Agenda packet — Atwater City Council, August 10, 2026 (part 2 of 6)

City of Atwater
City of Atwater 2024-2032 Housing Element Update
32 Conclusion
The Project would not result in hydrology and water quality impacts beyond those addressed or analyzed in the General Plan EIR nor present new information that shows impacts would be more significant than those described in the General Plan EIR. Therefore, the General Plan EIR applies to the proposed Project and no additional environmental assessment of hydrology and water quality is required.

6.11 Land Use and Planning
General Plan EIR Findings
Land use and planning are addressed in Section 4.1 and Appendix A of the General Plan EIR. The General Plan EIR concluded that implementation of the General Plan would result in less than significant impacts to the existing physical arrangement of land use with the implementation of General Plan goals and policies and Mitigation Measure 4.1-1a, which requires City staff review of potential project impacts upon surrounding development patterns and land uses. The General Plan EIR determined that implementation of the General Plan would result in a less than significant impact on existing communities with the implementation of the Plan’s goals and policies. The General Plan EIR found no impact related to conflicts with applicable land use plans and policies.

Addendum Analysis
The Housing Element Update would accommodate anticipated population growth associated with the City’s RHNA allocation. As discussed in Section 2.5, Buildout of Proposed Project and Comparison to the 2000 General Plan EIR, buildout of the proposed project is within the buildout projections analyzed in the General Plan EIR. The Zoning Code Update and Zoning Map Amendment would not result in any physical development.

Future development facilitated by the Project would undergo project-specific developmental review, including design review, and would be subject to adopted development standards and policies including those in the Land Use Element of the General Plan. Future development would also be required to adhere to policies in the General Plan, including goals LU-1, LU-2, LU-4, LU-5, LU10, LU-11, LU-12, LU-13, LU-14, LU-15, and CO-10; policies LU-1.1, LU-1.2, LU-2.1, LU-2.2, LU-4.1, LU5.1, LU-10.1, LU-10.2, LU-10.3, LU-11.1, LU-11.2, LU-11.3, LU-12.1, LU-13.1, LU-14.1, LU-14.2, LU15.1, LU-15.2, CO-10.1, and CO-10.2; and programs LU-1.b, LU-1.c, LU-2.a, LU-2.b, LU-4.a, LU-4.b, LU-4.c, LU-5.a, LU-5.b, LU-5.c, LU-10a, LU-12.a, LU-13.a, LU-14.a, LU-15.a, LU-15.b, and CO-10.a.

Adherence to the goals and policies included in the Land Use Element of the General Plan would ensure that future development would not conflict with a land use plan or policy. This would also include adherence to Mitigation Measure 4.1-1a in the General Plan EIR. Additionally, because the Project would facilitate the development of housing primarily on infill sites, development facilitated by the proposed project would not divide an established community. Because the Project would not facilitate development beyond what was considered in the General Plan EIR, the Project would not result in new significant environmental effects or a substantial increase in the severity of previously identified significant effects.

Conclusion
The Project would not result in land use and planning impacts beyond those addressed or analyzed in the General Plan EIR nor present new information that shows impacts would be more significant

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Addendum Evaluation
State Clearinghouse Number 1999061027 33
than those described in the General Plan EIR. Therefore, the General Plan EIR applies to the proposed Project and no additional environmental assessment of land use and planning is required.

6.12 Mineral Resources
General Plan EIR Findings
Mineral resources are addressed in Appendix A of the General Plan EIR. The General Plan EIR found no impact to mineral resources.

Addendum Analysis
There are no known significant mineral resources or mining operations in the city (United States Geological Survey 2024). The Project would result in infill development of sites within the City with the exception of annexation sites located outside city limits and currently planned for agricultural use, which would be subject to additional review and compliance with applicable local, state, and federal regulations at the time when annexation is proposed. Therefore, the Project would have no impact on mineral resources, similar to the General Plan EIR.

Conclusion
The Project would not result in mineral resources impacts beyond those addressed or analyzed in the General Plan EIR nor present new information that shows impacts would be more significant than those described in the General Plan EIR. Therefore, the General Plan EIR applies to the proposed Project and no additional environmental assessment of mineral resources is required.

6.13 Noise
General Plan EIR Findings
Noise is addressed in Section 4.4 of the General Plan EIR. The General Plan EIR determined that implementation of the General Plan would result in less than significant impacts to noise levels at sensitive and future noise-sensitive land uses with implementation of Mitigation Measures 4.4-1a and 4.4-1b, which require increased setbacks and noise barriers.

Addendum Analysis
The Housing Element Update would accommodate anticipated population growth associated with the City’s RHNA allocation. As discussed in Section 2.7, Buildout of Proposed Project and Comparison to the 2000 General Plan EIR, buildout of the proposed project is within the buildout projections analyzed in the General Plan EIR. The Zoning Code Update and Zoning Map Amendment would not result in any physical development.

Future development facilitated by the Project would undergo project-specific developmental review, including design review, would be subject to the requirements of the City of Atwater’s Municipal Code Chapter 8.44, and would be subject to Mitigation Measures 4.4-1a and 4.4-1b. The goals and policies in the Noise Element of the General Plan would also apply, including goals NO-1, NO-2, NO-3, NO-4, and NO-8; policies NO-1.1, NO-1.2, NO-1.3, NO-2.1, NO-2.2, NO-2.3, NO-2.4, NO2.5, NO-3.1, NO-4.1, and NO-8.1; and programs NO-1.a, NO-1.b, and NO-4.a.

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City of Atwater
City of Atwater 2024-2032 Housing Element Update
34 Because the Project would not facilitate development beyond what was considered in the General Plan EIR, the Project would not result in new significant environmental effects or a substantial increase in the severity of previously identified significant effects.

Conclusion
The Project would not result in noise impacts beyond those addressed or analyzed in the General Plan EIR nor present new information that shows impacts would be more significant than those described in the General Plan EIR. Therefore, the General Plan EIR applies to the proposed Project and no additional environmental assessment of noise is required.

6.14 Population and Housing
General Plan EIR Findings
Population and housing impacts are addressed in Section 4.1 and in Appendix A of the General Plan EIR. The General Plan EIR determined less than significant impacts related to growth inducement with the implementation of General Plan goals and policies and Mitigation Measure 4.1-1a, which requires City staff review of potential project impacts upon surrounding development patterns and land uses. The General Plan EIR determined that there would be no impact to the displacement of people or housing as a result of General Plan implementation.

As discussed in Section 2.5 of this document, the proposed Project would promote the development of housing to meet the City’s RHNA requirement and ensure that the Housing Element is in compliance with state law to accommodate anticipated population growth within the city. Future development facilitated by the Project would undergo project-specific developmental review, including design review, and would be subject to adopted development regulations. Furthermore, because the Project would not facilitate development beyond what was considered in the General Plan EIR, the Project would not result in new significant environmental effects or a substantial increase in the severity of previously identified significant effects.

Conclusion
The Project would not result in population and housing impacts beyond those addressed or analyzed in the General Plan EIR nor present new information that shows impacts would be more significant than those described in the General Plan EIR. Therefore, the General Plan EIR applies to the proposed Project and no additional environmental assessment of population and housing is required.

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Addendum Evaluation
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6.15 Public Services
General Plan EIR Findings
Public services are addressed in Section 4.10 of the General Plan EIR. The General Plan EIR determined that implementation of the General Plan would in less than significant impacts to the provision of additional police, fire, school, parks, and other public facilities and services with the implementation of the General Plan’s goals and policies.

Addendum Analysis
The Housing Element Update would accommodate anticipated population growth associated with the City’s RHNA allocation. As discussed in Section 2.7, Buildout of Proposed Project and Comparison to the 2000 General Plan EIR, buildout of the proposed Project is within the buildout projections analyzed in the General Plan EIR. The Zoning Code Update and Zoning Map Amendment would not result in any physical development.

The fundamental regulations and requirements of the General Plan and Zoning Code, such as meeting design standards, would continue to apply to all projects under the City’s jurisdiction. Goals and policies in the Land Use Element of the General Plan would enhance public services, including police, fire protection, schools and emergency access. Future development would be subject to the requirements of goals LU-17, LU-18, LU-19, LU-20, LU-21, and LU-22; policies LU-17.1, LU-17.2, LU18.1, LU-18.2, LU-18.3, LU-18.4, LU-18.5, LU-19.1, LU-20.1, LU-21.1, LU-21.2, LU-21.3, and LU-22.1; and programs LU-17.a, LU-17.b, LU-17.c, LU-18.a, LU-19.a, LU-20.a, LU-20.b, LU-21.a, and LU-21.b.

These goals, policies, and measures would continue to be required with implementation of the proposed Project.

Future development facilitated by the Project would undergo project-specific developmental review, including design review, and would be subject to adopted development regulations, including General Plan policies and community public facility fees, emergency access requirements, and fire protection requirements established in the City’s Municipal Code. Furthermore, because the Project would not facilitate development beyond what was considered in the General Plan EIR, the Project would not result in new significant environmental effects or a substantial increase in the severity of previously identified significant effects.

Impacts related to parks are addressed under Section 6.15, below.

Conclusion
The Project would not result in public services impacts beyond those addressed or analyzed in the General Plan EIR nor present new information that shows impacts would be more significant than those described in the General Plan EIR. Therefore, the General Plan EIR applies to the proposed Project and no additional environmental assessment of public services is required.

6.16 Recreation
General Plan EIR Findings
Recreation is addressed in Section 4.10 of the General Plan EIR on page 4.10-39. The General Plan EIR determined that impacts related to parks and recreational facilities would be less than significant with implementation of General Plan policies.

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City of Atwater
City of Atwater 2024-2032 Housing Element Update
36 Addendum Analysis
The Housing Element Update would accommodate anticipated population growth associated with the City’s RHNA allocation. As discussed in Section 2.7, Buildout of Proposed Project and Comparison to the 2000 General Plan EIR, buildout of the proposed project is within the buildout projections analyzed in the General Plan EIR. The Zoning Code Update and Zoning Map Amendment would not result in any physical development.

Because the Housing Element Update would not result in an increase in buildout above the buildout assumed in the General Plan EIR, there would be no increase in recreation impacts as compared to the General Plan. Additionally, goals and policies in the Land Use Element of the General Plan would continue to apply to future development, including policy LU-23.1, which sets a performance standard for the provision of parks and recreation facilities.

Future development facilitated by the Project would undergo project-specific developmental review, including design review, and would be subject to adopted development regulations, including General Plan policies and community park and recreation fees established in the City’s Municipal Code. Furthermore, because the Project would not facilitate development beyond what was considered in the General Plan EIR, the project would not result in new significant environmental effects or a substantial increase in the severity of previously identified significant effects.

Conclusion
The Project would not result in recreation impacts beyond those addressed or analyzed in the General Plan EIR nor present new information that shows impacts would be more significant than those described in the General Plan EIR. Therefore, the General Plan EIR applies to the proposed Project and no additional environmental assessment of recreation is required.

6.17 Transportation
General Plan EIR Findings
Transportation is discussed in Section 4.3 of the General Plan EIR. The General Plan EIR analyzed Level of Service (LOS) as the methodology to assess significance and found that traffic impacts would be less than significant with implementation of Mitigation Measure 4.3-1a, which requires individual project applicants to contribute their fair share to the construction of local roadway improvements. The General Plan EIR also determined that impacts to airport access, emergency access and evacuation, mass transit, and bicycle and pedestrian facilities would be less than significant with the implementation of General Plan goals and policies.

Since certification of the EIR and pursuant to Senate Bill (SB) 743, transportation impacts are evaluated using VMT instead of LOS.

Addendum Analysis
No specific developments are being approved as part of the Project, therefore, the Project would not directly or indirectly result in transportation impacts. Furthermore, the proposed project would increase density within the city to accommodate planned growth which would reduce VMT by promoting the creation of housing in areas near transit and other necessary services within the city.

Future development facilitated by the project would undergo project-specific developmental review

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and would be subject to adopted policies and programs identified in the General Plan EIR, including goals CIRC-1, CIRC-2, CIRC-3, CIRC-6, CIRC-7, SF-8, SF-10, SF-12; policies CIRC-1.1, CIRC-1.2, CIRC-1.3, CIRC-2.1, CIRC-2.2, CIRC-3.1, CIRC-3.2, CIRC-4.1, CIRC-4.2, CIRC-6.1, CIRC-6.2, CIRC-6.3, CIRC-7.1, SF8.1, SF-10.1, SF-10.2, SF-12.1, SF-12.2; and programs CIRC-1.a, SF-8.a, SF-12.a, SF-10.a, CIRC-6.a, CIRC-7.a, and CIRC-7.b. Future development would also continue to be subject to Mitigation Measure 4.3-1a.

Because the Project would not facilitate development beyond what was considered in the General Plan EIR, the Project would not result in new significant environmental effects or a substantial increase in the severity of previously identified significant effects.

Conclusion
The Project would not result in transportation impacts beyond those addressed or analyzed in the General Plan EIR nor present new information that shows impacts would be more significant than those described in the General Plan EIR. Therefore, the General Plan EIR applies to the proposed Project and no additional environmental assessment of transportation is required.

6.18 Tribal Cultural Resources
General Plan EIR Findings
Tribal Cultural Resources was added to the 2016 CEQA Guidelines as a separate environmental issue area. Thus, the General Plan EIR (certified July 2000) does not include a chapter or section dedicated to analysis of impacts to tribal cultural resources. However, it does analyze general impacts to historical and cultural resources (including archeological resources that may originate from Native American tribes) in Section 4.9. As the Notice of Preparation for the General Plan EIR was published before July 1, 2015, tribal consultation pursuant to Assembly Bill (AB) 52 was not required.

Addendum Analysis
In accordance with the requirements of Senate Bill (SB) 18, the City requested a tribal contact list from the California Native America Heritage Commission (NAHC). The NAHC responded to the City’s request, providing a list of contacts from the Native American tribal organizations that should be invited to consult with the City. The City also requested a review of the Sacred Lands File (SLF), the results of which indicated that the Housing Element update area is negative for Sacred Lands.

On January 16, 2024, the City sent letters inviting the local Tribal Nations to consult with the City under the provisions SB 18. The invitations advised the tribes that if consultation was desired, then they must formally accept the invitation in writing within 90-days of receipt of the City’s letter pursuant to SB 18. The City received no responses.

The proposed Project, in and of itself, would not propose or authorize specific development.

Because the Project is a policy document, the proposed project would not, in and of itself, result in impacts to tribal cultural resources such as causing a substantial adverse change in the significance of a tribal cultural resource. Future development facilitated by the Project would undergo projectspecific developmental review, including design review, and would be subject to adopted development regulations and subject to AB 52 compliance. Therefore, impacts would be less than significant.

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City of Atwater
City of Atwater 2024-2032 Housing Element Update
38 Conclusion
The Project would not result in tribal cultural resources impacts beyond those addressed or analyzed in the General Plan EIR nor present new information that shows impacts would be more significant than those described in the General Plan EIR. Therefore, the General Plan EIR applies to the proposed Project and no additional environmental assessment of tribal cultural resources is required.

6.19 Utilities and Service Systems
General Plan EIR Findings
Utilities and service systems are discussed in Section 4.10 of the General Plan EIR. The General Plan EIR determined that impacts related to water distribution systems, wastewater conveyance and treatment facilities, and utility services (including electricity, natural gas, and telecommunications) would result in less than significant impacts with the implantation of Mitigation Measures 4.10-1a,

4.10-1b, 4.10-2a, and 4.10-6, in addition to the implementation of General Plan goals, policies, and programs. Mitigation Measures 4.10-1a and 4.10-1b requires individual applicants to conduct a water study to determine the availability of potable water and the infrastructure required for conveyance and requires new facilities to be designed with water conserving devices. Mitigation Measure 4.10-2a requires individual projects to demonstrate available wastewater capacity to serve new development. Mitigation Measure 4.10-6 requires project applicants to coordinate with Pacific Gas and Electric Company and Pacific Bell to extend electrical, natural gas, and telephone services to individual project sites. The General Plan EIR determined that impacts related to solid waste services would be less than significant.

A discussion of stormwater is not included in the general Plan EIR, however analysis of this impact areas is included below.

Addendum Analysis
The Housing Element Update would accommodate anticipated population growth associated with the City’s RHNA allocation. As discussed in Section 2.7, Buildout of Proposed Project and Comparison to the 2000 General Plan EIR, buildout of the proposed Project is within the buildout projections analyzed in the General Plan EIR. The Zoning Code Update and Zoning Map Amendment would not result in any physical development.

Because the proposed Project would not exceed the buildout identified in the General Plan EIR, it would not result in an increase in demand for water supply, wastewater, electricity, natural gas, telecommunications, or solid waste services. Additionally, the proposed Project, in and of itself, would not propose or authorize specific development. Future development facilitated by the Project would undergo project-specific developmental review, including design review, and would be subject to adopted development regulations, such as the City of Atwater Municipal Code Section

13.04.100 requiring utility requirements to be met before construction bids are accepted. Future development facilitated by the project would undergo project-specific developmental review, including design review, and would be required to comply with General Plan goals and policies related to utilities and service systems, including goals LU-24 and LU-25; policies LU-24.1 and LU25.1; and programs LU-24.a and LU-25.a. Future development would also be required to implement Mitigation Measures 4.10-1a, 4.10-1b, 4.10-2a, and 4.10-6.

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Addendum Evaluation
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Because the Project would not facilitate development beyond what was considered in the General Plan EIR, the Project would not result in new significant environmental effects or a substantial increase in the severity of previously identified significant effects.

Conclusion
The Project would not result in utilities and service systems impacts beyond those addressed or analyzed in the General Plan EIR nor present new information that shows impacts would be more significant than those described in the General Plan EIR. Therefore, the General Plan EIR applies to the proposed Project and no additional environmental assessment of utilities and service systems is required.

6.20 Wildfire
General Plan EIR Findings
While wildland fires are addressed briefly in Appendix A of the General Plan EIR, the General Plan EIR does not include a separate section regarding wildfire, and such a discussion was not required under the CEQA Guidelines Appendix G checklist at the time the report was prepared. Though not technically required as part of an addendum, a discussion of wildfire impacts is provided herein to ensure completeness of the environmental analysis for the Housing Element Update project.

Addendum Analysis
The City of Atwater is in an area where the wildland fire risk is considered minimal. There are no State Responsibility Areas (SRAs) or Very High Fire Hazard Severity Zones (VHFHSZ) within the city of Atwater (CAL FIRE 2024). The nearest SRA is located approximately 7.6 miles northeast of the City and the nearest VHFHSZ is approximately 20 miles northeast of the city. Additionally, the Safety Element contains goals and policies, such as Goal SF-6 and Policies SF-6.1 through SF-6.4 to support and facilitate fire protection. These policies from the General Plan would minimize loss of life and property from wildland fires. Because it is a policy document, the Housing Element Update would not, in and of itself, result in impacts to wildfire. The Zoning Code Update and Zoning Map Amendment would not result in any physical development.

Future development facilitated by the project would undergo project-specific review and would be subject to adopted development standards. The California Fire Code would also reduce impacts associated with wildfire hazards. The Project anticipates the development of residential buildings within city limits, which was previously considered in the General Plan EIR. The proposed Project does not introduce development in areas inconsistent with these prior assumptions, except for annexation sites located outside city limits and currently planned for agricultural use, which would be subject to additional review and compliance with applicable local, state, and federal regulations at the time when annexation is proposed. With implementation of these standards, impacts would be less than significant.

Conclusion
The Project would not result in wildfire impacts beyond those addressed or analyzed in the General Plan EIR nor present new information that shows impacts would be more significant than those described in the General Plan EIR. Therefore, the General Plan EIR applies to the proposed Project and no additional environmental assessment of wildfire is required.

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City of Atwater
City of Atwater 2024-2032 Housing Element Update
40 6.21 Cumulative Impacts
General Plan EIR Findings
The General Plan EIR Section 6.0 determined that cumulative impacts related to land use and planning, hazards and hazardous materials, cultural resources, public services, and utilities would be considered less than significant. Cumulative impacts related to transportation, noise, hydrology and water quality, geology and soils, and biological resources would be considered less than significant with the mitigation discussed above for each impact criteria. Impacts related to agriculture and forestry resources, and air quality were determined to be cumulatively considerable.

Addendum Analysis
Since certification of the 2000 General Plan EIR, there has been no substantial development beyond the scope of the General Plan EIR that has been constructed within the city, and growth within the city has occurred at a slower rate than was anticipated in the 2000 General Plan EIR (refer to Section

2.7, Buildout of Proposed Project and Comparison to the 2000 General Plan EIR). There are no new substantial cumulative projects in the City that were not previously considered in the 2000 General Plan EIR. The cumulative conditions in the General Plan EIR have not substantially changed; therefore, the cumulative setting in the General Plan EIR remains the same for the purposes of this analysis.

The proposed Project would not result in new impacts compared to the General Plan EIR as analyzed in this Addendum. While the Project would result in the potential future development of a greater number of housing units in the City than analyzed in the General Plan EIR, the physical development area of the City would not be modified, with the exception of annexation sites located outside city limits and currently planned for agricultural use, which would be subject to additional review and compliance with applicable local, state, and federal regulations at the time when annexation is proposed. Therefore, no new or additional cumulatively considerable contributions to a significant cumulative impact would occur as a result of the Project.

Conclusion
The Project would not result in cumulative impacts beyond those addressed or analyzed in the General Plan EIR nor present new information that shows impacts would be more significant than those described in the General Plan EIR. Therefore, the General Plan EIR applies to the Project and no additional environmental assessment of cumulative impacts is required.

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Summary of Findings
State Clearinghouse Number 1999061027 41
7 Summary of Findings
The Housing Element Update is part of the City’s General Plan, and like other elements within the General Plan, it includes goals and policies that the City should meet when it comes to the planning of housing. The Housing Element is also unique from the other elements within the General Plan because it is required to be periodically updated to align with the State’s allocation of the RHNA.

Also, the Housing Element includes Housing Programs, such as the Rezoning Program and Annexation Program described in Section 1.5, that are required to be implemented within the planning period established for the Housing Element. These programs are usually implemented over time after the element is adopted.

The Project does not involve site-specific projects nor changes in the currently adopted General Plan land uses; therefore the adoption of the Project would be consistent with the General Plan EIR certified in July 2000. The General Plan EIR analyzed full buildout of the City’s General Plan. Future development facilitated by the Housing Element would be subject to applicable development standards; reviews established by City ordinances; General Plan goals, policies, and programs; and mitigation measures described in the General Plan EIR. Additionally, future development requiring discretionary review may be subject to CEQA compliance if it is not consistent with the General Plan or Housing Element. The Zoning Code Update and Zoning Map Amendment would not result in any physical development.

It has been determined through this analysis that the adoption of the Project would not result in impacts beyond those addressed or analyzed in the General Plan EIR, nor does the Project present new information that shows impacts would be more significant than those described in the General Plan EIR. Therefore, the General Plan EIR applies to the Project Update and no additional environmental compliance is required.

The analysis pursuant to Section 15162 demonstrates whether the lead agency can approve the activity as being within the scope of the existing certified EIR, that an addendum to the existing EIR would be appropriate, and no new environmental document, such as a new EIR, would be required.

The addendum need not be circulated for public review but can be included in or attached to the final EIR, and the decision-making body shall consider the addendum with the final EIR prior to deciding on the Project.

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City of Atwater
City of Atwater 2024-2032 Housing Element Update
42 8 References

8.1 Bibliography
Atwater, City of. 2000a. City of Atwater General Plan. July 2000. https://atwater.generalplan.org/documents-maps (accessed June 2024).

Atwater, City of. 2000b. Draft Environmental Impact Report for the Atwater General Plan Update.

SCH No. 1999061027. Certified November 1999.

California Department of Conservation. 2024. California Important Farmland Finder. https://maps.conservation.ca.gov/DLRP/CIFF/ (accessed November 2024).

California Department of Finance (DOF). 2024. E-5 Population and Housing Estimates for Cities, Counties, and the State, 2020-2024.
https://dof.ca.gov/forecasting/demographics/estimates/e-5-population-and-housingestimates-for-cities-counties-and-the-state-2020-2024/ (accessed July 2024).

California Department of Forestry and Fire Protection (CAL FIRE). 2024. Fire Hazard Severity Zones in State Responsibility Area. https://osfm.fire.ca.gov/what-we-do/community-wildfirepreparedness-and-mitigation/fire-hazard-severity-zones (accessed August 2024).

Merced County Association of Governments (MCAG). 2022. Final Regional Housing Needs Allocation Plan: Merced County Region. Adopted November 17, 2022.
https://www.mcagov.org/DocumentCenter/View/3863/MCAG-RHNA-Plan_FINAL- _11172022?bidId= (accessed November 2024).

United States Geological Survey. 2024. MRData. https://mrdata.usgs.gov/general/map-us.html (accessed November 2024).

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

RINCON CONSULTANTS, INC.

Matthew Maddox, AICP, Principal
Aileen Mahoney, Senior Environmental Planner
Michael Huang, Environmental Planner

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Appendix B: City of Atwater
2024-2032 Merced County MultiJurisdictional Housing
Element
Update
August 2026

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Table of Contents
2024-2032 Housing Element i
Table of Contents
B1 Review of Past Accomplishments............................................................................................. B1-1 B1.1 Effectiveness in Addressing Special Needs................................................................... B1-1 B1.2 Quantified Objectives ................................................................................................... B1-1 B1.3 Review of Past Accomplishments................................................................................. B1-2 B2 Public Participation..................................................................................................................... 2-1 B2.1 Pop-up Events............................................................................................................... B2-1 B2.2 Community Workshops ................................................................................................ B2-1 B2.3 Survey............................................................................................................................ B2-2 B2.4 Stakeholder Interviews................................................................................................. B2-2 B2.5 Additional Outreach...................................................................................................... B2-3 B2.6 Response to Community Input ..................................................................................... B2-4 B2.7 Public Review ................................................................................................................ B2-6 B2.7.1 May 2024 Public Review............................................................................... B2-6 B2.7.2 September 2024 Public Review.................................................................... B2-6 B2.7.3 February 2025 Public Review ....................................................................... B2-6 B2.7.4 Public Review Comment Matrix ................................................................... B2-6 B2.7.5 March/April 2026 Public Review .................................................................. B2-6 B3 Housing Needs Assessment...................................................................................................... B3-1 B3.1 Population Characteristics............................................................................................ B3-1 B3.2 Population Growth........................................................................................................ B3-1 B3.3 Age Characteristics........................................................................................................ B3-1 B3.4 Race and Ethnicity......................................................................................................... B3-2 B3.5 Economic Characteristics.............................................................................................. B3-3 B3.6 Household Characteristics ............................................................................................ B3-8 B3.7 Large Households.......................................................................................................... B3-9 B3.8 Overcrowding................................................................................................................ B3-9 B3.9 Special Needs Groups ................................................................................................. B3-10 B3.10 Housing Stock Characteristics..................................................................................... B3-23 B3.11 Distribution of Owner-Occupied Units ....................................................................... B3-30 B3.12 Housing Rents............................................................................................................. B3-31 B3.13 Housing Affordability .................................................................................................. B3-32 B3.14 Assisted Housing Units................................................................................................ B3-36 B4 Housing Constraints Analysis.................................................................................................... B4-1 B4.1 Summary of Local Housing Constraints........................................................................ B4-1 B4.2 Non-Governmental Constraints.................................................................................... B4-1 B4.2.1 Land Costs..................................................................................................... B4-2

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Merced County Association of Governments
Merced County Multi-Jurisdictional Housing Element (2024-2032) ii
B4.2.2 Construction Costs........................................................................................ B4-3 B4.2.3 Availability of Financing................................................................................ B4-4 B4.2.4 Requests for Lower Development Densities ................................................ B4-6 B4.3 Governmental Constraints............................................................................................ B4-6 B4.3.1 Land Use Controls......................................................................................... B4-6 B4.3.2 Residential Development Standards ............................................................ B4-9 B4.3.3 Provision of a Variety of Housing Types..................................................... B4-14 B4.3.4 Planning and Development Fees................................................................ B4-27 B4.3.5 Permit Types............................................................................................... B4-29 B4.3.6 Permit Procedures and Processing Times .................................................. B4-33 B4.3.7 Transparency in the Development Review Process ................................... B4-36 B4.3.8 Short-Term Housing Rentals....................................................................... B4-36 B4.3.9 Code Enforcement...................................................................................... B4-36 B4.4 Environmental Constraints ......................................................................................... B4-37 B4.4.1 Agricultural Lands....................................................................................... B4-38 B4.4.2 Seismic Zones.............................................................................................. B4-38 B4.4.3 Flood ........................................................................................................... B4-38 B4.4.4 Climate Change........................................................................................... B4-38 B4.4.5 Site Contaminants....................................................................................... B4-39 B4.4.6 Wildland/Urban Fire Hazards..................................................................... B4-39 B5 Affirmatively Furthering Fair Housing (AFFH)........................................................................... B5-1 B5.1 Introduction .................................................................................................................. B5-1 B5.2 Data Sources ................................................................................................................. B5-1 B5.3 Methodology................................................................................................................. B5-1 B5.4 Local Setting.................................................................................................................. B5-4 B5.5 Summary of AFFH Analysis Findings ........................................................................... B5-12 B5.6 Fair Housing Resources............................................................................................... B5-12 B5.7 Ability to Address Complaints..................................................................................... B5-16 B5.8 Segregation and Integration Patterns and Trends...................................................... B5-16 B5.9 Disparities in Access to Opportunities........................................................................ B5-37 B5.10 Disproportionate Housing Needs................................................................................ B5-51 B5.11 Local Area Knowledge................................................................................................. B5-60 B5.12 Housing Site Inventory Analysis.................................................................................. B5-66 B5.13 Contributing Factors and Meaningful Actions............................................................ B5-80 B5.14 Meaningful Actions to Address Fair Housing Issues................................................... B5-82 B6 Housing Resources and Site Inventory Analysis....................................................................... B6-1 B6.1 Regional Housing Needs Allocation .............................................................................. B6-1 B6.2 Meeting the RHNA ........................................................................................................ B6-2 B6.2.1 RHNA Credits ................................................................................................ B6-2

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Table of Contents
2024-2032 Housing Element iii
B6.3 Summary of RHNA Credits............................................................................................ B6-6 B6.4 Methodology................................................................................................................. B6-6 B6.4.1 Suitable Sites for Affordable Housing........................................................... B6-6 B6.5 Nonvacant Sites ............................................................................................................ B6-7 B6.5.1 Adequacy of Nonvacant Sites....................................................................... B6-7 B6.6 Development Trends................................................................................................... B6-13 B6.6.1 Realistic Development Capacity ................................................................. B6-13 B6.6.2 Likelihood of 100 percent Nonresidential Uses on Sites............................ B6-15 B6.7 Large Sites for Lower-Income Units............................................................................ B6-17 B6.7.1 Subdivision Process for Large Sites............................................................. B6-19 B6.8 Site Inventory.............................................................................................................. B6-20 B6.8.1 Rezone Sites................................................................................................ B6-34 B6.8.2 Sites used in Previous Planning Periods ..................................................... B6-40 B6.8.3 Adequacy of Residential Site Inventory in Meeting RHNA......................... B6-40 B6.9 Availability of Infrastructure and Services.................................................................. B6-41 B6.9.1 Wastewater System.................................................................................... B6-41 B6.9.2 Potable Water System................................................................................ B6-41 B6.9.3 Storm Water and Drainage......................................................................... B6-42 B6.9.4 Dry Utilities................................................................................................. B6-43 B6.10 Environmental Considerations.................................................................................... B6-43 B6.11 Opportunities for Energy Conservation...................................................................... B6-44 B7 Housing Plan ............................................................................................................................. B7-1 B7.1 Goals and Policies ......................................................................................................... B7-1 B7.2 Implementing Programs ............................................................................................... B7-3 B7.3 AFFH Actions Summary............................................................................................... B7-24 B7.4 Quantified Objectives ................................................................................................. B7-51 Tables
Table B1-1 Quantified Housing Objective and Achieved Accomplishments............................... B1-2 Table B1-2 Review of Past Accomplishments............................................................................. B1-2 Table B2-1 Summary of Comments and Responses ................................................................... B2-6 Table B3-1 Population Change (2000 - 2021) ............................................................................. B3-1 Table B3-2 Population by Age Group (2021)............................................................................... B3-2 Table B3-3 Population by Race.................................................................................................... B3-2 Table B3-4 Employment by Industry (2021) ............................................................................... B3-3 Table B3-5 Major Employers in Merced County (2024).............................................................. B3-4 Table B3-6 Occupational Employment and Wages by Major Occupational Group, Merced Metropolitan Area (2023)......................................................................................... B3-5 Table B3-7 HUD Income Limits by Person per Household.......................................................... B3-6

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Merced County Association of Governments
Merced County Multi-Jurisdictional Housing Element (2024-2032) iv
Table B3-8 State of California Income Categories....................................................................... B3-6 Table B3-9 Median Household Income by Race/Ethnicity (dollars)............................................ B3-7 Table B3-10 Cost Burdened Households by Tenure...................................................................... B3-8 Table B3-11 Overpayment by Tenure (dollars)............................................................................. B3-8 Table B3-12 Households by Type.................................................................................................. B3-9 Table B3-13 Large Households by Tenure..................................................................................... B3-9 Table B3-14 Overcrowding Severity by Tenure........................................................................... B3-10 Table B3-15 Senior Households by Tenure ................................................................................. B3-10 Table B3-16 Overpayment by Tenure Among Senior Households, Atwater............................... B3-11 Table B3-17 Cost Burdened Senior Households.......................................................................... B3-12 Table B3-18 Population by Number of Disabilities ..................................................................... B3-12 Table B3-19 Disability by Age for the Total Population .............................................................. B3-13 Table B3-20 Developmental Disability by Age ............................................................................ B3-13 Table B3-21 Developmental Disability by Residence.................................................................. B3-13 Table B3-22 Large Households by Tenure................................................................................... B3-14 Table B3-23 Large Households and Units ................................................................................... B3-15 Table B3-24 Single Female-Headed Households with Own Children.......................................... B3-15 Table B3-25 Female-Headed Family Households by Tenure ...................................................... B3-16 Table B3-26 Extremely Low-Income Households by Tenure ...................................................... B3-17 Table B3-27 Extremely Low-Income Households Overpaying by Tenure................................... B3-17 Table B3-28 Inventory of Public Assisted Complexes, Atwater .................................................. B3-18 Table B3-29 Farmworker Population .......................................................................................... B3-19 Table B3-30 Farmworkers in Merced County by Days Worked (2017)....................................... B3-20 Table B3-31 Unhoused Individuals by Type (2023)..................................................................... B3-21 Table B3-32 Unhoused Individuals by Ethnicity, Merced County (2023).................................... B3-22 Table B3-33 Total Housing Units Over Time (1980 to 2020)....................................................... B3-23 Table B3-34 Total Housing Units by Type ................................................................................... B3-24 Table B3-35 Housing Units by Tenure......................................................................................... B3-25 Table B3-36 Vacancy Status by Type for Total Vacant Units....................................................... B3-26 Table B3-37 Housing Unit Size .................................................................................................... B3-27 Table B3-38 Total Occupied Housing Units by Year Built............................................................ B3-28 Table B3-39 Substandard Housing Units..................................................................................... B3-29 Table B3-40 Median Housing Value Over Time (1980 to 2020).................................................. B3-29 Table B3-41 Median Housing Value from 2017 to 2021............................................................. B3-30 Table B3-42 Owner Occupied Units by Race............................................................................... B3-31 Table B3-43 Median Gross Rent Over Time, Atwater................................................................. B3-32 Table B3-44 Median Rent by Number of Bedrooms................................................................... B3-32 Table B3-45 Housing Affordability Matrix – Atwater (2021) ...................................................... B3-33 Table B3-46 Cost Burdened Owner-Occupied Households Over Time....................................... B3-35

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Table of Contents
2024-2032 Housing Element v
Table B3-47 Cost Burdened Renter-Occupied Households Over Time....................................... B3-35 Table B3-48 Cost Burden by Income and Tenure........................................................................ B3-35 Table B3-49 Inventory of Public Assisted Complexes – Atwater ................................................ B3-37 Table B4-1 Listed Land Prices – Atwater..................................................................................... B4-2 Table B4-2 Sold Land Prices – Atwater........................................................................................ B4-2 Table B6-3 Estimated Construction Cost – City of Atwater ........................................................ B4-3 Table B4-4 Site Area Per Dwelling Unit....................................................................................... B4-8 Table B4-5 Residential Development Standards......................................................................... B4-9 Table B4-6 Residential Parking Requirements.......................................................................... B4-11 Table B4-7 Residential Use Matrix ............................................................................................ B4-15 Table B4-8 Emergency Shelter Capacity Analysis...................................................................... B4-22 Table B4-9 Emergency Shelter Capacity Analysis in Commercial Thoroughfare Zone (C-T)..... B4-23 Table B4-10 Residential Development Planning Fees................................................................. B4-27 Table B4-11 Residential Development Fees................................................................................ B4-28 Table B4-12 Residential Development Fee Comparison............................................................. B4-29 Table B4-13 Timelines for Permit Procedures ............................................................................ B4-34 Table B4-14 Typical Processing Procedures by Project Type...................................................... B4-34 Table B5-1 Population by Racial Group (City of Atwater)......................................................... B5-16 Table B5-2 Employment Status by Disability Status (City of Atwater)...................................... B5-23 Table B5-3 Tenure by Household Type and Presence of Children (City of Atwater) ................ B5-25 Table B5-4 Demographics of RCAA ........................................................................................... B5-33 Table B5-5 Domains and List of Indicators for Opportunity Maps ........................................... B5-37 Table B5-6 Opportunity Map Scores and Categorization for Atwater...................................... B5-38 Table B5-7 Cost Burden by Income Category (2015-2019)....................................................... B5-52 Table B5-8 Large Households (City of Atwater)........................................................................ B5-53 Table B5-9 Race/Ethnicity of Homeless Population and Overall Population (City of Atwater)...................................................................................................... B5-57 Table B5-10 Proposed Housing Units by Resource Area............................................................. B5-67 Table B5-11 Site Inventory by Census Tract Characteristics....................................................... B5-78 Table B6-1 Atwater 2024-2032 RHNA......................................................................................... B6-1 Table B6-2 Pipeline Projects........................................................................................................ B6-4 Table B6-3 Remaining Share of RHNA......................................................................................... B6-6 Table B6-4 Nonvacant Sites......................................................................................................... B6-7 Table B6-5 Redevelopment Trends on Sites with Operational Agriculture .............................. B6-11 Table B6-6 Atwater Development Trends................................................................................. B6-13 Table B6-7 Realistic Capacity of Sites by Zoning District........................................................... B6-14 Table B6-8 Residential Projects in Zones that allow 100 percent Nonresidential Uses ........... B6-16 Table B6-9 Large Sites with Lower-Income Units...................................................................... B6-17 Table B6-10 Summary of Recent Developments on Large Sites in San Joaquin Valley .............. B6-18

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Merced County Association of Governments
Merced County Multi-Jurisdictional Housing Element (2024-2032) vi
Table B6-11 Atwater Site Inventory – Opportunity Sites............................................................ B6-25 Table B6-12 Proposed Rezone Sites to Accommodate RHNA Shortfall...................................... B6-35 Table B6-13 Annexation Sites ..................................................................................................... B6-39 Table B6-14 Sites Used in Previous Planning Periods................................................................. B6-40 Table B6-15 Adequacy of Residential Site Inventory .................................................................. B6-40 Table B7-1 Quantified Objectives 2024-2032 ........................................................................... B7-51 Figures
Figure B3-1 Median Household Income....................................................................................... B3-7 Figure B3-2 Unhoused Households by Type Over Time, Merced County .................................. B3-21 Figure B3-3 Unhoused Individuals by Type by Race (2023) ....................................................... B3-22 Figure B3-4 Median Contract Rent............................................................................................. B3-31 Figure B5-1 Atwater Neighborhoods............................................................................................ B5-3 Figure B5-2 Atwater Zoning Map ................................................................................................. B5-6 Figure B5-3 Renter-Occupied Concentration ............................................................................... B5-7 Figure B5-4 Atwater Aerial View .................................................................................................. B5-8 Figure B5-5 Atwater Population Density...................................................................................... B5-9 Figure B5-6 Percentage of Housing Built Before 1990............................................................... B5-10 Figure B5-7 Median Gross Rents............................................................................................... B5-11 Figure B5-8 Percent of Total Non-White Population (City of Atwater)...................................... B5-18 Figure B5-9 Predominant Populations (City of Atwater)............................................................ B5-19 Figure B5-10 Racial Segregation and Integration (City of Atwater) ............................................. B5-20 Figure B5-11 Disability by Type (City of Atwater)......................................................................... B5-21 Figure B5-12 Percent of Population with a Disability (City of Atwater)....................................... B5-22 Figure B5-13 Percent of Population with a Disability and Residential Care Facilities (City of Atwater) .................................................................................................................. B5-24 Figure B5-14 Female-Headed Households with Children Present, No Spouse/Partner Present and Child Care Centers (City of Atwater)................................................................ B5-27 Figure B5-15 Female-Headed Households with Children Present, No Spouse/Partner Present (City of Atwater)...................................................................................................... B5-28 Figure B5-16 Married Couple Households with Children Present (City of Atwater).................... B5-29 Figure B5-17 Median Household Income (City of Atwater)......................................................... B5-30 Figure B5-18 Low- and Moderate-Income Population (City of Atwater)..................................... B5-31 Figure B5-19 Poverty Status (City of Atwater) ............................................................................. B5-34 Figure B5-20 Racially Concentrated Areas of Affluence (City of Atwater)................................... B5-35 Figure B5-21 Housing Choice Vouchers........................................................................................ B5-36 Figure B5-22 Atwater TCAC Opportunity Areas........................................................................... B5-39 Figure B5-23 TCAC Opportunity Areas – Education Outcomes (City of Atwater)........................ B5-43 Figure B5-24 TCAC Opportunity Areas - Economic (City of Atwater)........................................... B5-44 Figure B5-25 Existing Bus Transit Services ................................................................................... B5-45

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Table of Contents
2024-2032 Housing Element vii
Figure B5-26 Walkability Index (City of Atwater)......................................................................... B5-46 Figure B5-27 CalEnviroScreen 4.0 Percentile Scores (City of Atwater)........................................ B5-48 Figure B5-28 TCAC Opportunity Areas - Environmental (City of Atwater)................................... B5-49 Figure B5-29 SB 535 Disadvantaged Communities (City of Atwater)........................................... B5-50 Figure B5-30 Overpayment by Home Owners (City of Atwater).................................................. B5-54 Figure B5-31 Overpayment by Renters (City of Atwater) ............................................................ B5-55 Figure B5-32 Overcrowded Households (City of Atwater)........................................................... B5-56 Figure B5-33 Displacement Risk (City of Atwater) ....................................................................... B5-59 Figure B5-34 City of Atwater Zoning Map.................................................................................... B5-65 Figure B5-35 Housing Opportunity Sites by TCAC Resource Area................................................ B5-68 Figure B5-36 Housing Opportunity Sites by Income Population.................................................. B5-70 Figure B5-37 Housing Opportunity Sites by Overcrowding.......................................................... B5-71 Figure B5-38 Housing Opportunity Sites by Overpayment by Renters........................................ B5-72 Figure B5-39 Housing Opportunity Sites by Total Non-White Population................................... B5-74 Figure B5-40 Housing Opportunity Sites by Displacement Risk................................................... B5-75 Figure B5-41 Housing Opportunity Sites by CalEnviroScreen Percentile Score ........................... B5-76 Figure B6-1 Pipeline Projects........................................................................................................ B6-5 Figure B6-2 Atwater Site Inventory (Current Zoning) ................................................................ B6-23 Figure B6-3 Atwater Site Inventory (Proposed Zoning) ............................................................. B6-24

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Merced County Association of Governments
Merced County Multi-Jurisdictional Housing Element (2024-2032) viii
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City of Atwater
Review of Past Accomplishments
2024-2032 Housing Element B1-1
B1 Review of Past Accomplishments
To develop appropriate programs to address the housing issues identified in the 2024-2032 Housing Element (6th cycle), the City of Atwater has reviewed the housing programs adopted in the 2015- 2022 Housing Element (5th cycle) and evaluated the effectiveness of these programs in delivering housing services and assistance. Table B1-1 summarizes the City’s progress toward the previous Regional Housing Needs Allocation (RHNA) and Table B1-2 provides a detailed program level assessment of housing accomplishments over the 5
th cycle planning period. Programs that are
routine staff functions with no specific actions and no direct City involvement are not continued as housing programs in the 6
th Cycle Housing Element.

B1.1 Effectiveness in Addressing Special Needs
The City was not successful in facilitating the development of housing for special needs groups during the 5th Cycle Housing Element. Programs developed for the 5th cycle identified specific solutions to housing for special needs groups such as seniors, homeless, low-income households, and/or persons with disabilities. Goal H-5 focuses on accommodating housing for special needs groups, including Program H-5a, which promotes senior housing, and Program H-5f, which implemented zoning for supportive and transitional housing. In addition, Program H-3f focuses on collaborating with nearby jurisdictions and housing assistance groups to implement special housing and homeless needs workshops. Program H-5c has also removed constraints for persons with disabilities to find accessible housing, as the City currently follows the California Building Code and its requirements for accessible living properties.

No housing units for special needs groups were developed during the 5th cycle, resulting from factors beyond the City’s control such as market conditions and financial barriers. Limited staffing and resources posed significant challenges to program implementation to support special housing needs. However, the City has taken several steps to address special needs housing. It participated in a regional workshop focused on housing and homelessness in collaboration with other jurisdictions and the Merced County Continuum of Care. The City adopted an ordinance allowing emergency shelters in its M-1 and M-2 zoning districts to comply with state legislation. Additionally, in 2019, Atwater amended its Zoning Code to permit supportive and transitional housing. These actions demonstrate the City's commitment to expanding housing options for individuals experiencing homelessness and other vulnerable populations. Programs in the 6th Cycle Housing Element build on these past accomplishments to further encourage the development and accessibility of housing for special needs.

B1.2 Quantified Objectives
Table B1-1 summarizes the City’s progress toward meeting the previous 5 th Cycle Housing Element
RHNA, as well as objectives to rehabilitate and conserve/preserve existing housing stock. The City of Atwater did not reach its 5
th cycle RHNA goals in the Extremely Low, Very Low-, Low-, and Moderate-Income categories.

Table B1-1 Quantified Housing Objective and Achieved Accomplishments New Construction Rehabilitation Preservation (At-Risk Units)

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Merced County Association of Governments
Merced County Multi-Jurisdictional Housing Element (2024-2032) B1-2
RHNA
(2016-2024) Actual Objectives Actual Objectives Actual
Extremely Low-Income - - - -
Very Low-Income 429 - - -
Low-Income 307 - - -
Moderate-Income 281 - - -
Above Moderate-Income 748 427 - -
Total 1,765 427 - -
B1.3 Review of Past Accomplishments
Table B1-2 provides a detailed program-level assessment of housing accomplishments during the 5 th
Cycle Housing Element planning period.

Table B1-2 Review of Past Accomplishments
Program Program Objectives Progress and Continued Appropriateness Goal H-1 – Provide suitable and adequate sites for residential development.

Program H-1a:

Vacant and NonVacant Underutilized
and Site Inventory
Program
The objective of this program is to assist
developers in finding suitable infill and
underutilized sites to meet a portion of
the City’s new housing construction
needs.

The City has been contacted by multiple interested
developers. The existing land use and zoning maps
are in the process of being re-evaluated for General
Plan amendment and zone change.

Effectiveness: Partially implemented
Continued Appropriateness: Program H-1a is
ongoing and will be incorporated into the 6th Cycle
Housing Element as Program 2.

Program H-1b:

Creation of Larger
Parcels through Site
Consolidation
The objective of this program is to
facilitate creation of larger parcels for
more efficient development of
multifamily housing and assist
developers in finding suitable vacant
infill and non-vacant underutilized sites
to meet a portion of the City's new
housing construction needs.

The City is re-evaluating program H-1b, as
developers are reluctant to pursue a multi-parcel
approach due to the complexities it introduces in
segmented financing.

Effectiveness: Not implemented due to market
constraints
Continued Appropriateness: Program H-1b will be
discontinued in the 6th Cycle Housing Element, as
developers have not shown interest in this
development approach.

Program H-1c:

Creation of Larger
Parcels through
Right-of-way
Abandonment
The objective of this program is to make
additional land available adjacent to
existing developed or underutilized land
to facilitate more efficient development
of five high density residential units
(Low to Very Low Income).

The City is re-evaluating program H-1c, as
developers are reluctant to pursue the creation of
larger parcels through right-of-way abandonment.

Effectiveness: Not implemented due to market
constraints
Continued Appropriateness: Program H-1c will be
discontinued in the 6th Cycle Housing Element, as
developers have not shown interest in this
development approach.

Program H-1d:

Ferrari Ranch
Annexation
The objective of this program is to bring
additional low and medium density
residential land into the City limits for
an estimated net gain of 82 total units,
including 80 low density units (Above
Moderate and Moderate Income) and
The Ferrari Ranch annexation has been completed.

However, no development has occurred at the site.

Additionally, the area is not designated for future
residential development. However, other lands
immediately north of Ferrari Ranch, outside the city

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City of Atwater
Review of Past Accomplishments
2024-2032 Housing Element B1-3
Program Program Objectives Progress and Continued Appropriateness two medium density units (Low
Income).
limits, are proposed to be designated for residential
development in the General Plan update.

Effectiveness: Not implemented due to land use
designations.

Continued Appropriateness: Program H-1d will not
be carried forward in the 6th Cycle Housing Element.

Program H-1e:

Western Residential
Land Annexations
The objective of this program is to bring
additional residential land into the City
limits. At the planned densities, the two
identified annexation areas would
accommodate up to 1,813 additional
units, including 1,010 low density
(Above Moderate and Moderate
Income), 360 medium density (Low
Income), and 443 high density units
(Very Low Income).

The City’s General Plan land use map is being reevaluated and recommended map adjustments will be proposed in the General Plan update that is
currently underway.

Effectiveness: Not implemented due to the
upcoming General Plan update.

Continued Appropriateness: Program H-1e will be
revised and incorporated into Program 2 to rezone
properties to accommodate high-density. residential
housing.

Program H-1f:

Residential Specific
Plans
The objective of this program is to
expedite residential development
opportunities on annexed lands, ensure
desired mix and arrangement of land
uses, and ensure provision and
financing of adequate infrastructure
and public services.

The City is proposing a mix of high-, medium-, and
low-density residential land use designations in
future annexation areas in the General Plan update.

Effectiveness: Partially implemented
Continued Appropriateness: Program H-1f will be
revised and incorporated into Program 2 to rezone
properties to accommodate high-density. residential
housing. .

Program H-1g:

Developer Resources
The objective of this program is to assist
developers in locating appropriate sites
for housing.

This program is ongoing and there has been
renewed developer interest in Atwater.

Effectiveness: Successfully implemented
Continued Appropriateness: Program H-1g ongoing
and will be incorporated into the 6
th Cycle Housing
Element as Program 2.

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Merced County Association of Governments
Merced County Multi-Jurisdictional Housing Element (2024-2032) B1-4
Program Program Objectives Progress and Continued Appropriateness Program H-1h:

General Plan
Amendment and
Rezone of Buhach
Road
The objective of this program is to
increase the supply of R‐3 land in a
location with demonstrated demand.

This program was not implemented. The City
reevaluated this program and determined it was
unnecessary as the RHNA can be met through the
Site Inventory..

Effectiveness: Not implemented
Continued Appropriateness: This program will not
be incorporated into the 6th Cycle Housing Element.

Program 2 will replace Program H-1h to ensure
there is sufficient supply of sites to support
additional housing development.

Goal H-2 – Accommodate a range of housing options by type, size, location, price, and tenure.

Program H-2a:

Designate Land for a
Mixture of Housing
Types
The objective of this program is to allow
and encourage a mix of housing types
and a range of housing densities
throughout the community.

The program is currently in practice. A General Plan
update to allow for a range of densities and housing
types is currently underway.

Effectiveness: Successfully implemented
Continued Appropriateness: Program H-2a will be
refined and incorporated into the 6
th Cycle Housing
Element as Program 2.

Program H-2b:

Encourage
Innovative
Subdivision and
Housing Design
The objective of this program is to
increase local awareness and
acceptance of alternative housing
designs and increase the range of
housing choices available to low‐ and
moderate‐income households.

This program was implemented during the planning
and successful approval process in August 2024 for
Sunset Apartments, a two-story, high-density
residential project.

Effectiveness: Successfully implemented
Continued Appropriateness: Program H-2b will be
discontinued in the 6th Cycle Housing Element but
incorporated into Program 8 to accommodate a
greater mix of dwelling types.

Program H-2c:

Evaluate Residential
Uses and
Development
Standards
The objective of this program is to
ensure that innovative housing types
are accommodated within the City and
that alternative housing designs can be
achieved on appropriate residential lots
within the City, while protecting
community aesthetic values.

The City adopted Residential Design Guidelines in
2011. Some of the language included is subjective;
however, the City only enforces objective standards
included in the Residential Design Guidelines.

Additional efforts to accommodate alternative
housing designs include updating the City’s
Accessory Dwelling Unit (ADU) ordinance in 2024 to
streamline the approval for ADUs and amending
development standards to comply with state law.

Effectiveness: Successfully implemented
Continued Appropriateness: Program H-2c was
completed and will not be continued into the 6th
Cycle Housing Element. Program 7 will update the
Residential Design Guidelines to remove subjective
language and replace it with objective standards.

Goal H-3 – Increase the supply of affordable housing in the city.

Program H-3a:

Promote
Homeownership for
Low- and ModerateIncome Households
The objective of this program is to
assist 15 moderate and 15 lowincome first-time homebuyers.

The City continues to partner with the Housing
Authority of Merced County and Self-Help
Enterprises to provide first-time homebuyer
assistance. The City has published a flyer advertising
the First-Time Homebuyers Program on the City
website and posted flyers and advertisements about
the program. While residents have shown interest in
the program, the City has observed that residents
have difficulty meeting the program’s qualification
requirements. Therefore, the City has expanded the

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City of Atwater
Review of Past Accomplishments
2024-2032 Housing Element B1-5
Program Program Objectives Progress and Continued Appropriateness eligibility requirements to make it easier for FirstTime Homebuyers to access the program.

Effectiveness: Successfully implemented
Continued Appropriateness: Program H-3a will be
refined to pursue additional homeownership
assistance opportunities and incorporated into the
6th Cycle Housing Element as Program 10.

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Merced County Association of Governments
Merced County Multi-Jurisdictional Housing Element (2024-2032) B1-6
Program Program Objectives Progress and Continued Appropriateness Program H-3b:

Affordable Housing
Requirements and
First Tier Affordable
Housing Incentives
The objective of this program is to
establish affordable housing
requirements and incentives to be
applied citywide. Assuming 1,500 total
units constructed under this program,
the program would result in 30 low
income units and 30 moderate income
units.

This program was not implemented due to
insufficient funds.

Effectiveness: Not implemented
Continued Appropriateness: Program H-3b will be
discontinued in the 6th Cycle Housing Element.

Program H-3c:

Density Bonus
Program
The objective of this program is to
incentivize development of affordable
housing by providing density bonuses to
developers meeting certain criteria for
housing projects, consistent with state
law.

The City has not yet implemented the program. Due
to limited staffing City has not adopted a density
bonus program and is not in compliance with state
density bonus law.

Effectiveness: Not yet implemented due to staffing
constraints
Continued Appropriateness: Program H-3c is
incomplete and will be refined and incorporated
into 6
th Cycle Housing Element as Program 7.

Program H-3d:

Pursue State and
Federal Funding for
Affordable Housing
The objective of this program is to
accommodate housing for 3 extremely
low, 7 very low; and 10 low income
units.

The City has applied to the following grants to fund
affordable housing:
▪ HOME grant
▪ First-Time Homebuyer Grant
▪ PLHA Grant
Effectiveness: Successfully implemented
Continued Appropriateness: Program H-3d is in
progress and the City will continue to apply for
funding to support housing opportunities for
extremely low-, very low-, and low-income
households during the 6th cycle.

Program H-3e:

Rental Assistance
The objective of this program is for
the City to assure that lower income
households find rental housing
assistance.

Due to limited staffing and resources, the City has
not yet implemented the program.

Effectiveness: Not yet implemented due to staffing
constraints
Continued Appropriateness: Program H-3e is
incomplete and will be refined and incorporated
into 6
th Cycle Housing Element as Program 10.

Program H-3f:

Collaborate with
Nearby Jurisdictions
and Housing
Assistance Groups
The City will participate in one special
housing and homeless needs
workshop on an annual basis.

The City has held the first meeting. The City is
currently collaborating with nearby jurisdictions on
housing needs for the 6th Cycle Housing Element.

Effectiveness: Partially implemented
Continued Appropriateness: Program H-3f will be
refined and incorporated into 6th Cycle Housing
Element as Program 1.

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City of Atwater
Review of Past Accomplishments
2024-2032 Housing Element B1-7
Program Program Objectives Progress and Continued Appropriateness Program H-3g: SelfHelp HousingThe objective of this program is to establish development of 40
additional ownership housing units: 5
extremely low, 10 very low‐income
and 25 low‐income.

The City has begun discussion with Habitat for
Humanity.

Effectiveness: Partially implemented
Continued Appropriateness: Program H-3g is
incomplete and will be refined and incorporated
into 6th Cycle Housing Element as Program 7 to
incentivize affordable housing development.

Program H-3h:

Water and Sewer
Service Priority
The objective of this program is to
establish policy prioritizing water and
sewer provision to lower income
housing developments.

The City has not yet implemented the program.

Effectiveness: Not yet implemented due to staffing
constraints
Continued Appropriateness: Program H-3h is
incomplete and will be refined and incorporated
into the 6th Cycle Housing Element as Program 11.

Program H-3i:

Mobile Home Park
Development
Incentives
The objective of this program is to
facilitate development of vacant land
zoned for mobile home park use and
maximize utilization of the land.

The City has not yet implemented this program due
to staffing constraints.

Effectiveness: Partially implemented
Continued Appropriateness: Program H-3h is
incomplete and will be refined and incorporated
into the 6th Cycle Housing Element as Program 6.

Goal H-4 – Maintain, conserve, and rehabilitate existing housing stock.

Program H-4a: Adopt
Updated Building
Codes
The objective of this program is to
ensure that newly constructed
housing is as safe and well-built as
possible.

The City’s building codes are in compliance with
state building codes and are updated every three
years.

Effectiveness: Successfully implemented
Continued Appropriateness: Program H-4a is
complete and will not be carried into the 6th Cycle
Housing Element.

Program H-4b:

Conduct Housing
Condition Survey
The objective of this program is to
establish baseline and maintain
updated information on housing
conditions to better target
rehabilitation efforts.

Implementation of this program will be
accomplished during the General Plan Update,
which has begun.

Effectiveness: Not yet implemented
Continued Appropriateness: Program H-4b is
incomplete and will not be carried forward in the
6th Cycle Housing Element as Program 9.

Program H-4c:

Housing
Rehabilitation Loan
Program
The objective of this program is to
pursue CDBG funds on an annual
basis to support the Housing
Rehabilitation Loan Program and
rehabilitate approximately 3 low and
2 very low income homes per year.

The City did not receive CDBG funds during the 5th
Cycle. However, as of 2026, the City has received
both CDBG and HOME funds for owner-occupied
rehabilitation programs.

Effectiveness: Partially implemented
Continued Appropriateness: Program H-4c is
incomplete and will be refined and incorporated
into the 6th Cycle Housing Element as Program 9.

Program H-4d: Home
Energy Renovation
Opportunity (HERO)
Program
The objective of this program is to
make the HERO Program available to
residents and rehabilitate
approximately 5 homes per year.

The City has not yet implemented the program due
to a lack of resources.

Effectiveness: Not yet implemented due to resource
constraints
Continued Appropriateness: Program H-4d is
incomplete and will be incorporated into the 6th
Cycle Housing Element as Program 9.

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Merced County Association of Governments
Merced County Multi-Jurisdictional Housing Element (2024-2032) B1-8
Program Program Objectives Progress and Continued Appropriateness Program H-4e:

Manufactured Home
Preservation
The objective of this program is to
preserve the condition and
affordability of larger mobile home
parks containing approximately 400
spaces; provide relocation assistance
to residents of parks that are not
feasible to preserve.

The present conditions have been deemed
acceptable.

Effectiveness: Successfully implemented
Continued Appropriateness: Program H-4e is
complete and will not be incorporated into the 6th
Cycle Housing Element.

Program H-4f:

Improve the
Condition of Rental
Housing
The City’s objective in requiring long‐
term affordability is to ensure that
substantially rehabilitated or
reconstructed housing units increase
the stock of affordable rental housing.

The City will also ensure that the
property owner provides relocation
assistance to current tenants and
allows these tenants a right of first
refusal to re-occupy their former
rental units, or another equivalent
unit, after the rehabilitation or
reconstruction has been completed.

Rehabilitate 25 very low and 25 lowincome rental housing units.

The City has not yet implemented the program due
to a lack of staff resources to audit rental properties and the ability to compete for available funding.

Effectiveness: Not yet implemented due to resource
constraints
Continued Appropriateness: Program H-4f is
incomplete and will not be carried forward in the
6th Cycle Housing Element
Program H-4g:

Address Unsafe
Building Conditions
The objective of this program is to
improve substandard residential
buildings condition and rehabilitate or
upgrade two units per year.

While the City has an active Code Enforcement
program, the City has not yet implemented a
program to improve substandard residential
buildings due to a lack of staff resources.

Effectiveness: Not yet implemented due to staff
constraints
Continued Appropriateness: Program H-4g is
ongoing and will be incorporated into the 6th Cycle
Housing Element as Program 9.

Goal H-5 – Accommodate housing for special needs groups.

Program H-5a:

Promote Senior
Housing
The objective of this program is to
identify funding sources for the
development of senior housing, and
facilitate senior housing development
through the density bonus program,
streamlined permit processing,
identification of suitable development
sites, and through other development
incentives such as reduced parking
requirements.

This program had limited community interest and
lack of resources.

Effectiveness: Not implemented due to
resource constraints and community
interest Continued Appropriateness: Program H-5
is incomplete and will not be carried forward.

Program 10 is included in the 6th Cycle Housing
Element to incentivize senior housing.

Program H-5b:

Accommodate
Housing for Persons
with Disabilities
The objective of this program is to
improve housing accessibility for
persons with disabilities by providing
exceptions to building and zoning
standards when those exceptions will
facilitate accessibility.

The City currently does not have any City-owned
residential single family or multifamily homes. All
tenant improvements and new construction
projects are required to meet ADA requirements.

Effectiveness: Not implemented
Continued Appropriateness: Program H-5b will not
be carried forward. Program 10 Lower-Income and
Special Needs Housing will address housing needs
for persons with disabilities in 6th Cycle Housing
Element

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City of Atwater
Review of Past Accomplishments
2024-2032 Housing Element B1-9
Program Program Objectives Progress and Continued Appropriateness Program H-5c:

Remove Constraints
to Persons with
Disabilities
The objective of this program is to
revise development standards and
community care provisions of the
Zoning Ordinance to better
accommodate persons with
disabilities and put procedures in
place to allow accommodation of
persons more easily with disabilities.

The City has adopted and enforces the 2025
California Building Code and its requirements for
accessible living properties. However, the City has
not adopted written procedures or guidelines for
reasonable accommodation requests in the Zoning
Ordinance due to limited staffing. In 2023, the City
adopted the ADA Transition Plan to improve
accessibility standards in the City.

Effectiveness: Partially implemented
Continued Appropriateness: Program H-5c is
partially complete and will be refined and carried
over into the 6th Cycle Housing Element as Program

6. Under Program 6, the City will revise the Zoning
Code to establish reasonable accommodation
procedures for persons with disabilities, consistent
with fair housing law
Program H-5d:

Zoning for
Farmworker Housing
The objective of this program is to
remove zoning constraints that would
preclude provision of farmworker
housing at appropriate locations
within the City.

No such provisions currently exist and therefore the
program has not yet been implemented.

Effectiveness: Not yet implemented
Continued Appropriateness: Program H-5d is
incomplete and will not be carried forward.

Program 10 will incentivize farmworker housing in
the 6th Cycle Housing Element.

Program H-5e:

Promote the
Development of
Smaller and Larger
Rental Units
The objective of this program is to
promote the development of a more
diverse rental market within the City
by encouraging a variety of unit sizes.

In 2019, the City approved mixed-use buildings in
the C-G zone (Resolution No PC 0124-19).

Effectiveness: Successfully implemented
Continued Appropriateness: Program H-5e is
ongoing but will not be carried into the 6th Cycle
Housing Element.

Program H-5f: Zoning
for Supportive
Housing and
Transitional Housing
The objective of this program is to
remove zoning constraints that would
preclude provision of supportive and
transitional housing at locations within
the City’s residential districts.

In 2019, the City adopted amendments to its Zoning
Code to allow supportive and transitional housing in
compliance with SB 2 (Resolution No. PC 106-19).

Effectiveness: Successfully implemented
Continued Appropriateness: Program H-5f is
complete and will not be carried over into the 6th
Cycle Housing Element.

Program H-5g:

Zoning for
Emergency Shelters
The objective of this program is to
remove zoning constraints that would
preclude provision of homeless shelters
within the R‐T district.

The City has adopted amendments to its Zoning
Code in compliance with SB 2. As a correction, SB 2
compliance was targeted for the M-1 and M-2
zones.

Effectiveness: Successfully implemented
Continued Appropriateness: Program H-5g is
complete and will not be carried over into the 6th
Cycle Housing Element.

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Merced County Association of Governments
Merced County Multi-Jurisdictional Housing Element (2024-2032) B1-10
Program Program Objectives Progress and Continued Appropriateness Program H-5h:

Facilitate Shelters,
Supportive Housing,
and Transitional
Housing
The objective of this program is to
identify a site and funding for an
emergency shelter or transitional
housing facility to meet local needs.

The City has adopted an ordinance for the M-1 and
M-2 zones to allow emergency shelters in
accordance with SB-2.

Effectiveness: Successfully implemented
Continued Appropriateness: Program H-5h is
complete and will not be carried over into the 6th
Cycle Housing Element. .

Program H-5i: Zoning
for Community Care
Facilities
The objective of this program is to
remove zoning constraints that would
preclude provision of community care
facilities at appropriate locations within
the City.

The program has not yet been implemented.

Effectiveness: Not yet implemented
Continued Appropriateness: Program H-5i is
incomplete. This program will be refined and
incorporated as part of Program 6 to address
community care facilities, consistent with state law.

Program H-5j: Zoning
for Single Room
Occupancy
The objective of this program is to
provide affordable housing options by
removing zoning constraints that would
preclude provision of single resident
occupancy units at appropriate
locations within the City.

No such provisions currently exist and therefore the
program has not yet been implemented.

Effectiveness: Not yet implemented
Continued Appropriateness: Program H-5j is
incomplete and will be refined and incorporated
into 6th Cycle Housing Element as Program 7 which
directs the City to permit single-occupancy units in
zones allowing hotel and motel uses.

Goal H-6 – Minimize the impact of governmental constraints on housing construction.

Program H-6a:

Zoning ordinance
amendments
The objective of this program is to
remove zoning constraints that would
preclude provision of manufactured
housing, mobile home parks, and
secondary housing units at
appropriate locations within the City.

This program was completed, but recent changes in
state law require further modifications to the City’s
zoning ordinance to facilitate manufactured housing
and accessory dwelling units.

Effectiveness: Partially implemented
Continued Appropriateness: Program H-6a will be
updated and incorporated into 6th Cycle Housing
Element as Program 8.

Program H-6b:

Amendments to
Planned
Development District
The objective of this program is to
increase the use of the City’s planned
development option as a tool to
provide affordable housing.

The City will begin analysis of revising the P-D
definitions in Chapter 17.

Effectiveness: Not yet implemented
Continued Appropriateness: Program H-6bis
incomplete and will not be carried into the 6th Cycle
Housing Element.

Goal H-7 – Promote energy efficiency in housing development.

Program H-7a:

Energy Conservation
Regulation for New
Construction
The objective of this program is to
reduce residential energy
consumption and reduce energy
costs, especially for low-income
residents.

The City will continue to adopt and enforce state
energy efficiency requirements for new residential
construction.

Effectiveness: Successfully implemented
Continued Appropriateness: Program H-7a is
ongoing and will be revised and incorporated into
the 6th Cycle Housing Element as Program 9.

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City of Atwater
Review of Past Accomplishments
2024-2032 Housing Element B1-11
Program Program Objectives Progress and Continued Appropriateness Program H-7b:

Energy code
awareness
promotion
The objective of this program is to
reduce residential energy
consumption and reduce energy
costs, especially for low-income
residents.

The City will continue to update its website and
Building division information materials. The City will
also work with alternative electrical energy
providers.

Effectiveness: Successfully implemented
Continued Appropriateness: Program H-7b is
ongoing and will be incorporated into the 6th Cycle
Housing Element as Program 13.

Program H-7c:

Weatherization and
energy conservation
for existing dwelling
units
The objective of this program is to
reduce residential energy
consumption and reduce energy
costs, especially for low-income
residents.

The City will continue to post and distribute
information on current available weatherization and
energy conservation programs.

Effectiveness: Successfully implemented
Continued Appropriateness: Program H-7c is
ongoing and will be incorporated into the 6th Cycle
Housing Element as Program 9.

Program H-7d:

Promotion of energy
efficient land use
planning
The objective of this program is to
reduce costs associated with
transportation, especially for lowincome residents, and make less costly transportation alternatives
available and feasible.

This program has not been implemented other than
to promote and encourage projects that are
pedestrian friendly to areas of convenience.

Effectiveness: Partially implemented
Continued Appropriateness: Program H-7d is
incomplete and will be revised and incorporated
into the 6th Cycle Housing Element as Program 1.

Program H-7e:

Promotion of water
conservation
The objective of this program is to
reduce costs associated with water
use, especially for low-income
residents.

The City has installed water meters throughout the
City to help prevent water waste by residents and
prevent overwatering.

Continued Appropriateness: Program H-7e will be
refined and incorporated into 6th Cycle Housing
Element as Program 9.

Goal H-8 – Ensure fair and equal housing opportunities for all.

Program H-8.1: Fair
Housing Services
The objective of this program is to
promote fair housing in Atwater and
reduce incidences of discrimination.

The City continues to ensure fair and equal housing
opportunities for all.

Effectiveness: Not yet implemented due to resource
constraints
Continued Appropriateness: Program H-8.1 is
ongoing and will be refined and incorporated into
the 6th Cycle Housing Element as Program 13.

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Merced County Association of Governments
Merced County Multi-Jurisdictional Housing Element (2024-2032) B1-12
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City of Atwater
Public Participation
2024-2032 Housing Element B2-1
B2 Public Participation
This section documents the efforts the City of Atwater made to engage the public and gather input to inform development of this Housing Element update. The Housing Element must reflect the values and preferences of the community. Government Code Section 65583(c)(8) states that the local government must make “a diligent effort to achieve public participation of all economic segments of the community in the development of the housing element.” This process not only includes community members, but also participation from local stakeholder groups. Accordingly, there were various public engagement efforts conducted at a regional level, including a community survey and stakeholder interviews, in the development of the regional Housing Element. These efforts are described in Chapter 1, Introduction and Regional Collaboration. Feedback from the City of Atwater’s outreach events helped shape the priorities and objectives of the Housing Element Update and are summarized in this Appendix as follows.

B2.1 Pop-up Events
City staff set up a tabling event at the Atwater Town Hall at the Atwater Community Center on May 30, 2023. Additionally, City staff handed out flyers with links to project website and survey to increase community awareness of the Housing Element process and encourage participation.

B2.2 Community Workshops
Flyers advertising the workshops were posted on City of Atwater’s website in advance of the workshop series to encourage public attendance and participation. The flyers provided meeting details (dates, times, locations, zoom links), the Housing Element Update website and email list, and were bilingual (English and Spanish).

A workshop on the Housing Element was hosted in Atwater on August 28, 2023. The workshop consisted of an informative PowerPoint presentation on housing sites, a questionnaire about the proposed sites, and a Q&A and public discussion period. The workshop activities invited participants to share their opinions on what makes their neighborhood great and their experience finding housing, take part in a sticker activity to rank the most effective housing programs, and reasons it is difficult to find housing in their communities. Participants were also asked to weigh in on the selected housing opportunity sites. The PowerPoint presentation was available in Spanish via written translation. Live Spanish translation was available upon request.

Atwater’s participants voiced their concerns regarding housing affordability and lack of housing due to strict development regulations. Participants hope to see greater development near places of work and essential resources.

Key findings from the workshops are as follows:
▪ Off-site improvement requirements make housing development expensive. ▪ High prices, lack of affordable housing, and cost of building housing make it difficult to find housing.
▪ Residents would like housing in proximity to schools, job opportunities, and parks. ▪ Residents’ ability to maintain their home helps improve a neighborhood.

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Merced County Association of Governments
Merced County Multi-Jurisdictional Housing Element (2024-2032) B2-2
▪ Rent-restricted affordable housing development, a variety of new housing, and fair housing services were the most voted programs for effectively addressing needs in Atwater with 3 votes each. This was followed by the development of rental housing for large households, housing for special needs housing development, and housing rehabilitation and repair with 2 votes each.

Renter protection and support and homelessness prevention and housing each received one vote.

B2.3 Survey
The City conducted a community survey to inform the 6
th Cycle Housing Element update. The survey
was advertised and made available online from March 27, 2023, through December 22, 2023. The survey was also made available during various community outreach events, including the Town Hall Pop-Up event on May 30, 2023, and the community workshop on August 28, 2023, in an effort to engage various groups and populations of the community. The survey consisted of 16 questions and used different formats for questions: checkbox, ranking, and open-ended questions. A total of 172 people responded to the survey. Of the responses, 18 participants, or roughly 10 percent of responders, either live, work, attend school, or own a business or property in Atwater.

The input provided by the participants included the following major themes:
▪ Affordability was the most important aspect when looking for new housing, followed by close to resources such as commercial, medical facilities, and work and school. Safe neighborhoods were also noted as important when searching for housing. Participants want housing near public transit stops, employment, and shopping centers.
▪ The largest barriers to affordable desirable housing are cost of housing and the limited supply of housing, particularly affordable housing. Respondents also noted the lack of good paying jobs to be able to afford housing.
▪ In addition to affordability and availability of housing, respondents noted that homelessness and housing quality were also urgent issues in the Merced Region. ▪ Respondents would like to see programs related to housing vouchers, landlord/tenant mediation services and home rehabilitation assistance.
▪ Housing with three or more bedrooms, housing with one or two bedrooms, and efficiency homes are the most needed housing in the region.
▪ In Atwater, participants suggested areas for housing development on Main Street and on vacant lots throughout the city.

Full survey results can be found in Appendix 1 to the Regional Housing Element, Community Survey Results.

B2.4 Stakeholder Interviews
The City also participated in a series of stakeholder interviews with service providers, residents, and housing developers held between August 8, 2023, and August 23, 2023, as part of the greater regional public participation efforts. Housing groups and service providers that service the needs of Atwater residents included Project Sentinel, Faith in the Valley, United Way of Merced County, and Merced County Workforce Investment. Much of the discussion was focused on countywide needs and issues, including low-income residents, seniors, persons with disabilities, and renters. A

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City of Atwater
Public Participation
2024-2032 Housing Element B2-3
complete summary of the stakeholder interviews can be found in Chapter 1, Introduction, to the Regional Housing Element. Key findings included:
▪ Service providers stated there is a need for affordable housing throughout the county with access to resources.
▪ Residents expressed that rental units need maintenance and repair. ▪ Additional housing services are needed throughout communities in the county include transitional housing, rental assistance, first-time homebuyer assistance, and education on tenants’ rights.
▪ Residents expressed concern over the high cost of housing, particularly for renters. ▪ Residents identified a need for more community engagement efforts that allow residents to participate in a meaningful way, including workshops and translation services during outreach events.

B2.5 Additional Outreach
The City held a virtual stakeholder interview on December 18, 2024, jointly with the cities of Dos Palos, Gustine, Livingston, and Los Banos.

The meeting consisted of a discussion on housing needs and fair housing issues, with specific emphasis on low-income and special needs households, to support the fair housing analysis and refine policies and programs within the Housing Plan. The questions asked to participants included:
▪ What are specific housing needs for lower-income and special needs households within the community?
▪ Are there special needs groups/populations within the jurisdiction that are lacking affordable housing/support services?
▪ What barriers do residents in low-income neighborhoods face when trying to access affordable housing?
▪ What services are most requested by renters? Homeowners? ▪ What additional supportive services (e.g., job training, mental health support, childcare) are most needed in the jurisdiction to help residents maintain stable housing and improve their quality of life?
The City invited 15 participants from various fair housing services, agencies, and developers. Four participants attended, consisting of a property owner, pro-housing advocate from Visionary Home Builders, a representative from a nonprofit affordable housing company, and a representative from the Merced County Continuum of Care.

Participants stated that there are not enough resources to support developers and property owners to construct affordable housing in Atwater, despite help from the City and various funding sources.

To this point, similar issues of lack of rental subsidies or project vouchers to competitively apply for funding opportunities, such as Project HomeKey, are constraints to affordable housing development in the City.

The representative from the Continuum of Care noted that there are 47 persons experiencing homelessness in the city, which require more behavioral health and substance abuse resources than currently available. The aging population in Atwater (persons over the age of 60) has a projected growth of 11 percent during the 6
th Housing Element cycle. This population relies of fixed income,

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Merced County Association of Governments
Merced County Multi-Jurisdictional Housing Element (2024-2032) B2-4
and needs further rental assistance and connections to City or County mental health services.

Childcare assistance was deemed to be another important request from the community during a regional homelessness summit.

B2.6 Response to Community Input
During community outreach, community members identified the following overarching themes regarding housing in Atwater. Below is a summary of how each theme is addressed in the Housing Element.

Need more affordable housing for both renters and buyers.

The City will accommodate at least 2,073 units affordable to very low-, low-, and moderate-income households. The City will accommodate these units on sites that are currently vacant or underutilized, including 29 sites that will be rezoned to allow higher residential densities.

At least 39 percent of units assumed to be affordable to moderate- and above moderatehouseholds will be on sites that support multi-family housing, encouraging the development of townhomes and condominiums for more affordable homeownership opportunities.

Housing Program 5 includes actions to encourage the development of at least 10 accessory dwelling units (ADUs) during the planning period by creating standard plans and streamlining the permit process. ADUs often provide relatively affordable rental options.

Through Housing Program 7, the City will expand opportunities for multi-family housing development by contacting non-profit and private developers to facilitate the production of affordable housing as well as pursue funding opportunities available at the local, regional, state and federal levels. Multi-family development provides affordable housing options to add into the City’s housing stock.

The City has 35 housing units that are deed-restricted as affordable housing for lower-income households. Although these are not at immediate risk of conversion to market-rate units, under Program 8, the City will work to preserve these units as affordable housing and will proactively monitor all other units to encourage continued affordability beyond existing covenants and work proactively with owners of affordable units to assist in rehabilitation needs.

Support for transit-oriented development and increasing density in areas with existing services.

Housing opportunity sites were prioritized by location, including proximity to transit, job centers, and community services. Site selection focused heavily on infill development of vacant and nonvacant sites along strategic corridors and in neighborhoods with existing services.

Housing Program 1 directs the City to collaborate with other jurisdictions on housing efforts, including funding opportunities, best practices, and other efforts to address housing, transit, economic development, and homeless issues in Merced County. This Program includes participation in the Merced County Association of Governments (MCAG) to manage and implement regional transit services, including an annual community workshop to identify transportation needs for Atwater residents.

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City of Atwater
Public Participation
2024-2032 Housing Element B2-5
Housing Program 12 directs the City to create a well-maintained city infrastructure to provide a safe and accessible urban environment. The City will collaborate with Merced County Transit (the Bus) to determine locations of bus stops to serve new developments in annexed neighborhoods. The city will also partner with local employment organizations to connect Atwater residents with job opportunities such as collaborating with the Bus to provide free bus passes to residents attending job fairs and interviews.

Need for rental assistance for low-income families and rent-restricted housing.

Housing Program 10 directs the City to assist in the development of housing to meet the needs of extremely low, very low- and low-income households and special needs households. The City will continue to work with Housing Authority of the County of Merced to provide housing choice vouchers, public housing, project-based vouchers, and migrant housing centers. The City was allocated Permanent Local Housing Allocation funds and will promote the availability of these funds on the City’s website with the goal of assisting eight households through this program.

Need to increase the variety of available rental and for sale housing types, including apartments and townhomes, and more options for three-bedroom units.

In order to facilitate a variety of housing types, especially housing for lower-income households and those with special needs, the City will remove constraints to housing development by amending the Zoning Code through Housing Program 6.

Through Housing Program 7, the City will expand opportunities for multi-family housing development by contacting non-profit and private developers to facilitate the production of affordable housing and pursuing funding opportunities at the local, regional, state and federal levels. Multi-family housing will increase the variety of available rental and for-sale housing types.

Need for housing rehabilitation services homeowners with aging housing stock and those with flood damage.

Housing Program 9 directs the City to utilize various programs and community partnerships to encourage the rehabilitation of housing units, as well as maintaining the supply of affordable housing. The City will work with non-profits in their community to assist with rehabilitation, annually research funding opportunities, with a goal to assist with five rehabilitation projects over eight years.

Need increased education on housing rights and legal resources for tenants and landlords.

Under Housing Program 13 the City works with the Merced County Housing Authority to provide fair housing information and resources to residents and housing providers. Educational flyers and factsheets will be distributed and shared on the City’s website, and annual staff trainings will start in 2026 on how to refer residents for fair housing complaints.

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Merced County Association of Governments
Merced County Multi-Jurisdictional Housing Element (2024-2032) B2-6
B2.7 Public Review
B2.7.1 May 2024 Public Review
The Draft Multi-Jurisdictional Housing Element was available for public review for the required 30 days, from May 13 to June 12, 2024. The City notified interested parties via email and the complete document was posted on the project website (https://mercedmjhe.com/) and it was printed and put out for review at the City’s Community Services Event on May 29, 2024. The City received one comment letter during the Public Review Period, summarized in Table B2-1, below.

B2.7.2 September 2024 Public Review
Following the formal submittal to HCD on July 1, 2024, the City received preliminary comments from HCD on the Draft Housing Element. The City revised the Draft Housing Element based on HCD’s preliminary comments and posted the revised Draft Housing Element from September 17 through September 24 on the project website, City’s website, and notified interested parties via email. The City received no comments.

B2.7.3 February 2025 Public Review
The City Revised the Draft Housing Element to address HCD’s formal comment letter. The 2 nd
Revised Draft Housing Element was available for public review from February 24, 2025 to March 3, 2025. The City notified interested parties via email and the complete document was posted on the project website (https://mercedmjhe.com/). The draft Housing Element was also published on the City’s website. The City received one comment letter during the Public Review Period, summarized in Table B2-1, below.

B2.7.4 Public Review Comment Matrix
A comment matrix with comments received and City responses is provided in Table B2-1 below.

Table B2-1 Summary of Comments and Responses
Comment Theme Comment Response
Affordability Comment regarding scarcity of affordable
housing at all income levels
This comment is acknowledged and programs
are intended to increase affordability
Resources Comment regarding resident education and
access of resources
This comment is acknowledged and programs
are intended to help residents find housing
resources
B2.7.5 March/April 2026 Public Review
The City Revised the Draft Housing Element to address HCD’s formal comment letter. The 3 rd
Revised Draft Housing Element was available for public review from March 31, 2026 to April 7, 2026.

The City notified interested parties via email and the complete document was posted on the project website (https://mercedmjhe.com/). The draft Housing Element was also published on the City’s website. The City did not receive any comments.

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City of Atwater
Public Participation
2024-2032 Housing Element B2-7
B2.7.6 June 2026 Public Review
The City revised the Draft Housing Element to address HCD’s preliminary comment letter. The Revised Draft Housing Element was available for public review from June 1, 2026 to June 7, 2026.

B2.7.7 July 2026 Public Review
The City revised the Draft Housing Element to amend the Site Inventory. The Revised Draft Housing Element was available for public review from July 10, 2026 to July 17, 2026. The City notified interested parties via email and the complete document was posted on the project website (https://mercedmjhe.com/). The draft Housing Element was also published on the City’s website.

The City did not receive any comments.

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City of Atwater
Housing Needs Assessment
2024-2032 Housing Element B3-1
B3 Housing Needs Assessment
This chapter provides an individual assessment of housing needs for the City of Atwater. This section summarizes demographic, employment, and housing characteristics. The main source of the information is the pre-approved data package for jurisdictions approved by the California Department of Housing and Community Development (HCD). This data is primarily sourced from the United States (U.S.) Census, the U.S. Department of Housing and Urban Development’s Comprehensive Housing Affordability Strategy (CHAS), and American Community Survey (ACS) 2017- 2021 five-year estimates. Tables and figures also include comparable data for Merced County and California where it is found most useful.

B3.1 Population Characteristics
Population characteristics, such as growth rate, age, and income levels, affect the type and amount of housing needed in a community. Residents’ age and income, employment trends, and other factors influence the type of housing needed and the community’s ability to afford housing. The following section analyzes the city of Atwater’s population characteristics and trends.

B3.2 Population Growth
Table B3-1 analyzes population change from 2000 to 2021. Atwater grew by 21.9 percent from 2000 to 2010, and 11.5 percent from 2010 to 2021. This was higher than both countywide and statewide population growth during both time periods.

Table B3-1 Population Change (2000 - 2021)
Jurisdiction 2000 2010 2021
Percent
Change
Percent
Change
2000-2010 2010-2021
Atwater 23,113 28,168 31,401 21.9% 11.5%
Merced County 210,554 255,793 279,150 21.5% 9.1%
California 33,971,648 37,253,956 39,455,353 9.7% 5.6%
Source: U.S. Census Bureau, Census 2000, 2010; Social Explorer tables for Census 2021.

B3.3 Age Characteristics
Table B3-2 shows population by age group and each group’s percentage of the total population. The age groups include preschool (under five years), school-age students (five to 17 years), college-age students (18 to 24 years), young adults (25 to 44), middle-aged adults (45 to 64), and seniors (65 and over). In Atwater, the largest age group is the young adult category, representing 27.5 percent of the total population, similar to the county (27.0 percent) and state (28.6 percent). The second largest group in Atwater is middle-aged adults at 22.8 percent. The smallest population by age are preschoolers at 6.0 percent, which is generally consistent with the county (7.5 percent) and slightly higher than the state (6.0 percent).

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Merced County Association of Governments
Merced County Multi-Jurisdictional Housing Element (2024-2032) B3-2
Table B3-2 Population by Age Group (2021)
Jurisdiction
Under 5
years
(Preschool)
5 to 17
years
(School-age
Students)
18 to 24
years
(College-age
Students)
25 to 44
(Young
Adults)
45 to 64
(Middleaged Adults)
65 years
and over
(Seniors)
Total
Population
Atwater 1,898 6,983 2,838 8,626 7,157 3,899 31,401
Percent 6.0% 22.2% 9.0% 27.5% 22.8% 12.4% -
Merced
County
20,969 61,609 31,111 75,342 59,131 30,988 279,150
Percent 7.5% 22.1% 11.1% 27.0% 21.2% 11.1% -
California 2,350,335 6,642,097 3,665,851 11,282,671 9,844,520 5,669,879 39,455,353 Percent 6.0% 16.8% 9.3% 28.6% 25.0% 14.4% -
Source: U.S. Census Bureau, ACS 2017-2021 (5-year Estimates), Table B01001.

B3.4 Race and Ethnicity
Table B3-3 shows race and ethnicity data for residents in Atwater, Merced County, and California. In Atwater, the majority of the population identifies as white at 51 percent, higher than the county (46.2 percent) and similar to the state (52.1 percent). The second largest population group is Some Other Race representing 30.2 percent of the total population in Atwater. This is similar to Merced County (33.7 percent), but much higher than the state (15.3 percent). In Atwater, 55.3 percent of the population identifies as Hispanic or Latino (of any race), which is lower than the county (61.2 percent) and higher than the state (39.5 percent).

Table B3-3 Population by Race
Jurisdiction
White
Alone
Black or
African
American
Alone
American
Indian and
Alaska
Native
Alone
Asian
Alone
Native
Hawaiian
and Other
Pacific
Islander
Alone
Some
Other Race
Alone1
Two or
More
Races2
Hispanic or
Latino, Any
Race Total
Atwater 16,026 1,252 250 1,611 257 9,475 2,530 17,360 31,401 Percent 51.0% 4.0% 0.8% 5.1% 0.8% 30.2% 8.1% 55.3% -
Merced
County
128,897 8,057 3,267 20,945 797 93,978 23,209 170,730 279,150 Percent 46.2% 2.9% 1.2% 7.5% 0.3% 33.7% 8.3% 61.2% -
California 20,553,732 2,233,258 360,607 5,887,396 148,278 6,036,865 4,235,217 15,593,787 39,455,353 Percent 52.1% 5.7% 0.9% 14.9% 0.4% 15.3% 10.7% 39.5% -
(1) Note: “Some other race alone” includes all other responses not included in the "white alone", "Black or African American alone", "American Indian and Alaska Native alone”, “Asian alone” and “Native Hawaiian and Other Pacific Islander alone” race categories (2) Note: “Two or more races” includes responses from all individuals who identify themselves as two or more of the aforementioned race groups. If an individual responded with both “two or more races” and “some other race,” their response was only included under “two or more races.”
Source: U.S. Census Bureau, ACS 2017-2021 (5-year Estimates), Table B02001; U.S. Census Bureau, ACS 2017-2021 (5-year Estimates), Table B03001.

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City of Atwater
Housing Needs Assessment
2024-2032 Housing Element B3-3
B3.5 Economic Characteristics
Employment
Understanding employment and occupation patterns can provide insight into present housing needs. Table B3-4 shows employment by industry. Educational Services, Health Care, and Social Assistance is the most common industry in Atwater, representing 25.4 percent of all industries. This is also the most common industry countywide (22 percent) and statewide (21.4 percent). The second largest industry in Atwater is Manufacturing with 11.5 percent, which is similar to the county and state. Of the major employers in Merced County, two are within Atwater. These include Western Marketing and Sales and Walmart Supercenter.1
Table B3-4 Employment by Industry (2021)
Industry Atwater Percent Merced County Percent California Percent Educational Services, and
Health Care and Social
Assistance
3,352 25.4% 23,797 22.0% 3,990,094 21.4%
Manufacturing 1,516 11.5% 11,778 10.9% 1,676,715 9.0%
Retail Trade 1,455 11.0% 11,804 10.9% 1,919,513 10.3%
Agriculture, Forestry, Fishing
and Hunting, And Mining
1,231 9.3% 12,326 11.4% 394,881 2.1%
Construction 1,064 8.1% 8,623 8.0% 1,235,586 6.6%
Transportation And
Warehousing, And Utilities
1,036 7.9% 7,626 7.1% 1,071,181 5.7%
Professional, Scientific, and
Management, and
Administrative, and Waste
Management Services
806 6.1% 7,146 6.6% 2,612,859 14.0%
Arts, Entertainment, and
Recreation, and
Accommodation and Food
Services
698 5.3% 7,682 7.1% 1,835,141 9.8%
Wholesale Trade 549 4.2% 4,036 3.7% 501,378 2.7%
Finance and Insurance, and Real
Estate, and Rental and Leasing
514 3.9% 3,075 2.8% 1,107,961 5.9%
Public Administration 502 3.8% 5,058 4.7% 864,476 4.6%
Other Services, Except Public
Administration
409 3.1% 4,275 4.0% 927,253 5.0%
Information 58 0.4% 968 0.9% 539,683 2.9%
Source: U.S. Census Bureau, ACS 2017-2021 (5-year Estimates), Table C24050.

According to the California Bureau of Labor Statistics, the unemployment rate in Atwater as of September 2024 is 7.7 percent, which is lower than the long-term average of 8.25 percent over the previous two years. Since 2020, Bureau of Labor Statistics Data indicates that unemployment rates 1 https://labormarketinfo.edd.ca.gov/majorer/countymajorer.asp?CountyCode=000047

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Merced County Association of Governments
Merced County Multi-Jurisdictional Housing Element (2024-2032) B3-4
have decreased significantly in Atwater and California. Atwater’s unemployment rate is lower than Merced County as a whole (9.1 percent) but is higher than the statewide average (5.3 percent).

Table B3-5 shows the major employers in Merced County, with the number of employees and type of industry. The majority of large employers are located in the City Merced, which is the county’s largest city and the County seat. The largest employers in Atwater include Walmart Supercenter (250-499 employees) and Western Marketing Sales (500-999 employees). Atwater does not anticipate any significant changes in employment trends and is not aware of any new large-scale employers coming to Atwater during the planning period.

Table B3-5 Major Employers in Merced County (2024)
Employer Name Number of Employees Location Industry
Costco Wholesale 100-249 Merced Wholesale Clubs
County-Merced-Behavioral Hlth 100-249 Merced Clinics
Dignity Health-Mercy Med Ctr 1,000-4,999 Merced Hospitals Foodmaxx 100-249 Merced Grocers-Retail
Foster Farms 1,000-4,999 Livingston Poultry Processing Plants (mfrs) Golden Valley Health Ctr 500-999 Merced Pharmacies
Golden Valley Health Ctr 100-249 Merced Clinics
Hilmar Cheese Co Inc 500-999 Hilmar Cheese Processors (mfrs) J Marchini & Son Inc 500-999 Le Grand Farming Service
Liberty Packing Co 250-499 Los Banos Packing & Crating Service Live Oak Farms 250-499 Le Grand Fruits & Vegetables-Growers & Shippers Livingston Union School District 250-499 Livingston School Districts Malibu Boats Inc 250-499 Merced Boats-Manufacturers
Memorial Hospital Los Banos 100-249 Los Banos Hospitals Mental Health Svc For Merced 250-49 Merced Mental Health Services Merced County Human Svc 500-999 Merced Government Offices-County Quad/Graphics Inc 500-999 Merced Printers (mfrs)
Scholle 100-249 Merced Packaging Materials-Manufacturers Sensient Natural Ingredients 250-499 Livingston Dehydrating Service (mfrs) University of CA Merced 500-999 Merced Schools-Universities & Colleges Academic Walmart 250-499 Merced Department Stores
Walmart Supercenter 250-499 Atwater Department Stores
Weaver Union School District 100-249 Merced School Districts Western Marketing & Sales 500-999 Atwater Farms
Yosemite Wholesale Warehouse 100-249 Merced Warehouses
Source: California Employment Development Department, Major Employers in Merced County. Accessed 2024 https://labormarketinfo.edd.ca.gov/majorer/countymajorer.asp?CountyCode=000047 Table B3-6 shows the employment estimates, average hourly wage and average annual wage for employment industries in the Merced Metropolitan Statistical Area (MSA), as of May 2023. The occupations offering the lowest wages are food preparation and serving related, healthcare support,

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City of Atwater
Housing Needs Assessment
2024-2032 Housing Element B3-5
farming, fishing, and forestry. Occupations offering the highest wages include Management, Legal, and Healthcare Practitioners.

The largest percentage of employed civilians in Atwater are in health care, manufacturing/ production, and retail. While healthcare practitioners’ average higher annual salaries ($107,806) than Merced County’s Area Median Income (AMI), which was $69,106 in 2021, Healthcare Support salaries ($36,900) average approximately 53 percent of the AMI. Additionally, average salaries for Production ($45,760) and Sales and other related occupations ($45,261) fall short of the AMI as well. Compared to the annual income limits shown on Table B3-6, it can be assumed that the majority of healthcare practitioners fall in the Above Moderate-income category, Production and Sales workers fall into the Low-income category, and Healthcare Support workers fall into the Very Low-income category.

Table B3-6 Occupational Employment and Wages by Major Occupational Group, Merced Metropolitan Area (2023)
Major Occupational Group Mean Hourly Wage Mean Annual Wage Total, all occupations $27.45 $57,096
Management $58.77 $113,073
Business and financial operations $37.87 $78,770
Computer and mathematical $43.64 $90,771
Architecture and engineering $43.00 $89,440
Life, physical, and social science $36.22 $75,338
Community and social service $28.81 $59,925
Legal $54.16 $112,653
Educational instruction and library $36.71 $76,357
Arts, design, entertainment, sports, and media $28.59 $59,467 Healthcare practitioners and technical $51.83 $107,806
Healthcare support $17.74 $36,900
Protective service $29.50 $61,360
Food preparation and serving related $17.87 $37,170
Building and grounds cleaning and maintenance $20.78 $43,222 Personal care and service $19.05 $39,624
Sales and related $21.76 $45,261
Office and administrative support $23.71 $49,317
Farming, fishing, and forestry $17.98 $37,398
Construction and extraction $30.48 $63,398
Installation, maintenance, and repair $30.43 $63,294
Production $22.00 $45,760
Transportation and material moving $22.02 $45,802
Source: U.S. Bureau of Labor Statistics. Occupational Employment and Wages in Merced (May 2023) https://www.bls.gov/regions/west/news-release/occupationalemploymentandwages_merced.htm

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Merced County Association of Governments
Merced County Multi-Jurisdictional Housing Element (2024-2032) B3-6
Income Definitions and Income Limits
The state and federal governments classify household income into several categories based upon the relationship to the county area median income (AMI), adjusted for household size. The U.S.

Department of Housing and Urban Development (HUD) estimate of AMI is used to set income limits for eligibility in federal housing programs. The income categories include:
▪ Acutely low-income households, which earn up to 15 percent AMI; ▪ Extremely low-income households, which earn up to 30 percent AMI; ▪ Very low-income households, which earn between 31 and 50 percent AMI; ▪ Low-income households, which earn between 51 and 80 percent AMI; and ▪ Median-income households, which earn 100 percent AMI.

For all income categories, income limits are defined for various household sizes based on a fourperson household as a reference point. Income limits for larger or smaller households are calculated by HUD (see Table B3-7). According to HUD, the AMI for a four-person household in Merced County was $80,300 in 2022.

Table B3-7 HUD Income Limits by Person per Household
Household Size: 1 2 3 4 5 6 7 8
Acutely Low-Income $8,450 $9,650 $10,850 $12,050 $13,000 $14,000 $14,950 $15,900 Extremely Low-Income $16,350 $18,700 $23,030 $27,750 $32,470 $37,190 $41,910 $46,630 Very Low-Income $27,300 $31,200 $35,100 $38,950 $42,100 $45,200 $48,300 $51,450 Low-Income $43,650 $49,850 $56,100 $62,300 $67,300 $72,300 $77,300 $82,250 Median-Income $56,200 $64,250 $72,250 $80,300 $84,730 $93,150 $99,550 $106,000 Moderate-Income $67,450 $77,100 $89,700 $96,350 $104,050 $111,750 $119,450 $127,200 Source: U.S. Department of Housing and Urban Development (HUD), 2022.

The California Department of Housing and Community Development (HCD) uses the income categories shown in Table B3-8 to determine eligibility for state housing programs. HCD’s methodology for calculating AMI is slightly different from HUD’s methodology, and therefore the AMI and income limits vary.

Table B3-8 State of California Income Categories
Income Category Percent of County AMI
Extremely Low 0-30% AMI
Very Low 31%-50% AMI
Low 51%-80% AMI
Moderate 81%-120% AMI
Above Moderate 120% AMI or greater
Source: California, CA Health & Safety Code Section 50093.

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City of Atwater
Housing Needs Assessment
2024-2032 Housing Element B3-7
Figure B3-1 shows median household income in Atwater as reported by the 2017-2021 ACS. This median income is for all households, regardless of household size. The median household income in Atwater was $59,436 in 2021, which was slightly higher than in Merced County ($58,861) and significantly lower than in California ($84,097).

Figure B3-1 Median Household Income
Source: U.S. Census Bureau, ACS 2017-2021 (5-year Estimates), Table B19013.

Table B3-9 compares the median household income by race in 2021. In Atwater, Asian and Native Hawaiian/Other Pacific Islander households had the highest median incomes at $73,381, followed by Some Other Race households at $61,324. This is generally consistent with the county and state numbers, where Asian and Native Hawaiian/Other Pacific Islander households’ income are on the higher end. American Indian and Alaskan Native households had the lowest median income in Atwater, which is generally consistent with the county and state.

Table B3-9 Median Household Income by Race/Ethnicity (dollars) Jurisdiction
White,
alone
Black or
African
American,
alone
American
Indian
and
Alaskan
Native,
alone
Asian,
alone
Native
Hawaiian
and Other
Pacific
Islander,
alone
Some
Other
Race,
alone
Two or
More
Races,
alone
Hispanic
or Latino,
Any Race
Atwater 59,386 46,010 26,823 73,365 73,381 61,324 60,909 58,679 Merced
County
60,918 45,573 50,214 71,829 125,500 55,083 56,355 54,635 California 88,616 58,958 66,904 108,477 87,066 63,975 79,777 67,327 Source: U.S. Census Bureau, ACS 2017-2021 (5-year Estimates), Table B19013.

Overpayment and Housing Cost Burdens
Table B3-10 lists the number of households overpaying for housing by tenure. Generally, renters are more affected by overpayment than owners. As shown, overpaying renter-occupied households account for 21.6 percent of households in Atwater, which is consistent with the county and state.

Overpaying renter occupied households comprise 11.3 percent of households in the city, which is comparable to the county (11.8 percent) but less than in California (14.4 percent). $59,436 $58,861
$84,097
$-
$20,000
$40,000
$60,000
$80,000
$100,000
Atwater Merced County California
Median Household Income

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Merced County Association of Governments
Merced County Multi-Jurisdictional Housing Element (2024-2032) B3-8
Table B3-10 Cost Burdened Households by Tenure
Jurisdiction Owner-Occupied Overpaying Renter-Occupied Overpaying Total Overpaying Atwater 1,162 2,231 3,393
Percent 11.3% 21.6% 32.9%
Merced County 9,611 17,470 27,081
Percent 11.8% 21.4% 33.2%
California 1,904,162 3,030,934 4,935,096
Percent 14.4% 22.9% 37.3%
Source: U.S. Census Bureau, ACS 2006-2010, 2011-15, 2017-2021 (5-year Estimates), Table B25091 and B25070 CHAS data provided by HUD provides information on cost burden based on the HUD Area Median Family Income (HAMFI). This data is included in Table B3-11 below. While the totals do not align exactly with 2021 ACS data presented above, the CHAS data identifies the level at which cost burdened households are overpaying for housing. As shown, 19.4 percent of cost burdened households are paying between 30 percent and 50 percent of their income on housing costs.

Further, 14.3 percent of households are spending more than 50 percent of their income on housing.

Based on CHAS data, Atwater has slightly higher rates of moderate and severe cost burden than Merced County, but a lower rate of moderate and severe cost burden than the state.

Table B3-11 Overpayment by Tenure (dollars)
Jurisdiction Moderate Cost Burden >30% to <=50% Severe Cost Burden >50% Total Households Atwater 1,780 1,314 9,160
Percent 19.4% 14.3% 100.0%
Merced County 14,710 12,285 80,010
Percent 18.4% 15.4% 100.0%
California 2,632,205 2,427,660 13,044,265
Percent 20.2% 18.6% 100.0%
Source: U.S. Department of Housing and Urban Development, CHAS 2015-2019 (5-Year Estimates), Table 7.

B3.6 Household Characteristics
Table B3-12 provides information on household types. Of the 10,309 households in Atwater, 5,096 are married-couple households with or without children, and 665 are cohabitating couple households with or without children. Approximately half the total households in Atwater, Merced County, and California are married-couple households.

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City of Atwater
Housing Needs Assessment
2024-2032 Housing Element B3-9
Table B3-12 Households by Type
Jurisdiction
Married-Couple Household Cohabitating Couple Household
Total
Total Children No Children Total Children Households
No
Children
Atwater 5,096 2,192 2,904 665 350 315 10,309
Percent 49.4% 21.3% 28.2% 6.5% 3.4% 3.1% -
Merced
County
39,912 18,171 21,741 6,862 3,910 2,952 81,618
Percent 48.9% 22.3% 26.6% 8.4% 4.8% 3.6% -
California 6,539,445 2,780,272 3,759,173 938,780 338,874 599,906 13,217,586 Percent 49.5% 21.0% 28.4% 7.1% 2.6% 4.5% -
Source: U.S. Census Bureau, ACS 2017-2021 (5-year Estimates), Table B11012.

B3.7 Large Households
Large family households are defined by U.S. Census Bureau as households containing five or more persons. Table B3-13 provides information on large households by tenure. As shown, 17.8 percent of households in Atwater consist of five or more people, which is lower than the county average and higher than the state. In Atwater, owner-occupied five-person households (6.4 percent of total households), renter-occupied five-person households (6.3 percent) and renter-occupied six-person households (1.6 percent) make up the largest percentages of large households, while owneroccupied six person households make up the smallest percentage of large households. Additionally, Atwater and Merced County have higher percentages of renter-occupied five- person households than in California.

Table B3-13 Large Households by Tenure
Jurisdiction
Total Large
Households
Owner-Occupied
Large Households
Renter-Occupied
Large Households
5-Person 6-Person
7-or-More
Person 5-Person 6-Person
7-or-More
Person
Atwater 1,835 658 107 141 651 169 109
Percent 17.8% 6.4% 1.0% 1.4% 6.3% 1.6% 1.1%
Merced County 17,710 4,737 1,952 1,649 5,380 2,184 1,808 Percent 21.7% 5.8% 2.4% 2.0% 6.6% 2.8% 2.2%
California 1,830,468 580,759 246,420 200,281 456,013 199,263 147,732 Percent 13.9% 4.4% 1.9% 1.5% 3.5% 1.5% 1.1%
Source: U.S. Census Bureau, ACS 2017-2021 (5-year Estimates), Table B25009.

B3.8 Overcrowding
The U.S. Census defines an overcrowded unit as one occupied by 1.01 persons or more per room (excluding bathrooms and kitchens). Units with more than 1.5 persons per room are considered severely overcrowded. Table B3-14 provides information on overcrowding by tenure in Atwater.

There is a total of 715 overcrowded households in the city, of which 32.7 percent are owneroccupied households, and the remaining 67.3 percent are renter-occupied.

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Merced County Association of Governments
Merced County Multi-Jurisdictional Housing Element (2024-2032) B3-10
Table B3-14 Overcrowding Severity by Tenure
Jurisdiction
Owner-Occupied Renter-Occupied
Total

1.0 to 1.5
Occupants per
Room
More than 1.5
Occupants per
Room Total

1.0 to 1.5
Occupants per
Room
More than 1.5
Occupants per
Room
Atwater 5,366 158 76 4,943 349 132
Percent 52.1% 1.5% 0.7% 47.9% 3.4% 1.3%
Merced County 42,146 1,766 551 39,472 3,090 1,362
Percent 51.6% 2.2% 0.7% 48.4% 3.8% 1.7%
California 7,335,247 229,637 82,236 5,882,339 453,625 321,169 Percent 55.5% 1.7% 0.6% 44.5% 3.4% 2.4%
Source: U.S. Census Bureau, ACS 2006-2010, 2011-2015, 2017-2021 (5-year Estimates), Table B25014.

B3.9 Special Needs Groups
Within the general population there are several groups of people who have special housing needs.

These needs can make it difficult for members of these groups to locate suitable housing. The following subsections identify and discuss these special housing needs groups.

Seniors
Table B3-15 identifies senior households in Atwater, Merced County, and California. The percentage row identifies the percent of the specified age range within all owner-occupied or renter-occupied household categories. There are far more owner-occupied senior households in Atwater (1,633 total), than renter-occupied senior households (816 total), which is like the county and state. As shown, seniors between the ages of 65 and 74 make up the largest percentages of owner and renter-occupied households (15.4 percent and 8.3 percent of total households, respectively), consistent with the county and state.

Table B3-15 Senior Households by Tenure
Jurisdiction
Owner-Occupied Renter-Occupied
65 to 74 75 to 84 85 and over 65 to 74 75 to 84 85 and over Atwater 826 545 262 409 302 105
Percent 15.4% 10.2% 4.9% 8.3% 6.1% 2.1%
Merced County 7,176 4,232 1,559 3,318 1,216 495
Percent 39.9% 23.5% 8.7% 18.4% 6.8% 2.8%
California 1,386,828 679,546 288,915 501,465 229,153 132,237 Percent 43.1% 21.1% 9.0% 15.6% 7.1% 4.1%
Source: U.S. Census Bureau, ACS 2017-2021 (5-year Estimates), Table B25007.

Table B3-16 shows the housing cost burdens by elderly family type and tenure in Atwater based on data extracted through HUD’s CHAS (note that the CHAS data defines senior or elderly as age 62 and over, as opposed to the ACS that reports seniors as age 65 and older). Based on data in this table, of all elderly persons in lower-income categories (less than or equal to 80 percent HAMFI),

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City of Atwater
Housing Needs Assessment
2024-2032 Housing Element B3-11
approximately 26.9 percent of all senior-owner households and 46.4 percent of all senior-renter households in Atwater had a housing cost burden of 30 percent or greater.

Table B3-16 Overpayment by Tenure Among Senior Households, Atwater Owners Renters
Total
Elderly
Family
Elderly
Non- family
Elderly
Family
Elderly
Non- family
Household Income <= 30% HAMFI Extremely Low-Income
TOTAL HOUSEHOLDS <= 30% HAMFI 45 135 25 105 310
Number w/ Cost Burden <= 30% 20 35 - 20 75
Number w/ Cost Burden > 30% to <= 50% 10 15 - 10 35
Number w/ Cost Burden > 50% 15 85 25 75 200
Percent with Cost Burden >30% HAMFI 56.0% 74.0% 100.0% 81.0% 76.0% Household Income > 30% to <= 50% HAMFI Very Low-Income
TOTAL HOUSEHOLDS > 30% to <= 50% HAMFI 30 150 40 45 265 Number w/ Cost Burden <= 30% 10 65 - 20 95
Number w/ Cost Burden > 30% to <= 50% 20 20 15 10 65
Number w/ Cost Burden > 50% - 65 25 15 105
Percent with Cost Burden >30% HAMFI 67.0% 57.0% 100.0% 56.0% 64.0% Household Income > 50% to <= 80% HAMFI Low-Income
TOTAL HOUSEHOLDS > 50% to <= 80% HAMFI 155 150 145 60 510 Number w/ Cost Burden <= 30% 90 90 60 15 255
Number w/ Cost Burden > 30% to <= 50% 55 60 85 45 245
Number w/ Cost Burden > 50% 10 - - - 10
Percent with Cost Burden >30% HAMFI 42.0% 40.0% 59.0% 75.0% 50.0% Household Income > 80% to <= 100% HAMFI
TOTAL HOUSEHOLDS > 80% to <= 100% HAMFI 55 10 50 44 159 Household Income > 100% HAMFI
TOTAL HOUSEHOLDS > 100% HAMFI 430 160 99 45 734
Total Income <80% HAMFI and Cost Burden > 30% 355 305 660 Percent Income <80% HAMFI and Cost Burden > 30% 26.9% 46.4% 33.4% GRAND TOTAL HOUSEHOLDS 715 605 359 299 1,978
Elderly family constitutes 2 persons with either or both age 62 and over.

HAMFI = HUD Area Median Family Income
Source: HUD Consolidated Planning / Comprehensive Housing Affordability Strategy (CHAS) database, 2015-2019 estimates, Table 7, accessed 2023. https://www.huduser.gov/portal/datasets/cp.html Table B3-17 summarizes cost burden data for units occupied by senior households. As shown,

63.7 percent of senior households in Atwater are cost burdened by less than or equal to 30 percent.

Further, 20.4 percent are cost burdened by greater than 30 percent and less than or equal to 50 percent, while 15.9 percent are cost burdened by more than 50 percent. There is a higher percentage of senior households cost burdened in Atwater than in Merced County by over 30 percent.

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Merced County Association of Governments
Merced County Multi-Jurisdictional Housing Element (2024-2032) B3-12
Table B3-17 Cost Burdened Senior Households
Jurisdiction Cost Burden <= 30% Cost Burden >30% to <=50% Cost Burden >50% Total Senior
Households
Atwater 1,260 403 315 1,978
Percent 63.7% 20.4% 15.9% 100.0%
Merced County 12,080 3,220 2,880 18,180
Percent 66.4% 17.7% 15.8% 100.0%
California 1,963,195 620,335 736,510 3,320,040
Percent 59.1% 18.7% 22.2% 100.0%
Source: U.S. Department of Housing and Urban Development, CHAS 2015-2019 (5-Year Estimates), Table 7.

Resources for Senior-Headed Households
The Merced County Housing Authority manages six senior housing complexes, none of which are in Atwater. As shown in Table B3-16, there are a total of 658 senior rental-occupied households in Atwater, of which 420 are lower-income. Based on this data, there is a significant gap between lower-income senior rental-occupied households and available units.

Persons with Disabilities (including Developmental Disabilities) Individuals with disabilities, including developmental disabilities, may require special housing accommodations or assistance. Community members with ambulatory difficulties, self-care limitations, or cognitive conditions may require assisted living or financial assistance. Table B3-18 identifies the number of residents with one or more disabilities. In Atwater, 7.3 percent of the total population has one type of disability, while 6.9 percent report two or more disabilities, which is similar to the county (6.6 percent and 6.3 percent, respectively) but higher than the state (5.4 percent and 5.2 percent, respectively). Among those with a disability, 51.4 percent have one disability, while 48.6 percent have two or more types of disability.

Table B3-18 Population by Number of Disabilities
Jurisdiction Total
With One Type
of Disability
With two or More
types of Disability No Disability
Atwater 31,214 2,266 2,144 26,804
Percent - 7.3% 6.9% 85.9%
Merced County 276,304 18,099 17,266 240,939
Percent - 6.6% 6.3% 87.2%
California 38,946,377 2,108,406 2,037,095 348,000,876
Percent 5.4% 5.2% 89.4%
Source: U.S. Census Bureau, ACS 2017-2021 (5-year Estimates), Table C18108.

Table B3-19 summarizes the population with a disability by age. In Atwater, residents aged 18 to 64 years make up the largest proportion of disabled individuals at 6.4 percent of the total population.

This is consistent with the county (6.8 percent) and higher than the state (5.1 percent). The under 18 years age group accounts for the smallest percent of those with a disability at 1.7 percent.

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City of Atwater
Housing Needs Assessment
2024-2032 Housing Element B3-13
Table B3-19 Disability by Age for the Total Population
Jurisdiction Total Under 18 Years 18 to 64 Years 65 Years and Older Atwater 31,214 523 2,005 1,882
Percent - 1.7% 6.4% 6.0%
Merced County 276,304 3,666 18,311 13,388
Percent - 1.3% 6.6% 4.9%
California 38,946,377 315,849 1,964,845 1,864,807
Percent 0.8% 5.1% 4.8%
Source: U.S. Census Bureau, ACS 2017-2021 (5-year Estimates), Table C18108.

Table B3-20 identifies residents with a developmental disability by age. In Atwater, most residents with a developmental disability are 18 years old and older, while the majority in both the state and county are under 18 years.

Table B3-20 Developmental Disability by Age
Jurisdiction Under 18 Years 18 Years and Older Total Population with a Disability Atwater 232 246 478
Merced County 1,507 1,287 2,794
California 192,384 185,353 377,737
Source: California Department of Developmental Services, DDS Quarterly Consumer Report, December 2021.

Table B3-21 includes data summarizing the housing location of residents with developmental disabilities. A majority of residents with a developmental disability in Atwater live in the home of a parent, family member, or guardian (385). An additional 47 residents live in an independent/ supported living facility, 29 residents live in community care facilities, 11 residents live in intermediate care facilities, and less than 11 residents live in foster/family homes.

Table B3-21 Developmental Disability by Residence
Residence Type City of Atwater Merced County California Home of Parent/Family/Guardian 385 2,937 309,381
Independent/Supported Living 47 232 27,881
Community Care Facility 29 80 23,728
Intermediate Care Facility 11 60 6,188
Foster/Family Home <11 <11 8,288
Other <11 <11 4,792
Total >472 >3,309 380,258
Source: California Department of Developmental Services, DDS Quarterly Consumer Report, January 2022.

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Merced County Association of Governments
Merced County Multi-Jurisdictional Housing Element (2024-2032) B3-14
The Supplemental Security Income (SSI) program, administered by the U.S. Social Security Administration, shows the number of persons with disabilities who may have housing needs because of their low incomes. As of December 2021, 10,190 SSI recipients in Merced County were receiving benefits because they were blind or disabled2.

Resources for Persons with Disabilities
According to the 2016-2024 Atwater Housing Element, the California Department of Developmental Services currently provides community-based services to persons with developmental disabilities through a statewide system of 21 regional centers, four developmental centers, and two community‐based facilities. Regional centers provide “point of entry” services to those that are developmentally disabled. The closest center to Atwater is the Central Valley Regional Center field office in Merced, approximately nine miles away. The Central Valley Regional Center is a non‐profit community agency that contracts with local businesses to provide services to developmentally disabled persons and their families. While there are no specific public housing resources that are accessible to people with disabilities in Atwater, there are 35 total public housing units available to low and moderate-income families and individuals in the city. As shown in Table B3-19, there are more than 4,000 people with a disability in Atwater, illustrating a significant gap in housing resources for residents with a disability.

Large Households
Table B3-22 provides information on large households by tenure in Atwater, Merced County, and California. See section 6.2.7: Large Households, above, for more information. As shown, there are 906 owner-occupied large households and 929 renter-occupied large households. There is a smaller percentage of total large households in Atwater (17.8 percent) than the county (21.7 percent) and a larger percentage than the state (13.9 percent).

Table B3-22 Large Households by Tenure
Jurisdiction
Total
Households
Owner-Occupied
Large Households
Renter-Occupied
Large Households
5-Person 6-Person
7-or-More
Person 5-Person 6-Person
7-or-More
Person
Atwater 10,309 658 107 141 651 169 109
Percent 6.4% 1.0% 1.4% 6.3% 1.6% 1.1%
Merced County 81,618 4,737 1,952 1,649 5,380 2,184 1,808 Percent 5.8% 2.4% 2.0% 6.6% 2.7% 2.2%
California 13,217,586 580,759 246,420 200,281 456,013 199,263 147,732 Percent 4.4% 1.9% 1.5% 3.5% 1.5% 1.1%
Source: U.S. Census Bureau, ACS 2016-2020 (5-year Estimates), Table B25009. 2 Source: U.S. Social Security administration. SSI Recipients by State and County, 2021. https://www.ssa.gov/policy/docs/statcomps/ssi_sc/2021/ca.html Note: Although these figures can give a sense of the proportion of the population with different types of disabilities, a much smaller proportion of the population may actually require specially adapted housing to accommodate disabilities.)

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City of Atwater
Housing Needs Assessment
2024-2032 Housing Element B3-15
Resources for Large Households
Units with four or more bedrooms are the primary housing resource for large households.

Table B3-23 compares the number of large households to the number of large units. Units with five or more rooms provide housing options for large households and work to lessen overcrowding. As shown, there are 360 units in Atwater with five or more bedrooms but 1,835 large households, leaving a resource gap of more than 1,475 units. When considering all large units with four or more bedrooms (1,651) there is still a resource gap of more than 184 units. To help mediate the issue of overcrowding and large households, the City will implement Program 7.

Table B3-23 Large Households and Units
Jurisdiction Total Households
Large Households
(5 or more persons) Total Units
Large Units
(4 bedrooms)
Large Units
(5 or more bedrooms)
Atwater 10,309 1,835 10,580 1,291 360
Percent 17.8% 12.5% 3.5%
Merced County 81,618 17,710 86,767 17,656 3,002
Percent 21.7% 21.6% 3.7%
California 13,217,586 1,830,468 14,328,539 2,373,268 596,588 Percent 13.8% 18.0% 4.5%
Source: U.S. Census Bureau, ACS 2017-2021 (Five-year Estimates), Tables DP04.

Female-Headed Households
Table B3-24 identifies single female-headed households with their own children under age 18. The table values do not include female-headed households with unrelated dependents. Atwater has a total of 1,050 single female-headed households with their own children under 18, representing 10.2 percent of total households. This is higher than the county (7.8 percent) and the state (4.7 percent).

Table B3-24 Single Female-Headed Households with Own Children Jurisdiction Total Households Single Female-Headed Households* Percent Atwater 10,309 1,050 10.2%
Merced County 81,618 6,365 7.8%
California 13,217,586 614,747 4.7%
Notes: Single Female-Headed Households with own children under age 18, does not include unrelated dependents.

Source: U.S. Census Bureau, ACS 2017-2021 (5-year Estimates), Table B11012.

Table B3-25 compares female-headed households by tenure. As shown, there is a larger percentage of renter-occupied female-headed households (59.8 percent) than owner-occupied households (40.2 percent). Both the county and state follow a similar trend.

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Merced County Association of Governments
Merced County Multi-Jurisdictional Housing Element (2024-2032) B3-16
Table B3-25 Female-Headed Family Households by Tenure
Jurisdiction Owner-Occupied Renter-Occupied Total
Atwater 806 1,201 2,007
Percent 40.2% 59.8%
Merced County 4,569 10,129 14,698
Percent 31.1% 68.9%
California 713,100 996,675 1,709,775
Percent 41.7% 58.3%
Source: U.S. Census Bureau, ACS 2017-2021 (5-year Estimates), Table B17010.

Resources for Single-Parent and Female-Headed Households Resources for lower-income female-headed households include existing affordable housing units in the city as well as rental assistance provided through the County’s Housing Choice Voucher (HCV) program. Below is a list of local agencies dedicated to assisting parents:
▪ First 5 Merced County is dedicated to improving the lives of Merced County’s young children, including Atwater, and their families through a comprehensive system of education, health services, and other crucial programs. The Strong Families programs enable families to raise their children in a safe, stable, and nurturing home. These programs work with families, educators, health, and social services providers to support parents and guardians. Below is a list of local agencies dedicated to assisting parents:
▪ Ace Overcomers Program, committed to helping teens and adults overcome the effects of adverse childhood experiences (ACEs).
▪ Merced County Office of Education, providing educational services to children and families including childcare subsidies to offset the costs of care. ▪ Sierra Vista Child and Family Services, committed to supporting the community by providing mental health services to children and youth ages 0 to 21. ▪ Maternal, Child, and Adolescent Health (MCAH) Services, providing information and services to mothers and children.

Extremely Low-Income Residents
Extremely low-income (ELI) households are defined as households with incomes under 30 percent of the AMI. ELI households typically consist of minimum wage workers, seniors on fixed incomes, the disabled, and farmworkers. This income group is likely to live in overcrowded and substandard housing conditions. Many ELI households overlap with other special housing needs groups such as seniors and people with disabilities, putting the group at a disproportionate need for affordable housing options. ELI households have specific housing needs that require greater government subsidies and assistance, housing with supportive services, single room occupancy (SRO) and/or shared housing, and/or rental subsidies or vouchers. In recent years, rising rents, higher income and credit standards imposed by landlords, and insufficient government assistance has exacerbated the problem. Without adequate assistance this group has a high risk of homelessness.

Table B3-26 identifies extremely low-income (ELI) households by tenure in Atwater. ELI households are households whose income is less than or equal to 30 percent of the AMI. Renter-occupied extremely low-income households account for 10.5 percent of total households in Atwater, significantly higher than owner-occupied extremely low-income households (4.0 percent). The

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City of Atwater
Housing Needs Assessment
2024-2032 Housing Element B3-17
percentage of renter-occupied extremely low-income households in the city is similar to the rate in the county (10.7 percent) and the state (10.8 percent). The percentage of owner-occupied extremely low-income households in Atwater (4.0 percent) is slightly higher than in Merced County (3.7 percent), but lower than in California (4.5 percent). There are 1,329 total extremely low-income households in Atwater, comprising approximately 14.5 percent of total households in the city. This is similar to the county (14.3 percent) and slightly lower than the state (15.3 percent).

Table B3-26 Extremely Low-Income Households by Tenure
Jurisdiction
Income <=30% HAMFI
Owner-Occupied Renter-Occupied Total ELI Households Total Households Atwater 364 965 1,329 9,160
Percent 4.0% 10.5% 14.5% 100.0%
Merced County 2,940 8,540 11,480 80,010
Percent 3.7% 10.7% 14.3% 100.0%
California 592,010 1,427,405 2,019,415 13,217,586
Percent 4.5% 10.8% 15.3% 100.0%
Source: U.S. Housing and Urban Development, CHAS 2015-2019 (5-Year Estimates), Table 7.

Table B3-27 summarizes cost burden among extremely low-income households. As shown, in Atwater 289 of 364 extremely low-income owner-occupied households (79.4 percent) are experiencing moderate or severe housing cost burden. This is similar to the county (79.1 percent) and the state (80.1 percent). In addition, 895 of the 965 extremely low-income renter-occupied households (2.73 percent) are experiencing a housing cost burden of over 30 percent of the household income. This is higher than in both the county (87.4 percent) and the state (87.9 percent). Among extremely low-income households in Atwater, 56.8 percent are renter-occupied households with a severe cost burden. This is higher than in the county (51.7 percent) and the state (51.4 percent). ELI households also generally experience more housing problems compared to other income categories. Approximately 75 percent of total ELI households experience any housing problem, while approximately 60 percent of low-income households and approximately 18 percent of moderate- and above moderate-income households experience any housing problem.

Table B3-27 Extremely Low-Income Households Overpaying by Tenure Jurisdiction
Owner-Occupied Renter-Occupied
Total ELI
Households
Cost
Burden
<30%
Moderate
Cost
Burden
30%-50%
Severe
Cost
Burden
>50%
Cost
Burden
<30%
Moderate
Cost
Burden
30%-50%
Severe
Cost
Burden
>50%
Atwater 75 95 194 70 140 755 1,329
Percent 5.6% 7.1% 14.6% 5.3% 10.5% 56.8% 100.0%
Merced County 615 595 1,730 1,075 1,530 5,935 11,480
Percent 5.4% 5.2% 15.1% 9.4% 13.3% 51.7% 100.0%
California 117,890 92,945 381,175 172,130 216,880 1,038,395 2,019,415 Percent 5.8% 4.6% 18.9% 8.5% 10.7% 51.4% 100.0%
Source: US Housing and Urban Development, CHAS 2015-2019 (5-Year Estimates).

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Merced County Association of Governments
Merced County Multi-Jurisdictional Housing Element (2024-2032) B3-18
Resources for Extremely Low-Income Households
The Housing Authority of the County of Merced currently administers the HCV Program, a federal rent subsidy program under the Department of Housing and Urban Development. The program provides rent subsidy to families in privately owned existing rental units in Merced County. The Housing Authority of the County of Merced currently administers 2,705 HCVs within the county. 3 In addition to the HCV program, the Housing Authority also administers Emergency Housing Vouchers (EHV). In order to be eligible for an EHV, an individual must meet one of the four eligibility criteria:

1. Homeless;

2. At risk of homelessness;

3. Fleeing, or attempting to flee, domestic violence, dating violence, sexual assault, stalking, or human trafficking;

4. Recently homeless and for whom providing rental assistance will prevent the family’s homelessness or having high risk of housing instability.4 Table B3-28 includes an inventory of affordable housing in Atwater. As shown, there are 35 affordable units in the city. These units serve households making less than 80 percent of the AMI.

Based on the identified need (965 ELI rental households) there is a significant need for additional units affordable to ELI households in the city.

Table B3-28 Inventory of Public Assisted Complexes, Atwater Name Address City Zip Affordable Units
Atwater Apartments - (Site A) 1191 Willow Street Atwater 95301 35 Note: All locally assisted or restricted developments may not be included in this list.

Source: California Housing Partnership, 2023.

Farmworkers
Farmworkers and day laborers are an essential component of California’s agriculture industry.

Farmers and farmworkers are the cornerstone of the larger food sector, which includes the industries that provide farmers with fertilizer and equipment; farms to produce crops and livestock; and industries that process, transport, and distribute food to consumers. Farmworker households are often compromised of extended family members or single male workers. Farmworkers make up the majority of the agricultural labor sector and include individuals whose primary income is earned through either seasonal or permanent agricultural labor.

Farmworkers are traditionally defined as persons whose primary incomes are earned through permanent or seasonal agricultural labor. Migrant farmworkers as a group consist of individuals who travel not only across county lines but also from one major geographic region of California to another to find work. Travel for work prevents them from returning to their primary residence every evening. Many migrant farmworkers are single males, most of whom are married and migrate alone 3 Housing Authority of Merced County, Housing Choice Voucher, http://www.merced-pha.com/housing-choice-voucher/ accessed June 2023.
4 Housing Authority of Merced County, Emergency Housing Vouchers, http://www.merced-pha.com/emergency-housing-vouchers-ehvfrequently-asked-questions-faq/ accessed June 2023.

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City of Atwater
Housing Needs Assessment
2024-2032 Housing Element B3-19
to support their families who live at home base. However, there are many migrant families who have more than one employed member.

When workloads increase during harvest periods, the labor force is supplemented by seasonal labor, often supplied by a labor contractor. Non-migrant seasonal farmworkers consist of individuals who work only during a harvest season, and who are able to return to their primary residence every evening. This group, which includes cannery workers, is fairly significant, and includes more than half of all farmworkers in the state. Permanent farmworkers comprise the smallest group of individuals employed in agriculture. Permanent farmworkers are employed year-round, usually by one employer in the agricultural industry. This group generally lives in rural areas in permanent housing provided by the grower. Providing migratory or seasonal farmworkers with affordable shelter has long presented a problem. Traditionally, growers offered some level of shelter to workers, yet the availability of grower-offered housing has dramatically decreased over the last twenty years. While housing for farmworkers is most convenient when located on or adjacent to farms, housing affordable at very low-income levels tends to be more feasible in cities. Housing in cities, with services located nearby, may also be more suitable for seasonal farmworkers whose families live with them. Increasingly, farmworkers are living in cities on a year-round basis, especially in existing single family rental units in older neighborhoods that offer relatively low-cost housing and its central location in relation to farmland.

According to a study conducted by the University of California, Merced, farmworker households frequently experience high poverty rates, severe overcrowding, and poor housing conditions, with a majority renting and living in substandard environments due to their typically lower incomes and face a disproportionate need for more affordable housing. These housing issues, combined with the demanding and poorly compensated nature of farmwork, often lead to negative health outcomes and exacerbate respiratory and infectious diseases.
5 The U.S. Department of Agriculture provides countywide farmworker population data generated by the Census of Agriculture. The most recent Census of Agriculture data (2017) identified 15,566 farmworkers in the county.6
Table B3-29 provides 2017-2021 ACS data for the total population of residents working in the agriculture, forestry, fishing and hunting, and mining industries (including farmworkers) in Atwater and Merced County. Atwater had 1,231 workers in these categories in 2021, representing 10.0 percent of the total population of workers in these industries across the county. Please note that this number is not strictly farmworkers, as the ACS data does not identify numbers in subcategories.

Table B3-29 Farmworker Population
Jurisdiction
Population in Agriculture, Forestry, Fishing and Hunting, and Mining Industries (Including Farmworkers)
Atwater 1,231
Percent 10.0%
Total Merced County 12,326
Source: U.S. Census Bureau, ACS 2017-2021 (5-year Estimates), Table C24050. 5 Farmworker Health in California. UC Merced. August 2022. https://clc.ucmerced.edu/sites/clc.ucmerced.edu/files/page/documents/fwhs_report_2.2.2383.pdf?_gl=1*1rg0e9w*_ga*MTU3Njc2MD MzNS4xNzA4OTk2Nzgx*_ga_TSE2LSBDQZ*MTcwODk5Njc4MC4xLjAuMTcwODk5Njc4MC42MC4wLjA. 6 U.S. Department of Agriculture, Census of Agriculture, https://www.nass.usda.gov/AgCensus/ accessed June 2023, accessed June 2023.

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Merced County Association of Governments
Merced County Multi-Jurisdictional Housing Element (2024-2032) B3-20
The USDA Census of Agriculture reported 1,397 farms with a total of 15,945 workers in Merced County (see Table B3-30). The majority of the farmworkers were seasonal, working fewer than 150 days per year.

Table B3-30 Farmworkers in Merced County by Days Worked (2017) Farm Type Number of Farms Number of Workers
150 Days or More (Year-Round)
Small Farms (less than 10 workers per farm 512 1,535
Large Farms (10 or more workers per farm) 291 7,853
Subtotal 803 9,388
Fewer than 150 Days (Seasonal)
Small Farms (less than 10 workers per farm) 438 1,346
Large Farms (10 or more workers per farm) 156 5,211
Subtotal 594 6,557
Total 1,397 15,945
Source: USDA. 2022 Census of Agriculture - County Data. https://www.nass.usda.gov/Publications/AgCensus/2022/Full_Report/Volume_1,_Chapter_2_County_Level/California/st06_2_007_007.pdf Resources for Farmworkers
The Housing Authority of Merced County funds four migrant housing centers, one of which is in Atwater. It contains 59 units that offer temporary housing from April through November. To be eligible for migrant housing, households must earn a minimum of $5,752.50 annually from farm labor employment. The Atwater Migrant Center is located on W. Westside Boulevard, Atwater. As reported in Table B3-29 above, there were more than 1,231 farmworkers living in Atwater in 2021.

Despite the housing opportunities listed above, there is a significant gap in housing resources for farmworkers in the city.

Unhoused Households
Figure B3-2 shows unhoused households by type between 2005 to 2022. As shown, 2005 had the highest reported number of unhoused households (1,101) by the Merced County Continuum of Care (CoC), the majority of which were unsheltered. Data for 2020 indicates that there were 559 unhoused households, including 313 of those counted as unsheltered. These numbers increased from 2020 to 2022, at which point over 680 households were unhoused in the county.

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City of Atwater
Housing Needs Assessment
2024-2032 Housing Element B3-21
Figure B3-2 Unhoused Households by Type Over Time, Merced County Source: U.S. HUD, CoC Homeless Populations and Subpopulations Reports (2005, 2010, 2015, 2020, 2022).

Point in time count data is reported by the CoC for Merced County, including Atwater. Table B3-31 provides the most recent (2023) point-in-time count for individual unhoused residents in the county. In 2023, there were a total of 784 unhoused people in Merced County, with 4.6 percent (36 people) living in Atwater.

Table B3-31 Unhoused Individuals by Type (2023)
Jurisdiction Sheltered Unsheltered Total
Atwater 9 27 36
Percent 2.3% 6.9% 4.6%
Total Merced County 394 390 784
Source: Merced City and County Continuum of Care, Point-in-Time Count (2022) Figure B3-3 identifies unhoused individuals by type and race in Merced County for the year 2023. As shown, 53.2 percent of unhoused individuals countywide were reported as sheltered. In terms of race, 69 percent reported as white, 17 percent as Black or African American, one percent as Asian, three percent as American Indian or Alaska Native, less than one percent as Native Hawaiian or Other Pacific Islander, and 10 percent as multiple races. 115
9 95 107 209
40 1
38 139
115
946
38 743
313
363
0 200
400
600
800
1000
1200
2005 2010 2015 2020 2022
Emergency Shelter Transitional Housing Unsheltered

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Merced County Association of Governments
Merced County Multi-Jurisdictional Housing Element (2024-2032) B3-22
Figure B3-3 Unhoused Individuals by Type by Race (2023) Source: Merced City and County Continuum of Care, Point-in-Time Count (2023) The 2023 Merced County CoC point in time count data also considers ethnicity, as shown in Table B3-32. Among those counted, 332 of 784 individuals (42.3 percent) identified as Hispanic/Latino.

Table B3-32 Unhoused Individuals by Ethnicity, Merced County (2023) Jurisdiction Sheltered Unsheltered Total
Hispanic/Latino (any race) 186 146 332
Percent 23.7 18.6 42.3
Not Hispanic/Latino 208 244 452
Percent 26.5 31.1 57.7
Source: Merced City and County Continuum of Care, Point-in-Time Count (2022).

The 2023 point-in-time count only provides specific demographic data for unsheltered residents in the cities of Merced and Los Banos.

Resources for Persons Unhoused Individuals
The City of Atwater has a transitional housing facility offered in the city. Operated by Community Social Model Advocate, the Tranquility Village is a women’s program offering eight family units with 57 total beds. It also houses women with children, offering treatment and child services. While Atwater does not have transitional housing for men, Community Social Model Advocate does operate a male program in Merced called the Hobie House. The facility is approximately nine miles from Atwater and offers 25 individual beds for those recovering from substance abuse.

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City of Atwater
Housing Needs Assessment
2024-2032 Housing Element B3-23
There are no emergency shelters in the city. The lack of resources for the unhoused in Atwater indicates a need for more accessible housing for the unhoused population.

B3.10 Housing Stock Characteristics
A community’s housing stock is defined as the collection of all housing units located within the jurisdiction. The characteristics of the housing stock, including growth, type, age, condition, tenure, vacancy rates, housing costs, and affordability are important in determining the housing needs for the community. The following sections detail the housing stock characteristics of Atwater to identify how well the current housing stock meets the needs of current and future residents.

Housing Growth
Table B3-33 summarizes the growth in the housing stock in Atwater by providing the total number of units constructed each decade from 1980 and 2020. The largest growth rate occurred between 1980 and 1990 with a 30.3 percent increase during this 10-year period. Between 1990 and 2000 the housing stock grew at a slower pace of 9.3 percent. Between 2000 and 2010, the number of housing units in the city increased by 20.4 percent, however in the 10 years from 2010 and 2020, production slowed again, with the number of housing units increasing by just 6.9 percent.

Table B3-33 Total Housing Units Over Time (1980 to 2020) Jurisdiction 1980 1990 2000 2010 2020
Atwater 5,696 7,422 8,114 9,771 10,448
Percent Change 30.3% 9.3% 20.4% 6.9%
Source: U.S. Census Bureau, Census 1980 (STF1:T65), 1990 (STF1:H1), 2000 (SF1:H1); ACS 2016-2020 (5-year Estimates), Table B25001.

Housing Type and Tenure
Table B3-34 identifies the total housing units by type in Atwater, Merced County, and California. In Atwater, single detached homes make up most of the housing stock, with 66.3 percent of total units. This is a lower percentage than the county with 73.8 percent and but greater than the state with 57.6 percent. The second most common housing type are 2-unit complexes, providing 9.2 percent of the total units in the city. This is much higher than both the county (3.2 percent) and the state (2.4 percent). Other common housing types in Atwater are three-to-four-unit complexes, comprising 6.1 percent of the total units in the city. This is higher than in the county (4.8 percent) and the state (5.4 percent). In both Atwater and Merced County, 20 to 49 unit complexes account for less than one percent of the housing stock. This is significantly lower than in California where 20- to-49-unit complexes account for approximately five percent of the housing stock.

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Merced County Association of Governments
Merced County Multi-Jurisdictional Housing Element (2024-2032) B3-24
Table B3-34 Total Housing Units by Type
Jurisdiction Total
1,
Detached
1,
Attached 2 3 or 4 5 to 9 10 to 19 20 to 49 50 or more
Mobile
Home
Boat, RV,
Van, etc.

Atwater 10,580 7,016 381 971 645 375 329 18 159 686 0
Percent 66.3% 3.6% 9.2% 6.1% 3.5% 3.1% 0.2% 1.5% 6.5% 0.0% Merced
County
86,767 64,045 1,908 2,785 4,172 3,876 1,634 801 1,649 5,775 122 Percent 73.8% 2.2% 3.2% 4.8% 4.5% 1.9% 0.9% 1.9% 6.7% 0.1% California 14,328,539 8,248,814 1,031,608 340,666 777,600 842,158 721,058 713,636 1,121,470 514,764 16,765 Percent 57.6% 7.2% 2.4% 5.4% 5.9% 5.0% 5.0% 7.8% 3.6% 0.1% Source: U.S. Census Bureau, ACS 2017-2021 (5-year Estimates), Table C24050.

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City of Atwater
Housing Needs Assessment
2024-2032 Housing Element B3-25
Table B3-35 indicates housing units by tenure. In Atwater, 52.1 percent of units are owner-occupied compared to 47.9 percent renter occupied. The percentage of owner-occupied households in the city is similar to the county (51.6 percent owner-occupied) and the state (55.5 percent).

Table B3-35 Housing Units by Tenure
Jurisdiction Total Owner-Occupied Renter-Occupied
Atwater 10,309 5,366 4,943
Percent 52.1% 47.9%
Merced County 81,618 42,146 39,472
Percent 51.6% 48.4%
California 13,217,586 7,335,247 5,882,339
Percent 55.5% 44.5%
Source: U.S. Census Bureau, ACS 2017-2021 (5-year Estimates), Table B25042.

Vacancy Rate
Table B3-36 provides data on vacancy status by type for the total vacant units. Of the total vacant units in Atwater (271), units for rent make up the largest percentage of total vacant units. These units make up 29.5 percent of total vacant units in the city, greater than the county (25.2 percent) and the state (21.7 percent). In Atwater, 8.5 percent of vacant units are used for seasonal, recreational or occasional use. By comparison, 10.8 percent of vacant units countywide and 33.4 percent in California fall into this category. There are no units in the city categorized as rented but not occupied or housing for migrant workers, illustrating that rental and farmworker housing are in high demand.

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Merced County Association of Governments
Merced County Multi-Jurisdictional Housing Element (2024-2032) B3-26
Table B3-36 Vacancy Status by Type for Total Vacant Units Jurisdiction
Total
Vacant Units For Rent
Rented, Not
Occupied For Sale Only
Sold, Not
Occupied
For Seasonal,
Recreational, or
Occasional Use
For Migrant
Workers Other Vacant
Atwater 271 80 0 40 58 23 0 70
Percent 2.6% 29.5% 0.0% 14.8% 21.4% 8.5% 0.0% 25.8%
Merced County 5,149 1,298 112 377 553 556 202 2,051
Percent 5.9% 25.2% 2.2% 7.3% 10.7% 10.8% 3.9% 39.8%
California 1,110,953 240,840 53,537 73,319 54,970 370,908 2,992 314,387 Percent 7.8% 21.7% 4.8% 6.6% 5.0% 33.4% 0.3% 28.3%
Source: U.S. Census Bureau, ACS 2017-2021 (5-year Estimates), Table B25004.

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City of Atwater
Housing Needs Assessment
2024-2032 Housing Element B3-27
Housing Unit Size
Table B3-37 provides housing unit size data for Atwater, Merced County, and California. In Atwater, three-bedroom units (52.8 percent) are the most common housing type, followed by two-bedroom (22.6 percent) and four-bedroom units (12.5 percent). This is similar to the statewide housing unit size trend; however, there is a notably larger stock of three-bedroom units in Atwater and Merced County when compared to the state.

Table B3-37 Housing Unit Size
Jurisdiction Total Studio 1 Bedroom 2 Bedroom 3 Bedroom 4 Bedroom 5 of More
Bedroom
Atwater 10,309 237 648 2,331 5,442 1,291 360
Percent 2.3% 6.3% 22.6% 52.8% 12.5% 3.5%
Merced County 81,618 1,883 4,320 16,306 38,451 17,656 3,002 Percent 2.3% 5.3% 20.0% 47.1% 21.6% 3.7%
California 13,217,586 564,387 1,691,491 3,539,857 4,451,995 2,373,268 596,588 Percent 4.3% 12.8% 26.8% 33.7% 18.0% 4.5%
Source: U.S. Census Bureau, ACS 2017-2021 (5-year Estimates), Table B25042.

Age and Condition of Housing Stock
Table B3-38 provides data on the total occupied housing units by year built. The city experienced the most growth between 1970 and 1979. During this period, 2,531 units were constructed, representing 24.6 percent of the housing stock at the time. California indicated a similar result, with the largest percentage of units constructed in the 1970s, making up 17.4 percent of the total housing stock. In contrast, Merced County saw the biggest growth between 2000 to 2009 with 16,856 units. Notably, in Atwater, only 329 units have been constructed since 2010, which is the lowest increase in housing units in the city since 1939. Of the total 10,309 occupied units, 6,234 units are more than 40 years old. This accounts for over half (60.5 percent) of the total occupied housing units today.

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Merced County Association of Governments
Merced County Multi-Jurisdictional Housing Element (2024-2032) B3-28
Table B3-38 Total Occupied Housing Units by Year Built
Jurisdiction Total
2020 or
later
2010 to
2019
2000 to
2009
1990 to
1999
1980 to
1989
1970 to
1979
1960 to
1969
1950 to
1959
1940 to
1949
1939 or
earlier
Atwater 10,309 0 329 1,464 752 1,530 2,531 1,129 1,537 819 218 Percent 0.0% 3.2% 14.2% 7.3% 14.8% 24.6% 11.0% 14.9% 7.9% 2.1% Merced
County
81,618 44 3,229 16,856 11,846 11,034 14,718 7,585 7,356 5,007 3,943 Percent 0.1% 4.0% 20.7% 14.5% 13.5% 18.0% 9.3% 9.0% 6.1% 4.8% California 13,217,586 15,877 634,508 1,451,946 1,438,264 1,980,874 2,295,943 1,728,569 1,755,123 753,750 1,162,732 Percent 0.1% 4.8% 11.0% 10.9% 15.0% 17.4% 13.1% 13.3% 5.7% 8.8% Source: U.S. Census Bureau, ACS 2017-2021 (5-year Estimates), Table B25036.

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City of Atwater
Housing Needs Assessment
2024-2032 Housing Element B3-29
Table B3-39 provides information on substandard housing units. In Atwater 0.2 percent of units lack kitchen facilities (22 units). There are no units in the city that lack plumbing facilities. This is similar to both the state and county. By comparison, however, Atwater’s substandard housing units make up a lower percent of total units (0.2 percent) compared to Merced County (0.8 percent) and California (1.5 percent).

The City’s Code Enforcement Division estimates that approximately 50 units require major rehabilitation and fewer than 15 units citywide are beyond the point of repair. There are no concentrated areas of substandard housing in the city.

Table B3-39 Substandard Housing Units
Jurisdiction Total Lacking Plumbing Facilities Lacking Kitchen Facilities Atwater 10,309 0 22
Percent 0.0% 0.2%
Merced County 81,618 298 357
Percent 0.4% 0.4%
California 13,217,586 53,643 149,252
Percent 0.4% 1.1%
Source:

Housing Costs
Median Home Sale Price
Table B3-40 provides information on the median housing value in Atwater from 1980 to 2020. As shown, prices rose steadily from 1980 to 1990, but experienced a much smaller increase in value from 1990 to 2000. Median home values increased by 114.8 percent from 2000 to 2010. A similar trend was seen across other jurisdictions in the county, where the smallest growth generally occurred between 1990 and 2000 and the largest growth occurred between 2000 and 2010.

Increases in value have slowed since 2010, with growth between 2010 and 2020 at 14.5 percent.

According to Zillow, the average house prices in Atwater were $294,434 in 2020 and $407,428 in 2024.

Table B3-40 Median Housing Value Over Time (1980 to 2020) Jurisdiction 1980 1990 2000 2010 2020
Atwater 56,000 89,400 99,900 214,600 $251,100
Percent Change 59.6% 11.7% 114.8% 14.5%
Dos Palos 44,300 66,900 88,500 179,800 $232,700
Percent Change 51.0% 32.3% 103.2% 22.7%
Gustine 50,800 96,000 111,400 183,700 $273,500
Percent Change 89.0% 16.0% 64.9% 32.8%
Livingston 43,400 71,900 92,300 244,900 $231,100
Percent Change 65.7% 28.4% 165.3% -6.0%
Los Banos 49,000 110,100 138,200 248,900 $315,500
Percent Change 124.7% 25.5% 80.1% 21.1%

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Merced County Association of Governments
Merced County Multi-Jurisdictional Housing Element (2024-2032) B3-30
Jurisdiction 1980 1990 2000 2010 2020
Merced 57,700 90,300 103,200 223,500 $251,500
Percent Change 56.5% 14.3% 116.6% 11.1%
Unincorporated County 53,100 90,100 110,900 241,000 $268,800 Percent Change 69.7% 23.1% 117.3% 10.3%
Note: Data are not inflation-adjusted to 2022 dollars.

Source: U.S. Census Bureau, Census 1980(ORG STF1), 1990(STF3), 2000(SF3); ACS 06-10, 16-20 (5-year Estimates), Table B25077.

Table B3-41 provides information on the median housing value in Atwater over the past five years.

As shown, housing values have steadily increased over this time period, with the greatest increase in value occurring between 2017 and 2018 (15.8 percent). The lowest growth occurred between 2020 and 2021 (5.6 percent). Jurisdictions throughout the county experienced a similar trend, where the highest median housing value growth occurred between 2017 and 2018, followed by significantly smaller gains between 2019 and 2020.

Table B3-41 Median Housing Value from 2017 to 2021
Jurisdiction 2017 2018 2019 2020 2021
Atwater 179,400 207,800 229,400 251,100 265,200
Percent Change - 15.8 10.4 9.5 5.6
Dos Palos 134,000 183,500 194,500 232,700 252,800
Percent Change - 36.9 6.0 19.6 8.6
Gustine 157,600 195,000 222,700 273,500 322,300
Percent Change - 23.7 14.2 22.8 17.8
Livingston 187,500 222,400 229,900 231,100 242,400
Percent Change - 18.6 3.4 0.5 4.9
Los Banos 226,700 265,500 293,400 315,500 340,800
Percent Change - 17.1 10.5 7.5 8.0
Merced 185,700 212,100 237,500 251,500 268,600
Percent Change - 14.2 12.0 5.9 6.8
Merced County 196,200 229,500 252,700 268,800 288,400
Percent Change - 17.0 10.1 6.4 7.3
Note: Data are not inflation-adjusted to 2022 dollars.

Source: ACS 2017-2021 (5-year Estimates), Table B25077.

B3.11 Distribution of Owner-Occupied Units
Table B3-42 compares data on the number of owner-occupied housing units by race in Atwater, Merced County, and California. In Atwater, a majority of owner-occupied units are occupied by residents that identify as white (59.8 percent). This is similar to Merced County (59.4 percent) and slightly higher than in California (41.6 percent).

Considering ethnicity, 41.2 percent of all owner-occupied units are occupied by Hispanic/Latino residents of any race. This is lower than in Merced County (43.5 percent) but higher than in California (24.1 percent). Given that 55.4 percent of the entire population of Atwater identifies as Hispanic/Latino of any race, this group is underrepresented in the housing market.

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City of Atwater
Housing Needs Assessment
2024-2032 Housing Element B3-31
Table B3-42 Owner Occupied Units by Race
Jurisdiction White Black
American
Indian
and
Alaska
Native Asian
Native
Hawaiian
and Other
Pacific
Islander
Some
Other
Race
Two or
More
Races
Hispanic/
Latino of
any Race
Atwater 3,210 272 49 294 11 1,123 407 2,212
Percent 59.8% 5.1% 0.9% 5.5% 0.2% 20.9% 7.6% 41.2%
Merced
County
25,012 1,182 436 2,801 43 9,588 3,084 18,848
Percent 59.3% 2.8% 1.0% 6.6% 0.1% 22.7% 7.3% 43.5%
California 4,660,216 287,300 53643 1,150,895 18,216 633,875 531,102 1,807,053 Percent 62.1% 3.8% 0.7% 15.3% 0.2% 8.4% 7.1% 24.1%
Source: U.S. Census Bureau, ACS 2017-2021 (5-year Estimates), Table B25003.

B3.12 Housing Rents
According to the 2017-2021 ACS, the median contract rent in Atwater was $844 per month (Figure B3-4). This was lower than the median for the county at $923 and significantly lower than the state median of $1,547. Recent rental market trend data from Apartments.com shows that the average rent for a two-bedroom apartment in Atwater as of September 2024 was approximately $1,078.7 The median rental price for all property types listed on Zillow.com was $1,600.8 Figure B3-4 Median Contract Rent
Source: U.S. Census Bureau, ACS 2017-2021 (5-year Estimates), Table B25058. 7 Rental Market Trends. Apartments.com. Accessed September 2024. https://www.apartments.com/rent-market-trends/atwater-ca 8 Zillow Rental Manager: Atwater, CA Rental Market. Accessed September 2024. https://www.zillow.com/rental-manager/markettrends/atwater-ca $844 $923
$1,547
$-
$200
$400
$600
$800
$1,000
$1,200
$1,400
$1,600
$1,800
Atwater Merced County California
Median Contract Rent

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Merced County Association of Governments
Merced County Multi-Jurisdictional Housing Element (2024-2032) B3-32
Table B3-43 below provides data on median gross rent from 1980 to 2020. Median gross rent has grown from $254 per month in 1980 to $1,044 in 2020. Between 2000 and 2010 rents in the city grew by 66.8 percent. From 2010 to 2020, rents grew at a slower rate of 20.1 percent.

Table B3-43 Median Gross Rent Over Time, Atwater
1980 1990 2000 2010 2020
Atwater $254 $446 $521 $869 $1,044
Percent Change 75.6% 16.8% 66.8% 20.1%
Source: Source: U.S. Census Bureau, Census 1980 (ORG STF3), 1990 (STF3), 2000 (SF3); ACS 2006-2010, 2016-2020 (5-year Estimates), Table B25064
Table B3-44 below provides an overview of median rent for rental housing by number of bedrooms based on 2017-2021 ACS data. As shown, median rent prices for all unit sizes were slightly lower in Atwater than in the county except for 3-bedroom units. Average rent prices in California are higher than in Atwater and throughout the county.

Table B3-44 Median Rent by Number of Bedrooms
Jurisdiction Studio 1 Bedroom 2 Bedroom 3 Bedroom 4 Bedroom Atwater $692 $732 $962 $1,312 $1,460
Merced County $708 $795 $989 $1,234 $1,548
California $1,293 $1,450 $1,737 $1,938 $2,326
Source: U.S. Census Bureau, ACS 2017-2021 (5-year Estimates), Table B25031.

B3.13 Housing Affordability
Housing affordability levels are calculated using the median household income. Affordable monthly housing costs are calculated by taking 30 percent of the annual income and dividing it by 12 months.

The rental utility allowance is a fixed number provided for each household size by the Merced County Housing Authority. Taxes, insurance, and homeowners’ association fees are calculated as 20 percent of the monthly affordable rent. Affordable monthly rent is calculated by subtracting affordable monthly housing costs and the rental utility allowance. Affordable home prices assume a 30-year fixed mortgage with a seven percent interest rate and 10 percent down payment. Taxes, insurance, and homeowners’ association fees only apply to homeowners.

Table B3-45 shows the maximum amount that a household can pay for housing each month without incurring a cost burden (overpayment) for Atwater. A summary of each income category’s ability to pay for housing is provided below the table.

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City of Atwater
Housing Needs Assessment
2024-2032 Housing Element B3-33
Table B3-45 Housing Affordability Matrix – Atwater (2021) Annual
Income
Limits
Affordable
Monthly
Housing Costs
Rental Utility
Allowance
(2020)
Taxes, Insurance,
Homeowners
Association Fees
Affordable
Rent
Affordable
Home Price
Extremely Low-Income (0-30% AMI)
1-Person (Studio) $13,000 $325 $192 $27 $133 $43,422
2-Person (1 BR) $14,850 $371 $233 $28 $138 $49,601
3-Person (2 BR) $16,750 $419 $236 $37 $183 $55,948
4-Person (3 BR) $18,600 $465 $257 $42 $208 $62,127
5-Person (4 BR) $20,100 $503 $279 $45 $224 $67,137
Very Low-Income (30-50% AMI)
1-Person $21,700 $543 $192 $70 $351 $72,482
2-Person $24,800 $620 $233 $77 $387 $82,836
3-Person $27,900 $698 $236 $92 $462 $93,191
4-Person $31,000 $775 $257 $104 $518 $103,545
5-Person $33,450 $836 $279 $111 $557 $111,729
Low-Income (50-80% AMI)
1-Person $34,700 $868 $192 $135 $676 $115,904
2-Person $39,650 $991 $233 $152 $758 $132,438
3-Person $44,600 $1,115 $236 $176 $879 $148,972
4-Person $49,600 $1,240 $257 $197 $983 $165,672
5-Person $53,550 $1,339 $279 $212 $1,060 $178,866
Median-Income (80-100% AMI)
1-Person $43,400 $1,085 $192 $179 $893 $144,963
2-Person $49,600 $1,240 $233 $201 $1,007 $165,672
3-Person $55,800 $1,395 $236 $232 $1,159 $186,381
4-Person $61,950 $1,549 $257 $258 $1,292 $206,923
5-Person $66,950 $1,674 $279 $279 $1,395 $223,624
Moderate-Income (100-120% AMI)
1-Person $52,050 $1,301 $192 $222 $1,109 $202,832
2-Person $59,500 $1,488 $233 $251 $1,255 $231,863
3-Person $66,950 $1,674 $236 $288 $1,438 $260,895
4-Person $74,350 $1,859 $257 $320 $1,602 $289,732
5-Person $80,300 $2,008 $279 $346 $1,729 $312,918
Source: U.S. Census Bureau, ACS 2017-2021 (5-year Estimates), Table B19113.

Extremely Low-income Households
Extremely low-income households earn 30 percent or less of the county family median income.

Extremely low-income households have an annual income of $13,000 or below for a one-person household and $20,100 or below for a five-person household. A very low-income household can generally afford homes offered at prices between $43,422 and $67,137, adjusting for household size. After deductions for utilities, a very low-income household can afford to pay approximately

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Merced County Association of Governments
Merced County Multi-Jurisdictional Housing Element (2024-2032) B3-34
$133 to $224 in monthly rent, depending on household size. Extremely low-income households cannot afford market-rate rental or ownership housing in Atwater.

Very- Low-income Households
Very low-income households earn between 31 and 50 percent of the county median income – up to $21,700 for a one-person household and up to $33,450 for a five-person household in 2022. A very low-income household can generally afford homes offered at prices between $72,482 and $111,729, adjusting for household size. After deductions for utilities, a very low-income household can afford to pay approximately $351 to $557 in monthly rent, depending on household size. Given the cost of housing in Atwater, very low-income households could not afford to purchase a home or rent an adequately sized unit.

Low-income Households
Low-income households earn between 51 and 80 percent of the county median income – up to $34,700 for a one-person household and up to $53,550 for a five-person household in 2022. A lowincome household can generally afford homes offered at prices between $115,905 and $178,886, adjusting for household size. After deductions for utilities, a low-income household can afford to pay approximately $676 to $1,060 in monthly rent, depending on household size. Finding appropriately sized market-rate rental housing can be challenging to households in this income group.

Median-Income Households
Median-income households earn between 80 and 100 percent of the county’s median income – up to $43,400 for a one-person household and up to $66,950 for a five-person household in 2022. The affordable home price for a median-income household ranges from $144,963 to $223,624. After deductions for utilities, a one-person median-income household could afford to pay up to $893 in rent per month and a five-person low-income household could afford to pay as much as $1,395.

Finding appropriately sized market-rate rental housing can be challenging to households in this income group.

Moderate-Income Households
Moderate-income households earn between 100 and 120 percent of the county’s median income – up to $52,050 for a one-person household and up to $80,300 for a five-person household in 2022.

The maximum affordable home price for a moderate-income household is $202,832 for a oneperson household and $312,918 for a five-person family. Moderate-income households in Merced County could afford to purchase the median priced home; however, finding an affordable adequately sized home could present a challenge for households earning incomes at the lower end of the middle/upper category. The maximum affordable rent payment for moderate-income households is between $1,109 and $1,729 per month. Appropriately sized market-rate rental housing is generally affordable to households in this income group.

Workforce Housing
Federal guidelines define workforce housing as housing that is affordable to households earning incomes within the range of 60 to 120 percent of the median income (in Atwater, that range is $37,170 to $74,340 for a household of four). A broader definition of workforce housing is housing that is affordable to people who work in the county. A four-person household with an annual

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City of Atwater
Housing Needs Assessment
2024-2032 Housing Element B3-35
income of $61,950 could afford monthly rent of $1,292 for a three-bedroom housing unit and a home purchase price of $206,923 without being burdened by housing costs. As noted in Table B3-44, the average monthly rental price for a three-bedroom unit is $1,312, just above the median income in Atwater.

Cost Burden
Table B3-46 and Table B3-47 identify cost-burdened households by tenure over time in Atwater.

There has been a decrease in the number of owner-occupied cost-burdened households from 1,446 households in 2010 to 1,104 in 2020. Cost-burdened renter-occupied households show different results, indicating noticeable increases from 1,415 in 2010 to 1,728 in 2020.

Table B3-46 Cost Burdened Owner-Occupied Households Over Time Jurisdiction 1980 1990 2000 2010 2020
Atwater 350 456 673 1,446 1,104
Percent Change 30.3% 47.6% 114.9% -23.7%
Note: Data are not inflation-adjusted to current 2022 dollars.

Source: U.S. Census Bureau, Census 1980 (ORG STF1), 1990 (STF3), 2000 (SF3); ACS 2006-2010, 2016-2020 (5-year Estimates), Table B25077.

Table B3-47 Cost Burdened Renter-Occupied Households Over Time Jurisdiction 1980 1990 2000 2010 2020
Atwater 533 968 895 1,415 1,728
Percent Change 81.6% -7.5% 58.1% 22.1%
Note: Data are not inflation-adjusted to current 2023 dollars.

Source: U.S. Census Bureau, Census 1980 (ORG STF1), 1990 (STF3), 2000 (SF3); ACS 2006-2010, 2016-2020 (5-year Estimates), Table B25077.

CHAS data provided by HUD provides information on cost burden by income category based on the HUD Area Median Family Income (HAMFI). This data is included in Table B3-48 below. While the totals do not align exactly with 2020 ACS data presented above, the CHAS data gives insight into which income categories are currently experiencing costs burdens in the city. As shown, extremely low- and very low-income households experience a high rate of cost burden greater than 30 percent, including 1,184 of 1,329 extremely low-income households and 870 of 1,198 very lowincome households.

Table B3-48 Cost Burden by Income and Tenure
Row Labels
Owner
occupied
Renter
occupied
Grand
Total
Household income is <= to 30% of HAMFI (extremely low-income) 364 965 1329 Housing cost burden is <= to 30% 75 70 145
Housing cost burden > 30% but <= to 50% 95 140 235
Housing cost burden is > 50% 194 755 949
Income is greater than 30% but <= to 50% of HAMFI (very low-income) 368 830 1198 Housing cost burden is <= to 30% 113 215 328
Housing cost burden is > 30% but <= to 50% 100 465 565
Housing cost burden is > 50% 155 150 305

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Merced County Association of Governments
Merced County Multi-Jurisdictional Housing Element (2024-2032) B3-36
Row Labels
Owner
occupied
Renter
occupied
Grand
Total
Income is > 50% but <= to 80% of HAMFI (low-income) 760 1089 1849 Housing cost burden is <= to 30% 495 670 1165
Housing cost burden is > 30% but <= to 50% 205 419 624
Housing cost burden is > 50% 60 - 60
Income is > 80% <= to 100% of HAMFI (median-income) 455 503 958 Housing cost burden is <= to 30% 300 445 745
Housing cost burden is > 30% but <= to 50% 155 58 213
Housing cost burden is > 50% - - 0
Income is greater than 100% of HAMFI (moderate-income) 2849 884 3733 Housing cost burden is <= to 30% 2,755 835 3590
Housing cost burden is > 30% but <= to 50% 94 49 143
Housing cost burden is > 50% - - 0
Grand Total 4796 4271 9067
Source: U.S. Department of Housing and Urban Development, Comprehensive Housing Affordability Strategy (CHAS) dataset, 2015- 2019 (5-Year Estimates), Table 6, Table 7.

B3.14 Assisted Housing Units
Assisted housing units are those that are restricted for use by occupants with limited household incomes. These units are assisted under federal, state, and/or local programs, including HUD programs, state and local bond programs, former redevelopment agency (RDA) programs, density bonus, or direct assistance programs.

At-Risk Housing Units
The California Housing Partnership maintains an affordable housing database to monitor changes in affordable housing and to identify units or housing developments that are at risk of converting to market-rate uses. Assisted units in the preservation data base are classified by the following risk categories:
▪ Low Risk: affordable housing units that are at-risk of converting to market rate in ten+ years and/or are owned by a large/stable non-profit, mission-driven developer. ▪ Moderate Risk: affordable housing units that are at-risk of converting to market rate in the next five to 10 years that do not have a known overlapping subsidy that would extend affordability and are not owned by a large/stable non-profit, mission-driven developer. ▪ High Risk: affordable housing units that are at-risk of converting to market rate in the next one to five years that do not have a known overlapping subsidy that would extend affordability and are not owned by a large/stable non-profit, mission-driven developer.

Table B3-49 shows assisted units in Atwater by estimated affordability end date. As shown, there are 35 assisted units in the city, and none of which are at risk of conversion by 2033.

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City of Atwater
Housing Needs Assessment
2024-2032 Housing Element B3-37
Table B3-49 Inventory of Public Assisted Complexes – Atwater Name Address City Zip Affordable Units Total Units Active Program(s) Estimated
Affordability End
Year/Date
Risk
Level
Atwater Apartments - (Site A) 1191 Willow Street Atwater 95301 35 36 LIHTC; HUD 2070 Low Note: All locally assisted or restricted developments may not be included in this list. *These developments are owned by the Merced County Housing Authority and are at low risk of conversion.

Source: California Housing Partnership, Publicly Assisted Housing Units, 2023.

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Merced County Association of Governments
Merced County Multi-Jurisdictional Housing Element (2024-2032) B3-38
Funding Sources for Assisted Housing
Preservation of at-risk housing requires not only financial resources but also administrative capacity of nonprofit organizations. The following resources are available for assisted housing.

HUD Section 8 Program
Under the HUD Section 8 program, which is administered by the Housing Authority of the County of Merced, participating building owners are entitled to receive HUD Fair Market Rents (FMRs) for units with Section 8 contracts. For Section 8 units, HUD makes up the difference between 30 percent of a household’s monthly income and the FMRs.

Low-Income Housing Tax Credit (LIHTC)
Created in 1986 by the Federal government, the LIHTC program offers tax incentives to encourage the development of affordable housing. The LIHTC is jointly administered by the IRS and State Housing Credit Agencies (HCA) and has funded over eight billion annual tax credit units nationwide.

California’s HCA is the State Tax Credit Allocation Committee (TCAC).

California Housing Finance Agency (CalHFA)
CalHFA uses approved private lenders and purchases loans that meet CalHFA standards to support very low, low, and moderate-income assisted units. CalHFA partners with jurisdictions, developers, and other organizations to provide a variety of resources including loan assistance programs for homebuyers and renters aimed at increasing housing opportunities for low- and moderate-income residents.

Housing Rehabilitation Program
The Housing Rehabilitation Program provides financing to repair income-eligible and owneroccupied homes in need of essential health and/or safety repairs. The Housing Rehabilitation program is funded by the State Department of Housing and Community Development grant programs. Common home repairs include roofing, plumbing, electrical, heating, cooling, insulation, foundation, windows, and handicap assessable modifications. Participating property must be owner-occupied and located within city limits.

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City of Atwater
Housing Constraints Analysis
2024-2032 Housing Element B4-1
B4 Housing Constraints Analysis
Constraints to the development of adequate and affordable housing include market, governmental, infrastructure, and environmental factors. These constraints may result in housing that is not affordable to low- and moderate-income households and may render residential construction economically infeasible for developers. Constraints to housing production significantly impact households with low and moderate-incomes and special needs.

According to Government Code Section 65583, local governments are required to analyze governmental and non-governmental constraints to the production, maintenance, and improvement of housing for persons of all income levels and those with special needs and, where appropriate and legally possible, remove governmental constraints to the maintenance, improvement, and development of housing as part of housing elements update. Where constraints to housing production are related to the City’s regulations or land use controls, the City must identify appropriate programs to mitigate these constraints, particularly ones that impact the production of affordable housing or housing for special needs populations.

The following chapter outlines non-governmental, governmental, environmental and infrastructure constraints and was used in the development of specific policies and actions included in the Housing Plan to remove barriers to housing and to incentivize housing production, specifically targeting housing production at all income levels and housing for persons with special needs.

B4.1 Summary of Local Housing Constraints
▪ The costs associated with developing housing have increased 30 percent over the last 12 months and are expected to continue to rise over the next fiscal year. There is a lack of federal, state, and local funding and the funding that is available is increasingly competitive. The time and effort needed to identify, compete for, and layer affordable housing funds is a major constraint to development of affordable housing in Atwater. ▪ Although Atwater’s development regulations allow for a variety of densities throughout the city, development standards are not sufficiently flexible. Height restrictions for multi-family developments, residential parking requirements for smaller units, and strict limitations on manufactured housing development all potentially constrain the development of a variety of housing types.
▪ Use permit regulations for group homes and residential care facilities could pose a constraint to housing for individuals with special needs and use permit regulations for emergency shelters and single-room occupancy (SRO) units in certain zones could pose a constraint on housing access for unhoused individuals. Additionally, the City’s definition of “family” is a constraint.

B4.2 Non-Governmental Constraints
The availability of housing is affected by a complex set of interrelated market factors including but not limited to cost of land, cost of construction, and availability of financing. These factors contribute to determining a new home’s sale price or the rents required to make a project feasible.

Non-governmental constraints include factors outside of direct governmental control that directly

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Merced County Association of Governments
Merced County Multi-Jurisdictional Housing Element (2024-2032) B4-2
impact housing prices. The cost of construction and the availability of financing contribute to the cost of housing and can hinder the production of housing. The following analysis accounts for these non-governmental constraints.

B4.2.1 Land Costs
The cost of land can impede the production of housing. Land costs are influenced by many variables, including land scarcity and developable density (both of which are indirectly controlled through governmental land use regulations), location, site constraints, availability of infrastructure improvements, and the availability of public utilities.

Table B4-1 provides the average price per acre for land listed for sale throughout Atwater in July 2023. The average price per acre is significantly higher for smaller lots ($282,611.46), most of which are located in residential or commercial zones. The price per acre is less for larger lots, averaging $34,919.99 per acre. Most of these larger properties are located in agricultural zones. The average price per acre for all plots is $158,765.73.

Table B4-1 Listed Land Prices – Atwater
Lot Size Average Price per Acre (Listed)
Less than 10 acres $282,611.46
10 or more acres $34,919.99
Average $/acre $158,765.73
Source: Zillow, Inc., 2023.

Table B4-2 provides the average price per acre for land sold in 2022 in Atwater. The average price per acre for all land sales was $245,557.50), higher than the average list price shown above. The average sales price per acre for larger lots averaged $34,865.04, which is in line with the asking price for listed properties ($34,919.99 per acre).

Table B4-2 Sold Land Prices – Atwater
Lot Size Average Price per Acre (Listed)
Less than 10 acres $456,250.00
10 or more acres $34,865.04
Average $/acre $245,557.50
Source: Zillow, Inc., 2023.

Conclusion
The housing market (vacant and developed land) in Atwater can vary depending on location, allowable density, availability of improvements, and proposed land use of the site. In general, entitled single-family subdivisions with infrastructure extension plans command higher prices than raw undeveloped land.

While land costs increase over time, these raw costs are not necessarily a constraint to housing. In general, land costs in Merced County are lower compared to coastal counties, and comparable in price to other nearby counties such as Madera and Fresno counties. As a result, raw land costs are not considered a constraint to the development of housing in Atwater.

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City of Atwater
Housing Constraints Analysis
2024-2032 Housing Element B4-3
Recommended Action
None required.

B4.2.2 Construction Costs
A major component of the cost of housing is the cost of building materials, including wood and wood-based products, cement, asphalt, roofing materials, and pipes. The availability and demand for such materials affects prices for these goods.

Another major cost component of new housing is labor. The cost of labor in Merced County is comparatively low because the area’s cost of living is relatively low compared to other areas in California. However, labor for government subsidized housing work is additionally costly for the Central Valley, as wages are rooted in the required State Labor Standards based on higher northern and southern California prevailing wages.

Based on recent affordable multi-family projects, the cost of construction in the county is estimated to be between $400,000 and $675,000 per unit.1 The estimate includes direct and indirect (e.g., insurance, permits, utilities, plans) construction costs, including material, labor, and equipment costs, the price of land, development impact fees, and administrative costs.

Table B6-3 shows the estimated typical development costs in Atwater for a single-family home, assumed to be 1,600 square feet, and a 10-unit multi-family development with 800 square foot units. This includes the price of land, site improvement costs, construction costs, and permit and development impact fees; however, this does not include financing or marketing costs by the developer. As shown in the table below, the typical cost of an individual single-family development is an estimated $772,779, while the development cost of an apartment unit is an estimated $367,556.

Table B6-3 Estimated Construction Cost – City of Atwater Cost Type Single-Family1 MultiFamily2
Home Price3 $480,000 $2,400,000
Site Improvement Cost $8,000 $20,000
Construction Cost $267,790 $1,198,400
Permit and Impact Fees $16,989 $57,160
Total Cost $772,779 $3,675,560
Cost per Unit $772,779 $367,556
1Assumed to be a 1,600 sq. ft. single-family home.
2Assumed to be a 10-unit multi-family complex of 800 sq. ft. units. 3Land price based on average price per square foot provided by the City at $300 per square foot The City of Atwater has conducted a polling of infrastructure related workers. The industry has experienced a 35 percent increase over the past three years. Construction work consisting of windows mill work and similar work has experienced a 40 percent increase over the past 24 months. 1 Central Valley Voice, City of Merced Affordable Housing Project Update, October 1, 2022, https://centralvalleyvoice.com/2023/02/22/city-of-merced-affordable-housing-project-update/ accessed June 2023.

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Merced County Association of Governments
Merced County Multi-Jurisdictional Housing Element (2024-2032) B4-4
There is little that municipalities can do to mitigate the impacts of high construction costs, apart from reducing the number of local amendments to uniform building codes that unnecessarily increase construction costs without significantly adding to health, safety, or construction quality.

Conclusion
Although the cost of construction constrains housing development, construction costs are similar across jurisdictions in Merced County, illustrating that the constraints are market driven rather than an impact of local policy.

Recommended Action
None required.

B4.2.3 Availability of Financing
Mortgage interest rates have a large influence over housing affordability. Higher interest rates increase a homebuyer’s monthly payment and decrease the range of housing that a household can afford. Lower interest rates result in a lower cost and lower monthly payments for the homebuyer.

When interest rates rise, housing prices typically fall to compensate. Similarly, when interest rates decrease, housing prices begin to rise. There is often a lag in the market, causing housing prices to remain high when interest rates rise until the market catches up. Lower-income households often find it most difficult to purchase a home during this time period.

Where financing is available, construction capital seems to be directed at the best transactions – those with large, established, and well-capitalized sponsors. Given recent trends of increasing interest rates, the availability of financing is likely to be more of a constraint on new housing construction during this Housing Element planning period than it has been in the recent past.

Market-Rate Development Financing
As discussed in Land Costs and Construction Costs, above, market-rate development is generally financed by investors, and the cost to build a project must be recovered by revenue from sales or rents, which drives up the ultimate rent or sales prices of new housing as the component costs increase. A market in which housing supply is limited and demand is high can support higher housing prices, but lower-income segments of the community are priced out. Therefore, it is difficult for the private sector, for-profit developers, and market-rate housing to meet the housing needs of all community members.

Affordable Housing Financing
A description of available funding sources for affordable development is provided in Chapter 3, Regional Housing Needs Assessment.

Mortgage and Rehabilitation Financing
The availability of financing affects the ability of residents to purchase or improve a home. Under the Home Mortgage Disclosure Act (HMDA), lending institutions are required to disclose information on the disposition of loan applications and the income, gender, and race of loan applicants. The primary purpose of reviewing the lending activity is to determine whether home financing is available to city residents. The data presented in this section includes the disposition of

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City of Atwater
Housing Constraints Analysis
2024-2032 Housing Element B4-5
loan applications submitted to financial institutions for home mortgages, home improvement, and refinance loans.

Lending activity data provides information regarding home financing availability for city residents.

The most recent data set available for Merced County from 2022 shows that 10,760 households applied for a home financing loan which includes loans for home purchase, home improvement, and refinancing. As discussed in Chapter 3, Regional Housing Constraints, of the total applications received for home purchase 47.7 percent of the loans originated while 15.7 percent were denied.

Conventional loans are made by the private sector (banks, mortgage companies, etc.) and are not guaranteed or insured by the U.S. government. Conversely, government-backed loans, such as those issued by the Federal Housing Administration, Department of Veterans Affairs, and the Rural Housing Services/Farm Service Agency, are completely or partially insured by the U.S. government. Within the county, 8,028 of the applications received were for conventional loans and 2,732 were for government backed loans. As discussed in Chapter 3, Regional Housing Constraints, 37 percent of the conventional loans originated, and 12.6 percent of the applications were denied.

Additionally, 10.7 percent of the government backed loans originated and 3.1 percent of the applications were denied.

County data shows that of the loans originated, Hispanic/Latino applicants comprised approximately 50 percent of approvals, white, non-Hispanic/Latino comprised approximately 30 percent, Asian American represented 16 percent, Black/African American applications represented three percent, and American Indian/Alaskan Native comprised less than one percent of approved applications.

American Indian/Alaskan Native and Black/African American residents were the only racial populations that was representative for mortgage applications relative to proportion of population.

Hispanic/Latino residents were underrepresented for mortgage applications (50 percent of applications, 61 percent of population). White, Non-Hispanic residents were overrepresented for mortgage applications approvals relative to proportion of population (30 percent of approvals, 26 percent of population), as were Asian American residents (16 percent of approvals, eight percent of population). Of application denials, Black/African American residents were overrepresented in application denials (four percent of denials, three percent of the population).

Construction Financing Timing
The timing between project approval and requests for building permits affects project viability.

Project delays may result from developers’ inability to secure financing for construction. In Atwater, the average time between project approval and request for building permit is typically three to nine months, but varies by type of project. Some projects take years to pull building permits and secure financing. Single-family homes usually experience the least delay (three to nine months). Multifamily housing construction tends to be more complex and usually requires more time between entitlement and building permit issuance (six to nine months).

Conclusion
Although discrimination in mortgage lending is prohibited by the federal Fair Housing Act, other factors may contribute to a potential homebuyer’s ability to secure safe financing, such as credit history, savings, and education regarding the home-buying process. Federal Financial Institutions Examination Council (FFIEC) HMDA data, by itself, does not provide insight into these other factors.

Therefore, it is important that the City supports housing education and opportunities for all residents.

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Merced County Association of Governments
Merced County Multi-Jurisdictional Housing Element (2024-2032) B4-6
Recommended Action
The City shall continue to implement goals and policies to support homeownership opportunities and home-buying education, particularly for racial and ethnic groups underrepresented in the homebuying market. This includes maintaining existing local programs such as the Homebuyer Assistance Program as well as state and federal program funding. The City will implement Program 10 to identify resources and funding to assist moderate and lower-income homebuyers. Through this program, Atwater will promote the availability of Permanent Local Housing Allocation (PLHA) funds provide assistance for qualifying applicants includes help to cover costs of mortgage, rent, rental deposit, and/or utility expenses, with the goal of assisting eight households through these funds.

B4.2.4 Requests for Lower Development Densities
Due to the use of Planned Development zones/districts identified in the City of Atwater’s Municipal Code, higher density yields are typical. The City has seen a demand for higher density housing in development applications and have not received any requests for lower densities than allowed.

B4.3 Governmental Constraints
Although local governments have little influence on market factors such as interest rates, local policies and regulations can still impact where, how much, and what type of residential development is built. Land use controls, site improvement requirements, fees and exactions, and permit processing procedures, among other policies and regulations, may constrain the maintenance, development, and improvement of housing.

B4.3.1 Land Use Controls
Land use controls provided in the General Plan and the Zoning Code influence housing production in various ways. Any permitted and conditionally permitted uses in each zone guide new development and provide both developers and the public with an understanding of how vacant land should be developed in the future. This includes the density of development that will occur within a particular zone, the compatibility of planned uses in each area, and the range and type of buildings and uses that will be located throughout Atwater.

B4.3.1.1 General Plan
The City of Atwater 2000 General Plan provides policies and programs to guide development in the city. The General Plan includes the provision of new residential neighborhoods, the development of policies that encourage mixed-use development in the downtown area and commercial areas, Zoning Code updates to accommodate residential and commercial areas, implementation of road safety measures, and the addition of an Environmental Justice element.

The Atwater General Plan contains the following residential land use designations:
▪ Very Low Density Residential: 0 to 3.0 units per acre. ▪ Low Density Residential: 3.1 to 7.0 units per acre.
▪ Medium Density Residential: 7.1 to 15.0 units per acre. ▪ High Density Residential: 15.1 to 35 units per acre

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City of Atwater
Housing Constraints Analysis
2024-2032 Housing Element B4-7
▪ Downtown Residential Mixed Use: 0 to 25 units per acre. ▪ Residential Transition: 0 to 21 units per acre.

Atwater is currently in the process of updating the General Plan, although it is unclear at this time if this update will change these residential land use designations.

Conclusion
The General Plan includes six residential land use designations with density ranges from 0 to 35 dwelling units per acre. These densities are sufficiently high to allow the development of affordable housing for all income levels. Minimum densities are included to maximize residential development on a limited supply of land as well as achieve a balance and variety of housing types.

Recommended Action
None required.

B4.3.1.2 Zoning Code
The City regulates the type, location, density, and scale of residential development primarily through the Zoning Code, as well as specific plan development codes. A zone is assigned to every parcel in the city and the Zoning Code identifies compatible uses. In general, the City’s zoning regulations are designed to encourage a more appropriate use of land, conserve and stabilize the value of property, provide adequate open space, facilitate provision of adequate community utilities, encourage building development of pleasant design, promote health and safety, and provide economic and social advantages resulting in planned use of land resources. Additionally, development standards such as setbacks, height limits, lot coverage, open space requirements, and parking are identified for each zone. Some zones may allow similar uses but have different development standards. Development standards in Atwater may be considered a constraint to the development of housing units if they are too restrictive or reduce the development potential on a specific parcel.

The City’s Zoning Code allows residential uses in the following zones:
▪ Agricultural Zones (A-P, A-R, R-R): The agricultural zones are intended to preserve lands best suited for agriculture from the encroachment of incompatible uses, as well as to protect lands designated for eventual urban development to ensure the orderly and beneficial conversion of these lands to nonagricultural use. The minimum site area is divided into three zones with varying minimum area requirements: Agricultural Preserve (A-P), Agricultural Residential (A-R), Rural Residential (R-R). The minimum site area is 10 acres for A-P, two acres for A-R, and one acre for R-R. All three zones permit single-family residences with a maximum of one unit per site.
▪ Residential Estate (R-E): The R-E zone is intended to provide living areas within the city limited to very low-density concentrations of single-family dwellings. The minimum site area is 16,000 square feet for permitted use. No more than one unit is allowed on each site in the R-E zone. ▪ Single-Family Residential (R-1): The R-1 zone is intended primarily to provide living areas at locations designated by the general plan for medium low and medium density including singlefamily dwellings. In the R-1 zone, no more than one dwelling unit is allowed on each site, except as provided under Section 17.26.030. Table B4-4 shows the minimum site area per dwelling unit in R-1 zones.

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Merced County Association of Governments
Merced County Multi-Jurisdictional Housing Element (2024-2032) B4-8
▪ Two-Family Residential (R-2): The R-2 zone is intended primarily for the development of twofamily residential structures at densities consistent with policies in the general plan. The minimum lot area is 6,000 square feet for permitted uses. The R-2 zone allows for two singlefamily dwellings or one duplex per lot on each site. ▪ Multiple-Family Residential (R-3): The R-3 zone is intended to provide living areas within the city limited to medium and high-density concentrations of multi-family housing. This includes singlefamily dwellings, duplex, and multi-family structures, except as provided under Chapters 17.22 and 17.24 of Atwater’s municipal code.
▪ Mobile home Park (R-M): The R-M zone intends to set regulations regarding mobile home parks at locations designated by the general plan. The minimum lot area is five acres with a minimum of 20 mobile home spaces.
▪ Residential Transition (R-T): The R-T zone is established to create a transition between commercial areas and adjacent residential neighborhoods, as well as on land where mixed uses have been approved through re-zoning. It can be used for median density multi-family residential zones and commercial uses on the condition that the Planning Commission approves the commercial development after a public hearing.
▪ Light Industrial Zone, Industrial Zone (M-1, M-2, respectively): The M-1 and M-2 zone and the industrial zone are intended to provide sites to accommodate process-oriented industries with modern plant or retail facilities. This also includes emergency shelters for those experiencing homelessness.

In Atwater, minimum residential lot sizes are required in some zones. Table B4-4 provides the minimum lot area per dwelling unit standard by zone.

Table B4-4 Site Area Per Dwelling Unit
Zone Lot Area
A-P 10 acres (0.1 units/gross acre)
A-R 2 acres (0.5 units/gross acre)
R-R 1 acre (1.0 unit/gross acre)
R-E 16,000 square feet (2.7 units/gross acre)
R-1-10 10,000 square feet (4.4 units/gross acre)
R-1-8 8,000 square feet (5.5 units/gross acre)
R-1-6 6,000 square feet (7.3 units/gross acre)
R-1-5 5,000 square feet (8.7 units/gross acre)
R-1-4 4,000 square feet (10.9 units/gross acre)
R-1-3 3,000 square feet (14.5 units/gross acre)
R-2 6,000 square feet (14.5 units/gross acre)
R-1-M 5,000 square feet/ unit (8.7 units/gross acre)
R-3-2 2,000 square feet/ unit (21.8 units/gross acre)
R-3-2.5 2,500 square feet/ unit (17.4 units/gross acre) R-3-1 1,000 square feet/ unit (43.6 units/gross acre)
R-3-1.5 1,500 square feet/ unit (29.0 units/gross acre) R-M 3,108 square feet/ unit (14.0 units/gross acre) [avg]

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City of Atwater
Housing Constraints Analysis
2024-2032 Housing Element B4-9
Zone Lot Area
R-T 2,000 square feet/ unit (21.0 units/gross acre)
M 0.5 acre
Source: Atwater Zoning Code, Adopted October 2023.

Conclusion
The City’s Zoning Code provides for a range of densities and is consistent with the General Plan land use designations.

Recommended Action
None required.

B4.3.2 Residential Development Standards
Table B4-5 shows the development standards for residential zones. The minimum parcel area for residential zones ranges from 3,000 square feet to five acres. Maximum site coverage is 70 to 75 percent of the lot area, depending on the zone.

The setback requirements are shown in Table B4-5.

The maximum height requirements are 35 feet for all residential zones. Maximum height requirements for ADUs are between 16 to 25 feet in all zones, depending on if the unit is attached or detached from the primary residence. Maximum density ranges from 0.1 units per acre in the A-R zone to 43.6 units per gross acre in the R-3 zone.

Table B4-5 Residential Development Standards
Zone
Minimum
Parcel Area
Minimum Setback (in feet)
Maximum
Height
(feet)1
Maximum
Height
(Accessory
Structure)
Maximum
Site
Coverage
(percent
of lot)
Maximum
Density
(du/acre)
Front
(feet)
Side
(feet)
Rear
(feet)
A-P 10 acres 30 10 30 35 35 - 0.1
A-R 2 acres 30 10 30 35 35 - 0.5
R-R 1 acre 30 10 30 35 35 - 1
R-E 2 14,300 sq. ft. 20 10 20 35 16 70 2.7
R-1-10 10,000 sq. ft. 20 10 20 35 16 70 4.4
R-1-8 8,000 sq. ft. 20 5 20 35 16 70 5.4
R-1-6 6,000 sq. ft. 20 5 15 35 16 70 7.3
R-1-5 5,000 sq. ft. 10 5 5 35 16 75 8.7
R-1-4 4,000 sq. ft. 10 5 5 35 16 75 10.9
R-1-3 2,400 sq. ft. 10 5 5 35 16 75 14.5
R-2 6,000 sq. ft. 15 5 20 35 16 70 14.5
R-1-M 5,000 sq. ft. 15 5 15 35 16 70 8.7
R-3-2.0 10,000 sq. ft. 15 5 20 35 16 70 21.8
R-3-2.5 10,000 sq. ft. 15 5 20 35 16 70 17.4

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Merced County Association of Governments
Merced County Multi-Jurisdictional Housing Element (2024-2032) B4-10
Zone
Minimum
Parcel Area
Minimum Setback (in feet)
Maximum
Height
(feet)1
Maximum
Height
(Accessory
Structure)
Maximum
Site
Coverage
(percent
of lot)
Maximum
Density
(du/acre)
Front
(feet)
Side
(feet)
Rear
(feet)
R-3-1.0 10,000 sq. ft. 15 5 15 35 - 70 43.6
R-3-1.5 10,000 sq. ft. 15 5 15 35 - 70 29.0
R-M 5 acres 20 5 5 - - 70 14
R-T 10,000 sq. ft. 10 5 5 35 16 - 21
M-1 0.5 acres 15 - - 35 - 90 -
M-2 0.5 acres 15 - - 35 6 90 -
Source: Atwater Zoning Code, Adopted November 2025.

Conclusion
Development standards related to parcel area, setbacks, height of primary structures, site coverage, and density do not constrain residential development. Limiting maximum height to 35 feet in multifamily zones is a potential constraint to housing development, specifically in the high density residential zone R-3-1.0, where achieving maximum density with a maximum height of 35 feet might be difficult. The City should provide an opportunity for minor modifications to height restrictions for developments with an affordable component.

Recommended Action
Amend the Zoning Code to allow for increased height in the R-3-1.0 residential zone to four stories and at a maximum height of at least 40 feet in order to achieve maximum density. Amend the Zoning Code to allow minor modifications to height restrictions developments with an affordability component, this will be implemented through Program 6 which will amend the development standards in the city’s Zoning Code.

B4.3.2.1 Parking
According to the Terner Center for Housing Innovation at UC Berkeley, parking can cost $25,000 to $75,000 per space to construct. However, given the age of data and the increased cost of land and construction costs discussed above, the costs per parking space are likely much higher.2 Parking provided in underground or structured parking facilities, or if required to be covered or enclosed, can significantly increase the cost of housing and could affect the feasibility of various housing projects in the city. In addition, requirements for parking space locations and maximum distances from dwelling units may also increase the cost of housing and affect the feasibility of housing projects. Requiring less parking not only reduces the project budget but can allow for more space to build additional housing units.

Atwater does not face any spatial constraints to parking provisions that would necessitate underground or structured parking facilities. However, covered or enclosed parking requirements contribute to increased housing costs in the city and potentially constrain affordable residential development.

Table B4-6 provides the residential parking requirements in Atwater. 2 Terner Center for Housing Innovation at UC Berkeley, 2016. Available at: http://ternercenter2.berkeley.edu/proforma/

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City of Atwater
Housing Constraints Analysis
2024-2032 Housing Element B4-11
Table B4-6 Residential Parking Requirements
Residential Use Required Parking Spaces
Single-family units Single-family units 2 per unit
Single-family units financed under
Farmers Home Administration
1 per unit
Multiple-family units 4 or less units 2 per unit
5 or more units 1.5 per unit
Studio apartments 2 per unit
Senior citizen housing 2 per unit
Mobile Home Park 2.2 per unit
Source: Atwater Zoning Code, Adopted October 2023.

Conclusion
Residential parking requirements for smaller units, including mobile homes, senior citizen housing, studios (2 parking spaces required per unit) pose a potential constraint to housing development.

Requiring more than one parking space for smaller units can be cost prohibitive for developers and may pose site design challenges.

Recommended Action
Revise the Zoning Code to require no more than one space per unit for mobile homes, senior citizen housing, studios, and one-bedroom units. Through Program 6, the Zoning Code will be updated to reduce parking requirements for the above housing types.

B4.3.2.2 Open Space and Park Requirements
Chapter 17.44.150.H of the Zoning Code outlines the City’s requirements for open space. Atwater names two main types of open space: private open space for reserved land for the exclusive use of residents, customers, and workers, and common open space set aside for the general public. Open space may be used for a variety of functions, such as noise buffers, aesthetics, active or passive recreation, wildlife conservation, flood control, groundwater recharge, and pedestrian and bicycle trails. The municipal code does not outline specific zones where open space and parks are required.

The City has few requirements regarding open space and parks in planned developments, although they state that the amount of open space provided should be based on the amount needed to effectively perform the function for which is intended. For example, small pockets of open space are not adequate as active recreational areas; an area large enough to support a sports court is more appropriate to perform that function. Open space buffers should also be large enough to achieve the desired goal of reducing noise. In addition, open space for recreation or social activities should be of minimum slope (less than 10 percent), take advantage of available sunlight, and be buffered from the noise and traffic of adjacent streets or other incompatible uses. Valuable natural resources such as waterways or trails and bike paths, that have been damaged or improperly used in the past, shall be restored.

In the Mobile Home Park Zone (R-M), all areas that are not occupied by mobile homes, accessory structures, and other buildings, paving or recreational facilities must be landscaped and maintained with lawn, ground cover, shrubbery or other ground materials approved by the Planning Commission. In addition, a minimum of 30 percent of the parcel must be landscaped or an open

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Merced County Multi-Jurisdictional Housing Element (2024-2032) B4-12
space recreation area, and each mobile home space must be provided with at least one tree with a preference towards shade trees. Open space recreation or common park areas should encompass at least eight percent of the total area of the mobile home park. For all zones in the medium density single-family zone, there is a minimum landscape and open space recreation requirement of 25 percent of the parcel. There are no other open space and park requirements for this zone.

Atwater’s Zoning Code has also designated the Open Space Combining Zone (O-S) to protect and maintain land to be used for outdoor recreation, the maintenance of public safety, and to encourage proper and orderly growth of the city of efficiently utilize public services, and to enhance the environment. Development in the O-S zone that does not require a building permit includes parks and recreational facilities and playgrounds including structures strictly related to recreation, flood plains, airport clear zones, public utilities, roads, trails, bikeways, information and directional signs, and temporary uses such as carnivals, fairs, exhibits and contests.

Conclusion
The open space and park requirements for planned developments, mobile home parks, and medium density single-family zones in Atwater do not constrain housing development.

Recommended Action
None required.

B4.3.2.3 Density Bonus
California law requires local jurisdictions to provide density bonuses (generally ranging from five to 80 percent) and development incentives or concessions for housing developments that include housing units that are affordable to lower- and moderate-income households or senior housing or the donation of land for housing within the local jurisdiction (Government Code Section 65915- 65918). Certain housing development projects may be granted unlimited density if they meet certain conditions, including projects where 100 percent of units are affordable units (including density bonus units) with no more than 20 percent of units for moderate-income households and the project is located within on-half mile of a major transit stop as defined by subdivision (b) of Section 21155 of the Public Resources Code. An unlimited density bonus means there is no cap on the total number of residential units per acre permitted on the site; however, there are other restrictions, such as height limits, that have a practical limiting effect on the number of units that can be built. Development incentives or concessions are reductions or modifications to site development standards or architectural design requirements that result in cost reductions, such as setbacks, parking requirements, and maximum building height.

Atwater’s 2017 Housing Element included programs directing the City to amend the Zoning Code to adopt a density bonus policy and other incentives or concessions for residential projects that include affordable or senior housing. While the necessary changes were detailed in the 2017 Housing Element, this density bonus program has not yet been codified into the City’s Zoning Code.

Inclusionary housing ordinances are implemented by local jurisdictions that require developers to reserve a certain percentage of units to further increase lower-income housing stock; however, Atwater does not have an inclusionary housing ordinance.

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City of Atwater
Housing Constraints Analysis
2024-2032 Housing Element B4-13
Conclusion
The Zoning Code does not address current density bonus standards and is not in compliance with State Density Bonus Law.

Recommended Action
Amend the Zoning Code to establish density bonuses for housing developments that include housing units affordable to very low-, low-, and moderate-income households or housing units for seniors and the donation of land for housing, consistent with current state laws and requirements.

To facilitate the development of affordable housing, the City will implement Program 7 to establish density bonus standards and density increases by adopting a Density Bonus Ordinance. Under this program, the Zoning Code will be amended by January 31, 2026, to establish density bonuses for the housing types listed above.

B4.3.2.4 On- and Off-Site Improvement Standards
The typical improvements required by local jurisdictions for subdivision and development of property include reasonable off-site and on-site improvements for the parcels being created, including those that are necessary for public health and safety and/or a necessary prerequisite for the orderly development of the surrounding area. As stated in the Department of Housing and Urban Development’s (HUD) study of Subdivision Requirements as a Regulatory Barrier, such requirements can reasonably be considered regulatory barriers to affordable housing if Atwater determines that the requirements are greater (and hence, more costly) than those necessary to achieve health and safety requirements in the community.

Citywide Development Standards
The City’s Zoning Code requires underground utilities for new residential development. Where possible, and feasible, joint use of trenching is encouraged. The City does not have the authority to require joint use of trenching by independent utility companies. Redevelopment projects and building permits proposing changes equal to more than 25 percent of the assessed value of the home, are required to bring street improvements up to City standards. In areas of the city that have previously been developed, funds for rehabilitation of substandard units have included provisions for street improvements. Street sections are designed to accommodate storm water drainage and to facilitate safe automobile, pedestrian, and bicycle circulation. Street improvements that provide sidewalks increase accessibility for persons with mobility impairments.

The City provides and operates water, sanitary sewer, and stormwater drainage services. Electricity, gas, communications, and garbage services are provided by outside entities. Utility companies that provide service to the City may require that between six and 10 feet of the area outside of the right‐ of‐way be reserved as a utility easement for the placement of service lines.

Improvement Standards
The City requires curbs, gutters, and sidewalks on all residential streets, including access ramps at corners. The typical right‐of‐way for local streets is approximately 60 feet, 40 feet of which is for pavement. The Municipal Code provides for a minimum right‐of‐way width of 60 feet for a subdivision. The Municipal Code also allows for private streets to deviate from the City standards, provided that future maintenance of the streets is assured by the developer. Streetlights and fire

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Merced County Association of Governments
Merced County Multi-Jurisdictional Housing Element (2024-2032) B4-14
hydrants are required at regular intervals within the city to ensure an acceptable level of public health and safety.

The extension of necessary utilities is also a requirement for all development in Atwater. The City provides and operates water, sanitary sewer, and stormwater drainage services. Electricity, gas, communications, and garbage services are provided by outside entities. The City has adequate capacity to provide water and sewer service to future housing development, and only needs to extend service lines to development areas. The improvement requirements imposed by those agencies are outside the purview of the City. However, the City does require approval from those agencies prior to the approval of any subdivision map. Utility companies that provide service to the City may require that between 6 and 10 feet of the area outside of the right‐of‐way be reserved as a utility easement for the placement of service lines.

Conclusion
On- and off-site improvement standards for the City of Atwater are typical of small cities and comparable to surrounding jurisdictions. The City does not consider the requirements and associated cumulative development costs of on- and off-site improvement to be greater than necessary. Although improvements contribute to the overall cost of housing projects, developers have not expressed them to be a constraint to development. However, the City will monitor such impacts in the future. Street improvements that provide sidewalks increase accessibility for persons with mobility impairments. The provision of street improvements is not a constraint to the development of housing as these requirements are necessary to achieve health and safety requirements.

Recommended Action
While on- and off-site improvement standards are not a constraint to housing development, the City will implement Housing Program 7 through which the City will provide opportunities to assist affordable housing development on a case-by-case basis.

B4.3.3 Provision of a Variety of Housing Types
Housing Element law specifies that jurisdictions must identify adequate sites that are zoned to encourage the development of a variety of housing types available to all economic segments of the population. People and households of different ages, types, incomes, and lifestyles have a variety of housing needs and preferences that evolve over time and in response to changing life circumstances. This includes single-family homes, multi-family housing, accessory dwelling units, mobile homes, agricultural employee housing, homeless shelters, and transitional housing, among others. Table B4-7 summarizes the housing types permitted and conditionally permitted in the City of Atwater.

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City of Atwater
Housing Constraints Analysis
2024-2032 Housing Element B4-15
Table B4-7 Residential Use Matrix
Residential Use A-R R-E 1 R-1
2 R-1-M R-2 R-3 R-M P-D R-T M
Single-Family (1 per lot) P P P P
Single-Family (2 per lot) P
Single-Family (Multiple) P P
Duplex P P P
Multi-family P P
Manufactured Housing C C P C P
Mobile home (1 per lot) P
Mobile home park C C
Transitional Housing P P P P P P
Supportive Housing P P P P P P
Living Quarters for Others3 A
Community Care Facilities C A
Second Unit A C
Accessory Dwelling Unit P P P
Patio Homes C
Mixed Use C
Emergency Shelter P
Nursing or Convalescent homes C
P= permitted use; A= accessory use; C= conditional use
1 This section includes R-E, R-1-10, R-1-8, R-1-6, under low density residential zones. 2 This section includes R-1-5, R-1-4, R-1-4, under medium-density single-family residential zones. 3 Chapter 17.16.030.E outlines this use as “living quarters for relatives, friends, or persons regularly employed on the premises, but not rented or otherwise conducted as a business, provided that no kitchen facilities are installed.” Source: Atwater Zoning Code, Adopted 1984
B4.3.3.1 Manufactured Housing
State law mandates that manufactured homes must be permitted in the same manner and in the same zones where conventional single-family structures are permitted (Government Code Section 65852.3). Manufactured housing is permitted in the R-M (Mobile Home Parks) and R-1-M (SingleFamily Residential-Mobile Home Zone) zones. They are also categorized as accessory dwelling units, meaning that conditional use of manufactured housing is permitted in R-E, R-1, and R-3 zones. Most of the City’s stock of manufactured housing is in mobile home parks. Although this housing type is allowed in the R-1-M zone, there is no land designated for the R-1-M zone.

Conclusion
Very few residential zones permit the construction of manufactured homes, which poses a constraint for the development of housing.

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Merced County Association of Governments
Merced County Multi-Jurisdictional Housing Element (2024-2032) B4-16
Recommended Action
The City will implement Program 6 to revise the Zoning Code to allow manufactured homes in all zones where single-family housing is permitted, subject only to the same requirements of conventional single-family housing.

B4.3.3.2 Accessory Dwelling Units
In recent years, several bills have added requirements for local governments related to accessory dwelling unit (ADU) regulation. Updates to state law in 2016 and 2017 included changes pertaining to the allowed size of ADUs, permitting ADUs by-right in at least some areas of a jurisdiction, and reduced parking requirements related to ADUs. More recent bills reduce the maximum allowable time to review and approve ADU applications to 60 days and remove lot size and replacement parking space requirements. AB 68 allows an ADU and a junior ADU (JADU) to be built on a singlefamily lot, if certain conditions are met. The State has also removed owner-occupancy requirements for ADUs, created a tiered permit fee structure for ADUs based on their size and location, and prohibits fees on units of less than 750 square feet. In addition, AB 671 requires the Housing Element to include plans to incentivize and encourage affordable ADU rentals.

In 2022, two laws were passed that affect ADU law. Both went into effect in 2023. SB 897 increases the existing height limit for attached and detached ADUs that meet certain conditions. AB 2221 clarifies existing ADU law to close procedural and permitting loopholes for approving ADUs, including the requirement for approving or denying applications within 60 days of application submittal and providing a full set of comments and remedies to applicants with denied applications.

Additionally, AB 2221 adds front setbacks to the list of local development standards that local governments cannot impose if they would preclude construction of an attached or detached ADU of at least 800 square feet, that is at least 16 feet in height and that has at least four-foot side and rear yard setbacks.

On January 1, 2025, three new laws pertaining to ADUs went into effect. These laws were signed by the Governor in September 2024. AB 2533 addresses unpermitted ADUs and JADUs, SB 1211 includes replacement parking requirements and how many ADUs are permitted on multifamily properties, and SB 1077 directs the California Coastal Commission and the Department of Housing and Community Development to develop guidance regarding ADUs and JADUs in coastal areas.

ADUs and JADUs are permitted by-right in the R-E, R-1, and R-3 zones. ADUs and JADUs are permitted as a converted unit in an existing space or a limited detached unit to each lot. Singlefamily lots permit one ADU and multi-family lots allow for one or more converted ADUs and two limited detached ADUs. Nonconforming ADUs may be permitted with a conditional use permit.

These units are subject to development standards and conditions outlined in Section 17.28.010 of the City’s Zoning Code and included below:

A. An ADU or JADU shall be either created in a residential or mixed-use zone with a building permit or in a single-family or multi-family zone with an ADU permit. a. Height. A detached ADU created on a lot with a single-family or multi-family unit may not exceed 16 feet. It may be up to 18 feet in height if it is created on a lot with an existing or proposed single-family or multi-family dwelling unit that is located one-half mile walking distance of a major transit stop or transit corridor. The ADU may be up to 20 feet in height to accommodate a roof pitch on the ADU that is aligned with that of the primary dwelling unit. A detached ADU created on a lot with a multi-family unit with more than one story above grade may not exceed 18 feet in height.

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City of Atwater
Housing Constraints Analysis
2024-2032 Housing Element B4-17
b. An ADU that is attached to a primary dwelling may not exceed 25 feet in height or the height limitation imposed by the underlying zone that applies to the primary dwelling, whichever is lower.

B. Fire Sprinklers. The ADU shall require sprinklers if the primary residence requires them. The construction of an ADU may not trigger a requirement for fire sprinklers to be installed in the existing primary dwelling.

C. Rental Term. No ADU or JADU may be rented for a term that is shorter than 30 days. This prohibition applies regardless of when the ADU or JADU was created.

D. No Separate Conveyance. An ADU or JADU may be rented, but except as otherwise provided in Government Code Section 65852.26, no ADU or JADU may be sold or otherwise conveyed separately from the lot and the primary dwelling (in the case of a single-family lot) or from the lot and all of the dwellings (in the case of a multi-family lot).

E. Septic System. If the ADU or JADU will connect to an on-site wastewater-treatment system, the owner must include with the application a percolation test completed within the last five years or, if the percolation test has been recertified, within the last 10 years.

F. Owner Occupancy. All ADUs and JADUs permitted after January 1, 2025, are subject to an owner-occupancy requirement. A natural person with legal or equitable title to the property must reside on the property for ADUs and the primary dwelling or JADU for JADUs. a. An ADU that is permitted after January 1, 2020, but before January 1, 2025, is not subject to any owner-occupancy requirement.
b. This requirement does not apply to a JADU if the property is entirely owned by another governmental agency, land trust, or housing organization.

G. Deed Restriction. A deed restriction must be recorded against the title of the property in the County Recorder’s office and a copy filed with the Community Development Department before a building permit is issued for an ADU/JADU. This restriction must run with the land and bind all future owners. The City outlines these provisions below:
a. Except as otherwise provided in Government Code section 65852.26, the ADU or JADU may not be sold separately from the primary dwelling.
b. The ADU or JADU is restricted to the approved size and to other attributes allowed by this section.
c. The deed restriction runs with the land and may be enforced against future property owners.
d. The deed restriction may be removed if the owner eliminates the ADU or JADU, as evidenced by, for example, removal of the kitchen facilities. To do so, an owner may make a written request to the Director, providing evidence that the ADU or JADU has in fact been eliminated. The Director may then determine whether the evidence supports the claim that the ADU or JADU has been eliminated. Appeal may be taken from the Director's determination consistent with other provisions of the Zoning Code. If the ADU or JADU is not entirely physically removed but is only eliminated by virtue of having a necessary component of an ADU or JADU removed, the remaining structure and improvements must otherwise comply with applicable provisions of this Code.

H. The deed restriction is enforceable by the director or his or her designee for the benefit of the City. Failure of the property owner to comply with the deed restriction may result in legal action against the property owner, and the City is authorized to obtain any remedy available to it at

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Merced County Multi-Jurisdictional Housing Element (2024-2032) B4-18
law or equity, including, but not limited to, obtaining an injunction enjoining the use of the ADU or JADU in violation of the recorded restrictions or abatement of the illegal unit. Income Reporting. In order to facilitate the City's obligation to identify adequate sites for housing in accordance with Government Code sections 65583.1 and 65852.2, the following requirements must be satisfied:
a. The applicant must provide the City with an estimate of the projected annualized rent that will be charged for the ADU or JADU when filing a building-permit application. b. Within 90 days after each yearly anniversary of the issuance of the building permit, the owner must report the actual rent charged for the ADU or JADU during the prior year. If the City does not receive the report within the 90-day period, the owner is in violation of this Code, and the City may send the owner a notice of violation and allow the owner another 30 days to submit the report. If the owner fails to submit the report within the 30-day period, the City may enforce this provision in accordance with applicable law.

I. Building & Safety.
a. The ADU/JADU units must comply with all local building code requirements. b. There must not be a change of group occupancy under the local building code, unless the building official or Code Enforcement Division makes a written finding based on substantial evidence in the record that the construction could have a specific, adverse impact on public health and safety. This does not prevent the City from changing the occupancy code of a space that was uninhabitable space or that was only permitted for nonresidential use and was subsequently converted for residential use in accordance with this section.

The City also requires additional requirements for accessory dwelling units that require an ADU permit, outlined below:

A. Maximum Size. A detached or attached ADU shall not exceed 850 square feet for a student or one-bedroom unit and 1,000 square feet for a unit with two or more bedrooms. a. An attached ADU that is created on a lot with an existing primary dwelling is limited to 50 percent of the floor area of the existing dwelling.
b. The application of other development standards in Chapter 17.28.010.F of Atwater’s municipal code might limit the size of the ADU, but it shall not require the ADU to be less than 800 square feet.

B. Floor Area Ratio (FAR). No ADU subject to Chapter 17.28.010.F may cause the total FAR of the lot to exceed 45 percent.

C. Setbacks. The ADU must conform to a four-foot side and rear-yard setback and 25-foot front yard setback, or 65 feet if it follows the provisions of Chapter 17.12.110 of Atwater’s Municipal Code. However, no setback is required if the ADU is constructed in the same location and dimensions as an existing structure.

D. Lot Coverage. No ADU subject to this section may cause the total lot coverage of the lot to exceed 50 percent.

E. Minimum Open Space. No ADU subject to this section may cause the total percentage of open space of the lot to fall below 50 percent.

F. Passageway. No passageway, as defined by Chapter 17.28.010.C.9 of Atwater’s municipal code, is required for an ADU.

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City of Atwater
Housing Constraints Analysis
2024-2032 Housing Element B4-19
G. Parking. Generally, one off-street parking space is required for each ADU, unless specified in Chapter 17.28.010.F.7.b of Atwater’s Municipal Code listed below, where no parking is required:
a. The ADU is located within one-half mile walking distance of public transit. b. The ADU is located within an architecturally and historically significant historic zone. c. The ADU is part of the proposed or existing residence or an accessory structure under Chapter 17.28.010.F.7.a of Atwater’s municipal code.
d. When on-street parking permits are required but not offered to the occupant of the ADU. e. When there is an established car share vehicle stop located within one block of the ADU. f. When the permit application to create an ADU is submi8tted with an application to create a new single-family or new multi-family dwelling on the same lot, provided that the ADU or the lot satisfies any other criteria listed above in subsections G.a-e.

H. Architectural Requirements. The materials, colors, architectural design, and roof slope of the ADU should match that of the primary dwelling. The internal horizontal dimensions of the ADU must be at least 10 feet wide in every direction, with a minimum interior wall height of seven feet. The exterior lighting must be limited to down-lights or otherwise required by the building or fire code. The ADU must have an independent exterior entrance located on the side or rear of the building and not facing the public right-of-way. All windows and doors of the ADU may not have a direct line of sight to an adjoining residential property. Windows and doors in the ADU that are less than 30 feet from a property line that is not a public right-of-way line must either be (for windows) clerestory with the bottom of the glass at least six feet above the finished floor, or (for windows and for doors) utilize frosted or obscure glass.

I. Landscape Requirements. Evergreen landscape screening must be planted and maintained between the ADU and adjacent parcels as follows:
a. At least one 15-gallon size plant shall be provided for every five linear feet of exterior wall.

Alternatively, at least one 24-inch box size plant shall be provided for every 10 linear feet of exterior wall.
b. Plant specimens must be at least six feet tall when installed. As an alternative, a solid fence of at least six feet in height may be installed.
c. All landscaping must be drought tolerant.
d. All landscaping must be from the City’s approved plant list.

J. Historical Protections. An ADU that is on or within 600 feet of real property that is listed in the California Register of Historic Resources must be located so as to not be visible from any public right-of-way.

Conclusion
The City of Atwater's ADU Ordinance was last updated in 2023 and is in compliance with California Government Code sections 65852.2 and 65852.22. The ADU Ordinance does not comply with new state laws that went into effect January 1, 2025.

Recommended Action
The City shall amend the ADU Ordinance to be in compliance with the most recent state laws.

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Merced County Association of Governments
Merced County Multi-Jurisdictional Housing Element (2024-2032) B4-20
B4.3.3.3 Multi-Family
Multi-family housing is permitted by-right in the R-2, R-3-2.5, R-3-2.0, R-3-1.5, and R-3-1.0 zones.

Multi-family development is not permitted in any other zone but can be incorporated into the R-T zone (residential transition) where a mix of two land uses has been approved over the years through re-zoning. Up to 21 dwelling units per acre may be allowed in the R-T zone, depending on environmental and site constraints.

Conclusion
Multi-family development requirements are not a constraint to residential development.

Recommended Action
None required.

B4.3.3.4 Group Homes/Residential Care Facilities
State law requires residential care facilities with six or fewer persons to be allowed by-right in all zones that allow residential uses in zones where single-family residential uses are allowed. Zoning Code section 17.06.174 defines a community care facility as any facility, place, or building which is maintained and operated to provide non‐medical residential care or day care services for children, adults, or children and adults, including, but not limited to, the physically handicapped, mentally impaired, or incompetent persons. A community care facility which services six or fewer persons is considered a residential use of the property. The Zoning Code does not specify a unique set of performance standards for community care facilities. Zoning Code section 17.06.240 defines a family as an individual or two or more persons related by blood, marriage, or adoption, or a group of not more than five persons (excluding domestic employees) who need not be related by blood, marriage, or adoption, living together in a single‐family dwelling unit. This definition could be considered a constraint in that it conflicts with state definitions allowing up to six unrelated persons within a residential context.

Community care facilities are permitted in agricultural (A-R) and low-density residential zones (R-E, R-1-10, R-1-8, and R-1-6) as accessory uses. For the A-R zone, the maximum occupancy is 12 persons, while the low-density residential zones don’t restrict the number of residents served by the facility. The City currently has no provisions in the Zoning Code to allow the development of group homes in additional residential zones.

In 2018, AB 2162 required cities to change their zoning to provide a “by-right” process and to expedite review for supportive housing projects of 50 units or fewer. This law applies to sites in zones where multi-family and mixed uses are permitted, including in nonresidential zones permitting multi-family use. Additionally, AB 2162 prohibits local governments from imposing any minimum parking requirements for units occupied by supportive housing residents if the development is located within one-half mile of a public transit stop. AB 2162 requires 25 percent of the units (or a minimum of 12 units, whichever is greater) to be approved by-right with no minimum parking. If the development consists of fewer than 12 units, then 100 percent of the units, excluding managers’ units, in the development shall be restricted to residents in supportive housing.

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City of Atwater
Housing Constraints Analysis
2024-2032 Housing Element B4-21
Conclusion
The City does not specify a detailed set of performance standards for community care facilities and only allows for such developments in two zones. The Zoning Code does not permit community care facilities with seven or more persons in all zones that permit housing, which constrains the development of these uses.

Recommended Action
The City will implement Program 6 to amend the Zoning Code to allow community care facilities serving six or fewer residents as a single-family use in all zones that permit housing and allow care facilities of seven or more residents in all zones that permit residential uses, with objectivity and approval certainty, subject only to the same restrictions imposed upon residential uses of similar type and form.

B4.3.3.5 Emergency Shelters
In 2019, AB 101 was passed requiring that a Low Barrier Navigation Center development be a use by-right in mixed use districts and nonresidential districts permitting multi-family uses. A Low Barrier Navigation Center is a low barrier, temporary, service-enriched shelter that helps homeless individuals and families obtain permanent housing. The City will need to amend its Zoning Code to explicitly allow the development of Low-Barrier Navigation Centers, by-right, in residential use and mixed-use districts, as well as nonresidential districts permitting multi-family uses.

AB 139, which went into effect on January 1, 2020, mandates that emergency shelters may only be subject to standards that apply to residential and commercial development within the same zone.

AB 139 also states that there should be sufficient parking to accommodate all staff working in the emergency shelter.

AB 2339 was passed in 2022 and went into effect January 1, 2023. AB 2339 requires that jurisdictions identify zoning designations where emergency shelters are allowed to include sites that meet at least one of the following:
▪ Vacant and zoned for residential use;
▪ Vacant and zoned for nonresidential use and located near amenities and services for homeless individuals;
▪ Nonvacant and is suitable for use as a shelter in the current planning period.

Emergency shelters are allowed by-right in the M-1 and M-2 zones and are not allowed in any zone allowing residential uses. However, due to the wide unavailability of vacant parcels in the M-1 and M-2 zones, the City also allotted areas within the Business Park (B-P) zone for emergency shelters.

The Zoning Code limits the maximum stay to six months or less. The definition of emergency shelter in the Zoning Code does not include interim interventions, (e.g., navigation centers, bridge housing, and respite or recuperative care), as required by AB 2339. The City’s standards for emergency shelters include the following:
▪ An emergency shelter may have up to 60 beds.
▪ Emergency shelters shall have separation of at least 300 feet from residential zones, parks, and schools.

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Merced County Association of Governments
Merced County Multi-Jurisdictional Housing Element (2024-2032) B4-22
▪ Facilities shall establish and maintain set hours for client intake and discharge. The hours of operation shall be consistent with the services provided and shall be posted in a publicly visible and accessible location on a sign that is no larger than one square foot. ▪ Outdoor activity and intake areas shall be screened from public view and from the view of adjacent properties.
▪ A security plan shall be submitted to the Sheriff's Department for review and approval prior to operation and shall be reviewed annually.
▪ On-site lighting shall be provided in all parking, pedestrian paths, and entry areas. ▪ A minimum of one supervisory level staff member must be present on the site during hours of operation. Operator(s) must ensure that loitering does not occur on the property during nonshelter hours and must ensure that clients are not loitering, littering, or otherwise creating a nuisance to the neighborhood.
▪ The emergency shelter shall provide on-site parking for all staff plus one space per ten occupants allowed at the maximum capacity.
▪ The maximum length of stay shall be no longer than six months, as established by the California Health and Safety Code for emergency shelters.
▪ Operation of emergency shelters shall comply with all federal, state, and local requirements, and all applicable Building, Fire, and Health and Safety codes.

The Merced County Point-in-time count estimated that 855 unhoused individuals were residing in the county in 2022, including 59 in Atwater. Of that number, 15 are unsheltered and 44 are sheltered. As shown in Table B4-8, Atwater has the potential capacity for more than 6,326 individuals in emergency shelters in the M-1 and M-2 zones, which is significantly greater than the identified 59 individuals counted in 2022.

Table B4-8 Emergency Shelter Capacity Analysis
APN Acreage Realistic Capacity (beds)
001-146-018 3.95 860
001-146-019 17.5 3,811
056-021-010 7.6 1,655
Total 29.05 6,326
Source: City of Atwater, 2023
Emergency shelters must be permitted in zones that allow residential uses. While there is sufficient capacity in M-1 and M-2 zones, these zones do not permit any type of residential uses. As a result, under Program 6, the City will amend the principal permitted uses in the Commercial Thoroughfare (C-T) zone to permit emergency shelters by-right, as well as mixed-use buildings that include residential uses. As shown in Table B4-9, Atwater has the potential capacity for 1,410 individuals in emergency shelters on vacant parcels in the C-T zone, exceeding the identified 59 individuals experiencing homelessness in 2022. These vacant C-T parcels are well situated with access to public transit and essential services. The majority of these identified parcels are located near the Atwater Loop bus route, commercial services such as grocery stores, community organizations, and health clinics. The Winton Commuter bus route also provides connections from Atwater to the City of Merced, where most countywide resources for persons experiencing homelessness are concentrated.

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City of Atwater
Housing Constraints Analysis
2024-2032 Housing Element B4-23
Table B4-9 Emergency Shelter Capacity Analysis in Commercial Thoroughfare Zone (C-T)
APN Acreage Realistic Capacity (beds)
004-110-013 1.50 327
005-120-030 1.05 228
005-120-050 2.88 627
005-120-056 1.05 228
Total 6.48 1,410
Source: City of Atwater, 2026
Conclusion
Maximum stay requirements pose a constraint to housing access for residents experiencing homelessness. In addition, emergency shelters are not allowed in any residential zones. This is not consistent with state law which requires that low-barrier navigation centers be allowed by-right in areas zoned for mixed use and nonresidential zones permitting multi-family uses. Furthermore, interim interventions are not included in the Zoning Code definition of emergency shelter.

The City requires more parking than is required to accommodate staff. As stipulated by AB 139, this adds additional project costs and is a constraint to the development of emergency shelters.

Additionally, the standard for design requirements related to views of adjacent properties and the requirement that emergency shelters have a separation of a minimum of 300 feet from residential zones, parks, and schools may also constrain development.

Recommended Action
The City will implement Program 6 to revise the definition of emergency shelter in the Zoning Code to remove maximum stay requirements, to include interim interventions, and to permit mixed-uses and emergency shelters by-right in C-N, C-C, C-T, and C-G zones subject to the same requirements for residential use of the same type in the same zone. Through Program 6, the Zoning Code will also be amended to define Low-Barrier Navigation Centers, consistent with state law and to explicitly allow by-right, in mixed-use and nonresidential districts permitting multi-family uses. The amendments to the Zoning Code under Program 6 will also ensure off-street parking requirements to provide parking spaces for staff only, remove maximum stay requirements, and remove the requirement to have a minimum 300 separation from residential zones, parks, and schools and the design requirements related to views of adjacent properties.

B4.3.3.6 Transitional and Supportive Housing
“Transitional housing” is defined as buildings configured as rental housing operating under program requirements that require the termination of assistance and recirculation of the assisted unit to another eligible program recipient at some predetermined future point in time, which shall be no less than six months from the beginning of the assistance. Transitional housing units are residential uses subject only to those requirements and restrictions that apply to other residential uses of the same type in the same zone.
“Supportive housing” is defined as housing with no limit on length of stay that is occupied by the target population and that is linked to on-site or off-site services that assist the supportive housing resident in retaining permanent housing, health services, and employment, as needed. Supportive

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Merced County Association of Governments
Merced County Multi-Jurisdictional Housing Element (2024-2032) B4-24
housing units are residential uses subject only to those requirements and restrictions that apply to other residential uses of the same type in the same zone. AB 2162, which went into effect on January 1, 2019, requires that cities allow supportive housing with up to 50 units by-right in multifamily and mixed-use zones and precludes cities from imposing parking requirements on supportive housing developments located within 0.5-mile of a public transit stop.

Transitional and supportive housing is allowed as permitted use in R-E, R-1, R-2, R-1-M, R-3, and R-T zones. R-3 zones and R-T zones also permit multi-family uses, in compliance with state law. The City does not impose additional requirements on transitional and supportive housing types beyond those that apply to residential uses.

Conclusion
The City allows transitional and supportive housing in zones allowing multi-family and mixed uses, in compliance with state law. However, the Zoning Code does not currently comply with AB 2162, whereby supportive housing that is within a half-mile of a transit line, no minimum parking spaces are required.

Recommended Action
Through Program 6, the City will update the Zoning Code to comply with AB 2162, whereby for supportive and transitional housing located within half-mile from transit, no minimum parking can be required.

B4.3.3.7 Farmworker Housing / Employee Housing
The Employee Housing Act (Health & Safety Code Section 17021.6) requires that any employee housing consisting of no more than 36 beds in group quarters or 12 units or spaces designed for use by a single family or household, shall be deemed an agricultural land use. No conditional use permit, zoning variance, or other zoning clearance shall be required of employee housing that is not required of any other agricultural activity in the same zone. The permitted occupancy in employee housing in a zone allowing agricultural uses shall include agricultural employees who do not work on the property where the employee housing is located. Health and Safety Code Section 17021.8 mandates that eligible agricultural employee housing developments are subject to a streamlined, ministerial approval process and not subject to a conditional use permit.

The Zoning Code does not allow the development of farmworker housing or employee housing in any residential or zone that permits agricultural uses. Further, there is no definition of farmworker housing or employee housing provided in the current Zoning Code.

Conclusion
The Zoning Code does not permit the development of farmworker and employee housing in any zone. The City’s Zoning Code does not comply with state law regarding farmworker/employee housing.

Recommended Action
The City will implement Program 6 to revise the Zoning Code to permit employee housing for six or fewer employees as a single-family residential use in zones that permit agricultural uses, allow farmworker and employee housing with up to 36 beds in group quarters or up to 12 units or spaces designed for use by a single-family or household as an agricultural use, and to allow eligible

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City of Atwater
Housing Constraints Analysis
2024-2032 Housing Element B4-25
agriculturally employee housing developments to be permitted ministerially to ensure compliance with the Employee Housing Act (Health & Safety Code Section 17021.6).

B4.3.3.8 Single-Room Occupancy Units
The City currently has no provisions in the Zoning Code to allow the development of single-room occupancy units (SROs).

Conclusion
Zoning Code standards do not permit the development of SROs, which constrains the production of a wide variety of housing types in the city.

Recommended Action
The City will implement Program 6 to revise the Zoning Code to allow the development of SROs in residential zones allowing multi-family uses (R-2, R-3) and/or in commercial zones allowing hotel and motel uses (C-C, C-T, DB-D, B-P). Additionally, the City will establish a procedure to encourage and facilitate SRO development in the allowable zoning districts.

Housing for Persons with Disabilities
California Government Code Section 65583 requires local jurisdictions to analyze potential and actual government constraints on the maintenance, improvement, and development of housing for persons with disabilities. This is to ensure that persons with either physical or mental disabilities are provided with reasonable accommodation for access to and the enjoyment of all facilities, including housing. Government Code Section 65583(c)(3) also requires housing elements to provide a program to “…address, and where appropriate and legally possible, remove governmental constraints to the maintenance, improvement, and development of housing for persons with disabilities.”
This section analyzes if the zoning policies and permitting procedures in Atwater impose any constraints to persons with disabilities accessing appropriate and adequate housing in the city.

B4.3.3.9 Definition of Family
Local jurisdictions may restrict access to housing for households that do not meet the jurisdiction’s definition for “family.” A restrictive definition of “family” that limits the number of individuals living together may illegally limit the development and siting of group homes for persons with disabilities, but not for housing families that are similarly sized or situated.

The City of Atwater’s definition of family is as follows:
▪ “Family” means an individual or two or more persons related by blood, marriage, or adoption, or a group of not more than five persons (excluding domestic employees) who need not be related by blood, marriage, or adoption, living together in a single-family dwelling unit.

Conclusion
The City’s definition of “family” restricts the number of persons living together to five. This is a constraint to the development of group homes with six or more persons. Additionally, the Zoning Code should not distinguish between biologically related and unrelated persons.

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Merced County Association of Governments
Merced County Multi-Jurisdictional Housing Element (2024-2032) B4-26
Recommended Action
Revise the City’s Zoning Code to remove the limit of number of persons residing in a dwelling unit as a “family” to comply with fair housing law The City will implement Program 6 to amend the Zoning Code to revise the definition of “family” to comply with fair housing laws.

B4.3.3.10 Reasonable Accommodation Procedures
The federal Fair Housing Act and the California Fair Employment and Housing Act require that cities and counties provide reasonable accommodation where such accommodation may be necessary to afford individuals with disabilities equal housing opportunities. Cities and counties must also consider requests for accommodations related to housing for people with disabilities and provide the accommodation when it is determined to be “reasonable” based on fair housing laws and the case law interpreting the statutes.

Reasonable accommodation is one of the tools intended to further housing opportunities for people with disabilities. These accommodations require that local jurisdictions make modifications or exceptions in their zoning laws and other land-use regulations when accommodations are necessary to afford individuals with disabilities an equal opportunity to use and enjoy a dwelling. For example, it may be a reasonable accommodation to waive a setback requirement so that a paved path of travel can be provided to residents with mobility impairments.

Reasonable accommodation enables developers and providers of housing for people with disabilities a means of requesting from the local government flexibility in the application of land use and zoning regulations or, in some instances, even a waiver of certain restrictions or requirements because it is necessary to achieve equal access to housing.

The City enforces the California Building Code (Title 24 of the California Code of Regulations), which regulates the access and adaptability of buildings to accommodate person with disabilities (access standards, safety measures, braille sign standards, etc.). The City allows existing and new homes to be retrofitted or fitted for features that provide accessibility and independent living for persons with disabilities. Handicapped parking is not addressed in the City’s parking requirements, but it is a provision in the California Building Code.

The City does not require special building code compliance or additional levels of review to build, improve, or convert housing for persons with physical disabilities. Requests for modifications to ensure disability housing access and accommodations do not require a building permit and many other accommodations can be permitted over the counter. Requests for reasonable accommodation can be made directly to the City’s ADA coordinator contact as listed on the City website for ADA Information. Resolution of the issue or request will begin immediately. There are no associated fees for requests for reasonable accommodation. Any person with disabilities or individuals representing such person can request permits for reasonable accommodations for disabled persons to City staff to allow modifications to facilitate access to housing for persons with disabilities, who use a standard entitlement process to ensure land use compatibility and sited facilities.

Conclusion
Atwater enforces state requirements related to reasonable accommodation. However, the City does not provide written procedures or guidelines for reasonable accommodations. This is a constraint for housing for persons with disabilities.

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City of Atwater
Housing Constraints Analysis
2024-2032 Housing Element B4-27
Recommended Action
The City should establish a written procedure for reasonable accommodation requests and provide the information on the City website.

B4.3.4 Planning and Development Fees
The development review process is intended to regulate all projects. Through this process, residential yard size and other open space uses are determined, which in turn control population density for conformance with the General Plan. Regulation is necessary to conserve and stabilize property values, provide adequate open space, diminish street congestion; facilitate adequate community utilities such as transportation, water, sewage, schools, parks, and other public facility requirements; and to safeguard public health, safety, and general welfare.

The City charges various fees and assessments to cover the cost of processing permits and providing certain services and utilities. Development impact fees in Atwater are reasonable in comparison to other jurisdictions in the state and region. Table B4-10 describes residential development planning fees for both single- and multi-family development.

Table B4-10 Residential Development Planning Fees
Fee Title Single-Family Unit Cost
Annexation Application $3,063 plus $115 per acre
Pre-zoning Deposit $2,041 + actual cost
Specific Plan Preparation Actual Cost + 20%
General Plan Amendment Preparation Deposit of $2,031, Actual Cost + 20% Site Plan Review Deposit of $1,029 + actual cost
Tentative Subdivision Map Deposit of $3,046 + $61 per lot, Actual Cost + 20% Tentative Parcel Map Deposit $1,876 + $61 per lot, Actual Cost + 20% Conditional Use Permit Actual Cost. $2,000 Minimum Deposit Variance Deposit $993, Actual Cost + 20%
Zone Change Deposit $1847, Actual Cost + 20%
PD Zone: Master Plan Application Deposit $2242, Actual Cost + 20% PD Zone: Final Development Plan Application Deposit $2242, Actual Cost + 20% Environmental Assessment Actual Cost + 20%
Source: City of Atwater, Miscellaneous Fee Schedule, Amended June 27, 2022.

Table B4-11 shows development impact and permit fees for single-family and multi-family prototype developments. The total cost of development impact and permit fees for a typical 12,000 square foot single‐family house on an existing lot is in excess of $22,000, or about 10.5 percent of the median sales price of $208,000 for such a home in Atwater. For a typical 800 square foot unit in a multi‐family development, these fees are approximately $14,000 per unit.

Table B4-11 Residential Development Fees
Impact Fees
Cost Per Unit
Single-Family Multi-Family
Development Impact and Connection Fees

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Merced County Association of Governments
Merced County Multi-Jurisdictional Housing Element (2024-2032) B4-28
Impact Fees
Cost Per Unit
Single-Family Multi-Family
Parks and Recreation $1,240 $1,020 per unit
Sewer Connection $400 $400 per unit
Sewer Capacity Fees Dwelling Unit: $3,667
Mobile Home: $3,312
Dwelling Unit: $3,667 per unit
Mobile Home: $3,312 per unit
Water Connection $400 $400 per unit
Water Capacity Fees Residential Estate: $2,989
Detached Single-Family Residential: $2,689
Med/High Density Residential: $1,257
per unit
Government Building $949 per acre $949 per acre
Fire $1,038 per acre $1,038 per acre
Police $800 per acre $800 per acre
Traffic Circulation $3,684 per acre $3,684 per acre
Traffic Signals/Options $312 per acre $312 per acre
Subtotal $21,958 $13,945
Development Permit Fees
Building Inspection Based on a Fee Type (Sq Footage) Based on Fee Type (Sq Footage) Building Plan Check
75% of project valuation or Based on 3rd
Party Hourly Rate
75% of project valuation or Based on 3rd
Party Hourly Rate
Site Improvement Inspection 3% of improvement value 3% of improvement value Site Improvement Plan Check Cost + 25% Cost + 25%
Notes:. Typical 6,000 sq. ft. residential lot and 1,500 sq. ft. single-family unit Source: City of Atwater, Schedule of Fees, 2023.

Single-family development fees in Atwater are comparable to similarly sized cities in the same county. Fees for a single-family unit range are approximately $21,958 in Atwater but range from $12,326 to $58,103 in the cities of Livingston, Dos Palos, Gustine, Los Banos, and Merced. Similarly, fees for multi-family are comparable, at approximately $13,945 per multi-family unit in Atwater.

Multi-family fees range from $8,997 to $47,550 per unit in other cities in the region. Table B4-12 shows a comparison of development fees in other Merced County jurisdictions.

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Atwater City CouncilAugust 10, 2026

Atwater City Council
August 10, 2026