of police
involvement. I prefer larger city’s like San Jose to create additional low income housing. I left San Jose to get away from the
homelessness & transient issues that run rampant in San Jose.
We should not encourage the homeless to congregate in Gilroy. Living in Gilroy is not a God given right.
Tiny Homes with support services
Need more grocery stores and highway widening before building more houses. I have been grocery shopping in Morgan
Hill. The grocery stores here are always packed, day and night.
Gilroy does not need more affordable housing. If it is not affordable as is then moving to another city should be the option.
Gilroy is already too crowded and the road access has not been expanded to accommodate. None of the above programs
are necessary nor will improve Gilroy.
Stop building homes. We are too crowded. If you have to build single family homes not monster homes (2 stories 3000 sq
feet) simple single family homes
Make incentives for townhomes
No high density housing.
Spanish Responses
Control price on rent and deposits.
Extremely low income housing.
Extremely low income housing.
More low-income apartments.
Help with all the requirements they ask for to rent a place. Help with that because ultimately they exaggeratedly ask for so
many requirements to sell an apartment or house
Q14. What types of programs or activities do you believe the City should implement in the 2023-
2031 Housing Element to address housing needs? (Select your top 3 recommendations.)
Total: Answers = 437; Skipped = 62
English: Answered = 314; Skipped = 49
Spanish: Answered = 123; Skipped = 13
5.A.a
Packet Pg. 272 Attachment: Draft Housing Element 9-12-22 (4016 : Review of the Draft Housing Element)
APPENDIX C ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 252
English Responses
Promote public transit options to new home communities
Section 8
Low income apartments based on gross income
Offer housing being built to LOCAL teachers, law enforcement, firefighters
Please stop building more houses until we have more water.
Stop building, we don’t have enough resources
Promoting affordable sustainable housing that moves towards 100% solar power that can be used to give back to the
community
Promote creation of well-paying jobs for existing residents
Build more grocery stores, etc to accommodate all types of income. Gilroy is only building low income units and forcing the
existing residents to go to Morgan Hill to grocery shop
Inclusionary housing ordinance for all new and rehabbed residential development
senior units
HABITAT FOR HUMANITY HOUSING
give low or free help to tenants
Provide incentives for developments that include units that are affordable to Extremely Low-income households
Provide money to Infrastructure and planning BEFORE adding any housing
Prevent overcrowding and stop building new affordable housing complexes where they are squeezed in and increase crime
in a relatively safe area.
We need to invest in the value of our city and make it better and cleaner. More retail businesses and better quality
educational system. Good rated schools
Help CURRENT RESIDENTS WITH PROSPECTIVE HOUSING COSTS.
Get out of CA housing plan and determine city's own future. We need to remain a community, not become another suburb
of San Jose
Allow BMR owners that are now empty nesters to rent extra rooms in their home without being penalized. A lot of them
have big yards to build ADUs.
Increase ELI affordable housing
Extremely low-income need truly affordable rents
Add amnesties that compensate all the building going on in the west side. More grocery stores. Morgan hill has well
managed and clean, large grocery stores with lots of parking
Support city infrastructure
21%22%20%
25%
17%
22%23%
17%
14%15%
10%
15%
6%
16%
22%
28%
39%
21%
32%33%
26%
16%
12%11%
28%
10%
63%
54%
28%24%28%25%
0%
28%
21%22%
43%
23%
3%
0%
10%
20%
30%
40%
50%
60%
70%
Total Responses English Spanish
5.A.a
Packet Pg. 273 Attachment: Draft Housing Element 9-12-22 (4016 : Review of the Draft Housing Element)
APPENDIX C ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 253
We need to care of those that are here, before we try to attract others to move here.
We need to re-zone to incentivize dense housing near transit.
Stop all single-family detached house construction immediately, and re-zone for small businesses and jobs.
Please take care of the homeowners who already live in Gilroy & update the existing neighborhoods. Stop trying to bring in
more low income / subsidized living, it mainly attracts the type of people who do not have anything invested in this city and
when you have no skin in the game, you don’t care what your “free” home or the city looks like.
Incentivize the splitting of large plots - 1 to 5 acres - into subdivisions for Miri houses for homeless. This will mix homeless
with regular society rather than putting them in concentrated areas where they are pressured into continuing or starting
bad choices.
More lower income housing for current residents
Provide enough parking for these apartments. They overflow in to the neighborhoods and detracts from the neighborhood
There are many places to move that is more affordable and less crowded than Gilroy. We do not need to continue to cram
more housing units of various types into our already full city.
Spanish Responses
A park for children with special needs.
housing for loving adults with non-severe disabilities.
to rent or Buy a house or where to live
A park for children with special needs. Including all the children.
Q15. Please describe any other considerations, policies, or programs the City should consider
here:
Total: Answers = 130; Skipped = 369
English: Answered = 119; Skipped = 244
Spanish: Answered = 11; Skipped = 125
English Responses:
Need case managers who do not discriminate or only help who they want.
Safe Park, transitional housing, family homeless shelter
Lower taxes on single family homes
There are too many badly planned housing developments like the one next to the armory on Wren or by the south sports
park, 3' setbacks do not allow plants to improve climate control. Townhouses would be a much better option.
Low income rent control. The moreover income can save the sooner we can vacate the unit to home ownership
More affordable Recreational Programs for all ages
The city of Gilroy is sprawling everywhere and it's sad to see. Gone are the nice areas around Christmas Hill Park. Filling
every green space with housing is idiocy. I've seen this in city after city, most recently Morgan Hill. They built high density
housing on Monterey that look like prison barracks. And what followed was a whole host of problems, gun shots all hours
of the day and night, constant police calls, harassment of established single home residents, a plethora of non working
street walking thugs. Morgan Hill used to have the criminal element that rented hotel rooms and worked their crimes. Now
the city council decided to invite them to live in the city by building huge multi people cramped high rises. It was a bad
decision by the city council, one that I would hope Gilroy would be smarter about. Lets talk about infrastructure - we don't
or won't have water for increased housing. We are all cutting back drastically now! How can you allow developments to
keep building without addressing the water issue. Even the water we have is polluted with high nitrates. Don't buckle under
to developers and the lure of more tax dollars. You'll be spending far more in city services than you will ever gain. It's time
to put out the "NO VACANCY" sign.
The City must take responsibility for the fact that it’s community that is homeless is THEIR responsibility and their people.
The City needs to immediately find sites for emergency housing, tiny homes etc and stop making excuses for why they
won’t. One I hear often is prioritizing parking over housing site options. We’ve done too little for too long!
Without sufficient water resources, this area can't support any additional citizens
More police
Co-join as many programs that would help fund the housing we need
Allow below-market housing by right
Most housing requires 3x the rent or more which makes it difficult for people to get into and keep housing. Minimum wage
is not comparable to coat of living
Section 8
Helping first time owners, who live and work in the town
All current apartments should have ac units especially low income apartments
traffic and congested street parking
5.A.a
Packet Pg. 274 Attachment: Draft Housing Element 9-12-22 (4016 : Review of the Draft Housing Element)
APPENDIX C ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 254
Again housing numbers are fine, need to build up business and downtown. Expanding faster then infrastructure sewer,
water etc and PD and Fire. Let’s focus on being able to take care of what we have before expanding more. Cart behind the
horse rather than ahead of it
Support improvements on Monterey and build apartments / condos in the downtown area.
make tiny home communities on vacant lots
Stop building until we are out of the drought.
Stop building, we don’t have enough resources and we are destroying the land around us!
Public transportation, water shortage with increased housing
There should be stricter rules, consequences, for the people who are living in our street who collect a bunch of junk. Those
living conditions are a hazard to the community members who live around it to see it, smell it and live around it; putting
their/families at risk. The city of Gilroy and law enforcement should be able/allowed to enforce fines, incarceration of those
who are not following rules/penal codes.
Stop accepting money in exchange for homeless groups to be bussed and left on our streets. Bus them back to where they
came from and clean up the camps. What has happened is terrifying.
In any development there should be required large open spaces for families to enjoy. The city should be having ideas about
where to put more open parks for families, children to go and enjoy
Stop all new housing construction. Extend recycled water to existing homes for landscape use. Subsidize grey water use for
landscape. Promote creation of well-paying jobs for existing residents.
how to overcome objections to changing nature of neighborhoods in line with State focus on Affirmatively Furthering Fair
Housing
Gilroy is already overcrowded. Bringing in low income housing will lower the value of the current residents who worked so
hard to buy their homes.
Better roads so traffic moves and you can get to and on 101
A safe parking facility as a bridge between homeless and housed
Gilroy needs more amenities for all the additional housing being built. No one ever addresses this issue. There is never an
answer.
Single individuals or small workforce families 2-3 should have more help so they can get better jobs or just not be homeless.
It's crazy that you have to be a single no income person on this city to get any help with access to subsidies or other
programs.
Inclusionary housing ordinance
Policies to address the needs of people with mental illness
Minimize construction red tape
Whatever programs the city supports, the support should be for working class families - i.e., support wage earners first.
There is a need for inclusionary housing ordinances in the City of Gilroy. As far as available resources, the City does not
have full-time Detox/substance abuse facilities or services (we just have a mobile unit that comes into town 1 day per week.)
Down-Payment Assistance to Middle Income work force.
Rent control especially for low income seniors
Zoning for high density housing downtown and near Caltrain and bus lines.
Consider aesthetics (like landscaping, open space, architectural beauty, comfort, and eco-intelligence) in ALL new and
rejuvenated construction. Such aesthetics make for happier residents throughout the city, in addition to the individual
neighborhood.
Community volunteers help seniors with painting their houses, etc.
Program for Single Parents & Seniors affordable housing.
renters need free help dealing with landlords who are not ethical
Control affordable pricing.
Establish a Safe Parking Program at 8th and Alexander
Sanctioned encampments land/areas for people/families who are living in vehicles/oversized/RV’s(and in transition of
finding more permanent housing.)
Safe parking program
I think the most immediate need is for safe parking programs like the one in Morgan Hill in Gilroy
Current and new affordable housing units should have an overseeing board to improve quality and safety of individuals
and families living there
Studies, planning, to City of Gilroy’s infrastructure is required followed by funding then changes. The city’s water, sewer,
power, garbage, and school require attention. The police department needs to be increased now. The current department
is useless as they make no efforts to stop crime, or murders. The downtown buildings on Monterey Rd. are substandard.
The retail and food is lost to Morgan Hill and San Jose.
5.A.a
Packet Pg. 275 Attachment: Draft Housing Element 9-12-22 (4016 : Review of the Draft Housing Element)
APPENDIX C ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 255
The city needs to stop taking cash grabs and refuse the new building of affordable housing duplexes. The city is small and
already overcrowded. This needs to stop. It is entirely unfair to residents that have lived here more than a decade that now
have to deal with the influx of new residents and yet no increase to general infrastructure. Where are the better roads?
More schools? If you want to be greedy as a board and continue taking money grabs, at least fix the city’s infrastructure
before you allow crime and overcrowding to befall us all.
Put pressure on the State or County to provide more Section 8 funding in order to help more people with their rent.
Slow the growth of construction like Morgan Hill does
Stop building new homes and low income housing communities. We need our town to be safe and modern and be of high
value. More retail spaces, shopping plazas, entertainment
I have grown up and loved in Gilroy and Morgan Hill all my life. During the 2008 housing crisis I was pushed out of my home
forced from Morgan Hill to Gilroy and in 2021 I was officially pushed out of Gilroy to move out of state across country to
find affordable and up to code homes. It breaks my heart to leave behind my family my friends and the only place I've ever
called home. My family history goes back over 120 years in Gilroy Morgan Hill and Hollister. That is my home and to struggle
for years to desperately cling to something that clearly doesn't want to keep around is sad. You talk about bringing incentive
programs for prospective residents but why aren't you serving the ones you have? Please put in things to do in town for
families, kids, teens, and adults alike. Don't cater to the rich they have enough.
More rent controlled apartments, public housing Q&A, housing workshops to prepare prospective buyers build timelines.
Programs to help people apply for housing and not be discouraged
Have more income based housing
Please limit the number of affordable housing units being built. Gilroy has set this quota at 59%, which is much higher than
the rest of Santa Clara county. Too many affordable housing units will lead to overcrowding and crime. Plus, we simply don't
have the infrastructure to support an influx of new residents. A lot of the streets are single lane, which is already leading to
traffic problems during peak hours.
Too many low income housing will negatively affect current homeowners who have worked so hard to purchase and
maintain their home. Our rights to maintain our home value need to be protected too.
make tiny home communities on vacant lots
I cannot stress enough the fact that the current housing being built is often far from basic things like schools, food/groceries,
and good public transit. Without integrating these things into new community developments, the city will have increasingly
terrible traffic and turn into a smaller version of the San Jose area, which is ridiculously congested.
Gilroy doesn't need to attract more homeless.
make sure people who are getting support from the county actually need it--way too much abuse of the housing program
Realistic infrastructure needs for housing and business growth to support outlaying areas expansion
Tenant protections against evictions that lead to more homelessness.
Gated parks with cameras
More options for homeless housing/encampments.
Homeless programs need to be set up for our community. People are living in their cars in our neighborhood parks, on
our county creeks and our city streets. It becomes a very unsafe environment for people just trying to enjoy our community.
We need to keep moving these encampments off our city and county areas so they reach out to programs being provided
for them.
Please no more duplexes or apartments. Gilroy has been attracting a lot of people who commit petty crimes. I think if you
allow more high density housing crime will get worse. We already have more than enough people living here. Let’s instead
concentrate on our homeless problem as well as use funds to spruce up the Gilroy we already have. The streets do not
need anymore people on them it’s congested enough all ready. The grocery stores are always packed as well. We do need
anymore housing.
Cleaning up the homeless problem
People with disabilities and seniors are who are on fixed incomes are being left out of the planning very often. Limited
funding for rental assistance and accessing it is very difficult if you are not the agency holding the purse strings.
Undocumented workers and seniors with little income are also being left out of the equation
A solid plan for housing the homeless, including a plan for the homeless with pets or those that do not want to participate
and insist on living in tents
Designate a staff associate to housing and funding availability from county and state programs.
This City is behind in creative ways to house the homeless. Think Tiny houses, church parking spaces for families to have
safe overnight stays, even if it’s their cars and have services there; etc.
I believe we must address housing needs of low income, very low income, and unhoused people. I believe all other new
housing should be proven sustainable before approved for building. California is facing resource scarcity issues--notably
water shortages--which must be built into planning.
We do not need to build housing on every open piece of land. Keep Gilroy beautiful. There is a responsible way to build
homes.
Allow BMR owners that are now empty nesters to rent extra rooms in their home without being penalized. A lot of the have
big yards to build ADUs.
5.A.a
Packet Pg. 276 Attachment: Draft Housing Element 9-12-22 (4016 : Review of the Draft Housing Element)
APPENDIX C ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 256
Restrict the number of housing units being built. Gilroy is growing too big and a majority of its residents do not work in the
area or support living here. Everyone is on the road for more than two hours to and from work in Silicon Valley. We need
better transit systems and better road conditions before allowing more people to move to Gilroy and travel on an already
inadequate highway system.
Need more amenities. Y developing the land around the outlets with businesses, it would bring income into the city
Consider impact on current residents and impact on traffic, fire and police infrastructure, water needs and environment.
Infrastructure. As a member of the Gilroy community, we need to have a town where we feel comfortable in and is
sustainable. Everything is crumbling around the city and why bill more when the cost to live here is not affordable.
Referencing the utilities like water garbage and PG&E. They are skyrocketing and at the same time nothing is being done to
maintain these systems except increase pricing on the homeowner. Our downtown looks like shit and no one wants to visit
it. We need restaurants and nice parks roads. We can’t build more housing without supporting the surrounding areas
I see so many of my peers experiencing homelessness because after their parents or whomever they lived with moved
away, or their loved one died, they had no idea what to do. I experienced homelessness myself as a child, again as young
adult, and now live in constant fear of not having somewhere to be safe or rest my head. I don't have any kids and make
less than 30, 000 year so there just isn't any resources for me. And if there are, it should be easily available information. All
I see is list with apartment phone numbers. Just not enough education on this very important matter. Thankyou.
Do not continue to expand Gilroy with new builds without updating our infrastructure and businesses -traffic is terrible, the
houses and neighbors we do have aren’t nice, both of our major grocery stores are right next to one another, current
residents need better quality of life before we grow
Renters must make 3x rent amount to qualify for an apartment is impossible in most cases! Finding other ways to qualify
Homes for seniors, single stories, 55+ adult communities.
Coordinate county services with new affordable housing to house homeless individuals
Expand our amenities on the west side. The city is forcing us to shop in Morgan hill because we have no consideration for
expansion except to add more housing
I get $1000 a month for disability my rent is $1000 in the trailer park I can’t make ends meet soon I will be homeless
Need supervised housing for small groups of mentally ill who can't adequately care for themselves or take their medication
reliably.
Sports programs for the young to teenagers
Don't allow apartments to be built right next to nice single family homes.
Most of us moved to Gilroy for the small rural town vibe - we do not want to be the next big city with big city problems. The
2040 quotas arbitrarily assigned by the state politicians who are totally out of touch with "our “reality will double Gilroy’s
population. We need to preserve the small town feel rather than give in to mass growth- we need smart growth, not
overgrowth.
Beautification of Old Gilroy, paving, implement Standard for apartment appearance.
I'd love to see an aggressive effort to up zone our main downtown commercial areas to allow residential/mixed retail. We
should build strong transit links to the job centers in Santa Clara County.
Stop all single-family detached house construction immediately, and re-zone for small businesses and jobs.
No new housing! We need good restaurants with outdoor seating. More grocery stores such as Whole Foods. And a
downtown renovation, and we need to preserve the open space we have. No new housing projects!!
Plan housing with transportation connections, plan for active transportation, consider climate change needs
I wish the city would install speed bumps down high traffic roads such as Wren Ave. Drivers have no regard for the speed
limit or kids playing/walking in the area. High speed drivers are a safety concern and a noise nuisance.
Inclusionary ordinance
There needs to be affordable and low income housing in all areas of Gilroy, not just the north area. It is like the west side is
exclusive and does not allow homes in that area. For too many years Gilroy has focused affordable low income housing in
North Gilroy
Stop growing the city so quickly and fix the existing issues. We don’t have enough grocery stores here. We don’t have
enough police force available. All this excessive building is just bringing more crime to the area. We are no longer a safe
city. Have you seen all these new people drive around here like we are in a Grand Prix. These new housing are not doing
anything if but making our infrastructure worse. They are not bringing new kids to schools locally because they can
commute with kids. Our district is broken, work on that. We can have six Starbucks but not enough places to buy food?
Focus on the city improvements first
Buy the large plot on las animas and create a better tent area with drug control, security, showers and laundry
Rent too high
There are more affordable places to live. It isn't any city's responsibility to make their location a handout resource using
hardworking taxpayers earnings.
Build affordable housing in a nice community
Please add Safe Park with support services
5.A.a
Packet Pg. 277 Attachment: Draft Housing Element 9-12-22 (4016 : Review of the Draft Housing Element)
APPENDIX C ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 257
It’s become increasingly difficult for just the regular service employer (truckers, utility workers, health care admins) to qualify
for purchasing a home that so many have to leave the area just to have a respectable home. The lower middle class are
now considered low income and there needs to be more than just one unit per housing development designated for the
low income. Good people in good homes equals a good city. It’s insane that we expect everyone to make $250k to live here
comfortably, we miss that small town feel.
There are so many things wrong with this town. Stop building high density housing. It looks like a ghetto. The ones being
built on first and Kern are going to be a nightmare. Not enough parking and the traffic lights to handle the traffic.
I believe that understanding individual households and their needs is essential to gaining knowledge for the housing
element of Gilroy. For instance, I am a single parent to two children. I’ve been renting for the past 6 years and make $170k
a year. The rental rates are darn near worse than mortgage rates. It is not helping to provide an option of purchasing in this
area. The housing crisis of cost and not even having homes that can suit people’s different family needs is unfair. Creating
factory type housing of all homes bunched together is not what everyone purchasing a home wants. Preferably homes can
be made with decent yard space to allow for personal gardening of produce and chickens.
Speed traps or speed bumps on W Las Animas Ave. This is an accident waiting to happen. Vehicles passing through from
Monterrey rd. to church (and vice versa) use this as an expressway at very high speeds. Please look into it.
Do not continue to make Gilroy more over crowded than it already has become. The infrastructure to get in and out of
Gilroy needs to be expanded. We do not need to make the city more appealing to increase the city population.
More work to improve our downtown, more restaurants and shopping. Not everything has to be low income focused, there
are a lot of middle class families that love living here and would like more amenities.
Spanish Responses:
Loans for home purchase
Loans and Incentives for Home Purchases They should encourage opportunities to own your own home and not pay rent
Lifelong
Free music classes.
More jobs
Base rents
Low cost housing is in high price
housing
Open space for exercise
Financial Aid for layer buyer
Childcare
Q16. Have you or someone you know ever encountered any of the forms of housing discrimination
described above?
Total: Answers = 421; Skipped = 78
English: Answered = 297; Skipped = 66
5.A.a
Packet Pg. 278 Attachment: Draft Housing Element 9-12-22 (4016 : Review of the Draft Housing Element)
APPENDIX C ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 258
Spanish: Answered = 124; Skipped = 12
English Responses
Predatory lending is rampant despite your income.
Same house is appraised for more due to buyers “assumed” race
Spanish Responses
For having a dog
Q17. If you believe that you or someone you know encountered housing discrimination, please
identify when that occurred (Please check all that apply)
Total: Answers = 312; Skipped = 187
English: Answered = 214; Skipped = 149
Spanish: Answered = 98; Skipped = 38
Q18. If you believe that you or someone you know encountered housing discrimination, please
identify the when that occurred (Please check all that apply)
Total: Answers = 334; Skipped = 165
English: Answered = 232; Skipped = 131
13%
31%
17%
27%
18%
36%
10%6%12%7%11%13%9%6%8%11%6%10%
71%
58%
66%
56%
70%
40%
ENGLISH SPANISH ENGLISH SPANISH ENGLISH SPANISH
BAY AREA SANTA CLARA COUNTY GILROY
In the last 2 years In the last 5 years More than 5 years ago Not applicable. Not aware of any discrimination
3%
53%
18%
4%
8%
11%
3%1%
3%
65%
15%
0%
6%
11%
2%1%3%
40%
32%
9%
15%
10%
3%
1%
0%
10%
20%
30%
40%
50%
60%
70%
Not applicable or
prefer not to say
No, I have not Yes, I have I think it happened
to me
I'm not sure I know someone
who has
I think I may know
someone who has
Other (please
specify)
Total Responses English Spanish
5.A.a
Packet Pg. 279 Attachment: Draft Housing Element 9-12-22 (4016 : Review of the Draft Housing Element)
APPENDIX C ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 259
Spanish: Answered = 102; Skipped = 34
English Responses
Homelessness
I know of no situations like this.
I do not know enough citizen of Gilroy to be able to answer this question
Realtors themselves are discriminatory -
Not accepting housing voucher
Amount of income
Not aware of discrimination specific cases
no opinion
I don’t know
victims/survivors of gender based violence
Criminal background
Unsure
Financial discrimination. Most time a standard practice is first months rent plus last month's rent plus a security deposit
plus a pet deposit. Then application fee. Easily over 7 to 8 k. Who the he'll has that saved
Criminal record (non violent)
Unknown
Consult Project Sentinel for this data.
I unaware of housing discrimination; we were hit with predatory lenders.
Housing Cost
Mentally ill and homeless
I do not see any discrimination
i don't feel comfortable saying Gilroy has 0 housing discrimination just because i haven't personally seen any. I’m white, so
where it does exist, I’d never experience it.
Q19. Please indicate whether you feel your city is: (Select one)
Total: Answers = 337; Skipped = 162
English: Answered = 266; Skipped = 97
Spanish: Answered = 71; Skipped = 65
20%
2%
7%
4%
8%
3%6%
3%
7%6%
19%
13%
3%
35%
2%
15%
8%9%
5%
13%
4%
14%
11%
34%
38%
9%
56%
11%
18%
9%
32%
11%13%11%
16%18%
55%
8%
0%
0%
10%
20%
30%
40%
50%
60%
Total Responses English Spanish
5.A.a
Packet Pg. 280 Attachment: Draft Housing Element 9-12-22 (4016 : Review of the Draft Housing Element)
APPENDIX C ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 260
English Responses
I don’t know
I know little about the many neighborhoods in Gilroy
Economic segregation
One of the truly great things in CA is it's diversity - but everyone needs to understand the laws that this state, county and
cities have adopted and abide by them.
Unsure
Unsure
Gilroy, like everywhere, is segregated by socio economic class, which aligns pretty well with race in the US.
unsure
Gilroy is pretty diverse with the exception of east of the tracks
Unsure
I think it is somewhat diverse.
Wonderfully diverse.
no significant Communities of Interest in Morgan Hill
Latinos who are lower income on east side I would guess
This is a poorly framed question, and serves little to no purpose.
Have not seen any stats on that
It is neither but can become segregated if the city doesn’t intervene
Not sure
It could be more integrated.
Gilroy seems to have concentrations of fewer ethnicities than most of the Bay Area.
Segregated by income which leads to segregation by race.
Unsure
Unsure
Unsure
Getting devalued and deprecated
i don’t know
I don't know
somewhat segregated
Unsure
Depends on affordability and income. You cannot buy or rent a Cadillac on a Chevrolet budget. My concern is for those
who think they are “owed” the right to higher housing and don’t want to work for it.
We have a large Hispanic population but it doesn't show in the newly developed homes.
46%
40%
14%
44%
38%
18%
57%
40%
3%
0%
10%
20%
30%
40%
50%
60%
Racially Segregated (defined as a high concentration of
persons of a particular race or ethnicity in a particular
geographic area when compared to the broader Bay
Area)
Racially Integrated (defined as not containing a higher
concentration of a particular protected class such as
race or ethnicity)
Other / Unsure.
Total Responses English Spanish
5.A.a
Packet Pg. 281 Attachment: Draft Housing Element 9-12-22 (4016 : Review of the Draft Housing Element)
APPENDIX C ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 261
I'm not really sure how racially segregated Gilroy is. I do know that a large port ion of the Hispanic population lives east of
Monterey Street and a very large portion of the white population lives west of Monterey Street.
No comment
More low income Mexican people live on the East side, but I think it is a result of income, not discrimination. Many Mexican
people live in all parts of Gilroy.
unsure
No information
I think Gilroy has a large Hispanic population but I think that is due to Hispanics always living here. Up until housing in areas
like San Jose became unaffordable did other races start moving South.
Gilroy does have a racial living divide. Although we all get along I believe, living areas are segregated. Not intentionally.
But it has never been fixed or dealt with
No we have a diverse city many who have been here over 20 years
Unsure
Unsure
Not sure
Unsure
Gilroy is not segregated. It merely has different neighborhoods with varying prices of homes or living accommodations.
This is how life is. If you can afford a small apartment then it will likely be located in a different area than someone who is
quite wealthy living in a more expensive area. This is not complicated and should not require special programs to put all at
a financially “equal" level. Handouts like affordable housing or restrictive rules will only create more financially dependent
people.
I suppose it would depend on the demographic rates but it's probably pretty segregated.
Unsure
Spanish Responses
I did not understand the question very well
Q20. In the past five years, have you had to move out of your residence in Gilroy when you did not
want to move?
Total: Answers = 406; Skipped = 93
English: Answered = 292; Skipped = 71
Spanish: Answered = 114; Skipped = 22
Q21. If you answered yes to the previous question, why did you have to move? (Select all that
apply)
Total: Answers = 98; Skipped = 401
English: Answered = 47; Skipped = 316
Spanish: Answered = 51; Skipped = 85
17%
83%
12%
88%
29%
71%
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
Yes No
Total Responses English Spanish
5.A.a
Packet Pg. 282 Attachment: Draft Housing Element 9-12-22 (4016 : Review of the Draft Housing Element)
APPENDIX C ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 262
English Responses
moved from Morgan Hill because of the increase of crime.
No protections in place to stop the landlord for doing so. They wanted more money and less accountability
Dad kicked me out
No
Rent is becoming unaffordable and within a year or two or will be forced to move away
Too many homeless were congregating near the park by my house, which was leading to crime. So I bought a home in what
I perceived as a safer neighborhood. However, now that affordable housing units are popping up all over the city, I don't
know if it's safe anywhere. The logical choice seems to be to move out of this city.
Travel times to and from work.
not applicable to me
Spanish Responses
The owner took my job
I didn't move
My rent went up
Status
Q22. Which of the following issues, if any, have limited the housing options you were able to
consider? (Please select all that apply)
Total: Answers = 349; Skipped = 150
English: Answered = 239; Skipped = 124
Spanish: Answered = 110; Skipped = 26
33%
13%
6%
2%4%
7%
3%
7%
2%4% 4%
7%
9%
57%
13%11%
0%
4%
11%
2%
9%
0%2%4%
11%
22%
42%
26%
8%6%8%10%
6%
12%
6%
10%8%10%8%
0%
10%
20%
30%
40%
50%
60%
Total Responses English Spanish
5.A.a
Packet Pg. 283 Attachment: Draft Housing Element 9-12-22 (4016 : Review of the Draft Housing Element)
APPENDIX C ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 263
English Responses
Lot sizes too small for anyone - (rats in a box syndrome)
Did not make enough income to qualify or afford
Priced out, outbid and investors buying
House prices, priced out of market
Having to earn 3x the rent in order to qualify for rental
refused rental because I had money in bank but no job
They wanted my paychecks to reflect 2.5x the cost of the rent.
affordable financing for buying - it is very hard to come by for the wage earner
Amount of rent
require single story
houses have become too expensive in Gilroy and criteria for affordable housing too strict
I don't feel safe anywhere in this town anymore, with people shooting at cops and people walking around with knives and
masks in our parks, and it's only going to get worse, it seems.
could only afford foreclosures/fixer-uppers
Low multi-family supply.
Homes are very expensive in Gilroy
Priced out of where we work. Had to move to Hollister even though our entire lives are in Gilroy.
Neighbors did not keep up their home maintenance
Many if those reasons applied until I worked harder and saved more money. I really wish City, state and federal government
would stop trying so hard to make life easier for everyone. You remove all of the hardship involved in life and all the people
you think you’re helping will never appreciate anything. It’s completely acceptable for people to struggle, even families with
kids. Real parents will step it up and find a way when they have no other option but to work harder.
Access to transit concerns
Did not accept housing
Housing prices (therefore monthly expenses) were out of our budget range.
Spanish Responses
Cost
My parents lost their jobs.
All this very expensive
Q23. Recent California Housing Law and California Department of Housing and Community
Development (HCD) require extensive analysis and identification of contributing factors for a
series of fair housing issues as part requires the 2023-2031 Housing Element to include local
resident and stakeholder input. Please select the most important contributing factors impacting
housing in Gilroy (select up to three):
Total: Answers = 370; Skipped = 129
English: Answered = 257; Skipped = 106
25%28%
11%13%
5%7%5%5%
48%
32%
13%12%
3%7%5%10%14%
60%
23%
37%
16%19%14%
3%
0%
10%
20%
30%
40%
50%
60%
70%
Total Responses English Spanish
5.A.a
Packet Pg. 284 Attachment: Draft Housing Element 9-12-22 (4016 : Review of the Draft Housing Element)
APPENDIX C ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 264
Spanish: Answered = 113; Skipped = 23
English Responses:
We have a good police department, but not enough of them. No new housing without additional city services including
new water sources. Weather from air dehydration as an example. Medical services are virtually non existent except for the
emergency room!
homes being sold to outside investors
Lack of well-paying jobs for EXISTING RESIDENTS.
no opinion
Not sure what sizes are needed, whether for singles or large families, but there seems to be a lack of affordable housing
for very low income households.
Too many very low income housing; need housing for moderate income households
Continue need for tenant dispute resolution help
We need to work on transportation/commute before expanding the city. It’s ridiculous that it take 1 hour to get to work in
San Jose because there is no work in town.
Gilroy is the LAST affordable place in SC county. So affordability is not a issue. The issue is the city isn't doing enough to
bring in high paying jobs. The only option people here have is to commute to the valley or work retail/service jobs. The city
planners are too busy building low income housing, which is going to make matters worse. Bring in some industry, high
tech, and other high paying jobs, and people will be able to afford the homes. That's the way to address the housing crisis,
NOT more government funded programs.
Lack of investment in schools in low income neighborhoods such that large differences in terms of access to technology,
field trips, and other resources exist between schools in low income areas and schools in moderate to high income areas
(largely connected to differing opportunities of parent groups to fundraise)
Council should realize many want Gilroy to remain a community and moving a bunch of people in through stack-n-pack
units will destroy that community.
Lack of local high-paying job opportunities.
lack of housing affordable housing for low income, extremely low income, and unhoused people.
Some City Council members opposition to affordable housing
Lack of affordable housing
None of the above
More Section 8 housing units are needed.
California should not require Gilroy to change or add different housing types. Nor should Gilroy get paid as an incentive to
add more affordable housing. This is a corrupt way of business.
8%9%
18%
11%9%
4%4%4%
14%16%
2%
11%
26%
50%
29%
23%
12% 12%
8%
46%
39%
7%
47%
15%
41%
25%
23%
12%10%
15%
21%
51%
1%
0%
10%
20%
30%
40%
50%
60%
Total Responses English Spanish
5.A.a
Packet Pg. 285 Attachment: Draft Housing Element 9-12-22 (4016 : Review of the Draft Housing Element)
APPENDIX C ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 265
Spanish Responses
It would be good if they didn't ask for credit because many of us don't have credit.
Q24. Rank your agreement with the following statements from strongly disagree (1), somewhat
disagree (2), somewhat agree (3) or strongly agree (4).
Total: Answers = 400; Skipped = 89
English: Answered = 286; Skipped = 77
Spanish: Answered = 124; Skipped = 12
Q25. Please share any comments or recommendations that will help inform and guide the
preparation of the City’s updated Housing Element.
Total: Answers = 107; Skipped = 392
English: Answered = 76; Skipped = 287
Spanish: Answered = 31; Skipped = 105
English Responses:
WHEN CONSIDERING AN INCREASE IN NEW HOUSING, THERE NEEDS TO ALSO BE AN INCREASE IN GROCERY STORES AND
PARKING TO ACCOMMODATE THE INCREASING POPULATION
I love Gilroy and all it offers!
Too many stores have closed, the water is becoming toxic and is in a declining supply. Existing city services such as fire and
police hire good people, but there is not enough of them for the existing population. Drugs, guns and gangs are taking over.
Medical care is lacking - why can't you attract quality medical care? Worse the city doesn't have the funding to improve on
these things. The city has no business allowing any developer to even think about another housing project. Get your
priorities straight - improve what you have before trying to build more ghetto like housing. The way to correct homelessness
is through education and better employment opportunities. See if you can work on that - find a developer for that, not
more crowded housing like Eagle ridge and that mess west of Santa Teresa.
Homeless is an issue in Gilroy too many homeless in the streets. housing developments such as apartment building are run
down make landlords liable to fix these units
Provide housing for the people who are here, not the ones you are hoping to replace them with
20%37%20%20%28%25%32%18%
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1 2 3 4
I live near high quality parks and recreation facilities I live near grocery stores with healthy and convenient options
I live a convenient distance from healthcare facilities Housing in my neighborhood is in good condition
I live in an area with a lower rate of crime It’s easy to find good schools in an area that I can afford
I live in an area with easy access to job opportunities It’s easy getting to places I want to go because of my mode of transportation
I feel that the water, air, and soil is healthy where I live
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APPENDIX C ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 266
I have been here over 13 years I stay with my parents I’m on ssi and am in need of housing my dad wants me out but I don’t
have section 8 I need a apartment for 300 or 400 dollars a month not unless I can get housing everywhere I look it’s 1,000
or more please help me get housing.
Gilroy is a bedroom community for Silicon Valley, across all socioeconomic levels. (Although more tech professionals can
WFH than before Covid-19!) Getting hourly trains from Gilroy to Palo Alto should be a priority. (Not a housing issue per se,
but if people are spending less on transportation, they have more for housing.)
moderate and Middle income Gilroy homeowners being ignored yet they pay their part in property taxes.
Gilroy needs 3-4 bedroom town houses, condos, and houses. Reasonably priced!
I love Gilroy!!!
We shouldn’t keep building just to build, each home should be made thoughtfully and invested in with purpose for future
sustainability. Our biggest resource is the sun, let’s use it and normalize accessibility to solar powered
homes/communities/schools. Water is also a diminishing concerning resource as well. How can we be resourceful in that
regard as well?
A lot of cockroaches near the schools. Sidewalks are dirty. Sometimes shoes hang on electricity wires. Roads have potholes
and not always paved alley ways. People let their dogs poop anywhere and everywhere so more garbage cans or doggie
stations would be nice throughout.
not sure if you can do anything about this, but marijuana smoking is a problem. I shouldn't have to smell neighbors smoking
weed when I'm in my house.
The school systems and Gilroy are very poor. And the closest good store is in Morgan Hill to shop bad. Crime and
homelessness is on the rise in all areas of Gilroy. I am not comfortable walking up at the levee or around town.
Stop building housing for new residents and concentrate on responsibly serving existing residents. Promote creation of
well-paying jobs for existing residents. Look for ways to REVERSE irresponsible growth in Glen Loma and Hecker Pass. Target
50,000 as maximum sustainable Gilroy population.
Combine with traffic and roads and parking on site, not on the street. The cars on the street at some units make them look
like the projects taking away from the experience of all
Where are the amenities with all the new housing going in!
I'm scared that at any moment I could become homeless. If that happens, I will surely lose my job, my pregnancy and
possibly my mind. It will be so hard to come back from that. But the prices in Gilroy for the most basic apartment, are
simply unreasonable.
We need extremely low income units
More affordable housing opportunities of all kinds
We need workforce housing opportunities
Commercial linkage fee to pay for this type of housing
Inclusionary housing ordinance to require 15 percent affordable units in all new residential development
The major problem for typical residents are the costs to buy and own. If the city of Gilroy wants to truly help employees,
focus on the ones that work - not the ones who don't. Help them by reducing the amount of crap in the following: 1) make
building and adding ADUs as simple as possible 2) Help working-class people qualify for loans 3) keep free enterprise as
the basis for your programs. Do not adopt socialism or worse yet, reward for those who do nothing.
I don't live in Gilroy but I serve clients who live in Gilroy.
Need to focus on housing for middle income households; excessive amount of very low income housing already exist or
planned in Gilroy beyond county requirements.
Please provide 55+ apartment, or single parent duplex communities that are affordable.
Transitional housing options for folks at-risk of being homeless and currently homeless. Options such as ADU’s, tiny homes,
etc.
"High quality" parks are needed for children. Just a few newer parks have been built where new developments are. The
existing parks have not been updated.
Unbiased studies need to be conducted. No new housing should be built until the current residences needs are addressed.
Invest in a more walkable and bikeable Gilroy! Most businesses and amenities are along main thoroughfares or in specific
parts of town, forcing most residents to drive for groceries, shopping, and other amenities. These same thoroughfares are
often how drivers exit town on their way to workplaces outside the city.
Invest in more mixed use zoning, especially in zones that are currently just residential.
We really need to figure out commute time and access. We need more Caltrain service and expand 101 into San Jose. We
need to work to afford to live in town so facilitate that first before building more homes and no jobs or roads.
Gilroy has done more than it’s share of home building over the past 20 years with one of the highest growth rate in the Bay
Area, yet the price if housing has just skyrocketed! Obviously building more quantity is not the answer. First-time
homebuyers and renters need financial help from the State or Federal government. The rents charged for even the
affordable units are out of reach of many. I am not sure just building more units will help them.
Overpopulation and low income housing is devaluing the city and more and more crime is evident
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APPENDIX C ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 267
Miller Park is disgusting it was our closest park for the kids and I stopped going altogether. The homelessness problem and
drug use was out of control their. The police presence was completely absent unless a fight, overdose, or rape occurred.
Its incredibly sad to see Gilroy feel the need to be like downtown Los Gatos. You have a predominantly Mexican population
and you should be proud to cater to these traditional customs and not white wash it.
I have lived in Gilroy my whole life I was born here. My kids and I are domestic violence victims and we are looking into
moving out of my moms house but it’s hard cause their is really no open waiting list or programs to help me with rent when
I need it
Bring industry and high paying jobs to the city, if you want to address the housing problem. Flooding the city with low rent
apartments isn't the solution. It's going to lead to overcrowding and crime. Gilroy already has a high crime rate and an influx
of low income housing is only going to make it worse. If this keeps up, all the tax paying, upstanding, home owners are
going to leave the city in droves. I guess it'll definitely become affordable to live here then.
The city and community organizations such as churches and non-profits should combine their efforts to create several
types of tiny home communities for the homeless from bare minimum shelter (shed structures with access to showers and
toilets) to permanent long term tiny house.
I would love to see the city do more to promote organic, sustainable farming practices in our community in an effort to
improve air and water quality.
I don't mean to sound mean or selfish, but Gilroy is doing pretty good. Attracting low-income and homeless is not going to
improve the quality of life for Gilroy.
Infill development needs to occur within in existing infrastructure. Affordable housing for working families.
Horrible water alkaline off the charts
A city of homeowners is a better place to live than one with a bunch of apartments. Build more single family homes with
yards and the quality of community will remain healthy and crime will remain low. Also, consider a regulation preventing
REITS and other large investment firms from buying housing in Gilroy. Keep the houses in the control of families, not
conglomerates.
We need more multifamily and affordable housing for families. Quality homeless shelters and transitional housing would
help the homeless that are forced to live in vehicles and tents.
We would love for the city of Gilroy to respect and maintain the beautiful outdoor spaces, lands and Not over develop. This
is why we moved to Gilroy over 25 years ago. We have seen many, many new homes developed in the past several years.
Traffic has worsened, roads need repair, and it is starting to feel like we are no longer in the country.
Too many of our residents live in Gilroy but commute to work in Silicon Valley. Gilroy needs to attract businesses that can
employ these tech workers, bringing wealth, investment and a sense of community to our city.
Homeless & crime is a large impact on community, increase in both is a concern. Roads & traffic are also being impacted
by so many new homes being built with no new accommodations being made with these increases! How can one pay a
million dollars or more for a home & have homeless encampments everywhere in town.
None at this time
Make sure there are easily accessible crosswalks that are lighted for seniors, children and families. There are many areas
in the City that do not have great cross walks, especially near parks and people jay-walk all the time
Gilroy is highly segregated, poorly designed from a city Planning perspective, including shopping and amenities. Old money,
power relations and structures, old thinking and politics controls Gilroy. Please do things differently.
We needs additional housing for low income, extremely low income, and unhoused persons. My belief is we have taken on
our fair share of middle income and high income housing, and should curb other development unless we have proven
resources to support, and adequate protection for the environment.
We need better infrastructure. Al these homes are being built with no investment into a new grocery store, places to eat,
places to shop. Gilroy needs more of the above items, otherwise people will continue to spend their hard earned money in
other cities like Morgan Hill.
I do not support projects that do not have to contribute to impacts such as traffic, public safety, and recreation/parks.
Stop housing and business development impacting natural environment. e.g Hecker Pass
Do not expand Gilroy with more new builds without investing in infrastructure, downtown and diversifying the businesses
we have. Are there incentive programs (for homebuyers and/or owners) that we can implement to fix up our less beautiful
neighborhoods before we just start building cookie cutter neighborhoods on the outskirts of town? It’s embarrassing to be
from Gilroy when our neighbors (Morgan Hill, Hollister and even San Juan Bautista) have grown so well!
I’m not sure if this is a city or utilities issue but if high density housing is going to continue to be built there needs to be be
something done to address the unreliable power service we have been receiving here. The power outages due to fires is to
be expected but our power goes out for hours — and even days— with no weather or fire issues at all. I really feel that in
order to continue to allow building to continue at the pace it’s been going this and the homeless encampments need to be
address.
Council members nor supportive of its most vulnerable population. Recall mayor
Build no housing until the drought is over.
Need more transportation options and improve our streets pot holes.
Please consult with Social Service agencies, both public and non-governmental. They know the needs better than those of
us not seeking housing at present.
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APPENDIX C ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 268
I love living in Gilroy because of the open farmland and the various parks. I also love that it’s not overcrowded with so many
people living in one home that there’s no parking on the street.
Please keep in mind parking when planning as well as not charging HOA dues.
Just don't make Gilroy lose its hometown feeling/look by overcrowding with so much housing and integrating apartments
and low income housing right next to expensive and nice homes.
My dad gave us the down-payment so that we could meet lender qualifications and closing costs. Our loan went thru
modification due to being predatory in nature; if the modification wasn't approved, we would have lost the house. The taxes
and insurance added to the mortgage payment is almost unachievable; we are happy that we are getting the tax write-off
as opposed to the landlord.
The city needs to focus on creating affordable housing rather than falling gor the political "selling the dream of
homeownership" rather than providing adequate affordable housing. Once the homelessness crisis is addressed, then they
can focus on "selling the dream of home ownership.
I just found out - based on this survey - that we are again low income; we always just squeaked under the poverty line when
the kids were young. Though we are doing ok, it's sad to know that we are again considered low income - the outrageously
high cost of living combined with extremely high land values are driving people, especially families away. Why stay here just
to struggle to make ends meet and find affordable rental housing, when they can move to other states where they CAN
afford to purchase a home with land - the politicians are driving California to the bottom of the list - we used to be at the
top of the list.
I feel like Old Gilroy is neglected. The streets are not well taken care of, and the houses are also not taken care of, I’m
assuming because of the amount of renters to owner ratio. There needs to be some kind of accountability for renters to
take care of their dwelling, and for apartment owners to make their complexes up to some standard
Gilroy should stop all detached housing construction and focus on job creation. Next priority should be on reliable, frequent,
extensive and affordable public transportation.
Do not continue to add assistance programs, affordable housing programs, etc. Put actual limits on the assistance that you
do have. Most anyone that has relatively good health has no business being unemployed. If they say they can’t make enough
working only one job then they should get 2 jobs and continually try to add new skills and education until they can get a
better job that pays more. I always loved that Gilroy residents were proud, hardworking, no nonsense, people. People that
would rather take a second job or work an extra shift before they put their hand out asking someone else to give their hard
earned money to support them. Unfortunately, everyone, especially our younger generation have no issue begging for
others money instead of working. Complaining about how hard it is instead of realizing if they just push through, work
harder, they will make it. I think there should absolutely be some forms of government assistance available. There are
legitimate reasons why people need help but the help has to have limits. These programs are destroying our communities
and handicapping the people you think you’re helping. And what’s frustrating to every hard working person who pays their
taxes is that you’re taking our hard earned money from us just to throw it away in programs that never work while bringing
in more of these people who abuse these programs into our neighborhoods. Crime rates go up, the hardworking, proud
people who moved to Gilroy to get away from cities like San Jose have to then sell their home and move away because your
well intentioned programs had no regard for the families that already live here. I can’t tell if this makes sense because the
box is so small but I hope you get the picture and hopefully someone actually reads these.
The city needs to prioritize resources for the unhoused population. City council members need to be better informed about
how to appropriately address race and equity related to housing and overall planning. Climate adaptation also needs to be
incorporated into this update. There are lots of county resources focused on increasing tree canopy, portable air filtration
systems and using buses as cooling centers.
We absolutely must build housing for the residents being pushed out by all of the “above moderate” housing. Affordable
units aren’t at all affordable for those working in Gilroy and our city has done too little for too long to address housing
inequalities. Our people without housing is increasing because generations of locals are being silenced and ignored. The
majority of voters voted for Zach and Rebecca who have robust inclusionary housing goals, want attainable housing options
for lower income residents and yet time and time again our current council ignores and outvoted them. It is disheartening
and frustrating to live in such an unresponsive town.
Homeless persons w/drug addictions need permanent housing. Most housing requires sober living. If they use they're out
on the street again. Where do they get to live? Also, some mentally ill people need to be monitored. Its more than just a
roof, they need special care and support without being institutionalized. What can the City plan for these circumstances?
Investing in affordable homes will dignify families that want to live in a nice area as Gilroy. Where are the plans for that?
Politics sometimes don't help on this topic
Create suitable housing for the homeless in Gilroy and stop shipping them to San José
Focus on schools and transportation. We have plenty of housing in comparison to those needs. Stop pandering to the
homeless and your homeless problem will greatly resolve. It's not heartless to encourage people to move to more
affordable areas. Many of our relatives have moved to other areas and states. It's time to grow up and become adults about
this. I don't go to an expensive restaurant and expect them to hand out their door for free. This is no different. Basic
economics folks.
We need to look at traffic issues.
It may be nice to have a Trader Joes in Gilroy’s southside. Mesa Ranch area.
Thank you for the opportunity to participate in this critical issue.
Over 40% of black/brown people are lower working class and this seems like a good time to raise them with offering them
the dignity of owning a home, making better homes available and not packing them into more housing apartments like
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APPENDIX C ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 269
sardines and saying we’re helping. What they’re paying for apartments is what they should be paying for a mortgage. It’s a
shame how $100k is now considered low income in our city.
Gilroy does not need to add more affordable housing to our already crowded city. There are enough places other than
Gilroy to live if it's not affordable here. We also do not need to build rehab facilities or shelters for the homeless issue. Most
of the homeless population are homeless by choice. The temp shelters will continue to perpetuate the irresponsible free
life that the homeless community desires. All you need to do is interview people who work directly with the homeless and
see for yourself that giving to them is not helping them.
Our family is considered middle class but we will never be able to afford a house in Gilroy, despite saving regularly. That
means we will have to leave in order to buy a house elsewhere. Gilroy is too focused on providing rentals. To close wealth
disparity, give people easier access and affordability to own homes.
All of Gilroy's water is ridiculously hard. I don't think just building houses or apartments will make people use them. People
are homeless for a multitude of reasons. Address those and build out programs for that in conjunction with some sort of
housing. No one that I know in Gilroy likes how low-income/high density housing looks. It's too metropolitan.
Spanish Responses:
Gilroy needs housing for extreme low income
Update the tabulators of the salary averages and the availability for housing payment, according to the current inflation.
In Gilroy there are no technology companies to have prices close to those of Santa Clara, San Francisco. So there is no
justification for having such high housing since the salaries mostly do not come from that branch.
need money
The city needs more extremely low income housing units. There are very few. The focus is always on low and very low.
There are many people who can't afford low and very low income housing in Gilroy.
We need low income apartments.
Homes that adapt to our budgets.
Need homes for extremely low incomes
Gilroy needs extremely low wage housing.
We needed extremely low income housing.
We need housing for extremely low income farmworkers.
We need low income housing.
That the owners arrange the apartments that give washing machines to all the apartments.
Take the community into account at every step.
Maintenance of old houses.
Extremely low income housing is needed in Gilroy.
That they build more very low income villas. That there is no rent control every year!
We need more housing for extremely low income people.
We need very cheap homes because the income is very low and everything is very expensive.
Give more publicity to housing assistance programs
More affordable farmworker housing
Well, beyond living more accessible for fieldworkers
lower rents
Rent prices are very high, we need rent control
More low-income housing is needed
We need economic living
Need houses at lower prices. financial aid
Please be aware of the requirements that they ask for to rent a place.
Safety in Gilroy has been down. I live in the area of Las Animas park, where it used to be quiet and safe to go to the park.
Now it's neither of them. And lately neighbors are suffering from theft of car parts in the middle of the day or night.
More information in Spanish for the Hispanic community
Previously the city had a program where families could work on the construction of the house and could buy it. This would
be a very good option.
Virtual Workshop – March 30, 2022
On March 30, 2022 the City of Gilroy sponsored a virtual workshop focused on educating the community about the Housing
Element Update planning process. As part of this workshop, attendees were encouraged to give feedback via the question and
answer function in Zoom, which were answered by either the presenter or in the chat box. Below is a listing of the questions as
well a summary of the most frequently voiced concerns.
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APPENDIX C ▐
City of Gilroy Housing Element ▐ 6th Cycle Housing Plan 270
How can our city and region assure the building of housing does not outpace available resources? Our water resources are
dwindling.
How can we as community/housing assistance programs assist those in leadership positions to “Fast Track" building
affordable housing (Particularly for the disabled community)?
Is the city considering any reductions in impact fees to encourage more development?
Have any office buildings or motels been reviewed for possible housing for our unhoused?
The responsibilities fall on other cities like ours. Most folks in affordable housing are not Gilroy. We need to house our own
and get resources. Why aren't other cities taking their fair share of the responsibility. It's been 30 years without enforcement
We definitely need more supportive housing! I believe many of the mentally ill would be able to function better if they had
some supervision and were able to stay on their medications.
We need more parking, especially for affordable units.
In addition to having a serious concern about our housing crisis, I have an infill 10,000 sq ft zoned r3 and as a PUD parcel
in Gilroy. I would like to develop this land in a way that would help our City achieve some our target goals for the lower
income population. My biggest concern is dealing with the whole permitting process.
As a current homeowner who really values Gilroy’s diversity (racial/ethnic, socioeconomic, political) I really hope that we
prioritize ensuring that low-income and working families can always be a part of our community. Gilroy should be a place
that someone can realize the “American Dream” by working hard, raising a family, and be able to own a home. Opportunities
not only for affordable rental housing but also for affordable home ownership will be critical.
Is Supportive Housing for the homeless part of this plan? That is housing that includes resources that address medical
needs, mental health needs, good public transportation, etc?
91% of Gilroy adults with developmental disabilities live at home with aging parents or in segregated licensed care facilities
not by choices but because of the lack of deeply affordable housing available. This is an issue that affects people of all
abilities in Gilroy. As we saw in tonight's presentation median income in Gilroy is significantly lower than Santa Clara
County's AMI which means that the majority of low income Gilroy residents will most likely fall well below VLI maximum
income. In RHNA cycle 5 the city exceeded its low income RHNA but as of 2021 has met only 63% of it Very Low Income
RHNA. The city needs to develop policies and programs to create housing at affordability levels to specifically promote
development of housing at deeper levels of affordability.
Virtual Workshop – June 28, 2022
On June 28, 2022 the City of Gilroy sponsored a virtual workshop focused on the RHNA sites and housing programs of Housing
Element Update. As part of this workshop, attendees were encouraged to give feedback via the question and answer function in
Zoom, which were answered by either the presenter or in the chat box. Below is a listing of the questions as well a summary of the
most frequently voiced concerns.
All but a few lower income sites are in areas designated by the state as low resource. How will you meet requirements to
affirmatively further fair housing?
These maps appear very segregated, all of the "low and affordable" on one side and moderate on the other side. What can
we do to spread the demographics?
The train does NOT provide robust service, nor has it for years now. I believe these policies are outdated.
There is no enforcement on this new policy, especially not in Gilroy. Landlords and property management companies flat
out refuse to take vouchers.
Is there any way to plan housing for Gavilan College students?
Will the western side of the city have a variety of housing; condos, market rate apartments, and single family? Something
to consider is changing demographic needs, smaller family size (or no children) and the desire to downside in retirement
years
Can survivors of gender-based violence be considered under this category?
Will year-round emergency shelter be proposed?
Community members have also requested that an ongoing, multi-year source of funding for basic needs services for
homeless residents be identified, rather than requiring providers to reapply each year. Will this be incorporated in the
housing element?
Will an Inclusionary Housing ordinance be prioritized?
It’s wonderful to see farmworker housing on the list! A big thank you to staff and consultant, great work
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DISCLAIMER: This document is intended to provide general information and does not constitute legal advice. Additional facts, facts
specific to a particular situation, or future developments may affect the subjects discussed in this FAQ. Seek the advice of your
attorney before acting or relying upon the following information.
Timing Requirements for Adoption of the Housing Element
and Required Rezoning
Technical Memo, August 2022
AB 1398 (Chapter 358, Statutes of 2020) amended the provisions of state housing element law related to the
implications of adopting a housing element after the due date. The current deadline for jurisdictions in the
nine counties that are members of the Association of Bay Area Governments (ABAG) to adopt the housing
element is January 31, 2023.
Previous Cycle Rules
To understand the new rules for adoption of a housing element, it may be helpful to compare them with those
adopted in the last housing element cycle, the fifth cycle, when housing elements were due in January 2015. In
the fifth cycle, if housing elements were not adopted by 120 days after the due date, the local jurisdiction was
required to prepare a new housing element every four years, rather than every eight years. Those jurisdictions
that adopted housing elements more than 120 days after the due date were required to adopt a mid-cycle
housing element in 2019.
New Sixth Cycle Rules
AB 1398 has eliminated any requirement for a four-year housing element once the Department of Housing
and Community Development (HCD) has found a community’s sixth cycle housing element in conformance
with state law (Government Code1 Section 65588(e)(4)(A)). Instead, state law sets deadlines for housing
element adoption and rezoning and consequences if those deadlines are not met.
1 Subsequent citations are to the Government Code unless otherwise stated.
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Housing Element Adoption and Timeline to Rezone
• If a housing element is adopted and found by HCD to be in compliance with state law by May 31, 2023,
then the jurisdiction has approximately three years after the date it adopts its housing element to
complete all rezoning required to provide adequate sites (Section 65583(c)(1)(A)).2
• If HCD does not find a housing element to be in compliance by May 31, 2023, then all rezoning
required to provide adequate sites must be accomplished by January 31, 2024 (Section
65588(e)(4)(C)(i)).
o Note that HCD has 60 days to review an adopted housing element (Section 65585(b)(3)). Any
community desiring to have three years to adopt the necessary zoning should adopt a
compliant housing element by April 1, 2023.
• If a housing element is adopted after January 31, 2024, HCD cannot find it in compliance with state law
until all necessary rezoning is adopted (Section 65588(e)(4)(C)(iii)).
In the Southern California Association of Governments (SCAG) region, the due date for Housing Elements,
October 15, 2021, has passed, and most jurisdictions are still working with HCD to receive certification.
Rezoning of Adequate Sites
If rezoning is not complete by the appropriate rezoning deadline as stated above, HCD is authorized to:
• Revoke its findings of compliance until rezoning is complete; and/or
• Refer the agency to the Attorney General (Section 65585(i), (j)).
HCD has adopted an additional policy relating to rezoning sites for lower income housing:
• If zoning required to provide adequate sites for lower income housing is adopted after the housing
element due date of January 31, 2023, it must provide for “by right” approval.
o “By right” approval means that a housing project that does not require a subdivision and that
contains 20 percent lower income housing is exempt from the California Environmental Quality
Act (CE A jurisdiction may require design review based on objective standards, but only if its “by
right” ordinance requires design review approval (Section 65583.2(i)).
2 The due date for these jurisdictions is either three years after the date the jurisdiction adopted its housing element, or three years
after the date that is 90 days after the jurisdiction received HCD’s comments on its draft element, whichever is earlier.
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Limitations on Denial of Certain Housing Projects
Once January 31, 2023 passes without adoption of a sixth cycle housing element, the locality’s adopted fifth
cycle housing element may no longer comply with all provisions of state housing element law. This may have
impacts on a jurisdiction’s ability to deny housing projects. Some factors that may be relevant include whether
the housing project includes a minimum of either 20% or 49% affordable units. Other laws, such as the
Housing Accountability Act and SB 35 (2017), may also affect a jurisdiction’s ability to deny a housing project.
Consult with your jurisdiction’s attorney before considering the denial of a housing project.
Eligibility for Certain Funding Programs
If a housing element is not consistent with state law or not found to be consistent by HCD, the jurisdiction may
not be eligible for certain funding programs.
Funding programs that may require the local jurisdiction’s adopted housing element to be in compliance with
HCD include3:
• Community Development Block Grant Program
• Infill Infrastructure Grant Program
• Transit Oriented Development Program
• Local Housing Trust Fund Program
• Affordable Housing and Sustainable Communities Program
• Permanent Local Housing Allocation Program
• Caltrans Sustainable Communities Grant Program
• MTC’s One Bay Area Grant (OBAG) Program
State funding programs that reward or incentivize projects in jurisdictions with compliant housing elements
include:
• Local Partnership Program: Projects are evaluated on how they advance housing element goals.
• Transit and Intercity Rail Capital Program: Projects must document how transit ridership growth is
supported by housing policies including evidence of compliance with state-required housing plans.
• Active Transportation Program: Infrastructure projects must address their potential to support existing
and planned housing, and planning projects must be consistent with local housing policies.
• HOME Investment Partnerships Program: Applications receive points for housing element compliance.
• Solutions for Congested Corridors Program: Projects must address how they support infill development,
which may include identifying housing element policies that streamline multifamily housing
development.
3 This list may not be exhaustive. Please check the regulations and guidelines for any funding program your jurisdiction is
considering.
5.A.b
Packet Pg. 294 Attachment: ABAG Memo Timing Requirements for Housing Element Adoption (4016 : Review of the Draft Housing Element)
September 2022 4
Some Housing Element Dates to Remember
January 31, 2023
• Deadline to have Housing Elements adopted by City Council or Board of Supervisors
• Any rezonings that happen after this date, or need to happen after this date, must provide for "by
right" approval of sites designated for lower income housing.
May 31, 2023 (120 days after the housing element adoption deadline)
• If HCD finds a housing element in compliance by May 31, 2023, the jurisdiction has approximately 3
years from the date of adoption to complete all rezoning.
• If a housing element is NOT found in compliance by May 31, 2023, all rezoning must be completed
within one year of the adoption deadline.
January 31, 2024 (One year after the original adoption deadline)
• Rezoning deadline for jurisdictions that did not meet the May 31, 2023 compliance deadline.4
• Starting January 31st, HCD will not certify any new housing elements, unless the required zoning is in
place.
2026 (Three years after compliant housing element adoption)
• Rezoning deadline for jurisdictions that meet the May 31, 2023 compliance deadline.5
4 If rezoning is not complete by the appropriate deadline, HCD is authorized to (1) revoke its findings of compliance until rezoning is
complete and (2) refer the agency to the state attorney general.
5 If rezoning is not complete by the appropriate deadline, HCD is authorized to (1) revoke its findings of compliance until rezoning is
complete and (2) refer the agency to the state attorney general.
5.A.b
Packet Pg. 295 Attachment: ABAG Memo Timing Requirements for Housing Element Adoption (4016 : Review of the Draft Housing Element)
psausedo@biabayarea.org
July 1, 2022
City of Gilroy
7351 Rosanna St.
Gilroy, CA 95020
Transmitted Electronically
Dear Ms. McCormick,
RE: 6th Cycle Housing Element: Constraints Section
The Building Industry Association of the Bay Area (BIA) respectfully submits the comments contained herein
regarding Gilroy’s draft Housing Element. Inclusive in each city’s DRAFT Housing element is a requirement to
include a chapter that provides a comprehensive listing and honest review of government and private sector
constraints that may inhibit a city’s ability to achieve buildout of its Housing Element.
Per HCD’s Construction by Income Building Activity Annual Report, Gilroy permitted 267 residential units in 2021
(VLI: 119, LI: 20, Mod: 0, Mkt: 128). ABAG’s 6th cycle RHNA allocation (2023-2031) for Gilroy is 1,773 total units i.e.,
669 VLI, 385 LI, 200 Moderate and 519 Market Rate. Considering the ongoing housing crisis, it is recommended
that Gilroy thoroughly analyze all government-imposed constraints along with non-government constraints that
add to the cost and/or inhibit the city’s ability to permit and produce new housing of all income levels i.e., VLI, LI,
Moderate and Market Rate.
BIA recommends the Constraints Section of the city’s Housing Element provide, at a minimum, a listing and
analysis of the following:
GOVERNMENT IMPOSED CONSTRAINTS:
Development Regulations:
Parking
FAR
Height and/or Density Ranges
Moratoriums on conversion of non-residential zoned land
Requiring Commercial Square Footage within Mixed-Use projects
Mitigation Fees
Increased Park Dedication Fees
Increase Affordable Housing Fees
Inclusionary Housing (IZ)
Increasing Inclusionary Housing mandates i.e., accelerating/increasing VLI/LI requirements for new housing
projects
Amenity/Community Benefit Plans (Public Art, PoPo’s i.e., Privately Owned/Public Open Spaces, Childcare
centers)
5.A.c
Packet Pg. 296 Attachment: Public Comments through 10-12-22 (4016 : Review of the Draft Housing Element)
Requiring “above & beyond” dedication requirements for Parks, Roads/Transportation, etc.
Environmental Constraints
Fault Zones
Historic Buildings/Neighborhoods
New Taxes
CFD’s for Schools, Infrastructure or Services
New/Increased/Extended Parcel Taxes
Any/All New Taxes on Housing
Revenue “Neutral” conditions (requiring new housing pay 100% for city services)
Mandated Labor Requirements
Project Labor Agreements
Prevailing Wage Requirements
“Local” Construction Workforce Requirements
Union Apprenticeship Requirements
“Local” Business Sourcing Requirement
Citizen Concerns:
Nimbyism/Neighborhood Opposition
CEQA Lawsuits solely to stop/delay housing projects
Permit Processing Time
Long permitting processing times or permit processes that have a high degree of uncertainty i.e., discretionary
reviews or processes with multiple public meetings, increase the cost of housing development for developers by
(1) increasing carrying costs waiting for permits or (2) increasing the chance that a project will be rejected
following a lengthy processing period.
NON-GOVERNMENT CONSTRAINTS
Land & Housing Development/Construction Costs
Land (average cost per multi-family unit approaches $100,000 throughout Bay Area)
Hard Costs (materials & labor)
Soft Costs (architects, consultants, govt fees, financing)
Supply-chain and inflationary costs of materials
BIA appreciates this opportunity to provide comment and recommendation on the City’s 6 th Cycle Housing Element
and looks forward to working with the City of Gilroy to positively address the region’s on-going housing crisis.
Respectfully,
Patricia E. Sausedo, Director
BIA Bay Area South Bay Government Affairs
5.A.c
Packet Pg. 297 Attachment: Public Comments through 10-12-22 (4016 : Review of the Draft Housing Element)
Carry the Vision, 7365 Monterey Road, Suite 203, Gilroy, CA 95020
www.carrythevision.org / 408.275.6133
Tax ID# 01-0952753
October 11, 2022
Re: City of Gilroy Housing Element 2023-2031
Dear City of Gilroy Councilmembers and Staff,
Carry the Vision (CTV) is committed to transforming our larger community by co-creating healing communities
that address the needs of people suffering from life’s challenges. Our initiatives place an intentional focus on
efforts to reimagine traditional systems that keeps communities of color disproportionally underserved, under-
resourced, and marginalized. We seek strategies that support communities of color, immigrants, formerly
incarcerated, the unhoused, those experiencing mental health and recovery challenges, women, and children.
We believe healing is possible when in partnership with community; in coordination with local government; and
in collaboration with partner organizations that creates resilience and supports empowerment in disadvantaged
communities.
This is a distinct opportunity to assess the critical housing needs in Gilroy. This process is also moment to raise
up community voices, especially community members who are disproportionately affected by housing policies,
have been historically excluded, and are at the highest risk of displacement. We commend the efforts made by
the city to encourage public participation in the development of the Housing Element, and our hope is that
these efforts will expand further during this next phase.
Our common vision of addressing the city’s critical housing needs and safeguarding the families within our
community enhances CTV’s existing partnership with the City of Gilroy, which we value immensely. Thank you
for providing the opportunity to share public comment on the draft Housing Element.
• We recommend that the city expand on prior community engagement efforts and create meaningful
engagement with all stakeholders to collect input on the current Draft and update the Draft with a clear
record of input received through this additional engagement. These discussions should clearly inform
the housing needs assessment, the constraints analysis, and the policies and programs proposed in
response.
• We recommend that the city reassess the components of the Housing Element to integrate local
knowledge gained through robust outreach and community engagement process, along with data, as
the foundation for decisions about housing goals, policies, and implementation programs.
• We recommend that the city expand survey efforts by increasing the opportunity of in-person
engagement, as a means to include and address the voices and needs of the extremely low-income
populations in our community.
• We recommend that the City expand upon the reported focus group findings to include support for
more local assistance, financial or otherwise to the extremely low-income populations.
• We recommend that the city to do further outreach in racially appropriate ways to ensure the
population’s needs are recorded and addressed in this housing element update.
• We ask that the city utilizes the current AMI levels recommended for the county.
5.A.c
Packet Pg. 298 Attachment: Public Comments through 10-12-22 (4016 : Review of the Draft Housing Element)
Carry the Vision, 7365 Monterey Road, Suite 203, Gilroy, CA 95020
www.carrythevision.org / 408.275.6133
Tax ID# 01-0952753
• We ask the city to adopt rent control laws, with the inclusion of rent increase limits and eviction
restrictions, to offer protection and stability to our most vulnerable populations.
Thank you for considering our input and placing value on the opinions of local community-based organizations in
making these important plans for our future housing models.
In community,
Shelley Swan
Shelley Swan
Executive Director
Carry the Vision
5.A.c
Packet Pg. 299 Attachment: Public Comments through 10-12-22 (4016 : Review of the Draft Housing Element)
1
Cindy McCormick
From:JEFF PARKS <jcparks4@verizon.net>
Sent:Sunday, July 10, 2022 9:28 AM
To:Cindy McCormick
Cc:Mayor Marie Blankley
Subject:EXTERNAL - Housing Elements
CAUTION: This email originated from an External Source. Please use proper judgment and caution when opening
attachments, clicking links, or responding to this email.
Dear Cindy,
I noticed on the city website that you encouraged citizens to email you suggestions if we had any regarding Housing
Elements, so I have stated them below.
I believe the city needs to better promote the Housing Elements workshops. Notifying the public 24 hours in advance on
NextDoor and Facebook does not suffice. These meetings need to be promoted frequently… multiple times per week
during the months when these meetings will be occurring.
Additionally, if it truly is important to gain public input, the Housing Elements survey should be promoted daily until it
closes in August. More importantly, these surveys also needs to be secure. Why are people able to take it multiple times
as long they do so on different browsers? Why are people who live outside of Gilroy allowed to take the survey? If part
of the goal is to also gain input from developers and advocates, their input needs to be accessed through separate
surveys. If not, the results gained through the current survey lack credibility in terms of what the Gilroy residents want
those with special interest could easily skew the results for their own benefit.
Finally, when will the link from the June 28th be posted on the city website? It was supposed to be posted a few days
after the meeting occurred, but I still don’t see it.
Thank you,
5.A.c
Packet Pg. 300 Attachment: Public Comments through 10-12-22 (4016 : Review of the Draft Housing Element)
2
Cheryl Parks
Sent from my iPhone
5.A.c
Packet Pg. 301 Attachment: Public Comments through 10-12-22 (4016 : Review of the Draft Housing Element)
1
Cindy McCormick
From:Chris Demers <chrisdemers11@yahoo.com>
Sent:Wednesday, March 30, 2022 6:52 PM
To:Cindy McCormick
Subject:EXTERNAL - housing solutions
Hi Cindy,
Thanks for your responses through chat. In follow up:
We have an affordable housing crisis, not an overall housing crisis. Other than increasing affordable
housing for low income households, I don't believe we should have substantial housing being built.
I've read the City's water plan (I have no objection to it given the information at hand) but it makes
assumptions about water availability through regional and state authorities--which may likely be
curtailed.
There should also be a local prohibition of companies owning single family dwellings, and renting
them for profit. If housing is designed as rental property I understand, but many companies (hedge
funds, investment trusts) are buying up single family homes and renting them out--which is driving up
the cost of housing and squeezing the amount of affordable housing.
Thanks for your work on behalf of the city, Chris
CAUTION: This email originated from an External Source. Please use proper judgment and caution when opening attachments, clicking links, or
responding to this email.
5.A.c
Packet Pg. 302 Attachment: Public Comments through 10-12-22 (4016 : Review of the Draft Housing Element)
1
Cindy McCormick
From:d.rodriguez@holidayinnexpressla.com
Sent:Wednesday, August 24, 2022 2:36 PM
To:Cindy McCormick; Cindy McCormick; City Clerk
Cc:freshgroupincla@yahoo.com
Subject:EXTERNAL - Schedule council meeting on Aug 29th
Attachments:City Zoning Letter.pdf
To whom it may concern:
On behalf of resident Mrs. Tina Chen, I’m reaching out to various departments for the city of Gilroy for
guidance in regards to zoning in the area.
Mrs. Chen is would like for the mayor, city council and planning commissioner to take into account a
few suggestions.
In the attached letter, Mrs. Chen goes into detail on how she may use her vacant land to help with
the development of the city.
As a business woman and operator of several properties, Mrs. Tina Chen wants to be able to work together
with the city of Gilroy to help find a solution to city concerns.
Best regards,
Delva Rodriguez
General Manager
Holiday Inn Express & Suites-LA Downtown West
611 S. Westlake Ave
Los Angeles, CA 90057
T: 213.483.6363
F: 213.483.0088
CAUTION: This email originated from an External Source. Please use proper judgment and caution when opening attachments, clicking links, or
responding to this email.
5.A.c
Packet Pg. 303 Attachment: Public Comments through 10-12-22 (4016 : Review of the Draft Housing Element)
5.A.c
Packet Pg. 304 Attachment: Public Comments through 10-12-22 (4016 : Review of the Draft Housing Element)
1
Cindy McCormick
From:JANEEN PRATT <jdrvision@aol.com>
Sent:Friday, March 25, 2022 12:08 PM
To:Cindy McCormick
Subject:EXTERNAL - Gilroy Housing Element Survey
CAUTION: This email originated from an External Source. Please use proper judgment and caution when opening
attachments, clicking links, or responding to this email.
Dear Cindy McCormick,
I submitted the online survey. However, I forgot two needed improvements in addition to the growth impacting Gilroy’s
infrastructure.
#1. The Gilroy Post Office !! This is urgent. This PO needs a bigger location and parking lot! We have a PO Box there
because we live in rural area of Gilroy.
The growth of market rate housing on South Santa Teresa and apts on 10th St. plus the apts. next to Safeway on First St.
will make this location even worse.
The staff can be rude and dismissive. There is one hispanic woman especially who I avoid. She offers no accountability
for incoming mail lost or getting someone elses mail in our PO Box. She gave me the wrong information for sending mail
to Canada. I went to the San Martin PO and had to redo my large envelopes to nine recipiants there.
I go to the San Martin Post Office to mail packages and time sensitive mail. Gilroy Post Office even lost the check we
submitted in the renewal envelope to renew our PO Box!! She told me it got lost. I told her we didnt lose it (the check).
I park on the street sometimes around the corner. When there is a service at the church on 4th Street there is no
parking at all.
Passports are done at this location crowding the reception area. Suggest suspending at this location until a larger site is
Identified. Whole families come in.
What about a new location in South Gilroy by Auto Mall? Had we known how bad the Gilroy PO was when we moved
here 4 years ago, we would have gotten our PO Box in San Martin.
#2. The alleyways that exist on the streets between homes need more security lighting. I hear talk about the breakins
and drug activity in the alleyways.
Thank you
Sent from my iPhone
5.A.c
Packet Pg. 305 Attachment: Public Comments through 10-12-22 (4016 : Review of the Draft Housing Element)
1
Cindy McCormick
From:JANEEN PRATT <jdrvision@aol.com>
Sent:Tuesday, March 29, 2022 11:15 AM
To:Cindy McCormick
Subject:EXTERNAL - Re: - Gilroy Housing Element Survey
CAUTION: This email originated from an External Source. Please use proper judgment and caution when opening
attachments, clicking links, or responding to this email.
Hi Cindy,
Thank you for your reply.
My goal in stating issues regarding the Gilroy Post Office was to underscore how the footprint and location is
underserving the needs of Gilroy’s explosive growth of new multiunit dwellings along with new single family homes.
The staff issues are minor compared to how underserved we are in Gilroy for postal services and access. We cannot pick
up our mail at our PO Box on Sundays either.
San Martin and Morgan Hill have kept up. I have filed sustantive claims with the postal service. Nothing has changed.
How can the city approve new housing projects without assessing and requiring the post office and other support
services to have their plan to keep up with the growth?
The City of Gilroy or The City Council cannot be blind to this fact. Doesn’t the City communicate with the postal service
how underserved we are?
Janeen
Sent from my iPhone
> On Mar 28, 2022, at 11:48 AM, Cindy McCormick <Cindy.McCormick@ci.gilroy.ca.us> wrote:
>
> Hi Janeen -
>
> Thank you for reaching out.
>
> I will forward your comments to the consultant. Unfortunately, the city does not operate the postal office and has no
jurisdiction over their staff. You may want to reach out to the post office directly to voice those concerns.
>
> I will forward your concern about the alleys to our public works department.
>
> Cindy
>
> -----Original Message-----
> From: JANEEN PRATT <jdrvision@aol.com>
> Sent: Friday, March 25, 2022 12:08 PM
> To: Cindy McCormick <Cindy.McCormick@ci.gilroy.ca.us>
5.A.c
Packet Pg. 306 Attachment: Public Comments through 10-12-22 (4016 : Review of the Draft Housing Element)
2
> Subject: EXTERNAL - Gilroy Housing Element Survey
>
> CAUTION: This email originated from an External Source. Please use proper judgment and caution when opening
attachments, clicking links, or responding to this email.
>
>
> Dear Cindy McCormick,
>
> I submitted the online survey. However, I forgot two needed improvements in addition to the growth impacting
Gilroy’s infrastructure.
>
> #1. The Gilroy Post Office !! This is urgent. This PO needs a bigger location and parking lot! We have a PO Box there
because we live in rural area of Gilroy.
>
> The growth of market rate housing on South Santa Teresa and apts on 10th St. plus the apts. next to Safeway on First
St. will make this location even worse.
>
> The staff can be rude and dismissive. There is one hispanic woman especially who I avoid. She offers no accountability
for incoming mail lost or getting someone elses mail in our PO Box. She gave me the wrong information for sending mail
to Canada. I went to the San Martin PO and had to redo my large envelopes to nine recipiants there.
>
> I go to the San Martin Post Office to mail packages and time sensitive mail. Gilroy Post Office even lost the check we
submitted in the renewal envelope to renew our PO Box!! She told me it got lost. I told her we didnt lose it (the check).
>
> I park on the street sometimes around the corner. When there is a service at the church on 4th Street there is no
parking at all.
>
> Passports are done at this location crowding the reception area. Suggest suspending at this location until a larger site is
Identified. Whole families come in.
>
> What about a new location in South Gilroy by Auto Mall? Had we known how bad the Gilroy PO was when we moved
here 4 years ago, we would have gotten our PO Box in San Martin.
>
> #2. The alleyways that exist on the streets between homes need more security lighting. I hear talk about the breakins
and drug activity in the alleyways.
>
> Thank you
>
>
> Sent from my iPhone
>
5.A.c
Packet Pg. 307 Attachment: Public Comments through 10-12-22 (4016 : Review of the Draft Housing Element)
Via Email
January 28, 2022
Karen Garner – Director of Community Development
Cindy McCormick, – Senior Planner, Planning Division
City of Gilroy, Community Development Department
7351 Rosanna St.
Gilroy, CA 95020
Re: City of Gilroy – Housing Element Priorities
Dear Ms. Garner and Ms. McCormick.
We are writing to you to share the results of our discussions of existing housing needs
and proposals we have for programs and policies that should be considered for inclusion
in the Housing Element Update you are currently preparing. We are also requesting an
opportunity to meet with your staff, and contracted consultant if appropriate, to discuss
these proposals in more detail and to determine the appropriate next steps for their
consideration.
The priorities outlined below were identified over the course of five meetings held by a
group of South County community leaders concerned about rising homelessness and
the inadequate supply of affordable housing, and interested in exploring solutions that
could be integrated into the Housing Element Update Process. These meetings were
convened and facilitated by SV@Home and the South County Compassion Center, and
participants were drawn from the diverse existing service and advocacy networks, and
included community members who volunteer regularly in direct service to those in need,
representatives of regional and local service organizations and housing policy
advocates, as well as residents experiencing homelessness or who were formerly
homeless.
Together, we understand that the Housing Element Update is a nearly once-in-a-decade
process to assess needs and develop concrete action plans to address the housing
issues in our community. We understand that changes to Housing Element law have
increased requirements for this assessment, including special populations such as
residents experiencing homelessness, and for the development of policies and programs
with specific, and measurable steps to address the unmet housing needs.
We also understand that the new requirement to engage in meaningful, frequent, and
ongoing community participation throughout the Housing Element process, including the
new requirements included in the Affirmatively Furthering Fair Housing guidance from
the state, have presented challenges for city staff and consultants across the county.
5.A.c
Packet Pg. 308 Attachment: Public Comments through 10-12-22 (4016 : Review of the Draft Housing Element)
The community meetings that have generated these priorities have been designed to
complement the City’s efforts.
As a group we brought our range of experiences to the discussion, and shared a wide
range of concrete actions we felt would address some of the needs we have identified.
Some of these ideas sought to elevate policy needs that had already been raised in
public discussions, others were reflections of the need to strengthen commitments or
leverage opportunities in existing programs, and some were new measures intended to
address the diversity of housing needs. The group then discussed the proposed actions
and the needs they were intended to address. Some items were combined, some were
determined to be redundant with existing programming, and new actions were identified
through the discussion. The group then went through a prioritization process, which
assessed the potential impact of specific actions, how aligned they were with our
understanding of state guidance, and how they might augment existing efforts. Through
this process the initial list of nearly 20 proposed actions was narrowed to the 8 priorities
detailed below.
Move forward with the previously approved Safe Parking program at the 8th &
Alexander site recently identified.
Identified need : Many individuals and families experiencing homelessness are
using a vehicle for shelter. With no designated safe parking site, these residents
lack the stability to stay connected to resources, remain safe, retain jobs,
maintain childrens’ access to school, and be better prepared to transition to
affordable housing, or back to market-rate housing.
Program to address : Safe Parking programs turn unused parking lots into safe
spaces for people living in their cars to park off public streets. They require some
basic city support, but because safe parking sites provide a fixed location, they
significantly improve the efficiency and effectiveness of service delivery. Safe
Parking programs can support this period and prevent people from ending up
more literally on the street.
In developing the required sites inventory, prioritize parcels for permanent
supportive housing, ELI, and VLI housing units downtown and in other central
locations accessible to resources and transit, especially parcels owned by public
agencies.
Identified need : Locating affordable housing in areas that are transit rich, close
to resources to meet basic needs, and well integrated in residential growth areas,
is the established best practice. Affirmatively furthering fair housing requires that
sites for permanent supportive housing, and homes for residents with extremely
low or very low incomes be located in areas with access to jobs, transit, and
resources, including public land that can expedite affordable housing
5.A.c
Packet Pg. 309 Attachment: Public Comments through 10-12-22 (4016 : Review of the Draft Housing Element)
development. One of the biggest challenges affordable housing developers face
in development of these units is the cost of land, especially when competing with
market-rate developers who have more money available.
Program to address : Surplus or underutilized government-owned land can help,
since affordable housing developers have priority to purchase this land.
Prioritizing sites downtown opens up opportunities and establishes community
expectations that the city is supporting affordable development in these areas. In
Gilroy we would strongly recommend both the VTA owned parking lot at the
transit center, and the 8th and Alexander property owned by Santa Clara County.
Create opportunities for community discussions and education about
homelessness, housing insecurity and specific housing needs to achieve an
atmosphere of acceptance and understanding.
Identified need : Current political will in the city regarding development of
affordable and permanent supportive housing reflects the need to build
understanding of causes and issues of homelessness, the people and lives
impacted by the lack of affordable housing, and the community benefits of safe,
stable, and affordable housing.
Program to address: We often misunderstand what housing needs look like,
who experiences housing insecurity, and how they can become homeless. Some
common understanding can be achieved with intentional and guided
communication between people that do not normally have an opportunity to
dialog with each other. This could include- but not be limited to- formats such as
community workshops, short video interviews, and media partnerships.
Pursue a partnership with other cities and the county for an affordable housing
portal that allows people to submit a single application for multiple affordable
housing developments.
Identified need : Currently, to apply for affordable housing, residents need to
search multiple websites and apply using many different web portals or paper
applications. Since many people are applying for so few units, a person in need
of affordable housing will need to apply for multiple opportunities to increase their
chances of success, submitting and resubmitting the same information multiple
times through many different channels. This process creates inequitable access
to affordable housing for people most in need who lack the resources and time to
monitor waitlist statuses, submit paper applications or have cognitive disabilities
which hinder their ability to complete multiple applications at a time. This
increases the likelihood that the renter will not successfully connect with an
available affordable unit.
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Packet Pg. 310 Attachment: Public Comments through 10-12-22 (4016 : Review of the Draft Housing Element)
Program to address : A single source and application for affordable housing
would help people find affordable housing without causing loss of time and
resources to hunt for it and resubmit the same information. A single source would
also allow the city or county to affirmatively market or share all affordable housing
opportunities to vulnerable and hard to reach populations. This portal could be
similar to the San Jose Doorways program currently in development, and Dahlia
in San Francisco , which provides a single starting point for people to apply for
affordable housing (inclusionary or standalone). A single source would also make
it easier for the city, county, and residents to track the availability of affordable
housing in their area.
Express an explicit commitment to continued funding for basic-needs services at
local encampments.
Identified need : Each year, service providers must reapply for city funding to
provide basic needs services at encampments where residents experiencing
homelessness are living. This process is often politically contentious and
uncertain. The lack of certainty impacts the ability of these organizations to
establish long-range plans and focus on service provision.
Program to address : Providing for the basic needs of residents experiencing
homelessness and living in encampments can improve health, safety, and quality
of life. Gilroy already provides funding on an annual basis for South County
Compassion Center to provide some of these services, but each year they must
reapply and wait for approval again. A long-range funding commitment from the
city provides more certainty and allows the Compassion Center to fully focus on
service provision.
Support and facilitate the creation of community-based nonprofits, which will
develop affordable housing, including the exploration of alternative models.
Identified need : Large multifamily affordable housing developments take years
to complete and do not meet the needs of all residents experiencing
homelessness or in need of affordable housing. This system makes it difficult for
the exploration of alternative and innovative home types that may be better able
to meet the needs of some residents. Currently, affordable housing is limited to
large complexes to make efficient use of land values. These projects, although
they are vital assets to the community, take long periods of time to fund, approve
and construct. The large sizes and lack of tenant input on governance also pose
challenges to the creation of a deeper sense of belonging, building a tight knit
community and facilitating neighborly connections.
5.A.c
Packet Pg. 311 Attachment: Public Comments through 10-12-22 (4016 : Review of the Draft Housing Element)
Program to address : We can expand our options of multifamily affordable
housing to more creative and innovative options that have tangible community
control and collaborative decision making tools, such as Community
Development Corporations (CDCs), co-housing, co-op housing, tiny home
communities, and community land trusts. However, since many of these options
do not exist in South County, significant financial and technical support and
training is needed to make them viable. Local efforts can complement the initial
commitments made by Santa Clara County to provide technical assistance.
Training can be assisted by other and more established non-profit organizations.
Partner with CDFIs to develop a loan program with full or partial loan forgiveness
for homeowners who build ADUs and restrict affordability for 15 years.
Identified need : While Accessory Dwelling Units have been successful at
increasing housing production and offering homes that are more affordable by
design, homeowners who are “house rich but cash poor” may struggle to obtain
financing to build an ADU.
Program to address : In partnership with a CDFI, the city should develop a loan
program with full or partial loan forgiveness for homeowners who build ADUs and
restrict affordability for 15 years. This would increase the ability of homeowners
to increase the number of homes available, secure deed-restricted affordability,
and provide an income stream for lower-income homeowners to increase their
financial stability. There is an existing low interest loan program administered by
the Housing Trust of Silicon Valley that could be used as a foundation for this
program.
Create a public awareness campaign to increase community knowledge of the
existing range of services for the unhoused and homelessness prevention
resources.
Identified need : Many residents who need help with housing issues are not
aware of the existing range of services for the unhoused and homelessness
prevention resources currently available in our city, or through the County’s 211
service. Many struggle to identify and access available resources on their own.
Information about local resources, including those funded through the county,
and the 211 service, is currently not available on city websites.
Program to address : The city should take steps to increase awareness of how
to access the services available locally, including the 211 system, which can help
residents in need navigate and access a wide variety of available resources in
the county. At minimum, this should include publishing information on the city’s
website in an easily accessible location and ensuring city staff are aware of the
program and can direct residents to it. The city should also consider a public
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awareness campaign using social media, publications such as city newsletters
and printed collateral, events, and additional channels to increase awareness of
the 211 system.
We recognize that our discussion were not representative of the full range of
perspectives in Gilroy,and that these proposed actions will not address the full
complexity of our local housing needs, but we are confident that our collective
experience represents a critical perspective in identifying existing housing needs and
actions that should be incorporated into the Housing Element Update. As noted above,
we are requesting an opportunity to meet with your staff (and consultant) to discuss
these proposals in more detail and to determine the appropriate next steps for their full
consideration.
Please contact Joanne Fierro at fierro5175@earthlink.net to set up a time for this
meeting.
Thank you for your consideration, we look forward to further discussion.
This letter is being submitted by a working coalition of community housing advocates,
community based housing and homeless service providers, and regional policy and
advocacy organizations. This group has come together out of a series of five community
meetings over the last three months with over 60 unique participants.
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Cindy McCormick
From:Joanne Fierro <fierro5175@earthlink.net>
Sent:Wednesday, September 21, 2022 7:53 AM
To:Cindy McCormick
Subject:EXTERNAL - RE: Gilroy Housing Element - 1st draft released
GILROY HOUSING ELEMENT/PUBLIC COMMENT
I have just a few ideas to offer about the 1st draft of the Housing Element.
I would really like to see a recommendation that the city hire a staff person to work solely on affordable housing issues.
In section H2 A-B it mentions a LEAP Grant from 2020 for $130,000 meant to help with affordable housing. I also know
that Destination Home was offering a 3 year grant to pay the salary of such a person. Gilroy needs to actively seek
money from State and County programs to help us reach the RHNA goals. The city does not have the resources to do it
alone. The city is missing so many opportunities to receive funds from State and County programs because no one is
researching or applying for the grants. We must be proactive.
Gilroy needs to adopt an Inclusionary Housing Ordinance. Just last month the council approved a plan for housing on 6 th
street and when the subject of BMR’s was brought up it was just passed over. That is not acceptable.
I was hoping to see more action on using Homekeys money to remodel old motels or hotels that are in our downtown.
These can be done much quicker than new builds and will help the unhoused transition into permanent housing. Gilroy
has done nothing to take advantage of the Homekeys program.
All in all, I feel that the Housing Element addresses many of the key issues. I appreciate that the focus group’s ideas are
well represented in the draft.
I look forward to our city leaders taking serious actions on the recommendations.
Sincerely, Joanne Fierro
CAUTION: This email originated from an External Source. Please use proper judgment and caution when opening attachments, clicking links, or
responding to this email.
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Sent from Mail for Windows
From: Cindy McCormick
Sent: Monday, September 12, 2022 11:07 AM
To: fierro5175@earthlink.net
Subject: Gilroy Housing Element - 1st draft released
Ms. Fierro,
Thank you again for your letter to the City regarding our 2023-2031 Housing Element.
We have released the first draft for public review and I wanted to personally reach out to you to let you know how you
can access the draft (see link below) and what the next steps will be.
Draft Link: https://www.cityofgilroy.org/DocumentCenter/View/13126/2023-2031-Housing-Element-1st-Draft-?bidId=
General Info: https://www.cityofgilroy.org/907/Housing-Element-Update
9/12/22: The 30-day public review begins today, September 12, 2022. We will evaluate all public comments and
incorporate revisions to the draft as appropriate or feasible.
9/23/22 (tentative): We intend to hold a Virtual community meeting to present the Housing Element Programs
and solicit feedback from the public. The virtual meeting would potentially occur during the lunch hour so that
individuals could participate while eating their lunch at home/office.
Week of October 3rd (tentative): We intend to hold an in-person community meeting to present the Housing
Element Programs and solicit feedback from the public. The meeting would potentially occur at 6:00 PM to
accommodate working individuals that prefer an evening meeting.
10/17/22 (tentative): We intend to hold an in-person public hearing with the City Council on October 17 th to
present the Draft Housing Element along with any major revisions based on public comment.
10/20/22 (tentative): As an alternative (or perhaps in addition to) to holding a meeting the week of October 3 rd,
we would hold an in-person public hearing with the Planning Commission on October 20 th to present the Draft
Housing Element along with any major revisions based on public comment.
Following the October 17th Council meeting (and potential Oct 20 th Commission meeting), the Housing Element
consultant will make revisions to the 1st Draft to reflect feedback from the community, the Planning Commission, and
the City Council. The City will then send the 2nd draft to the California Department of Housing and Community
Development for their review. It is anticipated that additional changes would be made prior to taking a final draft to the
City Council in January 2023.
Once again, I’d like to express how much we appreciate your recommendations. While we can’t feasibly adopt every
recommendation, we are certain that the City of Gilroy is making great strides to facilitate more housing in the City, and
more affordable housing through new policies such as the forthcoming Inclusionary Housing Policy; Density Bonus
program offering additional incentives for households with special housing needs such as large households, extremely
low income households, and farmworkers; programs to incentivize more affordable by design units including ADUs,
micro-units, and missing middle (duplex, triplex, fourplexes); reduced parking requirements for senior housing; a
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Displacement Prevention Policy; and a system to prioritize occupancy of existing and future affordable units with current
residents of Gilroy and individuals working within the City of Gilroy.
Respectfully,
CINDY MCCORMICK
CUSTOMER SERVICE MANAGER
Direct 408.846.0253 l Cindy.McCormick@cityofgilroy.org
Main 408.846.0440 l www.cityofgilroy.org/planning
7351 Rosanna Street | Gilroy | CA 95020
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DEVELOPMENTAL DISABILITIES HOUSING NEEDS ANALYSIS FOR
GILROY HOUSING ELEMENT
Introduction to Developmental Disabilities
California state law defines developmental disabilities as a disabling condition that emerged before age
18, is expected to be lifelong, and is a substantial disability attributable to major impairment of cognitive
and/or social functioning. A substantial disability is defined as “significant functional limitations…in
three or more of the following areas of major life activity, as appropriate to the person's age: Receptive
and expressive language; Learning; Self-care; Mobility; Self-direction; Capacity for independent living;
and/or Economic self-sufficiency”. Developmental disabilities include intellectual disability, autism, Down
syndrome, epilepsy, cerebral palsy, and other disabling conditions similar in their functional impact to an
intellectual disability. A developmental disability by definition does not include conditions that are solely
physical, psychiatric or learning disabilities (Section 4512 of the Welfare and Institutions Code and
Section 54000-54002 of the Code of Regulations). Under California’s Lanterman Developmental
Disabilities Services Act and the U.S. Supreme Court ’s 1999 decision in Olmstead v. L.C.,people with
developmental disabilities are entitled to receive community-based services that allow them to live in
the least restrictive setting of their choosing. In California these services are accessed through the state’s
21 Regional Centers and funded by the Department of Developmental Disabilities. This shift to
de-institutionalization has led to the closure of the most restrictive segregated settings and to the
requirement, under SB 812, that local jurisdictions in their Housing Elements assess and plan specifically
for the housing needs of people with developmental disabilities who receive supportive services from
the Regional Center in order to live in their home community.
Demographic and Other Trends Affecting the Housing Needs of People with
Developmental Disabilities
Lower Proportion of Adults with Developmental Disabilities in the City of Gilroy.The City of Gilroy is
home to 520 people with developmental disabilities (Table __). The table below shows that Gilroy has a
lower concentration of adults with developmental disabilities than other jurisdictions in Santa Clara
County as only 59% of Gilroy residents with developmental disabilities are 18 and older as compared to
63% of Santa Clara County residents with developmental disabilities being 18 and older. Instead, a higher
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proportion of Gilroy’s residents with developmental disabilities are under age 18 (41% vs 37%). As
discussed below, a lack of deeply affordable housing paired with supportive services could be one of the
factors contributing to less adults with developmental disabilities being able to live in the City of Gilroy.
Table ___ Gilroy and Santa Clara County Population with Developmental Disabilities
Age City of Gilroy City of
Gilroy
% of total
Santa Clara
County
Santa Clara County
% of total
Under age 18 212 41%4016 37%
18 and older 308 59%6737 63%
Total 520 100%10753 100%
Note: The City of Gilroy population with developmental disabilities was provided by San Andreas Regional Center as of November 2021. The
Santa Clara County population with developmental disabilities is based on county-level data published by the Department of Developmental
Services as of June 2021.
Living Arrangements of Gilroy Adults with Developmental Disabilities.Assessing the housing needs of
adults with developmental disabilities is of particular importance because as they age the adults will
require a residential option outside the family home, whereas the family home is the preferred living
option for children with developmental disabilities. Living Arrangements for adults with developmental
disabilities living in Gilroy closely mirrors that of all adults with developmental disabilities within the
County. As of November 2021, San Andreas Regional Center (SARC) reported that the family home is the
most prevalent living arrangement for Gilroy adults with developmental disabilities, with 65% of adults
continuing to live in the family home the same as is found throughout the County. Only 8% of Gilroy
adults with developmental disabilities have successfully transitioned to living in their own apartment,
lower than the 11% of Santa Clara County adults with developmental disabilities that have transitioned
into independent living. This is most likely due to a lack of deeply affordable housing within the City. As
discussed below, availability of Extremely Low Income (30% AMI) housing is needed for adults with
developmental disabilities to live independently. As of 2021, 26% of Gilroy adults were reported to be
living in licensed care facilities, higher than the County overall where only 23% of adults with
developmental disabilities are living in licensed care facilities. However, as discussed below,
opportunities for adults to live in a licensed care facility are declining throughout the County. This decline
is fueling the need for Gilroy to increase opportunities for adults with developmental disabilities to live in
affordable housing with supportive services in order to decrease risk of homelessness or displacement
when a parent or family member is no longer able to provide housing.
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Table ___ Living Arrangements of Adults with Developmental Disabilities in Gilroy Compared to Santa
Clara County
Adult Living
Arrangements Gilroy
Gilroy
Percent of Total Santa Clara County
County Percent of
Total
In the family home 200 65%4,362 65%
Own apartment with
supportive services 26 8%756 11%
Licensed Facilities 79 26%1,525 23%
Other (including
homeless)3 1%94 1%
Total Adults 308 100%6,737 100%
Note: The Gilroy population with developmental disabilities was provided by San Andreas Regional Center as of November 2021. The Santa
Clara County population with developmental disabilities is based on county-level data published by the Department of Developmental Services as
of June 2021.
Decline in Licensed Care Facilities in Santa Clara County.The Department of Developmental Services
reports that between September 2015 and June 2021, 5% fewer people with developmental disabilities
were able to be housed in licensed care facilities (including Community Care Facilities, Intermediate Care
Facilities, and Skilled Nursing Facilities) in Santa Clara County, even as the adult population in need of
residential options outside the family home grew. This trend increases the need for affordable housing
options coordinated with supportive services funded by the San Andreas Regional Center. The County’s
reduced supply of licensed care facilities increases the likelihood that Gilroy adults with developmental
disabilities will be forced out of the county when their parents are no longer able to house them--unless
there is a significant improvement in access to affordable housing.
Increase of Autism Diagnosis Reflected in Increase in Adults in their 20s and 30s.Growth in the Santa
Clara County adult population with developmental disabilities correlates with a well-documented annual
increase in the diagnosis of autism that began in the mid-1980s and did not level out until after 2015.
The cumulative impact of this trend is already seen in the growth of the Santa Clara County population
age 18 to 41 with developmental disabilities and will continue into the future. This trend has significant
implications for housing needs among Gilroy adults with developmental disabilities during the period of
the 2023-2031 Housing Element, as the population can be expected to continue to grow at a faster rate
than the general population.
Longer Life Spans.Between September 2015 and June 2021, the Department of Developmental Services
reports that the number of Santa Clara County residents with developmental disabilities age 62 and
older grew by 35% (Table __). This increase is generally attributable to well-documented gains in life
span, rather than to migration of seniors with developmental disabilities into Santa Clara County.
Longer life spans mean that more adults with developmental disabilities will outlive their parents and
family members who are by far the single largest source of housing for people with developmental
disabilities in Gilroy. Because older adults currently occupying a licensed facility in Santa Clara County are
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living longer, this reduced rate of occupant turnover, coupled with closing facilities, will make it more
difficult for middle-aged and senior adults who have been living with aging parents in Gilroy to transition
to licensed care when their parents pass away.
Table __ Changes in Age Distribution of Adult Population in Santa Clara County
Age 2015 Number 2021 Number % Change
18 to 31 2,767 3,515 27%
32 to 41 891 1,212 36%
42 to 51 833 705 -15%
52 to 61 702 744 6%
62 plus 416 561 35%
Total adults 5,609 6,737 20%
Source: Department of Developmental Services Quarterly Report by County.
Displacement.Notwithstanding 20% growth in Santa Clara County ’s total population of adults with
developmental disabilities, the Department of Developmental Services has documented a 15% decline in
the age group 42 to 51 in Santa Clara County between September 2015 and June 2021 (Table ___). In
light of gains in life expectancy, this loss can reasonably be attributed to displacement from the county
because of a lack of residential living options (either licensed facilities or affordable housing) when an
elderly family caregiver passes away or becomes unable to house and care for the adult. Displacement
takes a particular toll on adults with developmental disabilities who depend on familiarity with transit
routes and shopping and services, as well as support from community-based services and informal
networks built up over years of living in Gilroy.
Higher Rates of Physical Disabilities.People with developmental disabilities are more likely than the
general population to have an accompanying physical disability. Almost 20% of Santa Clara County
residents with developmental disabilities have limited mobility, and 15% have a vision or hearing
impairment. The need for an accessible unit coupled with the need for coordinated supportive services
compounds the housing barriers faced by those with both cognitive and physical disabilities.
Ineligibility for Many Affordable Rental Units.Some adults with developmental disabilities depend on
monthly income of around $1,000 from the Supplemental Security Income (SSI) program, pricing them
out of many of the limited number of affordable housing units in Gilroy. Those with employment tend to
work part-time in the lowest paid jobs and also struggle to income-qualify for many of the affordable
housing units now available for rent in Gilroy.
Transit-Dependent.Most adults with developmental disabilities do not drive or own a car and many rely
on public transit as a means to integration in the larger community.
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Best Practices for Inclusion of People with Developmental Disabilities in Typical
Affordable Housing
The City of Gilroy can meet the housing needs of people with developmental disabilities by adopting
policies and programs to continue promoting their inclusion with coordinated services in typical
affordable housing. The following considerations should guide the City of Gilroy in this pursuit:
●Integration in typical affordable housing is a priority in order to affirmatively further fair
housing for a group that has historically experienced no alternatives to segregated living and also
to counter the displacement of adults with developmental disabilities out of the City of Gilroy.
●Coordination of housing with onsite supportive services funded by the San Andreas Regional
Center should be encouraged. These fully funded coordinated services provide a supported
pathway for people with developmental disabilities to apply for and retain an affordable
apartment and are often as essential to a person with a developmental disability as a physically
modified unit is to a person with a mobility, vision, or hearing impairment.
●A mix of unit sizes at inclusive housing properties would address the needs of those who require
live-in aides, want to live with roommates or partners, or have children.
●Location near public transit would accommodate the transit-dependency of most adults with
developmental disabilities.
●Deeply affordable housing is needed by people with developmental disabilities.Per HCD
guidance, the City should plan for at least 334 Extremely Low Income (ELI) units, or 50% of its
Very Low Income RNHA allocation. ELI units are particularly important to people with
developmental disabilities, and some of the City’s planned production of ELI units should be
subject to a preference for people with developmental disabilities.
Policy and Program Recommendations
The City of Gilroy has a responsibility not simply to assess the housing needs of people with
developmental disabilities but also to create and implement policy, zoning, program and other changes
that make it more feasible for affordable housing developers to include people with developmental
disabilities in their housing plans. Currently the city has one affordable property, Villa Esperanza, which
includes 20 set aside units for people with developmental disabilities who benefit from on-site
supportive services funded by the San Andreas Regional Center. However, the city still has a long way to
go in meeting the housing needs of adult residents with developmental disabilities. In order to meet the
increasing needs of the City’s population of adults with developmental disabilities, policies and programs
that explicitly promote inclusion of people with developmental disabilities in affordable housing with
coordinated services provided by the San Andreas Regional Center are required. Below are examples of
programs and policies which can help to prevent homelessness or displacement of these vulnerable
residents as well as to provide opportunities for people with developmental disabilities to live in the
least restrictive setting of their choosing in line with the Olmstead Decision.
●Affirmatively Further Fair Housing by Producing More Extremely Low-Income Housing.Not
only is disability the highest-ranked source of Fair Housing complaints in Santa Clara County, a
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growing body of Santa Clara County data indicates that Black, Indigenous and other People of
Color (BIPOC) with disabilities experience higher rates of severe rent burden than either BIPOC
without disabilities or whites with disabilities. Such disparities in the experience of severe rent
burden, housing instability and displacement from the City of Gilroy are attributable to the
shortage of housing priced to be affordable to Extremely Low Income (ELI) households with
incomes below 30% of Area Median Income. Multiple barriers including high land and
construction costs and limited funding make it difficult for developers to produce Extremely Low
Income units that would help to reduce such disparities. Local zoning and other policies that
lead to increased production of Extremely Low Income units, as well as city staff dedicated to
implementing and overseeing those policies, will Affirmatively Further Fair Housing in the City of
Gilroy and decrease displacement and homelessness for the most at-risk residents, including
people with developmental disabilities.
Sample Language: The City of Gilroy ’s plans to Affirmatively Further Fair Housing for Black,
Indigenous and other People of Color, particularly those with disabilities, shall include policies
designed to increase the production of Extremely Low Income units, as well as adequate staff
capacity to implement and monitor the impact of these policies.
●Establish and monitor a quantitative goal.Tracking the City’s success in housing people with
developmental disabilities is essential to determine whether policies and programs are having an
effect in overcoming historic patterns of discrimination and exclusion of people with
developmental disabilities from affordable housing. A goal of 55 new Extremely Low-Income
housing units for City of Gilroy residents with developmental disabilities over the period of the
2023-2031 Housing Element would represent meaningful progress towards the total unmet
housing need of this special needs group.
Sample Language: The City of Gilroy shall monitor progress towards a quantitative goal of 55
new Extremely Low Income housing units that are subject to a preference for people with
developmental disabilities needing the coordinated services provided by San Andreas Regional
Center to live inclusively in affordable housing.
●Target City-Owned Land, Land Dedicated to Affordable Housing under the Inclusionary
Ordinance and City Housing Funds to Achieve City-Specific Priorities.City-owned land and city
housing funds are often essential to the development of affordable housing that is financially
feasible in the City of Gilroy. In creating guidelines for the scoring of any competitive proposals
for these scarce resources, the City should grant additional points to affordable housing projects
that address the housing needs of the residents who are most difficult to house under existing
state and federal housing finance programs--for example, by prioritizing proposals with a higher
number of Extremely Low Income units or that make a percentage of units subject to a
preference for identified categories of special needs people who would benefit from coordinated
onsite services, including but not limited to people with developmental disabilities who benefit
from services of the San Andreas Regional Center.
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Sample Language: In publishing requests for competitive proposals for any city-owned land or
city housing funds, the City of Gilroy shall grant additional points to proposals that address the
city’s most difficult to achieve housing priorities, by, for example, providing a greater number of
Extremely Low-Income units or committing to make a percentage of the units subject to a
preference for people with special needs who will benefit from coordinated onsite services, such
as people with developmental disabilities who receive services from the San Andreas Regional
Center.
●Local Density Bonus.Like many state and federal housing finance programs, the state density
bonus program incentivizes the production of housing at the Low and Very Low Income level.
But in counties like Santa Clara County, with one of the highest Area Median Incomes in the
state, these incentives have the effect of making much of the available affordable housing out of
reach for residents on fixed incomes (including seniors and persons with disabilities) or who are
working in low wage jobs and are thus unable to meet minimum income requirements to afford
the rent assigned to the Very Low Income category. The City of Gilroy should add additional local
incentives to the state density bonus law to make it more responsive to the impact of Santa Clara
County’s high Area Median Income on the affordability of housing for Giloy residents who are
Extremely Low Income. The city should also include additional incentives for projects that make
a percentage of units subject to a preference for identified categories of special needs
populations who experience the greatest barriers to housing access including but not limited to
people with developmental disabilities who benefit from services of the San Andreas Regional
Center.
Sample Language: In addition to implementing the California density bonus statute, the City
shall provide an additional local density bonus, incentives, and/or concessions for housing
projects that include at least 5% of the units for people at the Extremely Low-Income
affordability level or committing to make a percentage of the units subject to a preference for
people with special needs who will benefit from coordinated onsite services, such as people with
developmental disabilities who receive services from the San Andreas Regional Center.
●Offer Developers a Range of Affordability Options Under the Inclusionary Ordinance.
California law (AB 1505, the “Palmer Fix”) explicitly allows cities to adopt inclusionary housing
ordinances that address a range of income levels from moderate-income to extremely
low-income. In developing its inclusionary housing policy the City should take advantage of this
authority to make its ordinance more responsive to local needs by offering developers a menu of
options for including affordable units, for example, by setting a higher percentage of units priced
for moderate income and a lower percentage of units priced for extremely low income or
targeted to special needs populations. Such a menu would address a broader range of Gilroy
housing needs, while giving developers more options for meeting the inclusionary requirement.
Sample Language: In developing its inclusionary housing policy, the City of Gilroy shall offer
developers a menu of options for achieving affordability, adjusting the percentage of units
required to be affordable depending on the degree of affordability achieved (moderate-income,
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low income, very low income, and extremely low income) or special needs groups targeted,
including, for example, people with developmental disabilities who will benefit from coordinated
onsite services provided by the San Andreas Regional Center.
●Extremely Low-Income Accessory Dwelling Units.As part of a larger plan to increase the supply
of Accessory Dwelling Units (ADUs), the City should consider creating a financing and/or
incentives program for homeowners who build ADUs and rent them for at least 15 years at
Extremely Low Income rent levels or that are subject to a preference for identified categories of
special needs people who would benefit from coordinated onsite services, including but not
limited to people with developmental disabilities who benefit from services of the San Andreas
Regional Center.
Sample Language: Subject to funding availability, the City shall devise a program of financing
and/or incentives for Accessory Dwelling Units subject to rent restrictions for at least 15 years at
Extremely Low-Income rent levels and/or target special needs populations, such as people with
developmental disabilities who will benefit from coordinated services provided by the San
Andreas Regional Center.
●Reduce Parking Requirements for People with Developmental and Other Disabilities.Because
most adults with developmental disabilities do not drive or own a car, the City of Gilroy should
revise its ordinances to limit parking required for affordable units for people with developmental
disabilities to .5 space for each affordable studio or 1 bedroom unit and 1 space for an affordable
2 bedroom unit or larger. A similar reduction is recommended for affordable, physically
accessible units.
Sample Language: The City of Gilroy shall encourage the inclusion of people with developmental
and other disabilities in affordable housing by recognizing their transit dependence and
establishing lower parking ratios for units targeted to people with developmental and other
disabilities than would otherwise be required for affordable housing.
●Affirmative Marketing of Physically Accessible Units:Developers are allowed to affirmatively
market accessible units to disability-serving organizations in Santa Clara County (i.e., San
Andreas Regional Center, Housing Choices Coalition for Person with Developmental Disabilities,
Silicon Valley Independent Living Center and others) but rarely take this step. Affirmative
marketing is particularly needed by people with developmental disabilities who, because of
cognitive, communication and social impairment, often rely on housing navigation services
funded by the San Andreas Regional Center to learn about and apply for affordable housing.
Sample Language: As a condition of the disposition of any city-owned land, the award of city
financing, any density bonus concessions, or land use exceptions or waivers for any affordable
housing project, the City of Gilroy shall require that the housing developer implement an
affirmative marketing plan for state-mandated physically accessible units which, among other
measures, provides disability-serving organizations adequate prior notice of the availability of
the accessible units and a process for supporting people with qualifying disabilities to apply.
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1
Cindy McCormick
From:Kalisha Webster <kalisha@housingchoices.org>
Sent:Thursday, August 25, 2022 4:28 PM
To:Cindy McCormick
Cc:Dennise Jauregui
Subject:EXTERNAL - Gilroy Developmental Disability Data for 2023-2031 Housing Element
Attachments:Gilroy Housing Element Housing Needs Analysis for Developmental Disabilities.docx.pdf
Hello Cindy,
It was great getting to speak with you on Tuesday during Gilroy's presentation to the Equity Advisory Group. My name is
Kalisha Webster and I am the Senior Housing Advocate at Housing Choices, a nonprofit organization funded by the San
Andreas Regional Center (SARC) to support people with developmental and other disabilities to find and retain
affordable housing.
Pursuant to SB 812, SARC has contracted Housing Choices to engage with cities throughout Santa Clara County as they
update their Housing Elements to provide data on the housing needs and best practices for inclusion of people with
developmental disabilities in their housing plans. Please find attached Housing Choices assessment of the housing needs
of Gilroy residents with developmental disabilities, as well as, a list of specific policy and program recommendations to
incentivize the development of affordable and accessible housing for inclusion in the draft 2023-2031 Housing Element.
Please note that the data tables are not numbered because we assume these tables will follow numbering in the larger
document. If we can provide any more information, please let me know.
We are eager to work with you on this component of the Housing Element. In particular, we would like to:
Meet with you to receive your feedback on our submission, particularly on the feasibility of the specific
recommendations that are included
Learn from you about other policy and program recommendations that are surfacing in the development of the
Housing Element that might also have an impact on housing for people with developmental disabilities.
Identify other appropriate venues for discussing our submission
Learn how we can support you in engaging Gilroy households with developmental disabilities in the outreach
process
Post our recommendations for feedback on your Housing Elements web page
Any other ideas you might have to help us broaden the larger community’s understanding of the critical
importance of deeply affordable housing to people with developmental disabilities.
Thank you so much for your work to bring more affordable housing to Gilroy.
Best Regards,
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Packet Pg. 325 Attachment: Public Comments through 10-12-22 (4016 : Review of the Draft Housing Element)
4 North Second Street, Suite 1300 | San Jose, CA 95113
Phone: 408-293-4790 | Fax: 408-293-0106 | lawfoundation.org | Tax ID 52-1014751
Advancing Justice
Housing | Health | Children & Youth
October 12, 2022
City of Gilroy
7351 Rosanna Street
Gilroy, CA 95020
Attn: Cindy McCormick
Dear Ms. McCormick,
The Law Foundation of Silicon Valley has represented low-income people in Gilroy and Santa
Clara County for over 40 years. As part of our work, we represent tenants in eviction
proceedings, advocate for better housing policies, organize with tenants in the community, as
well as run a hotline and provide walk-in services for tenants in need. As a result of our work, we
are in a unique position to see firsthand the obstacles and injustices faced by low-income tenants
and tenants of color in Gilroy every day. We believe that the Housing Element presents a
valuable opportunity to address those injustices and improve the lives of tenants living in Gilroy.
The current draft of the Housing Element has many goals and strategies that would be beneficial
to tenants, low-income residents, and historically marginalized communities in Gilroy. However,
we believe that the current draft is inadequate as it fails to identify specific timelines for the
programs and goals. We also believe the City needs to establish stronger programs to improve
the Housing Element.
We believe housing should be made more accessible to Gilroy residents, not more difficult. At
the Law Foundation of Silicon Valley, we see the huge economic impact the pandemic has had
through the number of eviction related calls we receive. In most cases, Gilroy residents are
facing non-payment of rent evictions and/or have accumulated substantial debt during the
pandemic through no fault of their own. This widely affects the working class and service
workers in Gilroy who often make minimum wage in an inflated housing market, which in many
cases pushes residents out of Gilroy. We also view housing unaffordability as a racial justice
issue. In fact, 80% of the people facing eviction that come to our office for help are people of
color.
The following outlines improvements that should be made to the Housing Element draft.
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Packet Pg. 326 Attachment: Public Comments through 10-12-22 (4016 : Review of the Draft Housing Element)
4 North Second Street, Suite 1300 | San Jose, CA 95112
P 408-293-4790 | f 408-293-0106 | www.lawfoundation.org | Tax ID 52-1014751
1. Accountability for Landlords and Management Companies
The Housing Element draft does not include sufficient accountability measures for landlords and
management companies that violate the law. Rather, the Housing Element draft takes an
educational approach. While this may be helpful to predominately small landlords who may be
unaware of the law, this will have no impact on those knowingly and willingly violating the law.
Indeed, management companies and big landlords should in particular be aware of local laws, as
it is their business to know. Yet, tenants continue to live in substandard conditions, pay illegally
high rents, and fall victim to landlord harassment, discrimination, and retaliation.
To address this, greater fines should be imposed and collected on landlords, as well as the
possibility of criminal charges for serious and repeat offenders. Furthermore, there should be a
streamlined mechanism that enables the city of Gilroy to take on management of buildings that
have fallen into disrepair to make the necessary repairs and renovations to keep the building up
to code.
Gilroy should also pass an anti-harassment ordinance, such as the one in Los Angeles,
which provides greater recourse for tenants who are harassed, including an award of up to
$10,000 per violation. Additionally, resources and funding should be provided to enable tenants
to bring affirmative suits against their landlord for violating the law. This should also be a
priority of the Gilroy city attorney to hold landlords accountable for violations of the law.
2. Tenant based voucher advocacy
The Housing Element draft goals to support tenant-based voucher holders are great starting
points. Housing Choice Voucher tenants are among the most vulnerable for displacement as a
result of the lack of landlords willing to accept vouchers. Despite state and local legislation,
HCV tenants still face source of income discrimination from private landlords. Many are unable
to secure or maintain housing despite their subsidy. Strong enforcement of source of income
discrimination laws is critical in ensuring HCV tenants access housing. The Draft does not
provide much clarity in what these enforcement mechanisms will be or whether this will be a
function of the Gilroy City Attorney’s Office or County Counsel. Further, centering the goal of
getting HCV tenants housed would help create more accessible housing in addition to penalizing
landlords who discriminate.
A major barrier that HCV tenants face is the lack of affordable housing. Often, HCV tenants are
priced out of higher resource areas because their subsidies are not enough to cover the full
amount of rent. One of the solutions that the Draft could explore is ways to increase the amount
covered by the subsidy for HCV tenants, which would help these tenants access homes that they
would not otherwise have been able to afford. Further, the draft could also provide more clarity
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Packet Pg. 327 Attachment: Public Comments through 10-12-22 (4016 : Review of the Draft Housing Element)
4 North Second Street, Suite 1300 | San Jose, CA 95112
P 408-293-4790 | f 408-293-0106 | www.lawfoundation.org | Tax ID 52-1014751
around how funding will be allocated to Santa Clara County Housing Authority to produce
housing for HCV tenants.
The Draft could also explore ways to work with SCCHA to help HCV tenants maintain their
vouchers. Voucher terminations are detrimental to low income tenants and could lead to many
families becoming unhoused. A solution the Draft could explore in its collaboration
with SCCHA is a diversion program to voucher terminations in order to give HCV tenants the
opportunity to maintain their subsidy and remain housed.
3. Affirmatively Further Fair Housing
The Draft includes additional analysis to assist the City in determining what factors have created
the segregation that exists in the City. Some of these additional figures lack a key or explanation
of their importance, such as Figures X. Additional information is also needed when describing
the resources available to residents facing discrimination.
The Draft merely states that in order to address fair housing issues, the City contracts with and
directs residents to Project Sentinel, which provides counseling, investigation, mediation and
assistance with filing complaints. While referrals to Project Sentinel are extremely valuable at
enforcing tenants’ rights in the face of discrimination, it is limited in its ability to prevent it, or to
effect systemic change.
For instance, the City identified potential discrimination in lending practices, resulting in denial
of home loans to certain ethnic groups as a potential cause of neighborhood segregation. The city
has not identified how referrals to Project Sentinel will prevent or address this issue.
4. Tenant Protections
The City claims in the Draft that it cannot control market rent prices but fails to consider passage
of rent control. The City’s policies and program should include explicit commitments towards
strengthening tenant protections and keeping rental housing affordable. While state law provides
some limited rent stabilization for certain units under the Tenant Protection Act, it caps annual
rent increases at rates of as high as 10%, the current maximum rent increase, and does not apply
to all residents in Fairfield. Reliance upon the state law is inadequate to prevent displacement of
the City’s low-income and rent-burdened households.
5. Code Enforcement
The Housing Element draft does not include a plan to implement strict accountability measures
for landlords who are non-compliant with the municipal code. Many of the clients we assist at
Law Foundation find themselves facing retaliatory eviction notices when they contact code
enforcement regarding habitability issues. Tenants often do not know what to do when they
request repairs or bring up serious habitability concerns to landlords who refuse to make repairs.
Some tenants also face serious health concerns when landlords refuse to address habitability
issues such as mold or pests. The housing element should include a plan to implement strict
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Packet Pg. 328 Attachment: Public Comments through 10-12-22 (4016 : Review of the Draft Housing Element)
4 North Second Street, Suite 1300 | San Jose, CA 95112
P 408-293-4790 | f 408-293-0106 | www.lawfoundation.org | Tax ID 52-1014751
measures to hold landlords accountable as it is part of landlord’s responsibilities to provide a
habitable living space.
6. LIHTC Properties
The Law Foundation of Silicon Valley has been working with tenants that live in LIHTC
properties and have serious concerns about the recent rental increase notices tenants have been
receiving, many of which are over 10% because the rent is not based on a person’s income, but
on the area median income. LIHTC tenants generally have less protections on rent increases than
AB 1482 covered properties when it comes to rent increases and are also not covered under AB
1482 which caps rent at no more than 10% in a 12-month period. We believe the Housing
Element should address this issue by including LIHTC protections to prevent LIHTC owners
from spiking rents by percentages higher than rent regulated properties.
Thank you for taking the time to read this letter. If you would like to follow up on any of these
issues, you may contact Nuemi Guzman, Co-Interim Director at Law Foundation of silicon
Valley at 408-280-2424 or nuemig@lawfoundation.org.
Sincerely,
/s/
Nuemi Guzman, Co-Interim Director
Ruben Garcia, Community Housing Advocate
Kianna Evans, JD Advocate
Jorge Casas Cuellar, Community Housing Advocate
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Cindy McCormick
From:Maria Aguilar <md12aguilar@yahoo.com>
Sent:Friday, September 16, 2022 5:21 PM
To:Cindy McCormick
Subject:EXTERNAL - Housing element
I'm in favor of the proposed housing element draft 2023-2031, I have attended various presentations including the in
person August 29th event at city hall.
Sent from Yahoo Mail on Android
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Packet Pg. 330 Attachment: Public Comments through 10-12-22 (4016 : Review of the Draft Housing Element)
1
Cindy McCormick
From:Marya Hart <marya.hart@yahoo.com>
Sent:Thursday, September 22, 2022 1:52 PM
To:Cindy McCormick
Subject:EXTERNAL - Housing
CAUTION: This email originated from an External Source. Please use proper judgment and caution when opening
attachments, clicking links, or responding to this email.
I moved to Gilroy to be able to view the beautiful hills around us. But now you are ruining the views with houses and
two story apartments. If you look at how the homeless live and notice all the junk and squaller they create do you really
wand all that spread all over Gilroy at “low income” housing??? Stop all this building covering our beautiful hills and
trees!!!!
Sent from my iPhone
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Packet Pg. 331 Attachment: Public Comments through 10-12-22 (4016 : Review of the Draft Housing Element)
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Cindy McCormick
From:Kenneth Rosales <kenneth@siliconvalleyathome.org>
Sent:Wednesday, June 8, 2022 10:46 PM
Cc:Mathew Reed
Subject:EXTERNAL - Making Housing Elements Work through State Enforcement
Good Evening Honorable Mayor, Councilmembers, and City Staff,
Your jurisdiction is either preparing for the release or is reviewing the first draft of your 6th Cycle Draft
Housing Element before it is submitted to the California Department of Housing and Community Development
(HCD) for initial review. As you may have heard, the vast majority of cities in the first rounds of submissions
have received substantial comments from HCD outlining deficiencies and are being required to complete
additional work to adjust and improve their housing elements so that they move into compliance. We believe
this current moment presents an opportunity to assess working drafts with an eye on how the HCD review
team has described some common issues they have observed. As of April 2022, jurisdictions in three major
regions had submitted their “final” Housing Elements by their given deadlines but have continued to work
with HCD on developing compliant Housing Element Updates:
The San Diego Association of Governments’ Housing Element deadline was on April 15, 2021, of which
only 7 of 19 jurisdictions were in compliance;
The Southern California Association of Governments’ deadline was on October 15, 2021, of which
only 7 of 197 jurisdictions were in compliance; and
The Sacramento Council of Governments’ Housing Element deadline was on May 15, 2021, of which
only 17 of 28 jurisdictions were in compliance.
On March 25, 2022, SV@Home hosted a discussion during our monthly Housing Action Coalition event with
David Zisser and Melinda Coy, HCD’s leadership for the Housing Element review team, titled “Making Housing
Elements Work through State Enforcement” (click here). David and Melinda discussed how they will enforce
Housing Element law and provided local advocates guidance on what they can do to help jurisdictions meet
Housing Element requirements. Therefore, we would like to share the event recording and presentation slides
as resources for your jurisdiction to use as you draft, publish, edit, and submit your Draft Housing Elements to
HCD (available here). We have included time stamps on key topics within the webpage to make it easier to
navigate the recording.
HCD reinforced the fact that they no longer consider the Housing Element Update to be a paper exercise, but
instead a contract between jurisdictions and the state on housing commitments for eight-and-a-half years. To
this end, HCD’s new Housing Accountability Unit will be monitoring implementation and will hold jurisdictions
to the commitments laid out in the Housing Element’s plan.The following are key take-aways from HDC’s
presentation, which we felt were particularly useful to consider as drafts are being finalized and reviewed:
Most Common and Overarching Concerns - HCD has found that Housing Elements overwhelmingly
describe but do not analyze the data that is provided.
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Whenever data is included into Housing Elements, they want jurisdictions to ask themselves: What
does the data mean? How are these assumptions supported?
Further, HCD discussed they would like jurisdictions to “show their work” for the conclusions that are
drawn, to avoid assumptions, and to use their analyses as tools that guide solutions, rather than simply
explaining existing conditions. In this way, the various sections (e.g. needs assessment, sites inventory,
constraints, etc.) should be reflective of and inform each other.
Affirmatively Furthering Fair Housing (AFFH) - HCD is looking for an analysis of patterns and trends - a
story about the jurisdiction over time and how it has changed - rather than a demographic “data
dump”.
They provided an example of what jurisdictions can ask themselves when providing their analyses: has
our community become more diverse? Less diverse? Where are the areas of poverty and how have
they evolved? How does this help to highlight the housing needs of each jurisdiction?
HCD would also like to see strategies for how local jurisdictions can “move the needle” (i.e. make
progress) and assess whether the metrics and milestones of their actions will be successful in eight-
and-a-half years.
They recommended jurisdictions review the City of Sacramento’s Housing Element on how AFFH can
be adequately addressed and the City of Folsom’s Housing Element for a good example of AFFH in a
high resourced community.
AFFH: High-resourced and Lower-resourced neighborhoods - Under AFFH guidelines, it is important to
add affordable housing opportunities throughout the jurisdiction. They clarified, however, that AFFH is
also about providing community development options or programs to increase resources in low-
resourced areas, preventing displacement, and increasing housing opportunities in terms of both sites
and mobility.
Site Inventory - HCD recommended jurisdictions provide supporting data to the selection of their sites,
including the underlying assumptions to pick a site, such as development trends and substantive site-
specific analysis.
When choosing sites, HCD suggested that a discussion of the selection process be included, answering:
Why were the factors that shaped the process chosen, and how did those assumptions relate to
answering the question: “is this a development opportunity within the planning period?”
For non-vacant sites, they mentioned jurisdictions should specifically provide substantial evidence that
an existing use is likely to be discontinued. Such evidence could include: 1) site specific information on
whether the use will be discontinued in an eight-and-a-half year period and explain the factors leading
to that conclusion, 2) what market and development trends are there to support discontinued use, and
3) what programs and actions could be taken by the jurisdiction to address the constraints that might
impede the redevelopment of non-vacant sites.
Further, HCD expects site inventories to be responsive to the AFFH analysis, rather than be considered
independent.
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Governmental and Market Constraints to the Development of Housing - HCD discussed that
constraints are to be analyzed and assessed for their potential impact, rather than simply noted and/or
justified.
They also advised jurisdictions to consider the perspective of a potential developer and ask: how does
the range of development standards, processing fees, various impact fees, etc. affect the development
of housing? How long does it take to get planning and construction approvals, and what are the
additional costs? What are the points of discretionary uncertainty in the process? Are there systems in
place to process streamlined applications? How might substantial or minor changes in these elements
of the development process have the cumulative impact of facilitating more development in your
jurisdiction?
HCD delved into the need of a thorough assessment and a clear timeline for developing concrete policy
or program changes in response to these analyzed constraints rather than referencing on-going or
future assessments that need to be conducted. They want to see studies made within the Housing
Element Update itself to construct a policy or program rather than prescribing a “study” as the policy
or program itself.
Importantly, HCD recommended that the constraints analysis be reflected in the assessment of site-
specific conditions that are identified in the site inventory.
Programs and Policies - HCD explained how jurisdictions should present clear prioritization and
provide specific actions and timelines for each policy and program, along with clearly explaining what a
jurisdiction will do to make implementation more realistic and feasible.
They suggested jurisdictions avoid the use of general language like “explore”, “consider'', “evaluate”,
or “study”. Instead, HCD would like to see a detailed discussion about what exactly is going to be
explored, what will be done, to what end, and what the outcome(s) would be. HCD gave the example
of replacing language such as "will explore providing incentives" with "we will develop an incentives
program that will reduce fees/provide cost savings".
Moreover, HCD deliberated on how a jurisdiction’s policies and programs should build on the
assessment of existing measures and go beyond previous cycles. Policies and programs should support
the narrative in the housing needs and development constraints analysis and be responsive to
additional requirements of the AFFH analysis.
Funding - HCD detailed how they will not accept the rationale that the lack of subsidies for affordable
housing development is an insurmountable impediment to fulfilling housing commitments. Instead,
they advised jurisdictions to find ways to spur development through land use reforms and additional
financing mechanisms. These might include adopting a strong local density bonus program, an
inclusionary housing ordinance with a robust in-lieu fee structure, or other impact fees as a mechanism
to support affordable housing development. HCD also recommended looking into ways of lowering
costs by deferring or waiving fees and taxes.
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Non-Compliant Housing Elements - HCD cautioned that jurisdictions with non-compliant Housing
Elements will be ineligible for, or face delays in receiving, state funding. Jurisdictions would also be
unable to use inconsistent zoning/general plan standards to deny affordable housing projects, and
could be subject to additional legal ramifications and fines.
Implementation of RHNA through the 6th Cycle - HCD re-emphasized that jurisdictions are required to
monitor and adjust their site inventories to sustain capacity for their housing allocation througho ut the
planning period.
Enforcement - HCD will review actions and inactions submitted in the Annual Progress Report by local
jurisdictions and they will take action on jurisdictions that are inconsistent with their Housing
Elements. HCD will also respond to public complaints if a jurisdiction's actions are in violation with
state law.
We appreciate that additional guidance has been made available from multiple sources, including ABAG/MTC
and the Santa Clara County Planning Collaborative - they have been instrumental in guiding us all through this
complicated process. We know that the Housing Element Update has been a significant undertaking and that
the HCD review process has been less central to the public and council’s engagement to date. We hope that
this letter provides constructive insight into what HCD will likely highlight and that it further enables local
engagement throughout the next phases of the Housing Element process. We also hope that meaningful
public participation will continue to be a priority as feedback is received from the state and incorporated into
future drafts.
We appreciate your continued coordination on this Housing Element journey and we look forward to
deepening our engagement as we move closer to January 2023.
Best,
Kenneth Rosales (He/Him)
Planning Senior Associate| SV@Home
408.518.0676
kenneth@siliconvalleyathome.org
#ReimaginingHome Learn more about Affordable Housing Month 2022
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Packet Pg. 335 Attachment: Public Comments through 10-12-22 (4016 : Review of the Draft Housing Element)
1
Cindy McCormick
From:Alison Cingolani <alison@siliconvalleyathome.org>
Sent:Monday, June 13, 2022 5:58 PM
To:Alison Cingolani
Subject:EXTERNAL - Declining school enrollment: Planning for new housing can help
Attachments:City of Gilroy.pdf
Silicon Valley Community Leaders,
We are reaching out to you as local council members, city staff, school district superintendents, and school
board members to share recent research we have conducted on declining school enrollment in your cities and
school districts. Right now, cities have a critical opportunity to stabilize and strengthen the local
schools that are the cornerstone of our communities and our collective future, by planning for new
housing.
As most of you know, every city in the Bay Area is currently engaged in a state-mandated process – the
Housing Element Update – of planning for a significant number of new homes affordable to residents of all
income levels. Meanwhile, school districts throughout the County are experiencing significant declines in
enrollment, with local elementary schools being particularly hard hit, as the shortage and rising cost of housing
forces many families to leave for more affordable locations. The effect has been devastating. For some of our
districts fewer students means massive budget deficits; for others it means destabilizing inefficiencies. In all
our districts declining enrollment means disruption, instability, loss of our school families, loss of our next
generation of teachers, and often heart-wrenching school closures and consolidation. These troubling
enrollment declines are impacting public, private, and charter schools, began before the pandemic, and are
forecast to continue through the next decade- unless local leaders take action. See how enrollment declines
are affecting your city, and how that compares to the county here or in the attached PDF.
Our recent report, produced in partnership with the Silicon Valley Community Foundation and Palo Alto
Forward, shows that strategic planning for new housing development, by both location and affordability, offers
an opportunity to stabilize local schools by creating more affordable options for younger families with school
age children, and to reduce student attrition caused by housing instability and displacement. This is an area
where the education community and local officials share a common interest, and must show collective
leadership.
Learn more about declining enrollment in individual schools and districts in your communities and planning for
new homes through the Housing Element Update, and view The Missing Piece: How New Homes Can Help
Save Our Schools from Declining Enrollment, a conversation with Peter Ortiz, President of the Santa Clara
County Board of Education, Jennifer DiBrienza, Vice President of the Palo Alto Unified School District Board,
and Steve Levy, Director and Senior Economist of the Center for the Continuing Study of the California
Economy.
Contact Alison Cingolani at SV@Home for more information on how local community leaders can be a part of
this discussion.
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Packet Pg. 336 Attachment: Public Comments through 10-12-22 (4016 : Review of the Draft Housing Element)
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Source: California Department of Education
Source: California Department of Finance
In partnership,
Alison Cingolani
Policy & Research Senior Associate|SV@Home
408.785.0531 I alison@siliconvalleyathome.org
Silicon Valley Is Home. Join our Houser Movement. Become a member!
350 W Julian St. #5, San José, CA 95110
Website Facebook LinkedIn Twitter
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Packet Pg. 337 Attachment: Public Comments through 10-12-22 (4016 : Review of the Draft Housing Element)
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Cindy McCormick
From:Emily Ramos <emily@siliconvalleyathome.org>
Sent:Friday, July 1, 2022 7:27 PM
To:Mayor Marie Blankley; Council Member Peter Leroe-Munoz; Council Member Rebeca
Armendariz; Council Member Dion Bracco; Council Member Zachary Hilton; Council
Member Carol Marques; Council Member Fred Tovar; Cindy McCormick
Cc:Mathew Reed
Subject:EXTERNAL - Housing Element – Anti-displacement policies to Affirmatively Further Fair
Housing
Attachments:SVH Letter RE - Housing Element Anti-Displacement AFFH [7-1-2022].pdf
Dear Mayor Blankley, Mayor Pro Tempore Leroe-Munoz, and Councilmembers Armendariz, Bracco, Hilton, Marques and
Tovar:
On behalf of SV@Home, please see the attached letter about anti-displacement policies to affirmatively further fair
housing in the housing element.
Kind regards,
Emily Ann Ramos
Preservation and Protection Associate, SV@Home
650.468.0493 I emily@siliconvalleyathome.org
350 W Julian St. #5, San José, CA 95110
Website Facebook LinkedIn Twitter Become a Member
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Packet Pg. 338 Attachment: Public Comments through 10-12-22 (4016 : Review of the Draft Housing Element)
350 W. Julian Street, Building 5, San José, CA 95110
www.svathome.org • info@siliconvalleyathome.org
Submitted via email
October 12, 2022
Cindy McCormick, Senior Planner, Planning Division
City of Gilroy
7351 Rosanna St.
Gilroy, CA 95020
Dear Ms. McCormick:
RE: Draft Housing Element Update
The 6th Cycle Housing Element Update process is a unique opportunity to fully assess
housing needs in Gilroy and to identify new tools to address these needs and constraints on
developing housing. This process is also an opportunity to engage deliberately with the full
community, especially community members who represent populations that have been
historically excluded and are at risk of displacement, to share their housing needs. This
unique opportunity is one that is required to adhere to the clear legal guidance as outlined
by the California Department of Housing and Community Development (HCD) in multiple
documents interpreting state law.
This is not a simple process, and we appreciate the work that Gilroy staff, elected and
appointed representatives, and members of the community have done over the last six to
nine months. However, as you know, the expectations for this process are high, and
jurisdictions throughout the State have struggled to generate compliant housing elements
for this cycle. Santa Clara County has had the benefit of significant analysis and reflection on
the substantive requirements of the Housing Element Update process, and the lessons
learned by other regions. The Comment Letters recently received by the Cities of Mountain
View and Sunnyvale have shown the consistency of HCD review throughout the State, and
point to the importance of these next months to taking the steps necessary to produce a
compliant document. We believe Gilroy’s current draft will require significant, substantive
revision to comply with state law and receive certification before state sanctions apply.
Local jurisdictions are required to make a Draft Housing Element available for a 30-day
public comment period to receive input, and then address concerns prior to submission of
the Draft Housing Element to the state. To that end, SV@Home is submitting the following
comments.
Outreach, community input, and targeted AFFH outreach as the foundation of the Housing
Element Update process
The Draft provides some documentation of stakeholder and community outreach, with
summaries of groups, goals, and feedback received from stakeholders, as well as survey
Board of Directors
Kevin Zwick, Chair
United Way Bar Area
Gina Dalma, Vice Chair
Silicon Valley Community
Foundation
Candice Gonzalez, Secretary
Sand Hill Property Company
Andrea Osgood, Treasurer
Eden Housing
Shiloh Ballard
Silicon Valley Bicycle Coalition
Bob Brownstein
Working Partnerships USA
Amie Fishman
Non-Profit Housing
Association of Northern CA
Ron Gonzales
Hispanic Foundation
of Silicon Valley
Javier Gonzalez
Google
Poncho Guevara
Sacred Heart Community
Service
Janice Jensen
Habitat for Humanity
East Bay/Silicon Valley
Janikke Klem
Jan Lindenthal
MidPen Housing
Jennifer Loving
Destination: Home
Mary Murtagh
EAH Housing
Chris Neale
The Core Companies
Kelly Snider
Kelly Snider Consulting
Staff
Regina Celestin Williams
Executive Director
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Packet Pg. 339 Attachment: Public Comments through 10-12-22 (4016 : Review of the Draft Housing Element)
October 12, 2022
Re: Draft Housing Element Update
Page 2 of 8
350 W. Julian Street, Building 5, San José, CA 95110
408.780.8411 • www.svathome.org • info@siliconvalleyathome.org
responses that include quotes from participants and summaries of feedback. However, the Draft indicates that
just over half of the invited individuals who represented service providers, nonprofits, and other stakeholders
participated in focus group interviews about the housing needs and issues in Gilroy. It is not clear what efforts
were made to re-engage with stakeholders who did not respond to the initial invitation, or to engage with
populations represented by those who did not respond.
We recommend that the City expand on prior community engagement efforts and create
meaningful two-way engagement with all stakeholders to collect input on the current Draft, and
update the Draft with a clear record of input received through this additional engagement. These
discussions should clearly inform the housing needs assessment, the constraints analysis, and the
policies and programs proposed in response.
Although the Housing Needs Assessment illuminates housing challenges of key populations, including
farmworkers, those with intellectual and developmental disabilities, and the elderly, it lists only a broad range
of statistical sources as the basis for the assessment and does not incorporate local knowledge gathered from
community outreach. As a result, the Draft does not respond to some of the community needs identified
during community engagement. For example, despite having the second-highest number of unhoused
residents in the county, Council’s previous approval of a safe parking program, a letter from the South County
community leaders recommending a safe parking program, and five community requests for a safe parking
site written in on the survey, there is no mention of safe parking as a need or a program in the Draft.
We recommend that the City reassess the components of the Housing Element to integrate local
knowledge gained through robust outreach and community engagement process, along with data,
as the foundation for decisions about housing goals, policies, and implementation programs.
Meeting RHNA Levels and Housing Opportunity Sites Inventory
We are concerned that the Sites and Resources and Draft Sites Inventory sections of the current Draft contain
inaccuracies that have made it difficult for us to confidently assess these portions of the document. The
following examples are intended to highlight some of these inaccuracies:
• The Sites and Resources section of the Draft describes several of the City’s zoning ordinances
incorrectly, and in several cases, fails to take into account recently passed legislation. For example,
Table 54: Existing Residential Parking Standards indicates that an ADU is required to have one off-
street parking stall, while the City’s ADU ordinance lists a range of exemptions that would eliminate
this requirement for most ADUs. Table 55: Residential Use Table lists restrictions on duplexes in R1
zones that are both illegal under California Senate Bill 9, which was signed into law on September 16,
2021, and in conflict with the City’s own current SB 9 ordinance.
• 16 sites listed in the Inventory (p. 239 - 241) have addresses on “Monterey Street” or “Monterey
Highway” which are not names of any roadway within the City’s boundaries. The correct address
would be “Monterey Road,” which is used appropriately for another 11 sites in the Inventory.
• The sites at the following addresses are listed in the Inventory as “Vacant,” but have current uses:
o 7273 Eigleberry St: currently occupied by a multifamily home
o 7101 Eigleberry St: currently occupied by a single-family home
o 8340 Swanston Lane: currently occupied by a single-family home
o 110 Old Gilroy St: currently occupied by Muscle House Gym and surface parking
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o 7050 Monterey Rd: entitled for Sumano Bakery Commercial to move in with a public
storefront
The APNs listed for these sites do not match the addresses provided by the City.
SV@Home recommends aligning the Draft Housing Element with state law and the City’s current
ordinances, and ensuring that all information provided is factually correct. If a parcel in the Draft
Site Inventory does not have a street address, we recommend using a description of the parcel’s
location rather than a nearby address to clearly communicate which site is included.
Table 69: Proposed, Entitled, and Pending Projects lists sites that the City indicates are pipeline projects,
however, the definition of “Pending” projects is not established in the Draft. Our review indicates that
“Pending” projects appear to include active construction sites with approved building permits and leased sites
that have already been issued certificates of occupancy, but the information provided in the draft is
inadequate to discern the current stage of the approval process for each project. According to the Housing
Element Annual Progress Report, projects that acquired building permits within the current planning period
would count as progress towards a jurisdiction’s 5th Cycle RHNA, and would therefore not qualify to be
included in the 6th Cycle Housing Element sites inventory. Including them in the 6th Cycle Housing Element
would result in a Draft Sites Inventory that falls below adequate capacity for the City’s RHNA, which is not
permitted under SB 330 and State Housing Element law.
We recommend that the City of Gilroy avoid double-counting housing units in both the 5th and 6th
cycle by removing any sites from the inventory that received building permits prior to June 30,
2022.
Table 72: Housing Capacity estimates that 140 new ADUs will be built during the RHNA cycle, and that 60
percent of these will count towards the City’s lower-income obligations.
These forecasts are likely based on the ADU calculation methodology provided to Bay Area cities by the
Association of Bay Area Governments (ABAG). While we understand why cities are using this guidance in their
Housing Element planning process, we believe that this methodology is flawed in two ways: 1) it assumes
significantly lower rents than unpublished local studies have shown, and we have found in our analysis that
the ABAG methodology subsequently credits far more units to affordable goals than is warranted, and 2) it
assumes that all ADUs are used as primary residences, rather than home offices, guest rooms, or play spaces
for children. Together, these failings lead to a significant overstatement of ADU impact.
Further, although the Draft includes programs intended to boost ADU production in high-resource areas
(Programs A-6, A-7, and G-3), none of the programs incentivize ADU affordability or remove governmental
constraints, such as Gilroy's current restriction of ADUs to 1,000 square feet rather than the State’s allowable
maximum of 1,200 square feet. Program G-3 commits to market ADU processes and benefits to homeowners
in higher opportunity areas, and Program A-6 commits to review the geographic distribution of ADUs every 2
years and adjust the strategy if annual city-wide production rates do not increase by 7.5 units per year. It is not
clear how these programs in combination will help the City achieve its lower-income RHNA through ADUs, or
effectively measure or address real opportunities for affordability in ADUs in high-resource areas.
We recommend that if the City intends to rely on ADUs for a substantial portion of its lower-income
RHNA, particularly as a way to affirmatively further fair housing by giving lower-income families
access to high-resource areas, that it create policies that actively incentivize ADU production and
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affordability in these areas. We also recommend that the proposed review analyze both the actual
use of existing ADUs, and the rental rates for those that are serving as housing.
Placement of high density homes near public transportation is important in meeting our regional goals to
reduce greenhouse gas emissions, expand multi-modal opportunities, and provide future tenants convenient
access to the resources they need. However, complying with the requirement to affirmatively furthering fair
housing (AFFH) requires that cities show efforts to provide access to affordable housing options throughout
the entire city, including in high resource areas. This requirement has been documented explicitly in HCD’s
extensive guidance, provided in April 2021, as well as in many subsequent HCD technical assistance and
housing element review letters. It is important to site affordable housing throughout the city, especially in
areas where lower-income communities and people of color have been historically excluded through land use
restrictions and city policy.
In the Affirmatively Furthering Fair Housing chapter of the Draft Housing Element, the City completes a
thorough analysis that demonstrates and produces clear visualizations of patterns of racial, ethnic, and
economic segregation in the City. However, despite this thorough understanding, the City has chosen to
deliberately site its lower-income RHNA in ways that will perpetuate existing segregation, with lower-income
sites located in areas that are racially/ ethnically concentrated area of poverty (R/ECAPS), have poor scores for
CalEnviroScreen 4.0, are overcrowded and rent-burdened, and have poor opportunity scores for economic,
education, and environmental outcomes. This has led to sites for low- and very low-income residents being
variously located in industrial areas and adjacent to sloughs, sandwiched between old motels, and pressed
against railroad tracks. Although the City describes this as a deliberate effort to prevent displacement of
vulnerable residents from their existing communities, this approach does not comply with legislative direction
or HCD guidance to affirmatively further fair housing. Further, the City states that they expect the R/ECAPs to
become rich in resources because of development occurring within the Downtown Specific Plan, which was
passed in 2005 and has not yet had that effect on the area. While the draft siting decisions, as the City notes,
may not worsen patterns of segregation, they fail to meet the AFFH standard of replacing segregated living
patterns with truly integrated and balanced living patterns. This is particularly true in Gilroy, in which the
Latinx community disproportionately experiences housing instability and exclusion from the higher resourced
areas in the City.
We recommend that the City of Gilroy comply with HCD’s extensive guidance on planning sites for
lower-income housing in high-resource areas, and dispersing low-income sites throughout the city
rather than over-relying on the Downtown Specific Plan and concentrating lower-income sites in
high-poverty areas.
A review of the City’s Sites Inventory focusing on the Downtown Specific Plan area, which falls within a
R/ECAP, found that roughly half of the lower-income units are in this major plan area. Of those units, nearly 60
percent are planned for sites that have capacities of 50 units or less, a metric that holds true for lower-income
sites throughout the site inventory. According to the Housing Element Sites Inventory Guidebook, lower-
income sites that do not have a capacity of 50 to 150 units are less competitive for State and Federal resources
to build affordable housing, which makes them less financially feasible. HCD requires a site-by-site
assessment, and/or a detailed analysis that uses recent local development trends, to demonstrate the
feasibility of these sites redeveloping with low-income housing despite their limited capacity. If these sites are
not developed, the City would have a RHNA deficit (inclusive of the 15 percent buffer) of approximately 280
lower-income units. Given that the likelihood of adequately funding lower-income units is low, these sites
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should either have their realistic capacity assumptions heavily discounted, or be removed from the Sites
Inventory and be replaced with sites that, as HCD strongly recommends, could accommodate developments of
50-150 units.
We recommend that sites planned for lower-income homes with a capacity of fewer than 50 units
be removed from the Sites Inventory and be replaced with sites that, as HCD strongly recommends,
could accommodate developments of 50-150 units. In lieu of that, the City should heavily discount
the realistic capacity of sites planned for fewer than 50 lower-income units and add additional sites
to the inventory to address the resulting capacity deficit.
The Draft Sites Inventory and Sites and Resources section are also deeply concerning for the absence of the
required thorough analysis to demonstrate the feasibility of lower-income sites developing at the stated
realistic capacity within the 6th planning cycle. For example, 8955, 8915, and 8985 Monterey Rd., referred to
in the Sites and Resources section as the “R4 Northern Cluster,” are adjacent nonvacant parcels that were
included in both the 4th and 5th cycle Inventories. They contain active uses including a Spanish-language
church, used car lot, and daycare center. The City provides no analysis as to why these uses are likely to be
discontinued or the parcels are likely to be redeveloped with housing now, when they have not been in the
prior two cycles.
Housing Element guidance requires that cities complete a robust analysis for any nonvacant site in the
Inventory, including existing leases or other contracts that would prevent redevelopment of the site;
development trends in the city related to nonvacant sites, such as a description of the local government’s
track record and specific role in encouraging and facilitating redevelopment, adaptive reuse, or recycling to
residential or more intensive residential uses, or a program to do so; and market conditions that would
encourage redevelopment of the property. The housing element must include substantial evidence that the
use will likely be discontinued during the planning period.
SV@Home recommends that the City provide a robust analysis of nonvacant sites in the Inventory
using the criteria required under housing element law, and include substantial evidence that the
existing use will likely be discontinued during the planning period.
Part of meeting AFFH guidelines is to invest in the infrastructure of historically disinvested communities. The
City’s Downtown Specific Plan area, which falls within a R/ECAP, offers an opportunity to take advantage of
regional transportation funding opportunities included in Plan Bay Area 2050 to invest in this historically
disinvested area of the City. The program is administered by and supported through technical assistance from
the Metropolitan Transportation Commission and the Association of Bay Area Governments.
We recommend that the City explore how the Housing Element may align with the affordable
housing protection, preservation, and production requirements of the Metropolitan Transportation
Commission’s recently adopted Transit Oriented Communities Policy as a way to acquire
transportation funding in 2023 for the REAP 2.0/PDA Planning and Technical Assistance Grants and
in 2027 under the One Bay Area Grant 4 program. This would provide opportunities to invest in
lower-resourced areas and meet AFFH requirements.
Anti-Displacement Policies and Programs to Affirmatively Further Fair Housing
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The experience of rent burden, displacement, homelessness, and other indicators of housing needs and
instability in a community falls disproportionately on the Latinx residents of the City. As noted above, this
assessment should be integrated into the sites selection process to provide access to resource rich areas of
the City. To the extent that these needs cannot be fully addressed through the sites selection process, this
assessment should also inform targeted policies and programs to address housing instability within this
segment of the population. AFFH is not a uni-dimensional effort, but should be incorporated throughout the
various sections of the Housing Element Update. We do not believe that the current draft has done this work.
Policy F-5: Displacement Prevention Policy lists a number of programs under consideration for inclusion,
including tenant option to purchase agreements for redevelopment projects, a just cause eviction ordinance,
relocation agreements, and one-for-one replacement of demolished housing units at equivalent affordability.
However, this program lacks any quantifiable metrics, simply stating that the City will “adopt the policy,”
which may or may not contain any of these programs, within three years of the adoption of the housing
element. None of the policies under consideration are defined, and the scope and impact of policies with
these titles can vary widely.
Programs F-1: Source of Income Protection and F-2: Fair Housing Counseling are conceptually worthy of
inclusion in the housing element, but the metrics for success (outreach to 50 landlords or tenants, and provide
information to 30 households annually) do not measure the impact or effectiveness of the programs.
Earlier this year, SV@Home sent a letter to the City of Gilroy describing anti-displacement policies the City
could adopt to affirmatively further fair housing. Two of the recommended policies, a rent survey program
and a tenant resource center, would enable the City to conduct outreach and gather data to ensure that these
programs are advancing the City's housing goals. Our previous letter also lists a community / tenant
opportunity to purchase (COPA / TOPA), eviction reduction program, tenant relocation assistance, and net loss
policy, which seem to be reflected in Program F-5. However, since those programs are not defined in the
Draft, it is unclear whether they are likely to be impactful. All programs should provide a clear timeline with
concrete action steps.
We applaud the intent to develop displacement prevention programs, but recommend that
the City clearly define programs and enumerate concrete action steps to ensure that
program goals are meaningfully met. The City should develop clear, measurable outcomes
for their anti-displacement programs.
Program E-7: Development and Conservation of Housing for Farmworkers lists as part of its quantified
objective that the program will “Preserve and maintain the… Ochoa Migrant Center (100 units).” The Draft
Housing Element repeatedly refers to the Arturo Ochoa Migrant Center as a “homeless facility in Gilroy,”
including it as one of the City’s Accomplishments under 5th Cycle Program H-4.D, and as part of the City’s plan
to address the needs of its unhoused residents. However, not only is the Ochoa Migrant Center not located
within Gilroy’s boundaries, it receives no funding, support, or programming from the City.
We recommend that the City assume responsibility for all its residents, and take real, concrete,
actionable steps to provide services and improve outcomes for the City’s residents experiencing
homelessness. For specific recommendations, we refer the City to the letter sent via email on
January 28, 2022 by a group of South County community leaders concerned about rising
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homelessness and the inadequate supply of affordable housing, which outlined community
priorities identified over the course of five meetings and proposed concrete, actionable solutions.
Analysis of Governmental And Nongovernmental Constraints On Housing Production
The City of Gilroy’s analysis of governmental and nongovernmental constraints on housing production lacks
the robust analysis required of the housing element by HCD. The following comments represent
recommendations that could have the most impact and provide the City of Gilroy with improved tools to
strengthen its ability to substantially increase its housing production.
Although the Draft summarizes the various sections of the City’s Zoning Ordinance, no analysis is offered of
the financial impact of any development standard listed. Instead, the Zoning Ordinance as a whole is
summarily deemed to not be a constraint to development. For example, parking standards are virtually the
same across the city, even in areas designated for high density, transit-adjacent land use, such as Downtown.
The City requires multifamily developments to have 1-1.5 stalls per unit as well as guest space. While there is
some acknowledgement of parking standards posing a constraint to development, the concern is dismissed as
the recent construction of several developments demonstrate that existing parking standards “are not an
unreasonable constraint.”
SV@Home recommends a deeper analysis of parking standards as they are applied across the city.
Given that parking has been proven to increase the total cost of development,
maintaining minimum parking ratios, particularly in those high density zoning districts, should be
eliminated if not completely eliminated. This analysis should include an assessment of the impact of
the recently passed, AB 2097, which eliminates minimum parking requirements for any
development within a half-mile of public transit. Particular attention should be paid to AFFH
Program E-6: Study Reduced Parking Requirements for Senior Housing.
The current Inclusionary Zoning Ordinance is limited to two Neighborhood District areas, and is explicitly
identified as a “constraint to development.” There is, however, no analysis and no explanation of why
inclusionary units are only designated for one type of land use. There is mention of a proposed study of an
inclusionary policy, which SV@Home strongly supports. Recently adopted, Inclusionary Housing policies have
become essential tools in increasing affordable housing units in jurisdictions throughout the county, including
the nearby city of Morgan Hill. However, the costs of development in Santa Clara County are significant, and
cities like Gilroy may need to develop locally appropriate policies to facilitate affordable housing development.
SV@Home recommends that the City enact incentive mechanisms such as affordable housing
overlay zones and local density bonuses to offset any potential for inclusionary policies to act as
constraints to development, and highly recommend a detailed timeline for this proposal to ensure
that the adoption and implementation of the inclusionary policy occurs during the 6th cycle
planning period.
The City of Gilroy has not provided any substantive analysis of the cumulative financial impacts of processing
and permitting approval times. Lack of adequate staffing is cited as a reason for delays, but there remain key
moments within the permitting approvals process that could be shortened or streamlined, including City
Council and the Planning Commission roles in the discretionary approval process.
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SV@Home recommends that the City of Gilroy conduct a thorough analysis of its processing and
permitting approvals timeline, with close attention to legislative input and timelines.
SV@Home recommends that. AFFH Program B-5: Permit Streamlining should the be updated to
include the administrative actions necessary to implement the new building permit transparency
and streamlining process required under AB 2234.
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Overall, SV@Home recognizes the work of the City of Gilroy to craft policies and programs focused on housing
production that reflect RHNA requirements. There are proposed policies that indicate the City’s commitment
to not only increasing its housing production but also protecting its most vulnerable residents in need of
decent, safe affordable housing. The concerns and recommendations outlined above will strengthen the
efforts The City of Gilroy has made and ensure its success.
SV@Home values its partnership with the City of Gilroy and it is in that spirit that we provide our feedback on
the Draft Housing Element. We welcome the opportunity to engage in an ongoing dialogue as the Draft
Housing Element moves through cycles of review and revision, with the shared goal of addressing the City’s
urgent housing need by boosting production of homes at all income levels, preserving existing affordable
homes, and protecting the families in them.
Sincerely,
Regina Celestin Williams
Executive Director
CC:
Mayor and Council
HCD Housing Element Review Staff
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July 1, 2022
Submitted via email
Mayor Blankley and Councilmembers
City of Gilroy
7351 Rosanna Street
Gilroy, CA 95020
Dear Mayor Blankley, Mayor Pro Tempore Leroe-Munoz, and Councilmembers Armendariz,
Bracco, Hilton, Marques and Tovar:
RE: Housing Element – Anti-displacement policies to Affirmatively Further Fair Housing
For much of the Housing Element Update process, the focus has been on the scale of the
Regional Housing Needs Allocation (RHNA) and the planning process of identifying potential
housing opportunity sites to meet these requirements. What we have observed through this
process is that there is relatively less understanding and attention to the broader Housing
Element requirements under Affirmatively Further Fair Housing (AFFH).
Through state law, AFFH not only requires that the city plan and implement policies that
give low-income families the opportunity to live in high resource and affluent areas, but also
to adopt policies that address disproportionate housing needs, including displacement risks,
of protected classes. In every jurisdiction in the County lower-income renters -
disproportionately working families of color, and people on fixed incomes including seniors
and people with disabilities - struggle with housing instability due to extreme rent burden
and/or overcrowding. In nearly all jurisdictions the impact of displacement can be tracked
through changing demographics over time.
The California Department of Housing and Community Development (HCD) issued
guidelines and examples of policies to Affirmatively Further Fair Housing. We know that
many jurisdictions throughout the County have been looking at policy options to respond to
these requirements. Over the last 36 months the City of Palo Alto, in partnership with
SV@Home, explored and adopted a number of creative policies designed to protect renters
and stabilize families and communities. While the research and policy making process in
Palo Alto was pretty extensive, we believe that the Assessment of Fair Housing, and the
targeted outreach through the needs assessment, and program/policy development
process, likely provide evidence that tenant protections policies are needed, where few
policies existed before.
When the policy process began in Palo Alto, the City already had a right to a one-year lease
and voluntary landlord/tenant mediation programs. These programs were valuable in some
cases, but research and community engagement found that their reach was very limited and
the effective enforcement was difficult to assess. However, a number of policies that alone
address only a small piece of the need, were actually determined to be complimentary, and
together were more likely to have real impact.
Board of Directors
Kevin Zwick, Chair
United Way Bay Area
Gina Dalma, Vice Chair
Silicon Valley Community
Foundation
Candice Gonzalez, Secretary
Sand Hill Property Company
Andrea Osgood, Treasurer
Eden Housing
Shiloh Ballard
Silicon Valley Bicycle Coalition
Bob Brownstein
Working Partnerships USA
Amie Fishman
Non-Profit Housing
Association of Northern CA
Ron Gonzales
Hispanic Foundation
of Silicon Valley
Javier Gonzalez
Google
Poncho Guevara
Sacred Heart Community
Service
Janice Jensen
Habitat for Humanity
East Bay/Silicon Valley
Janikke Klem
Jan LIndenthal
MidPen Housing
Jennifer Loving
Destination: Home
Mary Murtagh
EAH Housing
Chris Neale
The Core Companies
Kelly Snider
Kelly Snider Consulting
Jennifer Van Every
The Van Every Group
STAFF
Leslye Corsiglia
Executive Director
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Based on the work in Palo Alto, and a number of other cities, below are a number of policies that the City of Gilroy
should consider, or build upon, to further the community’s anti-displacement goals by addressing housing instability.
1) Rental Survey Program
Rental survey systems collect basic information on rental housing – changes to tenancies, changes to rents - to
empower cities to better understand the challenges faced by renters, and the effectiveness of state and local
renter protections.
2) Tenant Relocation Assistance
When tenants are displaced due to redevelopment of an existing rental property, or the conversion of that
property to another use, this policy would require the property owner to provide assistance to the tenant to help
them relocate to another home.
3) Eviction Reduction Program
This expands on existing state law (AB 1482: The Tenant Protection Act of 2019), which limits the reasons a
landlord can evict a tenant, to additional types of rental properties otherwise not covered by the state. Local
jurisdictions can determine which loopholes they would like to close. Currently, state law exempts:
a) Single family homes not owned by a corporation
b) Rental property built within the past 15 years, including accessory dwelling units.
c) Any duplex where the owner occupied the unit before the other unit’s tenancy and continues to occupy the
unit.
d) Housing restricted by a deed, regulatory restrictions, or other recorded document limiting the affordability to
low or moderate income households.
e) Mobile homes.
f) Rental property subject to local ordinances that restrict rent increases to less than 5% plus CPI.
g) Single family homes where the owner occupies and rents at least 2 bedrooms or units (ADUs and JADUs).
h) Owner occupied rental properties where the tenant shares bathroom or kitchen facilities with the owner.
i) Hotels
j) Rental property provided by non-profit hospitals, organizations such as churches, extended care for the
elderly, adult care facilities etc.
4) Anti Rent-Gouging Policy
This policy also expands on existing state law (AB 1482: The Tenant Protection Act of 2019), which limits annual
rent increases to 5% plus the Consumer Price Index (CPI), by including additional units exempted by state law.
Each city can determine which loopholes they would like to close. They can also adopt lower thresholds for
maximum increases like San Jose (5%) and Mountain View (CPI). Currently, state law exempts:
a) Single Family homes not owned by a corporation
b) Rental property built within the past 15 years, including accessory dwelling units.
c) Any duplex where the owner occupied the unit before the other unit’s tenancy and continues to occupy the
unit.
d) Housing restricted by a deed, regulatory restrictions, or other recorded document limiting the affordability to
low or moderate income households.
e) Mobile homes.
f) Hotels
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5) Security Deposit Limit
This policy would limit the amount that can be charged for security deposits to 1.5 times the monthly rent, and
help reduce the financial obstacles to entry for low-income households.
6) Fair Chance Ordinance
This ordinance would limit landlords' ability to ask applicants about their history of interaction with the criminal
justice system, which disproportionately impacts Black and brown households. The policy would not make it illegal
for landlords to run background checks on tenants, but would make it illegal to include these questions on the
initial rental application.
7) Right to Counsel
This program would provide tenants with legal assistance in eviction cases. Tenants experiencing housing
instability will be better able to enjoy the rights they have, feel more empowered to exercise those rights, and be
more likely to stay housed more often.
8) Tenant/Community Opportunity to Purchase (TOPA/COPA)
The local jurisdiction could provide tenants and/or community-based organizations notice of intended sale of
rented property, and provide a specific time period during which the tenants and/or organization have the
opportunity to purchase the property. Tenants at risk of being displaced through the sale of a building would be
provided with another option to potentially stay in their home. A version of this policy is actively being explored
and studied in the City of San Jose.
9) Proactive Rental Inspection
This establishes a program for code enforcement officers to routinely inspect the rental housing inventory.
Through these programs tenants are more likely to be protected from living in substandard housing, and local
jurisdictions may catch habitability issues before they become so large that they require “red tag” evictions.
10) Tenant Resource Center
As a response to the pandemic, the cities of San Jose and Mountain View created Eviction Help Centers where
tenants and landlords could receive information on local laws, assistance to apply for rent relief and legal aid.
These cities are now looking at making the centers a permanent tenant/housing resource center post-pandemic.
11) City-wide Affordable Rent Portals
A portal for submitting a common application for affordable housing would save the tremendous amount of time
and energy it currently takes to submit the same information on separate applications for each affordable
property. A clearinghouse of affordable housing opportunities would also allow the city or county to affirmatively
market to vulnerable and hard to reach populations. Current examples of these portals include San Jose Doorways
and Dalia in San Francisco.
12) Increase Multi-lingual engagement with city services and housing opportunities
Language barriers can keep many communities from accessing the housing opportunities and services they need.
Taking steps to increase the city’s capacity to engage under multiple languages can improve those outcomes.
13) Net-loss policy
SB 330 (The Housing Crisis Act of 2019) requires that protected units are replaced one-for-one in cases of the
redevelopment of a rental property. These provisions are currently mandated by state law, but local jurisdictions
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can adopt permanent no-net-loss ordinances. This policy would protect critical sources of housing affordable to
lower-income families, and incentivize higher-density infill redevelopment when paired with land use policies to
support the feasibility of this redevelopment.
These policies have been developed with consideration of some of the major barriers to housing stability, and causes
of displacement, which have been identified through an extensive research and engagement process in Palo Alto, and
a few other jurisdictions in the county. Through the housing element, these anti-displacement policies should be
considered a comprehensive package of responses to address the complexity of the challenges faced by renters in
Gilroy. For further information and if you have any questions, please feel free to reach out to our Preservation and
Protection Associate, Emily Ann Ramos at emily@siliconvalleyathome.org.
Thank you for considering anti-displacement and tenant protections solutions to affirmatively further fair housing.
Sincerely,
Mathew Reed
Policy Director
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Housing Affordability &
Declining School Enrollment
Countywide Enrollment Trends in Public, Private,
and Charter Schools –p. 2
Which Districts Are Affected? –p. 3
Connection to Housing –p. 4
What’s Ahead in the Next Decade –p. 5
Your City –p. 6
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Packet Pg. 351 Attachment: Public Comments through 10-12-22 (4016 : Review of the Draft Housing
Santa Clara County Elementary Enrollment is Declining in All School Types
Elementary school enrollment has
declined across traditional public schools,
charter schools, & private schools.
From California Department of Education: Enrollment Multi-Year Summary by Grade and Private School Affidavit Information
Both public and private K-12 schools
are losing students
Enrollment declines were widespread before the pandemic
•K-12 Enrollment has fallen
12% over the 7 years since
2014-15, a loss of more
than 37,600 children.
•Elementary schools, serving
younger children, are
seeing larger declines.
•Enrollment declines were
widespread before the
pandemic began: the 2019-
20 enrollment census was
taken in October 2019.
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Packet Pg. 352 Attachment: Public Comments through 10-12-22 (4016 : Review of the Draft Housing
The enrollment problem is
widespread
•In our public schools countywide, elementary
enrollment has declined every year since 2014.
•All but one elementary district is experiencing
enrollment decline -most over 20%.
•This represents a loss of almost 25,000
elementary students.
•Both wealthy school districts and school districts
in lower-income communities are suffering.
From California Department of Education: Public Schools and Districts, Enrollment
Multi-Year Summary by Grade, and Free and Reduced-Price Meal Eligibility
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Packet Pg. 353 Attachment: Public Comments through 10-12-22 (4016 : Review of the Draft Housing
Rapid Growth in Rent and Home Prices Caused
by Housing Shortage is Displacing Families
•Home prices have increased
close to 300% in the last
decade.
•Since 2012, rent has increased
more than 75%.
•The housing shortage creates a
market where young families
are “priced out.”
•Lower and moderate income
families are increasingly
displaced by rising rents.
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Packet Pg. 354 Attachment: Public Comments through 10-12-22 (4016 : Review of the Draft Housing
What’s ahead?
Enrollment is Forecast to
Continue to Decline
Without New Housing
•Elementary school enrollment across
traditional public, private, and charter
schools will continue to decline 13%
over the next decade.
•K-12 school enrollment will decline
15% over the next decade-a loss of
more than 41,000 students.
From California Department of Finance: California Public K-12 Graded
Enrollment and High School Graduate Projections by County —2021 Series
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What does this look like
at the city level?
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Elementary Schools in the City of Gilroy
Face Declining Enrollment
•All but two
elementary schools
have seen enrollment
declines, ranging as
high as 20%.
•Gilroy’s elementary
schools have 79 fewer
elementary students
than they did in 2014.From California Department of Education: Public Schools and Districts and Enrollment Multi-Year
Summary by Grade
All schools in Gilroy Unified School District
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1
Cindy McCormick
From:Keith Diggs <keith@yesinmybackyard.org>
Sent:Wednesday, September 28, 2022 8:43 AM
To:Cindy McCormick
Subject:EXTERNAL - Re: Gilroy Draft Housing Element Released for Public Comment
Hi Cindy, thanks for your and the consultant's presentation last night. I'm attaching two letters my organization has
previously written; I will be writing one in a few weeks on Gilroy's draft.
What I am really looking for is the first city to stop policing the way homes look. In practice I would expect this to mean
dense missing-middle housing, if someone wants to build it, across the places where we see single-family homes today.
Like most people my age, I'm out of patience for the usual arguments about aesthetics, neighborhood character, and the
car traffic that's actually more attributable to sprawl than infill. Seven-figure median home prices shouldn't happen
anywhere. This month I paid $1360 to rent a 100 sqft shed where I can't really use the bathroom at night because it wakes
up the dogs of the family I'm renting from. This is the only way I can keep my housing costs affordable. And I am an
eighth-year attorney. I shudder to think how hard this market must be for entry-level or service workers who make less
than I do, or for people who have a family to feed.
No city to my knowledge has found the political courage to abolish design control, but one eventually will, and that city
will be considered a leader. If Gilroy's truly interested, I happen to be moving (as I do every month) on Friday, and I can
stop in Gilroy around 1pm or so. Let me know.
220228 YL Policy Letter.pdf
Gilroy_220421_Kapur.pdf
Keith
Diggs
⋕⋖
Housing
Elements Advocacy Manager
703-409-5198
On Mon, Sep 12, 2022 at 12:24 PM Cindy McCormick <Cindy.McCormick@ci.gilroy.ca.us> wrote:
Good afternoon,
The City has released the 1st Draft of the 2023-2031 Housing Element, kicking off the 30-day public review period.
Comments are welcome via this email or they can be mailed to the address below (Attn: Cindy McCormick). The City
CAUTION: This email originated from an External Source. Please use proper judgment and caution when opening attachments, clicking links, or
responding to this email.
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2
will also hold one or more public meetings to receive public comments on the Draft. The meeting date(s) will be
announced on the City’s website as soon as they are confirmed.
For more information on the Housing Element, including videos of past meetings and the August 29 th Study Session
powerpoint slides, please visit our Housing Element Update webpage. Be sure to click on the “Community Meetings”
tab (it is one of four tabs near the top third of the page).
Respectfully,
CINDY MCCORMICK
CUSTOMER SERVICE MANAGER
Direct 408.846.0253 l Cindy.McCormick@cityofgilroy.org
Main 408.846.0440 l www.cityofgilroy.org/planning
7351 Rosanna Street | Gilroy | CA 95020
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Campaign for Fair Housing Elements
fairhousingelements.org
The City of Gilroy
Via email:cindy.mccormick@cityofgilroy.org
Cc:HousingElements@hcd.ca.gov
October 12, 2022
Re:Gilroy’s Draft Housing Element
To the City of Gilroy:
YIMBY Law appreciates the City’s recognition that the “majority of [its] growth is
expected to take the form of multifamily housing.” (Gilroy Draft Housing Element,
p.175.) We also support the City’s program A-9 to “[f]acilitate [m]issing [m]iddle”
housing—but question why such a program would be confined to “designated zones.”
(See id.p.216.) We asked this very question at your September 27 community
meeting. Your consultant answered that missing-middle is allowed in some zones, and
showed some pictures of missing-middle housing. Respectfully, we ask the City to
respond to, not dodge, the question: why not allow missing-middle everywhere?
Densification is critical to stemming the City’s affordability crisis. The Realtors report
that Gilroy’s median home price is $1.1 million. This is simply not affordable, even to
many with above-moderate incomes. It is a slap in the face to would-be Gilroy
residents with lower incomes. The only practical way to afford a home with such
exorbitant costs is to consume as little housing (or land) as possible, and yet the City
enforces wasteful minimum lot sizes of 5,000 square feet or more in the great part of
its territory that is zoned for low density. (Draft, p.138.) This zone, incidentally, seems
to be where most Gilroy residents face a risk of displacement. (Id.p.115.) Yet few
opportunity sites are designated there. (Id.p.238.)We urge the City to open this zone
for the multifamily development that it acknowledges it needs. California law protects
existing tenants from displacement with a right of return at affordable rates (Gov.
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Packet Pg. 360 Attachment: Public Comments through 10-12-22 (4016 : Review of the Draft Housing Element)
Code § 66300(d)), and we are committed to seeing that law enforced. Displacement
fears should not be cited as a reason to outlaw the construction of the housing Gilroy
residents need.
We also question the City’s site inventory. We understand that the Glen Loma
apartment project (Draft, p.182) has already been built and issued its certificate of
occupancy. If that is true, it should not be counted toward the City’s 2023–2031 need
allocation, as it currently is. (See id.p.184.) Similarly,the JEMCOR developments at 1st
& Kern and Hecker Pass & Santa Teresa (id.p.182)are far along and could be certified
for occupancy this year. Other sites seem not to be vacant, contrary to what the City
represents. For example, the “[v]acant” site at 7050 Monterey (id.p.241) is reportedly
in use by Sumano’s Bakery.
We look forward to seeing these issues addressed in the City’s next draft. We have
attached a courtesy copy of our standard policy recommendations for the City’s
consideration as well. Please contact me with questions.
Sincerely,
Keith Diggs
Housing Elements Advocacy Manager, YIMBY Law
keith@yimbylaw.org
Campaign for Fair Housing Elements
fairhousingelements.org 2
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Packet Pg. 361 Attachment: Public Comments through 10-12-22 (4016 : Review of the Draft Housing Element)
April 21, 2022
Dear Gilroy City Council:
We are writing on behalf of YIMBY Law and Greenbelt Alliance regarding Gilroy’s 6th Cycle Housing Ele‐
ment Update. YIMBY Law is a legal nonprofit working to make housing in California more accessible and af‐
fordable through enforcement of state law. Greenbelt Alliance is an environmental nonprofit working to en‐
sure that the Bay Area’s lands and communities are resilient to a changing climate.
We are writing to remind you of Gilroy's obligation to include sufficient sites in your upcoming Housing Ele‐
ment to accommodate your Regional Housing Needs Allocation (RHNA) of 1,773 units.
In the Annual Progress Reports that Gilroy submitted to HCD, we observe the following trend of housing
units permitted in the last four years:
Year Housing units permitted
2018 110
2019 196
2020 270
2021 275
Average, 2018-2021 213
To meet the 6th cycle RHNA target, the rate of new housing permits in Gilroy would need to increase from
213 units per year in 2018-2021 to 222 units per year in the next 8 years. This is a 4% increase from recent
years. If the current pace were to continue, Gilroy would meet only 96% of its new housing target.
Based on these trends, it is unlikely that Gilroy’s existing realistic zoning capacity is sufficient to meet its 6th
cycle RHNA target. According to HCD’s Housing Element Site Inventory Guidebook, housing elements must
analyze the realistic capacity of their sites, which may include considerations of “[l]ocal or regional track re‐
cords”, “past production trends”, and “the rate at which similar parcels were developed during the previous
planning period”. A housing element that does not include a significant rezoning component is therefore un‐
likely to be compliant with state law.
We urge Gilroy to include a major rezoning component in its Housing Element—a rezoning large enough to
close the gap between recent housing production trends and the RHNA target. The rezoning should be within
existing communities and should comply with the city’s obligation to Affirmatively Further Fair Housing. We
also urge Gilroy to ease any other constraints, such as discretionary approval processes or impact fees, that may
impede the rate of development on your city's housing sites.
Thank you,
Sid Kapur, East Bay YIMBY (sidharthkapur1@gmail.com)
Rafa Sonnenfeld, YIMBY Law (rafa@yimbylaw.org)
Zoe Siegel, Greenbelt Alliance (zsiegel@greenbelt.org)
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February 28, 2022
Policy Recommendations for 6th Cycle Housing Element
Dear Planning staff:
YIMBY Law submits this letter to share our policy goals and recommendations for the
Policies and Programs section of your Housing Element. We appreciate the
opportunity to participate in the Housing Element process.
The Policies and Programs section of the city’s Housing Element must respond
to data, analysis and findings presented in the Housing Needs section.We
repeatedly see findings that housing prices are high, segregation exists, and there is a
lack of housing for special populations, but the Policies and Programs don’t respond
to these findings or try to change outcomes. The overview of the city’s housing
environment should set the scene, and the policies and programs should explain
what the city is going to do to fix it.
Our policy goals are as follows:
Affirmatively Furthering Fair Housing
1.Prioritize rezoning in high resource, historically exclusionary neighborhoods.
Many of the highest resource neighborhoods with the best access to jobs, good
schools, and other amenities have histories of exclusion which are still reflected in
their zoning. Cities should rezone to allow more housing opportunities in those
neighborhoods, particularly those with low Vehicle Miles Traveled, as part of their
1
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Housing Elements.
2.Establish a strong tenant protection ordinance so that new housing benefits
everyone.Development should not permanently displace current residents.
Housing replacement programs, temporary housing vouchers, right of return, and
demolition controls will create stability for renters while allowing new homes to be
built for new households and to accommodate the growth associated with RHNA.
In your sites inventory and rezoning programs, you should prioritize development
on sites with owner-occupied housing & commercial uses over those with existing
rent-controlled apartments or other rental housing with lower income residents.
3.Support homeownership opportunities for historically excluded groups.
Homeownership continues to be a path to building financial security and
inter-generational wealth, which has been systematically denied to many
Americans. As a society, we need to make this right by intentionally offering
opportunities to communities who have been excluded. The housing element
should identify opportunities to create a variety of for-sale housing types and
create programs to facilitate property ownership among excluded groups.
Site Capacity
4.Adequately plan for density.Ensure that a site’s density will accommodate the
number of homes that are projected to be built. In addition, make sure height
limits, setback requirements, FAR, and other controls allow for adequate density
and the ability to achieve a site’s realistic capacity. Housing will not be feasible if
you have a high density paired with low height limits. This density should be
emphasized around jobs and transit and should go beyond the Mullin density in
those areas.
5.Provide sufficient zoned capacity to accommodate all income levels,
including a minimum No Net Loss buffer of 30%.Not every site will be
developed at maximum density during the eight-year planning period. Identify an
ample amount of opportunity sites and zone the sites to accommodate
lower-income housing types (usually a statutory minimum of 30 dwelling units per
acre) to give the city the best chance at meeting its RHNA.
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6.Use data from the 5th Cycle to calculate the likelihood of development for
your 6th Cycle site inventory.Likelihood of development is a measure of the
probability of an inventory site being developed during the planning period. The
median likelihood of development across the state is 25%, meaning only one of
every four sites will likely be developed during the planning period for the median
city. Incorporating the likelihood of development into the zoned capacity will set
the city up to successfully achieve their RHNA, making the housing element less of
a paper exercise and more of an actionable, functional document.
Accessory Dwelling Units
7.Commit to an automatic mid-cycle adjustment if ADU permitting activity is
lower than estimated in the housing element.We highly recommend
complying with HCD’s standards of using one of its “safe harbor” methodologies to
anticipate future ADU production. However, if the city is optimistic about ADU
growth, then creating an automatic mid-cycle adjustment will automatically
facilitate alternative housing options (i.e., a rezoning program, removing
development constraints, ADU incentives, etc.) if the city falls behind the estimated
ADU production.
8.Incentivize new ADUs, including those that are rent-restricted for moderate-
or lower-income households or that are prioritized for households with
housing choice vouchers.Consider offering low- or no-interest loans, forgivable
loans, impact fee waivers for ADUs that are 750 square feet or larger, allowances
to facilitate two-story and second-story ADU construction, etc.
Zoning
9.Allow residential to be built in areas that are zoned for commercial use.
There are a myriad of ways to do this, but a housing overlay is one common policy.
Additionally, consider eliminating new commercial space in mixed-use
developments where there is not a strong demand or there is otherwise a glut of
commercial space that is unused or frequently vacant.
10.Allow flexibility in inclusionary zoning.Cities should require different
percentages for different AMI levels. Additionally, we urge cities to incentivize land
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dedication to affordable developers in order for market-rate developers to meet
their inclusionary requirements. Avoid getting trapped into thinking that the
affordable units must be “sprinkled throughout” the market-rate units, or require
the market-rate units to look exactly the same as the affordable ones. This should
be balanced against not locating all of the affordable units in one place and
ghettoizing neighborhoods by creating or perpetuating racially concentrated areas
of poverty.
Better Entitlement Process & Reducing Barriers to Development
11.Ensure that the city has a ministerial process for housing permitting,
especially multi-family housing, and remove impact fees for deed-restricted
housing.A discretionary process for housing development creates uncertainty
and adds to the cost of construction. For example, multi-family housing should not
require a conditional use permit or city council approval unless the builder is
asking for unique and extraordinary concessions. Right-sizing governmental
constraints, entitlement processes, and impact fees will help the city successfully
meet its RHNA.
12.Reduce parking standards and eliminate parking minimums.Minimum
parking requirements are a major constraint on housing, especially for lower cost
housing types. They can cost in excess of $30,000 per spot and can raise rents by
as much as 17%, and eliminating them is particularly important for smaller & other
spatially constrained sites. Consider adopting a parking maximum.
13.Cap fees on all new housing.Most construction costs are outside the City’s
control, but reducing impact fees can demonstrate that a city is serious about
building new housing. At a minimum, cities should delay the collection of impact
fees until the issuance of the certificate of occupancy to reduce financial impacts
on new housing and make the units cheaper by not asking the developer to carry
impact fee charges or debt throughout the construction phase.
14.Provide local funding.One of the largest barriers to building new affordable
homes is the lack of city/county funds available to assemble sites, provide gap
funding, and to pay for dedicated staff. Without new funding, especially at the
local level, we will not be able to build more affordable homes. There are three
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new revenue streams that should be considered: 1)Transfer tax, a one-time
payment levied by a jurisdiction on the sale of a home, may be utilized to raise
much needed revenue to fund affordable homes; 2)Vacancy tax may be collected
on vacant land to convince landowners to sell their underutilized properties and
be used to fund the construction of affordable homes; 3)Commercial linkage
fees should be adopted or revisited for increases on new commercial
developments.
We urge you to include these policies in your 6th cycle Housing Element.
Best regards,
Sonja Trauss
Executive Director
YIMBY Law
sonja@yimbylaw.org
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