Escalon City Council
August 10, 2026

Escalon 2023-2031 Housing Element Fair Housing Assessment – Section 5 p. 46

5.5.2 Overcrowding
Households where the number of occupants per room falls between 1.01 and 1.5 are considered to be overcrowded. Households with a ratio exceeding 1.51 persons per room are designated as being severely overcrowded. The calculation of persons per room excludes spaces such as bathrooms, porches, foyers, halls, and half-rooms. This method of assessing residential overcrowding not only sheds light on living conditions but also holds implications for demographic and socioeconomic contexts. Studies have shown that overcrowding is linked to an elevated risk of contracting communicable diseases, a higher prevalence of respiratory illnesses, and a heightened vulnerability to homelessness. In Escalon, 11 households are overcrowded.

Table 13: Occupants Per Room for Households by Race and Ethnicity in Escalon, 2021 Race or Ethnicity Total
Households
# Units with 1.00 or
Fewer Occupants
Per Room
# Units with 1.01 or
More Occupants
Per Room
Total Non-Institutionalized
Population 2,866 2,855 11
White Alone, Not Hispanic or
Latino 2,024 2,024 0
Black or African American Alone 38 38 0
Asian Alone 32 32 0
Hispanic or Latino (of any race) 460 449 11
Source: U.S. Census Bureau, American Community Survey 5-Year Estimates, 2021

Escalon 2023-2031 Housing Element Fair Housing Assessment – Section 5 p. 47 Data concerning severe overcrowding by race and ethnicity is not available, but there is data on severe overcrowding by housing tenure. In Escalon, there are no households, owner-occupied or renter-occupied, that are severely overcrowded.

Table 14: Overcrowding for Households by Tenure in Escalon, 2021 Tenure Total Households
# Units with 1.00 or
Fewer Occupants
Per Room
# Units with 1.01 to 1.50
Occupants
Per Room
# Units with 1.50 or
More Occupants
Per Room
OwnerOccupied 2,048 2037 11 0
RenterOccupied 818 818 0 0
Source: U.S. Census Bureau, American Community Survey 5-Year Estimates, 2021

Escalon 2023-2031 Housing Element Fair Housing Assessment – Section 5 p. 48 As shown in Figure 25 and Figure 26, less than 10% of all housing units are overcrowded or severely overcrowded.

Figure 25: Overcrowded Households by Census Tract

Escalon 2023-2031 Housing Element Fair Housing Assessment – Section 5 p. 49 Figure 26: Severely Overcrowded Households by Census Tract

Escalon 2023-2031 Housing Element Fair Housing Assessment – Section 5 p. 50

5.5.3 Substandard Housing
As outlined by the U.S. Census, substandard housing issues can be categorized into two types: (1) Residences lacking amenities like hot and cold piped water, a flush toilet, and a bathtub or shower; and (2) Homes where kitchen facilities are deficient, such as the absence of a sink with piped water, a stove or range, or a refrigerator. In San Joaquin County, 1.7% of renter households lack a complete kitchen and 0.6% lack plumbing.

Rates of substandard housing are lower in Escalon than San Joaquin County with no households lacking complete kitchens or plumbing.

Table 15: Substandard Housing Issues in Escalon & San Joaquin County, 2021 Escalon
(2010)
Escalon
(2021)
San Joaquin
County
(2010)
San Joaquin
County
(2021)
Owner Renter Owner Renter Owner Renter Owner Renter
Lacking Complete
Kitchen (%) 0.0 0.0 0.0 0.0 0.4 1.9 0.4 1.7
Lacking Plumbing
(%) 0.4 0.0 0.0 0.0 0.5 0.6 0.3 0.6
Similar to the limited percentage of inadequate housing units in Escalon, the neighboring regions also exhibit minimal levels of substandard housing units. Areas within the surrounding region that do contain substandard housing units hover around 5%, with most substandard housing units in the unincorporated county areas. Figure 27 and Figure 28 indicate that 5-10% of housing units to the east of Escalon lack complete plumbing and kitchen facilities. However, this area slightly surpasses the threshold at 5.49% and is within the general range of the surrounding region.

Escalon 2023-2031 Housing Element Fair Housing Assessment – Section 5 p. 51 Figure 27: Regional Housing Units Lacking Complete Plumbing

Escalon 2023-2031 Housing Element Fair Housing Assessment – Section 5 p. 52 Figure 28: Regional Housing Units Lacking Complete Kitchen

Escalon 2023-2031 Housing Element Fair Housing Assessment – Section 5 p. 53 Figure 29 depicts the structural age of housing within Escalon. As shown in the map below, older housing is dispersed throughout the City, with a slight predominance of housing built before 1960 located east of Escalon Avenue and newer subdivisions generally located outside of the downtown core. City staff estimate that 50 units throughout the City are in need of rehabilitation. Program 3-2 has been included to facilitate rehabilitation of units in need, with a target of proactively reaching and supporting the improved energy efficiency conditions of 50 households throughout the planning period through the provision of low-flow plumbing fixtures or comparable electrical upgrades.

Figure 29: Age of Structures

Escalon 2023-2031 Housing Element Fair Housing Assessment – Section 5 p. 54

5.5.4 Displacement
Changes in neighborhood composition often stem from established patterns of racial inequity and segregation. Neighborhood change is influenced by three processes: the movement of people, public policies, and investments such as capital improvements and planned transit stops, along with the flow of private capital. These processes can disproportionately affect people of color, lower income households, individuals with disabilities, larger families, and those who are at risk of homelessness or currently experiencing homelessness. Additionally, they can also cause displacement and homelessness.

In this context, displacement refers to the involuntary relocation of a household due to actions taken by landlords or shifts in the market. Displacement is driven by a combination of increasing housing costs, income inequality, stagnant wages, and inadequate production of housing at market rates. Decades of disinvestment in low-income communities can result in rent gaps, or disparities between current rental income and potentially achievable rental income if the property is converted to its most profitable use.

Consequently, market forces and speculative investment can contribute to the occurrence of displacement.

The University of California, Berkeley (UCB) Urban Displacement Project Bay Area Model 2020 identifies Escalon as Lower Displacement Risk for all households (Figure 30, Figure 31, Figure 32. The surrounding areas of Stockton and Modesto are identified as At-Risk of Displacement, Elevated Displacement, and High Displacement for all households.

Escalon 2023-2031 Housing Element Fair Housing Assessment – Section 5 p. 55 Figure 30: Displacement Risk for All Households, 2022

Escalon 2023-2031 Housing Element Fair Housing Assessment – Section 5 p. 56 Figure 31: Displacement Risk for Low-Income Households, 2022

Escalon 2023-2031 Housing Element Fair Housing Assessment – Section 5 p. 57 Figure 32: Displacement Risk for Very Low-Income Households, 2022

Escalon 2023-2031 Housing Element Fair Housing Assessment – Section 5 p. 58 Displacement can also occur as a result of natural disasters. Figure 33 and Figure 34 identify areas that are at risk of flooding and disaster-driven displacement. In Escalon, the Special Flood Hazard Areas are located outside of the City.

Figure 33: Special Flood Hazard Areas Near Escalon, 2022

Escalon 2023-2031 Housing Element Fair Housing Assessment – Section 5 p. 59 Figure 34: Special Flood Hazard Areas in the San Joaquin Valley Area, 2022

Escalon 2023-2031 Housing Element Fair Housing Assessment – Section 5 p. 60

5.5.5 Homelessness
The Department of Housing and Urban Development (HUD) defines homelessness as any, “individual or family who lacks a fixed, regular, and adequate nighttime residence,” or an individual whose, “primary nighttime residence [is] not designed for or ordinarily used as a regular sleeping accommodation… including a car, park, abandoned building, bus or train station, airport, or camping ground.” This also includes those at risk of being homeless, those fleeing domestic violence, those who have no other residence, and those who lack the resources to obtain permanent housing. HUD defines a ‘‘chronically homeless’’ individual as “a homeless individual with a disability [who has been homeless] … continuously for at least twelve (12) months or on at least four (4) separate occasions in the last three (3) years, where the combined occasions total a length of time of at least twelve (12) months.”
The most recent homeless count (Point-In-Time Count) in Escalon was in 2024, when one (1) unsheltered person was counted. In Escalon, there is no emergency shelter housing. Emergency shelters are located in the surrounding jurisdictions of Modesto, Manteca, Tracy and Modesto. Information regarding the three most recent Point-In-Time Counts in Escalon and the surrounding area can be found in Section 4.

Escalon 2023-2031 Housing Element Fair Housing Assessment – Section 5 p. 61 Figure 35: Emergency Shelter Housing, 2021
Section 5.6 Contributing Factors & Housing Programs
Data compiled in this Fair Housing Assessment found potential challenges to fair housing and to equal access to affordable housing throughout the City, including the following:

1. Availability of affordable units in a range of sizes

2. Inaccessible sidewalks, pedestrian crossings, or other infrastructure

3. Lack of language access

4. Community opposition

5. Land use and zoning laws

6. Lack of resources for fair housing agencies and organizations

5.6.1 Ranking of Contributing Factors
Contributing factors are the factors that create, contribute to, perpetuate, or increase the severity of fair housing issues, including the following factors identified.

Escalon 2023-2031 Housing Element Fair Housing Assessment – Section 5 p. 62 The first high priority contributing factor is availability of units in a range of sizes. Programs support ADUs, missing middle housing, and zoning for a variety of housing types, all to address disparate housing needs including displacement risk.

The second contributing factor relates to connectivity. Any future for Escalon would be best served by greater linkages between neighborhoods, especially for residents in need of pedestrian connectivity and/or public transportation.

The third contributing factor is lack of language access. Programs are primarily focused on bringing greater Spanish language access into housing sustainability, tenant support, and voucher applications through robust public outreach.

The fourth contributing factor is community opposition regarding segregation and integration. Escalon’s housing programs support integration on a local and regional basis.

The fifth contributing factor is land use and zoning laws. The City has a variety of programs to come into compliance with State law and support the development of a variety of housing types in Escalon to reduce disparities in access to opportunities.

The sixth and final contributing factor pertains to lack of resources for fair housing agencies and organizations. As a community relatively distanced from population centers with highest access to fair housing resources, Escalon can actively pursue connection with regional partners and fulfill fair housing actions as an independent resource. Program actions contained in the Housing Strategy include regional and local solutions.

5.6.2 Contributing Factors & Program Actions
The following Programs will be implemented to address these prioritized fair housing issues and contributing factors (ranked by highest, high, and moderate priority):

Table 16: Fair Housing Issues, Contributing Factors, and Program Actions Contributing Factor Program Actions
Availability of units in a
range of sizes
(Highest Priority)
Program 2-1: Zoning for a Variety of Housing Types
Program 2-3(A): Missing Middle Housing – SB 684/SB
1123
Program 2-3(B): Missing Middle Housing – SB 9
Program 2-4: Accessory Dwelling Units
Inaccessible sidewalks,
pedestrian crossings, or
other infrastructure
(Highest Priority)
Program 2-2: Senior Housing
Program 2-5: Affordable Housing Funding & Incentives
Program 3-1: Neighborhood Improvements
Lack of language access
(High Priority)
Program 3-4(C): Bilingual Energy Efficiency Outreach
Program 3-4(D): Bilingual Energy Conservation Outreach

Escalon 2023-2031 Housing Element Fair Housing Assessment – Section 5 p. 63 Program 5-2(A): Bilingual HCV Information
Program 5-2(B): Bilingual Tenant/Landlord Rights Toolkit Program 5-2(E): Bilingual Rental Agreements in CityAssisted Developments Program 5-3(B): Bilingual Tenant Relocation Assistance
Information
Community opposition
(High Priority)
Program 1-1(A): Housing Administration
Program 1-3: Accessible & Transparent Development
Application Information and Standards
Program 4-1(B): Removal of Constraints – Developer
Outreach
Land use and zoning laws
(Moderate Priority)
Program 1-3: Accessible & Transparent Development
Application Information and Standards
Program 2-1: Zoning for a Variety of Housing Types
• (A): Permanent Supportive Housing
• (B): Low Barrier Navigation Centers
• (C): Employee Housing
• (D): Junior Accessory Dwelling Units
• (E): Residential Care Facilities
• (F): Manufactured Homes
• (G): Family Housing
• (H): Density Bonus Law
• (I): Single-Room Occupancy Housing
• (J): Emergency Shelters
Program 4-3: Parking Reductions for Eligible Projects
Lack of resources for fair
housing agencies and
organizations
(Moderate Priority)
Program 5-1: Equal Housing Opportunity
Program 5-4: Housing Choice Vouchers
Program 5-5: Reasonable Accommodation

Escalon 2023-2031 Housing Element Fair Housing Assessment – Section 5 p. 64

5.6.3 Housing Programs & AFFH Considerations
The Housing Programs outlined in Section 2 address a variety of fair housing issues and opportunities, including housing mobility, the provision of new housing opportunities in areas of higher opportunity, place-based strategies for community revitalization, anti-displacement measures, and outreach and enforcement mechanisms to ensure that the City is proactively engaging the community to access these programs. Each program includes metrics that the City will use throughout the planning period to measure its success in affirmatively furthering fair housing.

In order to affirmatively further fair housing, an agency will ensure that actions within its jurisdiction avoid perpetuating patterns of segregation, and actively support integration. Most programs have citywide geographic targeting designations due to the small size of Escalon – 7,471 residents as of 2020. Yet in comparison to the region, Escalon has a comparatively high resource designation, and regional efforts can support the greater Escalon community moving forward.

Table 17: Housing Program Metrics to Affirmatively Further Fair Housing Action Area Key Program Specific
Commitments
Timeline Geographic
Targeting
2023-2031
Metrics
Housing
Mobility
Program 5-2:

Removal of
Impediments to
Fair Housing
Provide fair
housing
information,
conduct outreach
to areas with
CC&Rs,
host/participate in
Housing Resource
Fair, include
bilingual rental
agreements,
partner with
regional
organizations.

Ongoing, with
deliverables
ranging from
June 30, 2024 to
December 31,
2031.

Citywide,
including
neighborhoods
and subdivisions
with Covenants,
Conditions &
Restrictions
(CC&Rs).

Educate renters,
homeowners, and
landlords on fair
housing laws and
resources
available to
promote
increased
housing stability,
fair housing
practices, and
affirmatively
further fair
housing.

Escalon 2023-2031 Housing Element Fair Housing Assessment – Section 5 p. 65 Place-Based
Strategies for
Community
Revitalization
Program 3-1:

Neighborhood
Improvements
Capital
Improvement Plan
(CIP) prioritization;
explore accessory
commercial units
(ACUs).

Annually, with
CIP update,
following HEU
adoption, and
ACUs by 2030.

Citywide,
emphasizing
areas with aging
housing stock &
infrastructure.

Support at least
three capital
improvement
projects in areas
of highest need.

Displacement Program 5-3:

Anti-Displacement
Actions
Require
replacement
housing units,
provide bilingual
information, assess
tenant relocation
provisions, and
apply for
rehabilitation
funding.

Ongoing, with
deliverables
ranging from
March 30, 2025
to December 31,
2031.

Citywide,
including
affordable
housing
developments.

Maintain and
rehabilitate two
single-family
residences and
14 trailers of the
existing housing
stock, require
code compliance
for rental units,
monitor the
affordability of 42
affordable units,
and ensure
tenants are paid
relocation
payments for nofault just cause.

Outreach &
Enforcement
Program 4-2:

Housing Outreach
and Stakeholder
Engagement
Survey, meetings,
partnership,
marketing
materials, and
religious institution
outreach.
(Bi)annually,
ongoing;
marketing,
outreach by
June 2025.

Regional,
including
developers active
in San Joaquin
and Stanislaus.

Secure funding
and monitor the
effectiveness of
programs,
procedures, and
incentives.

Escalon 2023-2031 Housing Element Fair Housing Assessment – Section 5 p. 66

5.6.4 Local Data & Knowledge
The Contributing Factors and the Fair Housing Assessment as a whole are largely informed by Federal and State data. In addition to these quantitative data sources, local data and knowledge provide a holistic assessment of fair housing issues to inform the City’s fair housing analysis and program actions. The following table addresses and summarizes key issues highlighted by the State Department of Housing & Community Development (HCD) in the May 2024 publication, A Guide for Incorporating Local Data and Knowledge based on local knowledge from staff and community feedback.

Table 18: Local Data and Knowledge of Fair Housing Issues in Escalon Action Area Criteria Question Response
Segregation
and Integration
Race
Any areas or
neighborhoods
considered to be
concentrated minority
communities?
Households in Escalon
are generally integrated,
with higher racial
segregation noted in
small farmworker housing
clusters and labor camps
scattered through the
surrounding orchards and
dairies in this part of San
Joaquin/Stanislaus
County.

Are any areas known
to have particularly
low concentrations of
minority residents?
Escalon is primarily
populated by White and
Latino residents with no
prominent geographic
concentrations of racial
minorities.

Are there any known
historic factors that
have led to these
patterns? Are there
current factors that
reinforce these
patterns? Are there
any factors that are
changing these
patterns over time?
Change in populations
from demographics with
single digits such as
Black and Native
American population
have diminished in
numbers.

Escalon 2023-2031 Housing Element Fair Housing Assessment – Section 5 p. 67 Segregation
and Integration
(cont.)
Disability
Any areas or
neighborhoods with
concentrations of
persons with
disabilities?
No, approximately 7.8
percent of the Escalon
population has a
disability. Of the 578
people with a disability,
433 (75 percent) are over
the age of 35. The age
group with the highest
percentage of individuals
with a disability is the 65
to 74 are group, with

23.35% of these
individuals having a
disability. Within Escalon,
the percentage of the
population with a
disability is slightly higher
(10%) on the east side of
the City (east of
McHenry) than on the
west side (7.5%). Local
staff have indicated that
the City’s largest senior
care facility and the two
senior mobilehome parks
are also located on the
east side of McHenry,
which may contribute to
the disparity.

Any concentrations of
group homes or
residential care
facilities?
Residential care facilities
and group homes are
generally distributed
throughout Escalon.

Have there been any
permits issued for
construction of ramp
or other accessibility
modifications to
homes in the area?
No known recent
requests for accessibility
modifications.

Reasonable
accommodation is

Escalon 2023-2031 Housing Element Fair Housing Assessment – Section 5 p. 68 Segregation and
Integration
(cont.)
Disability
(cont.)
Have any requests for
reasonable
accommodation been
made during the last
planning period?
provided over the counter
at no charge.

Any locational
differences in terms of
disabilities? Recent
accessibility
improvements? Areas
in need of
improvements?
Older neighborhoods
generally require greater
infill improvements to
ensure amenities (such
as ADA-compliant
sidewalks), the City of
Escalon has incorporated
ADA upgrades into the
Capital Improvement
Program (CIP).

Familial Status
Any areas or
neighborhoods with
concentrations of
families? Non-families
or smaller homes?
No known prominent
concentrations of
families, non-families or
smaller homes such as
mobile and trailer parks.

Any child care
facilities? Any
locational differences?
Childcare facilities and
schools are generally
integrated throughout
Escalon.

Income
Any areas of the
community that are
considered to be
lower-income, highpoverty areas?
Older neighborhoods in
Escalon express some
disparities in income,
including in mobile home
communities and trailer
parks primarily located
east of McHenry Avenue.

Any areas of the
community that are
considered to be
higher-income areas?
Newer neighborhoods
tend to be correlated with
higher median incomes,
as noted by Census block
group data for
subdivisions generally

Escalon 2023-2031 Housing Element Fair Housing Assessment – Section 5 p. 69 Segregation
and Integration
(cont.)
Income (cont.)
located on the City’s west
side.

Are there any known
areas where a lot of
HCV/Section 8 renters
live?
No known concentrations
of renters with Section 8
Housing Choice
Vouchers.

Any housing assisted
by public financing in
the city? If so, any
areas of the city with a
concentration of
housing assisted by
public financing?
The City does not have
any known areas with
concentrations of
assisted housing, and
participates in financing
programs that can help
residents access or
improve affordable
housing citywide.

Disparities in
Access to
Opportunity
Education
Discuss local schools
and geographic
availability.

In Escalon Unified Schol
district, there are seven
schools within the district
elementary, middle and
high school. Schools are
distributed throughout the
City, with minimal
disparities in student
achievement.

Discuss local school
performance
compared to the
region.

Per student achievement
data, Escalon has
comparable or better
educational achievement
than the surrounding
region.

Discuss local
performance and any
differences in access
to education
opportunities from
neighborhood to
neighborhood.

School achievement is
roughly equivalent across
Escalon neighborhoods.

Data for English
Language Arts/Literacy
and Mathematics
achievement levels within
EUSD, comparing them

Escalon 2023-2031 Housing Element Fair Housing Assessment – Section 5 p. 70 Disparities in
Access to
Opportunity
(cont.)
Education
(cont.)
against both the San
Joaquin County and
State of California
averages. EUSD
outperforms the County
average in the higher
achievement categories
of "Standard Exceeded"
and "Standard Met" in
both subjects. In the
EUSD, County, and
State, over two-thirds of
students scored within
the "Standard Nearly
Met" and "Standard Not
Met" categories in
Mathematics.

Discuss any upper
education
opportunities,
including vocational
opportunities.

No community colleges
or universities within
Escalon; residents are
located within proximity to
San Joaquin Delta
College.

Discuss any trends
and past and current
local efforts to
improve access to
education
opportunities.

Escalon continues to
invest in educational
access as the City grows.

Do community
members have the
opportunity to select
the schools that their
students attend, or are
schools assigned by
geography? Are there
private or charter
options in the
community? If families
In Escalon there are
seven schools, 2,724
students, 40.4%
economically
disadvantaged, 60%
minority enrollment
(52.7% Hispanic/Latino,

41.8% white, 1.7% Asian,

0.8% Black). Parents do
not choose their school

Escalon 2023-2031 Housing Element Fair Housing Assessment – Section 5 p. 71 Disparities in
Access to
Opportunity
(cont.)
Education
(cont.)
have the ability to
select schools, are
there higher-demand
schools in the
community?
but are assigned by
address.

Are there any known
factors that influence
the current rates of
high school
graduation or college
attendance?
No known factors of local
significance.

Are there any
organizations that
provide services like
tutoring that could
help to improve
educational
outcomes? Any
differences between
neighborhoods in
terms of access?
No known factors of local
significance.

Any new
subdivisions? New
master planned
areas? Differences in
schools?
The City’s new
subdivisions are
generally located on the
western side of Escalon.

Economic
What are the major
employers in the area,
or major industries?
Where are they
located?
Are there major
industries that are not
nearby that many
residents work in?
How has this changed
The largest employer in
Escalon is the City itself.

Agriculture surrounding
the City provides another
form of employment for
Escalon residents.

The City’s relative
proximity to the Bay Area
and Greater Sacramento
economies further
provide for employment

Escalon 2023-2031 Housing Element Fair Housing Assessment – Section 5 p. 72 Disparities in
Access to
Opportunity
(cont.)
Economic
(cont.)
recently? Are there
new areas of the
county that have
developed commercial
or industrial uses? Or
are there areas that
were previously job
centers that are no
longer in as high of
use?
opportunity within a larger
commute shed.

No changes, central of
the city maintains most of
facilities. Areas of
revitalization include
some of these public
facilities and nearby
roads with CIP.

Is high-speed internet
readily available in the
area? Do any areas
have known
challenges with cell
signal access?
High-speed internet and
cellular data is readily
available throughout
Escalon with no known or
prominent disparities in
access.

Are there any known
economic
development
programs or initiatives
planned or in place
that might influence
the jobs landscape in
the next ten years?
The City participates in
economic development
initiatives focused on
workforce development
and diversification
intended to bring
technical support to cities
in the Central Valley such
as Escalon.

Transportation
Discuss countywide
transportation system,
including different
modes.

Full discussion in Section

5.4.4 (Transportation).

Discuss local access
to the countywide
transportation system,
such as routes and
locations.

Local transportation
access includes eTrans
daily round trips to
Modesto. Bus stops are
primarily located along
the McHenry Avenue
corridor, through the
City’s downtown and to
the Almond Grove mobile

Escalon 2023-2031 Housing Element Fair Housing Assessment – Section 5 p. 73 Disparities in
Access to
Opportunity
(cont.)
Transportation
(cont.)
home park on the City’s
eastern side. Dial-A-Ride
services are also
available for the general
public.

Discuss any local
efforts to assist
access to different
transportation modes,
including public
transit, walking and
biking.

The City utilizes a Dial-ARide system, limiting
citywide disparities.

How do residents
without access to a
car travel to work or to
access resources like
medical care? Is this
different depending on
the industry that
residents work in?
Consistent with suburban
jurisdictions throughout
California, residents
without access to a car
may experience higher
bus headways than in
urban areas. Residents in
Escalon can connect to
the City’s transit network,
with destinations primarily
in core areas of
surrounding cities.

Agricultural employees in
the broader region may
experience pronounced
difficulty traveling to work
without a personal
vehicle due to
decentralized locations.

Any engineering
reports or
assessments of
capital improvements?
Any differences
between
neighborhoods?
The City’s Capital
Improvement Plan (CIP)
prioritizes roadway
deterioration, sidewalk
gaps, drainage
deficiencies, accessibility
barriers, and streetscape

Escalon 2023-2031 Housing Element Fair Housing Assessment – Section 5 p. 74 Disparities in
Access to
Opportunity
(cont.)
Transportation
(cont.)
conditions in the City’s
older neighborhoods.

What are the physical
conditions of local
roads like? Are there
street lights, traffic
lights, or bike
infrastructure in any
parts of the
community?
The City’s pavement
condition is generally
favorable, with some
older areas with greater
deterioration. The City’s
bike network is primarily
comprised of Class II
bicycle lanes on major
arterials like McHenry
Avenue.

Are there known highcollision corridors or
areas of high traffic on
a regular basis?
The City’s major arterials
are more prone to
collisions than
neighborhood streets.

Any Safe Routes to
Schools plans or
programs in place?
Where in the
community are
sidewalks available or
not available? Any
differences between
neighborhoods?
Escalon maintains an
active Safe Routes to
School program in
coordination with EUSD,
with past improvements
around Dent Elementary,
El Portal Middle School,
and Escalon High School.

Sidewalk conditions vary
by neighborhood age:
older central core and
east side areas have
more gaps and missing
ADA ramps, while newer
west side subdivisions
generally have
continuous, ADA
compliant sidewalks. The
City’s CIP prioritizes
sidewalk infill and ADA
upgrades in older
neighborhoods to

Escalon 2023-2031 Housing Element Fair Housing Assessment – Section 5 p. 75 Disparities in
Access to
Opportunity
(cont.)
Transportation
(cont.)
improve access to
schools.

Any major community
facilities and any
differences in access
between
neighborhoods?
Major community facilities
are concentrated
centrally, given the size of
Escalon rather than being
evenly distributed across
distinct neighborhood.

However, neighborhood
parks and schools are
distributed throughout
Escalon.

Any differences
between
neighborhoods in
terms of access to
transportation
options? Biking?
Walking?
Neighborhoods are
primarily defined by age,
with newer
neighborhoods farther
from key amenities than
older neighborhoods, but
with more complete,
ADA-accessible
infrastructure.

Have there been any
major infrastructure
investments in the
recent past? This can
include, but is not
limited to, roads,
bridges, or
water/sewer
infrastructure. Are
there any major
infrastructure projects
planned for the next
ten years?
Escalon has completed
several recent
infrastructure
investments, including
ADA sidewalk upgrades,
pavement rehabilitation
on key arterials, and
targeted water and sewer
line replacements in older
neighborhoods. Over the
next ten years, the City’s
Capital Improvement
Program identifies major
projects such as roadway
resurfacing on Escalon
Avenue, continued
sidewalk infill and ADA
upgrades, storm drainage

Escalon 2023-2031 Housing Element Fair Housing Assessment – Section 5 p. 76 Disparities in
Access to
Opportunity
(cont.)
Transportation
(cont.)
improvements in older
east side neighborhoods,
and phased water/sewer
system modernization to
support planned growth
areas.

Environment
Any public safety
reports (e.g., water
quality, sewer,
circulation)? Any
differences between
neighborhoods?
Escalon Avenue, from
State Route 120 to the
northerly City limits, has
plans to be rehabilitated
with new pavement
overlay and thermoplastic
striping, and
reconstruction of
deteriorating sidewalks
on the west side between
Lillian Avenue and La
Mesa Street.

Are there known
major sources of
pollution in the area?
Where are they
located, if so? This
could include things
like industrial sources,
groundwater
contamination from
agriculture, or lead
paint exposure in
older homes.

Are there places
where residential
development should
be avoided due to
environmental
conditions, or where
existing environmental
conditions are
Localized pollution is
generally derived from
industrial areas in south
Escalon. Consistent with
the region, pesticide drift
can also be a broader
factor in pollution
generated by agricultural
activity. Due to the
industrial concentration
on the south end of
Escalon, the City’s
housing stock is located
to the north, west, and
east of the City and the
City’s Housing Sites
Inventory reflects that
need as well.

Escalon 2023-2031 Housing Element Fair Housing Assessment – Section 5 p. 77 Disparities in
Access to
Opportunity
(cont.)
Environment
(cont.)
negatively effecting
residents?
Do any
neighborhoods lack
access to parks or
other outdoor spaces?
Are there other
notable community
amenities, and where
are they? Any
differences between
neighborhoods in
terms of access?
Parks are located mainly
in the center of Escalon,
with neighborhood
disparities in residential
neighborhoods.

Are there any new
subdivisions or new
master planned
areas? Any
differences in parks,
other amenities
between
neighborhoods?
New subdivisions in the
development pipeline
include Murphy Ranch on
the City’s western edge.

Parks and amenities are
generally distributed
throughout Escalon’s
neighborhoods.

Are there any
differences between
neighborhoods with
respect to access to
shopping? Healthy
foods?
The City’s larger grocery
stores (Escalon Food
Center, Mar-Val) are
generally located on the
eastern side of the City.

Disproportionate
Housing Needs,
Including
Displacement
Overpayment
Any recent increases
in rents or sales
prices? Any
differences between
neighborhoods? How
does that compare to
incomes in the area?
A majority of Escalon
residents surveyed noted
an increase in housing
costs over the last ten
years. No known
significant disparities by
neighborhood.

Any patterns of
evictions or
No known disparate
patterns of evictions or

Escalon 2023-2031 Housing Element Fair Housing Assessment – Section 5 p. 78 Disproportionate
Housing Needs,
Including
Displacement
(cont.)
foreclosures between
neighborhoods?
foreclosures between
neighborhoods.

Overcrowding
Are there any areas
that are known to
have higher rates of
household
overcrowding, such as
"doubling-up" families
in one house? Any
information from code
enforcement officers?
Older neighborhoods
surrounding the City’s
central core tend to have
more overcrowding, as
supported by data and
anecdotal accounts.

Housing
Conditions
Any areas of the City
with more or less units
in need of
rehabilitation and
replacement?
Older homes closer to the
City’s downtown core are
generally in greater need
than newer subdivisions
at the City’s edges.

Any differences in
housing conditions
based on unit types
(single family,
multifamily,
mobilehome) and
locations?
Housing conditions are
generally consistent
across housing type, and
more closely correlated
with age of structures.

Are there any known
areas where the
physical conditions of
housing suggest a
high need for
rehabilitation for
safety or accessibility
reasons?
The City has limited
homes found in need of
demolition or substantial
rehabilitation for
habitability reasons.

Escalon 2023-2031 Housing Element Fair Housing Assessment – Section 5 p. 79 Disproportionate
Housing Needs,
Including
Displacement
(cont.)
Housing
Conditions
(cont.)
Have there been any
subdivisions
developed in the past
ten years? If so, how
large were the lots in
these developments?
Are there differences
between new
subdivisions and older
areas? any new
master planned areas
that have different
infrastructure?
Differences in rents
and prices and
locational differences?
Subdivisions within the
past ten years have
mostly been small lot
subdivisions, with larger
projects undergoing
development approval.

Are there any types of
housing that are
known to be not
widely available? If so,
which neighborhoods?
The City is predominated
by single-family homes,
with limited large
multifamily development.

Are there any areas
where there have
been a high rate of
code enforcement
complaints? What
were the issues that
drove the complaint?
No known areas of
disproportionate code
enforcement complaints.

Persons
Experiencing
Homelessness
Are there any areas
where homeless
community members
tend to congregate?
This could either be
encampment areas,
parking areas where
people who live in
vehicles park, or
areas where people
congregate during the
The City of Escalon does
not have a consistent
population of homeless
residents. The City of
Escalon has taken action
to address homelessness
by working with the City’s
regional partners to direct
individuals experiencing
homelessness to
resources within San

Escalon 2023-2031 Housing Element Fair Housing Assessment – Section 5 p. 80 Disproportionate
Housing Needs,
Including
Displacement
(cont.)
Persons
Experiencing
Homelessness
(cont.)
day, such as libraries,
parks, or community
centers. If so, is there
access to
transportation,
services and
programs?
Joaquin and Stanislaus
County.

Any programs to
provide emergency
rental assistance? If
so, how is that
assistance available?
Any differences
between
neighborhoods?
Escalon Strong is a
community resilience and
support initiative in the
City of Escalon that
emerged to coordinate
local resources,
volunteers, and
communication during
times of need, including
during the COVID-19
pandemic.

Displacement
Any areas or
neighborhoods that
have experienced
significant increases
in rents and sales
prices? Are people
moving or evicted as a
result?
A majority of Escalon
residents surveyed noted
an increase in housing
costs over the last ten
years. No known
significant disparities by
neighborhood.

Any local events that
led to displacement?
No known local events
exacerbate displacement.

Do any areas have a
higher percentage of
housing with higher
susceptibility to
environmental
damage due to
building age or
design?
The City’s older
neighborhoods in the
central core are more
likely to have homes in
need of rehabilitation or
repair due to age.

Escalon 2023-2031 Housing Element Fair Housing Assessment – Section 5 p. 81 Other Relevant Factors
Describe any past
zoning or land use
decisions that
influenced socioeconomic patterns.

Broad patterns of singlefamily zoning have
shaped Escalon in a
manner similar to
comparable jurisdictions
throughout California and
the nation. The existing
housing stock exhibits a
greater variety of housing
types closer to the
downtown core that are
more accessible to
residents of a variety of
incomes.

Describe any
settlement trends,
major developments
or population trends
that influenced socioeconomic patterns.

Does the city have
any defining features
to the land use
pattern? Topography,
Railroads? Highways?
Major roadways?
Does that influence
socio-economic
patterns?
Escalon’s flat
topography supported
early
agriculture, railroads catal
yzed settlement and
economic activity,
and highways have
expanded its role in
regional commerce.

These factors have
collectively shaped a land
use pattern that blends
rural agricultural land with
limited suburban
development, with socioeconomic patterns rooted
in farming, transportation
logistics, and regional
connectivity.

Any recent
engineering reports,
assessments of
infrastructure supply
or quality, public
safety reports, capital
The City’s Capital
Improvement Plan (CIP)
is adopted on a five-year
cycle and includes
investments in areas with
aging infrastructure to

Escalon 2023-2031 Housing Element Fair Housing Assessment – Section 5 p. 82 Other Relevant Factors (cont.)
improvement
program? Does this
information describe
or show any
differences?
better connect Escalon’s
circulation network.

Escalon 2023-2031 Housing Element Fair Housing Assessment – Section 5 p. 83 Section 5.7 Fair Housing & Housing Sites

5.7.1 Segregation & Integration
Housing sites identified to meet Escalon’s RHNA are distributed throughout the community in a manner that affirmatively furthers fair housing. Escalon contains areas designated as Highest Resource, High Resource, and Moderate Resource, and sites are primarily distributed throughout these Highest and High Resource, not concentrated by income, and supported by fair housing programs.

Figure 36: Housing Sites and Resource Areas
The following table includes analysis of sites by location within Escalon with relation to fair housing indicators including neighborhood segregation, access to opportunity, and displacement risk. The City’s tracts do not exhibit a disparity in citywide segregation, and sites are distributed throughout the City. The City’s lowest-income block group contains the highest share of both lower-income and above-moderate RHNA, and the highestincome block group contains the second highest share of lower-income RHNA.

Escalon 2023-2031 Housing Element Fair Housing Assessment – Section 5 p. 84 Table 19: Distribution of RHNA Capacity by Census Tract/Block Group & AFFH Indicators Block
Group Tract
RHNA Capacity
AFFH Indicators
Segregation & Integration Access to Opportunity Displacement Risk VLI
LI
MI AMI
Median Household IncomeNeighborhood Segregation Typologies2020 LatinoWhite Pop. (%)Disability Rate (%)2026 TCAC Resource AreaEcon. ScoreEnv. ScoreEdu. ScoreOvercrowding Rate (%)Overpayment Rate, Renter (%)Overpayment Rate, Owner (%) 1 49.03
(W)
0 0 5 $87,000 High
Segregation 32/60 7.80
High

0.66 0.61 0.63 0.00 52.44 25.37
2 213 53 91 $67,074 High
1 49.04
(E)
58 25 0 $111,222
High
Segregation 31/60 8.84
High

0.71 0.64 0.68 1.89 52.79 37.07
2 0 0 0 $95,878 Moderate
3 0 0 0 $73,500 Moderate
4 10 2 1 $69,295 High

Escalon 2023-2031 Housing Element Fair Housing Assessment – Section 5 p. 85

5.7.2 Racially & Ethnically Concentrated Areas of Poverty There are no racially/ethnically concentrated areas of poverty or racially concentrated areas of affluence within Escalon.

5.7.3 Disproportionate Housing Needs Including Displacement Risk of displacement and cost burden are highest amongst low-income renter households. The location of housing sites will not exacerbate these conditions, and programs are included to address this need, including Program 5-3: Anti-Displacement Actions.

Table 20: Summary of Local Data and Knowledge
Category City of Escalon – Summary of Local Data and Knowledge Housing
Conditions
Age of housing stock: 20% of homes east of McHenry / Escalon Avenue were built before 1960. West-side neighborhoods tend to be somewhat newer overall, with more homes built between 1978 and 1995 but the west side has a larger mix of building dates.

Substandard plumbing/kitchen: Citywide, no households lack complete plumbing or kitchens; a small pocket located just east (but outside of) the city shows 5.49% of units with incomplete facilities, slightly above the 5% “concern” threshold but still lower than adjacent unincorporated areas.

Windshield survey: One red-tagged single-family home in northwest Escalon needs demolition/replacement; this opportunity site is included in the City’s Sites Inventory. Otherwise, no dilapidated units were observed in need of replacement or major rehabilitation. According to Building & Code Enforcement staff, there are no areas or blocks that have shown repeated health and safety violations.

Code
Enforcement
Insight
City staff report low overall case volume. Most complaints received by Code Enforcement involve minor yard or exterior maintenance issues, with no neighborhood standing out as a “hot spot.”
Overpayment
& Cost Burden
71 % of renter households and 22% of owner households pay >30 % of income toward housing (HUD CHAS, 2019). Spatial analysis shows:
‒ North Escalon: 40-60% of renters are cost-burdened;
‒ South Escalon: 40-60% of homeowners are cost-burdened.

Cost burden pressures affect both tenure groups, with some variation between sub-areas within the City. Generally, owners of newer homes on

Escalon 2023-2031 Housing Element Fair Housing Assessment – Section 5 p. 86 the west side of Escalon tend to be more cost-burdened than owners of older homes on the east side. The cost burden for renters is more evenly dispersed throughout the City. A small area in southwest shows a significantly higher percentage of cost burden/overpayment for homeowners (40-60%) than for renters (20% of less); however, this is an industrial area with only one residentially-zoned parcel, indicating potential inaccuracies in the reporting data.

Overcrowding Only 11 households citywide are overcrowded (>1.01 persons/room), and no households are severely overcrowded (>1.5). Overcrowding is not spatially concentrated: maps show <10 % overcrowding in every tract, and staff confirm that there are no clear areas of overcrowding.

Displacement
Risk
The UC-Berkeley Urban Displacement Project classifies all of Escalon as “Lower Displacement Risk” for all, low-income, and very-low-income households. Flood-hazard zones lie outside city limits, so disasterinduced displacement risk is minimal. No recent large-scale redevelopment, evictions, or rent hikes have been reported by staff.

Homelessness Point-in-Time counts recorded 4 unsheltered individuals in 2019; the 2022 PIT count did not cover Escalon. The 2024 count identified only 1 unsheltered person. City staff report that there are no fixed encampments; and providers indicate that homelessness is transient within the City and is generally handled through referrals to regional shelters.

Mobile-/Manufactured Home
Communities
A 103 space mobile homes park on Jackson Avenue, established in 1972, provides a form of affordable housing for Escalon seniors. Program 5-3 provides for the rehabilitation of 14 trailers and relocation assistance for any no-fault evictions. No current closure threats have been identified.

Other Local
Risk Indicators
Vacancy is low (1.5%), indicating limited surplus housing.

Extremely-Low-Income (ELI) renters: 64.5% experience at least one housing problem (cost burden, overcrowding, or substandard conditions).

Since overcrowding and substandard issue rates are very low in Escalon, the predominant housing problem for ELI households is cost burden/overpayment.

Female-headed households (9.4% of Escalon households) have median incomes that 57% below the citywide median, elevating cost burden and overpayment risk.

Escalon 2023-2031 Housing Element Fair Housing Assessment – Section 5 p. 87

5.7.4 Disparities in Access to Opportunity
There are minimal disparities in access to opportunity by protected class and income throughout Escalon. Sites on the southern end of the City are located in a Moderate Resource Area. Program 3-1: Neighborhood Improvements is included to support infrastructure improvements in Moderate Resource areas and adjacent to new developments.

5.7.5 Improved and Exacerbated Conditions
The identified housing sites are spread throughout the City and sites with capacity for lower-income housing are not concentrated in areas with a high concentration of existing affordable housing. Escalon’s sites are primarily located within High and Highest Resource Areas, higher than the most neighboring jurisdictions in both San Joaquin and Stanislaus Counties. Additionally, fair housing conditions are not exacerbated by the housing development anticipated within the 6th Cycle Housing Element.

Fair Housing Considerations in Site Selection. Housing sites identified to meet Escalon’s RHNA are distributed across the City in a manner that affirmatively furthers fair housing. As shown on the Housing Sites and Resource Areas map (Figure 36), sites, especially those intended to accommodate lower-income households, are primarily located in High and Highest Resource areas rather than clustered in any single neighborhood. Escalon has no R/ECAPs or areas of high segregation and poverty, so placing new affordable units in these higher-opportunity areas is expected to support integration and not exacerbate segregation patterns. This approach aligns with the TCAC/HCD opportunity framework (resource-area designations) used in the Fair Housing Assessment.

Findings on Improved/Exacerbated Conditions and Mitigations. The analysis finds minimal disparities in access to opportunity across Escalon and confirms the identified sites do not worsen fair-housing conditions. A small number of sites in the city’s south lie in a Moderate Resource area; these are paired with place-based investments (Program 3-1: Neighborhood Improvements) and anti-displacement measures (Program 5-3) so development in Moderate areas is accompanied by infrastructure upgrades and tenant protections. The Urban Displacement Project classifies all of Escalon as “Lower Displacement Risk,” which the City intends to maintain through these program actions. Collectively, the geographic distribution of sites and the paired program commitments are expected to improve access to opportunity for lower-income households and avoid exacerbating patterns of segregation or displacement risk.

Escalon 2023-2031 Housing Element Fair Housing Assessment – Section 5 p. 88

5.7.6 Sites by Access to Healthy Environment
As identified in Section 5.4.3 (Access to a Healthy Environment), Escalon does not have a CalEnviroScreen 4.0 score indicating substantial pollution, and all portions of the City are in the 58th percentile relative to statewide census tracts. Regionally, Escalon has lower (favorable) scores in comparison to neighboring communities such as Riverbank and Oakdale. Therefore, the Sites Inventory would not concentrate lower-income units in areas of disproportionate pollution burden.

The highest outlier in Escalon’s overall CalEnviroScreen 4.0 score included a 99th percentile rating for toxic releases. This data is likely linked to historic pollution events, and there are no known major pollution events within the prior planning period that would indicate a deviation from the broader San Joaquin Valley Air District’s 29% decrease in toxic air emissions from 2013 to 2022. Housing Element sites are separated from the City’s industrial zones to uphold environmental health and public safety.

Escalon has three major supermarkets distributed throughout the City: the Escalon Food Center (downtown), Mar-Val (south end on McHenry), and Orlando’s Market (east end on Yosemite). The distribution of housing sites throughout Escalon provides residents with consistent access to full-service grocery stores with nutritious options, alongside a variety of lower-cost options including delis, convenience stores, and the Dollar General.

Residents facing food insecurity have central access to the downtown food pantry and mobile farmers market distribution service hosted by Community Action Resources of Escalon (C.A.R.E.), with programs to provide weekly supplemental food to 110-120 income-qualifying households, alongside a program for seniors over 60 years of age.

Furthermore, the greater Escalon area has a rich agricultural heritage, with fresh produce available for purchase directly from purveyors at farmstands along major arterials in all directions outside of City limits.

5.7.7 Sites by Access to Transportation
Sites are primarily located within ½ mile of a transit stop, with all sites and pipeline projects serving low-income residents accessible to transit. Local bus service runs along McHenry Avenue and the eastern stretch of Highway 120, and the western side of Escalon is farther from bus stops. However, the service operates as a dial-a-ride system, lessening the need for a resident to be in close proximity to a bus stop to achieve mobility. The western half of Escalon is a High and Highest Resource Area, and the relative lack of transportation does not indicate an exacerbation of segregation patterns. The sole inventoried site outside of ½ mile of transit is Murphy Ranch, a 72-unit pipeline project with 67 marketrate and 7 moderate-income for-sale units. To ensure comprehensive transportation opportunity is pursued for all Escalon residents, Program 3-1(D) is included to coordinate existing transportation planning efforts with expanded citywide service. For further information, see Section 5.4.4 (Transportation).

Escalon 2023-2031 Housing Element Fair Housing Assessment – Section 5 p. 89 Figure 37: Transit Stop Areas, Caltrans, 2023
Walk Score© is a nationally recognized, place-based metric that measures the walkability and bikeability of a location based on proximity to everyday amenities such as schools, grocery stores, parks, retail, and services, with higher scores indicating that more daily needs can be met on foot. In Escalon, the majority of inventoried sites are located in areas with favorable Walk Scores, reflecting strong pedestrian access to the City’s core amenities, including schools, parks, neighborhood retail, civic services, and employment opportunities. This pattern demonstrates that most sites support daily needs being met within a short walking distance, which can reduce transportation cost burdens and increase household mobility.

From an affirmatively furthering fair housing (AFFH) perspective, siting housing in walkable, amenity-rich areas advances place-based strategies by promoting equitable access to community assets, supporting residents who may not have reliable vehicle access, and reinforcing inclusive neighborhood development. Locating housing opportunities in these walkable contexts helps address historic patterns of exclusion by ensuring that lower-income households, families, seniors, and people with disabilities have access to neighborhoods that provide connectivity, services, and quality-of-life benefits comparable to those available to higher-income residents.

Escalon 2023-2031 Housing Element Fair Housing Assessment – Section 5 p. 90 Despite a variety of scores among inventoried sites, all sites suitable for affordable housing development were located within a 20-minute walk to Downtown Escalon.

Program 4-3(C) is included in the Housing Strategy to ensure that new developments contain micromobility (bike and scooter) parking consistent with State law, and to enhance bicycle and pedestrian access within new housing development. The following table details Walk Scores and Bike Scores for sites included in the Housing Element:

Table 21: Walk & Bike Scores, Escalon Housing Sites Inventory, 2023-2031 Site
# Site Address Walk Score Bike Score
1 1124 E California St 72 – Very Walkable 52 – Bikeable 2 1090 E California St
1070 E California St
1062 E California St
73 – Very Walkable 53 – Bikeable
3 1034 E California St 66 – Somewhat Walkable 53 – Bikeable 4 1112 First St 64 – Somewhat Walkable 49 – Somewhat Bikeable 5/6 3100 S McHenry Ave
3200 S McHenry Ave 31 – Car-Dependent 33 – Somewhat Bikeable 7 S McHenry Ave 31 – Car-Dependent 33 – Somewhat Bikeable 8 1310 Irwin Ave 52 – Somewhat Walkable 45 – Somewhat Bikeable 9 1780 Autumnwood Ct 13 – Car-Dependent 30 – Somewhat Bikeable 10 1260 Lillian Ave 68 – Somewhat Walkable 52 – Bikeable 11 1511 Catherine Way 28 – Car-Dependent 31 – Somewhat Bikeable 12 1155 Escalon Ave 58 – Somewhat Walkable 50 – Bikeable 13 2149 Jackson Ave 66 – Somewhat Walkable 49 – Somewhat Bikeable Citywide 73 – Very Walkable 53 – Bikeable

Escalon 2023-2031 Housing Element Fair Housing Assessment – Section 5 p. 91

5.7.8 Sites by Access to Educational Opportunities
The location of housing sites west of McHenry Avenue generally position prospective residents with opportunities to attend desirable public schools, including Van Allen Elementary School located two miles west of City limits at Van Allen Road and Highway 120. Collegeville and Farmington Elementary Schools, located 8-10 miles north/northwest of Escalon, had comprehensively lower test scores and educational metrics than schools within the City of Escalon and the immediate vicinity.

Escalon has one traditional elementary, middle, and high school located within City limits:

Dent Elementary (K-5), El Portal Middle (6-8), and Escalon High (9-12). These schools possess test scores and other educational metrics roughly comparable to statewide averages, with all falling in the top 50% of California public schools.

California Department of Education data indicated a slight disparity in school enrollment by race and ethnicity in greater Escalon. Dent Elementary, El Portal Middle, and Escalon High noted a majority or near-majority of Hispanic/Latino attendees in contrast with Escalon Charter Academy (65.8% white) and Van Allen Elementary (54.5% white).

Further, Escalon Charter Academy noted the lowest share of economically disadvantaged students eligible for free or reduced-price lunch (26%) in contrast with the remainder of Escalon area schools ranging from Escalon High (43%) to Dent Elementary (57%).

Given the moderate disparities between educational options and location of Housing Element sites in proximity to high performing schools, sites are distributed in a manner that affirmatively furthers fair housing and improves access to educational opportunities for Escalon residents.

Escalon 2023-2031 Housing Element Fair Housing Assessment – Section 5 p. 92

5.7.9 Sites by Access to Recreational Opportunities
Escalon’s park system includes recreational opportunities distributed throughout the four quadrants of the City, with parks catering to a variety of ages with amenities including play areas, grass areas, barbecues, sports fields and courts, and a covered gazebo and stage downtown. Housing sites are distributed throughout the City with consistent access to the parks system in a manner that affirmatively furthers fair housing.

Figure 38: Escalon Parks, Schools and Housing Sites

Adoption Draft
Appendices
August 2026
Attachment 5

City of Escalon 2023-2031 Housing Element - Appendix A p. 1

APPENDIX A
This section outlines the City’s progress toward achieving its 5th Cycle Housing Element programs, including lessons learned and information about specific populations served, where available. This evaluation of the effectiveness of the 5th Cycle Programs informed the identification of new and modified programs for the 6th Cycle Housing Element. A summary of the City's overall progress in achieving its 5th Cycle programs is provided at the end.

Table A1: 2019 Housing Element Program Implementation Status Program Timeframe Progress and Lessons
Learned Status
Program 1-1 Maintain
Residential Zoning
Retain existing residential zoning
and discourage non-residential
uses in these zones through
maintaining Zoning Ordinance
provisions that require:
• A use permit for of all
nonresidential uses in
residential zoning,
• Site plan approval of any
residential use of more than
three units and all
nonresidential uses; and,
• Construction of at least an
8-foot masonry wall to
separate residential uses
from non-residential uses.

Ongoing
This program was
successfully
implemented and
residential uses and
lands were protected. No
residentially-zoned lands
were lost to other uses
during the planning
period.

Program is implemented
through existing zoning and
does not need to be carried
forward.

City of Escalon 2023-2031 Housing Element - Appendix A p. 2 Program 1-2 Neighborhood
Improvements
Use available means to improve
neighborhoods, including:
• Identify priorities for
improvements in the City’s
older residential
neighborhoods, including
curbs, gutters, and
sidewalks; housing
rehabilitation; and
neighborhood improvement
activities. Where needed
improvements are identified
in lower income areas, seek
supplemental state funding
for the improvements to
supplement the City’s
CDBG and HOME funds. If
funding remains limited,
focus on high priority
activities. Ensure that
improvements consider
accessibility for seniors and
disabled persons, focusing
on areas where seniors and
other populations
congregate and walk, to
Ongoing; update Capital
Improvements Program
on an annual basis
This program has been
successfully
implemented on an
annual basis. Capital
improvement projects
are reviewed and
updated annually. The
City uses Risk
Management (RMA)
Sidewalk Grant to repair
sidewalks annually. City
offers residents to
participate in a sidewalk
repair day where
Precision Concrete
Cutting offers bulk
discounts for sidewalks
repaired on a certain
day. The City was not
successful in securing
supplemental state
funding, but continues to
focus use of its CDBG
and HOME funds on
high-priority activities.

Program has been modified
and carried forward.

City of Escalon 2023-2031 Housing Element - Appendix A p. 3 ensure that the curbs,
sidewalks, and lighting is
appropriate to prevent both
fall-related and trafficrelated accidents.
• Continue to update the
City's Capital Improvement
Program (CIP) to ensure
that neighborhoods needing
improvement are scheduled
for funding at a specific
budget year in the future.
• Encourage homeowners to
use Improvement Bond Acts
under which residents can
install curbs and gutters and
have the cost added to their
taxes.

Program 1-3 Housing
Rehabilitation Program
Continue and expand the City’s
Housing Rehabilitation Program
through the following activities:
• Continue to provide funding
for the City’s Housing
Rehabilitation Program
through the HOME and
CDBG funds available to
Ongoing
This Program has been
successfully
implemented. The
County Rehabilitation
Program is active and
information pamphlets
with program information
are made available
through social media,
newsletters, and on the
Program has been modified
and carried forward due to a
continued need for a home
rehabilitation program.

City of Escalon 2023-2031 Housing Element - Appendix A p. 4 the City administered by the
Urban County and HOME
Consortium.
• Coordinate with San
Joaquin County to
determine if the County has
the capacity to administer
additional housing
rehabilitation funds for the
City’s Housing
Rehabilitation Program
once CalHOME or similar
funds are available for
housing rehabilitation. If
there is capacity and funds
are available, apply for
CalHOME or similar funds
to supplement the housing
rehabilitation program
offered to City residents
through the County.
• Make pamphlets available
at City Hall, the public
library, other public facilities,
and on the City’s website
that describe available
housing rehabilitation and
home repair programs,
City website, as well as
at City Hall. If the City
has an applicant for
CDBG Home
Rehabilitation, the City
asks the County if they
can support the
applicant with additional
funds.

Additional outreach and
collaboration with the
County could help to
increase visibility and
use of all available
programs. CalHOME
funds were applied for
but were not awarded.

City of Escalon 2023-2031 Housing Element - Appendix A p. 5 including San Joaquin
County Aging and
Community Services
assistance with accessibility
improvements. Note: If
funding is unavailable in a
given year, then pamphlets
should not be distributed.
• Community Development,
Building, Public Works, and
Police Department staff
shall coordinate to identify
areas of the City with a high
incidence of homes with
deferred maintenance and
target these areas for code
enforcement. This should
be completed in conjunction
with identifying priority
activities under Program 1-

2. • Distribute program
information in conjunction
with continuing building
code enforcement.

Program 1-4 Conservation of
Affordable Units Ongoing
This program has been
successfully
implemented but will be
Program has been modified
and carried forward.

Program is not needed

City of Escalon 2023-2031 Housing Element - Appendix A p. 6 Conserve the existing supply of
subsidized and below-market-rate
housing to ensure that affordability
is preserved through an early
warning system and timely
application of state and federal
grant funds for conservation.
• Contact owners/operators of
subsidized multi-family
housing at least annually to
determine the status of atrisk units.
• Upon approval of assisted
multifamily housing projects,
provide the project applicant
with the City’s noticing
requirements.
updated to include
specific early warning
and noticing
requirements when the
City has units at risk of
conversion to market
rate (year).
during this cycle because
there are no at risk units.

Program 2-1 Adoption of the
Latest Model Codes
The City will review the model
codes adopted by the State and
adopt changes to the City’s codes,
as appropriate, to provide for safe
and decent housing, accessible
development, and energyefficient/energy-conserving
practices.

Ongoing
This program has been
implemented as new
Codes are adopted by
the State. The City
adopts the latest model
codes every three years
as they become
available.

Program has been modified
and carried forward.

City of Escalon 2023-2031 Housing Element - Appendix A p. 7 Program 2-2 Urban Residential
Densities and Density Bonuses
The City will continue, on an
ongoing basis, to monitor its
policies and ordinances to provide
for the most efficient densities and
ensure that the City can
accommodate its RHNA including
extremely low, very low, and low
income units. As part of addressing
housing needs, the City will
continue to identify appropriate
housing sites that allow a range of
densities and accommodate the
City’s allocation while continuing to
ensure that the City’s development
standards provide for appropriate
design techniques, including
setbacks, site layout, and massing
of structures, that reflect the small
town character of the City. The City
should continue to implement
compact, smart growth principles
such as traditional neighborhood
design and traffic calming
techniques.

Ongoing
This program is
successfully
implemented as needed.

No additional housing
sites have been needed
for the City to meet its
RHNA. The City adopted
Senior and Multi-Family
Design Guidelines to
streamline the approval
process. City continues
to monitor the vacant
sites inventory for
potential development.

Program has been modified
and carried forward.

City of Escalon 2023-2031 Housing Element - Appendix A p. 8 Program 2-3 Affordable Housing
Incentives
Continue to provide incentives and
mechanisms that promote
development of affordable
housing, including multifamily, that
is affordable to a range of incomes
including extremely low, very low,
and low, including:
• Allow duplexes to be built
on corner lots in the R-1
zoning district, provided that
each unit faces a separate
street so that the duplex
looks like a single family
dwelling from either street;
• Grant density bonuses
commensurate with State
Density Bonus law;
• Exempt one of two multifamily units in accordance
with the Growth
Management Ordinance;
• Guarantee building permits
for affordable senior
housing under the Growth
Management Ordinance;
Review and update
brochure in 2020 and as
necessary thereafter;
promote use of
incentives and available
programs on an ongoing
basis
Program has been
successfully
implemented and
brochure updates are
ongoing as state law
changes. Incentives
under Program 2-3 have
been made available to
promote the
development of
affordable housing.

This program has been fully
implemented and will not be
carried forward. The City
will continue to comply with
state Density Bonus and
Accessory Dwelling Unit
laws.

City of Escalon 2023-2031 Housing Element - Appendix A p. 9 • Encourage the use of the
density bonus for the
provision of lower and
moderate income housing
units;
• Permit accessory dwelling
units in accordance with
State Law;
• Allow flexibility of
development standards and
innovative housing types;
• Permit full utilization of
existing lots that do not
meet lot size or setback
requirements, as allowed by
Chapter 17.46 of the Zoning
Ordinance; and
• Expedite processing of
affordable units, including
extremely low, very low, and
low income, and special
needs units, including
senior, disabled,
developmentally disabled,
farmworker/employee, large
family, emergency shelters,
and supportive/transitional
housing.

City of Escalon 2023-2031 Housing Element - Appendix A p. 10 The City will review and update the
City’s brochure describing various
incentives, mechanisms, and
funding programs for providing
affordable housing in the City,
including density bonuses, and
recent changes to the provisions
for accessory dwelling units by
June 2020. Update thereafter on
an as-needed basis.

The City will also support
applications for affordable and
special needs projects through
seeking funding for extremely low,
very low, and low income units
through available funding sources,
such as CalHOME, Affordable
Housing Initiative Program, and
other sources. If the City has
requests for financial assistance
for multiple projects, projects
providing extremely low income
housing will receive priority.

Program 2-4 Small Lot
Consolidation and Development
Encourage consolidation and
development of small multi-family
parcels.

Ongoing
Program 2-4 has been
successfully
implemented. Staff
provides technical
assistance while meeting
Program has been modified
and carried forward.

City of Escalon 2023-2031 Housing Element - Appendix A p. 11 • Provide incentives, such as
staff assistance and
financial assistance through
available affordable housing
funding sources, to
encourage owners of small,
contiguous parcels
appropriate for affordable
housing, including those
parcels southwest of the
McHenry Avenue/Highway
120 intersection, to
consolidate lots.
• Assist affordable housing
developers with the
purchase and consolidation
of small, contiguous
parcels, through providing
staff assistance and
financial assistance, when
available through CDBG,
HOME, or other appropriate
funds.
with developers. For
example, staff met with
the owner of the parcels
southwest of McHenry
Avenue/Highway 120
and encouraged him to
merge them into larger
parcels for easier
development.

Additionally, the City
Council recently
approved fee deferral
and reduction for
Countrywood Cottages
Senior Housing on
Countrywood Lane.

Program 2-5 Growth
Management Ordinance
The City will continue to evaluate
implementation of the Growth
Management Ordinance on an
Annual review; revisions
within 12 months of
identification of
impediment
This program has been
implemented. The GMO
provisions have been
evaluated and have not
been identified as a
Pursuant to SB 330 and the
HAA, the City will not
enforce its GMO Ordinance
before January 1, 2030.

Residential development

City of Escalon 2023-2031 Housing Element - Appendix A p. 12 annual basis, including requested
allocations by types of units (single
family, multi-family, and mobile
homes) and allocations by
affordability level.

During the remainder of the 5th
Cycle planning period, if
applications exceed available
allocations, the City will seek input
from development and affordable
housing stakeholders, including
the Building Industry Association
(BIA), development community,
and affordable housing advocates,
in reviewing the effects of the
Growth Management Ordinance. If
the Growth Management
Ordinance presents an obstacle to
the development of the City’s fair
share of regional housing needs,
the City will revise the ordinance
accordingly. Potential revisions
may include:
• Increasing the number of
units that may be rolled over
(e.g., allowing 125
allocations rather than 100
constraint to the
provision of housing.

Applications and interest
have not exceeded
available allocations.

The GMO is not
currently in effect due to
changes in State law..
will continue to be
monitored during this period
to ensure that adequate
infrastructure and other
community facilities are in
place to serve development
that allows the City to fulfill
its RHNA obligations.

Before 1-1-2030, the City
will work with HCD and
make any needed
modifications to its GMO
Ordinance to ensure
compliance with State law
and does not pose an
unnecessary constraint to
the production of housing.

City of Escalon 2023-2031 Housing Element - Appendix A p. 13 with up to 75 new
allocations)
• Prioritizing multi-family and
affordable projects until the
City has met its share of the
regional housing need;
and/or
• Increasing the allocation for
senior projects.

Program 2-6 Site Plan Review
and Approval
In order to remove conflicts from
the Zoning Code and to reduce
subjectivity in the site plan review
process, the City will:
1) Remove conflicting
language from the Planned
Development overlay
chapter that requires a PD
for all multifamily projects,
while the provisions in
Section 17.11.040 do not
require a PD for multifamily
projects, including
condominiums and
townhomes, in the R3 and
C2 zones. The Planned
Within one month of
Housing Element
adoption
This program has been
successfully completed.

This program has been
completed and will not be
carried forward.

City of Escalon 2023-2031 Housing Element - Appendix A p. 14 Development overlay
chapter shall identify that a
Planned Development
overlay is only required
where identified by the
appropriate notation in
Section 17.11.040 and shall
not requirement a rezone
with a Planned
Development overlay for
multifamily, including but not
limited to apartments,
condominiums, and
townhomes, in the R3 zone.
2) Either revise Zoning Code
Section 17.54.040(D) to
modify the site plan review
process to remove or define
subjective language, or
implement supplemental
design guidelines that
provide standards,
definitions, and examples
that illustrate or describe
project components that
would comply with the site
plan review findings.

City of Escalon 2023-2031 Housing Element - Appendix A p. 15 Program 2-7 Implement State
Housing Laws
The City will revise the Zoning
Code to implement the following
requirements of State law:
1) Establish the SB 35
streamlining approval
process and standards for
eligible projects, as set forth
under Government Code
Section 65913.4.
2) Revise Zoning Code
Section 17.11.040 to identify
the same permit
requirements for
manufactured homes as
single family homes, as
required by Government
Code Section 65852.3.
3) Define low barrier
navigation center as a use
allowed by right and
develop standards and
requirements for processing
a low barrier navigation
center consistent with the
requirements of State law,
including Government Code
Within eight months of
Housing Element
adoptions
There are varying levels
of implementation of the
actions included under
Program 2-7. Progress
on each item is as
follows:
1) The City has not
received an SB
35 project, and a
streamlined
approval process
has not yet been
developed. This
action will be
carried over into
the 6th cycle.
2) Manufactured
homes are
permitted by right
in all residential
and commercial
districts.
3) This item was not
implemented due
to an oversight,
and will be carried
over to the 6th
cycle.

Implementation of actions 1
and 3 have been modified
and carried forward.

City of Escalon 2023-2031 Housing Element - Appendix A p. 16 Sections 65660 through
65668.
4) Establish standards and
requirements for processing
supportive housing by right
consistent with the
requirements of State law,
including Government Code
Sections 65650 through
65656.
5) Revise the accessory
dwelling unit standards to
allow an ADU to be
considered ministerially in
all zones that allow
residential uses.
4) Supportive
housing is
permitted subject
to the same
requirements and
standards as
residential uses of
the same type.
5) Accessory
dwelling units are
approved through
a ministerial
process.

Program 2-8 Monitor Housing
Fees
The City will monitor its
development project, project
applications, and development
impact fees to ensure that the fees
do not pose an undue constraint to
residential development. In the
event that the fees are determined
to constrain development, the City
will work with a developer to defer
fee payment for a reasonable
Ongoing
This program has been
partially implemented in
that consultations with
developers and
stakeholders have not
determined fees to be a
significant constraint to
development. Developer
Impact Fees are updated
through Nexus Studies.

If a developer requests a
fee payment deferral, the
Program has been modified
and carried forward.

City of Escalon 2023-2031 Housing Element - Appendix A p. 17 amount of time (e.g., at final
inspection or issuance of certificate
of occupancy).

City will work with them
on a deferred payment
schedule. However,
changes to state law will
require a restructuring of
fees with the next Fee
Study, so the program
will be modified and
carried over in the 6th
cycle.

Program 3-1 Provision of Public
Services
The City will continue with its
efforts to expand and improve the
sewer and water system serving
the City. The City has adopted
master storm drainage, sewer, and
water plans that will permit service
to all segments of the General
Plan area. These plans shall be
implemented as needed to provide
service to developing areas to the
extent the improvements are
needed to accommodate the City’s
fair share of regional housing
needs. Implementation actions will
include the following:

Well 1 completion in
2020 and McHenry Lift
Station improvements
completed in 2019
Construction of the new
McHenry Lift Station and
associated
improvements has been
completed. Phase I
Sewer pipeline project
has been completed.

Phase II Sewer Pipeline
Project is under
construction. Phase III
Sewer Pipeline has
entered design.

Additionally, construction
of Well 1A, which will
replace Well 1, has
begun.

Program has been
successfully implemented
and will not be carried
forward.

City of Escalon 2023-2031 Housing Element - Appendix A p. 18 • Continue to review available
funding sources including
the State Revolving Fund
Loans, State Infrastructure
Bank Loans, bonds or
assessment district
financing, federal
infrastructure financing, and
commercial bank loans to
determine appropriate
financing sources to assist
in construction of the water
system and wastewater
facility improvements;
• Continue implementing the
Well 1 replacement project
with a planned completion
date in 2020;
• Continue implementing the
construction of the new
McHenry Lift Station and
associated pipeline
improvements, with a
planned completion date in
November 2019; and
• Ensuring that the City
continues to identify and
implement necessary water

City of Escalon 2023-2031 Housing Element - Appendix A p. 19 and sewer infrastructure
improvements to ensure
that the City continues to be
able to accommodate its
housing needs.

Program 3-2 Adequate Lower
Income Sites
The City will ensure that adequate
lower income sites are
accommodated by ensuring that
sites are proximate to existing
infrastructure (water, sewer, dry
utilities) or are included in a plan to
extend infrastructure to the site
and through streamlining the
permitting process for sites that
have been included in previous
Housing Element cycles pursuant
to Government Code Section
65583.2(c) through the following
actions:
1) Update the Zoning Code to
ensure that the City
complies with Government
Code Section 65583.2(c) for
parcels included in Table 4-
3 that have been included in
one or more Housing
Within one year of
Housing Element
adoption
Adequate lower income
sites were maintained;
however, the Zoning
Code was not updated.

Program actions will
need to be carried over
in the 6th cycle.

Program has been modified
and carried forward.

City of Escalon 2023-2031 Housing Element - Appendix A p. 20 Elements (non-vacant sites)
or two consecutive planning
periods (vacant sites). The
revisions to the Zoning
Code shall ensure that:
a. Residential uses are
allowed by-right for
housing
developments in
which at least 20
percent of the units
are affordable to
lower income
households. Use by
right means that the
affordable housing
development is not
subject to a
conditional use
permit, planned unit
development permit,
or other discretionary
local government
review or approval
that would constitute
a “project” for
purposes of Division
13 (commencing with
Section 21000) of the

City of Escalon 2023-2031 Housing Element - Appendix A p. 21 Public Resources
Code. However, any
subdivision of the
sites shall be subject
to all laws, including,
but not limited to, the
local government
ordinance
implementing the
Subdivision Map Act;
and
b. Permitted densities
shall allow at least 20
dwelling units per
acre.

Program 3-3 Encourage Mixed
Use and Residential
Development in Commercial
Areas
Encourage mixed use and
residential development in
commercial areas through:
• Continuing to allow multifamily residential as a
permitted use with a
preliminary development
plan in the community
commercial (C-2) zone.

Ongoing
This program has been
successfully
implemented. Leer
Village, a mixed-use
development comprised
of eight residential units
and one commercial
office space in the
downtown area, was
developed during the
planning period. Flexible
development standards
are provided consistent
Program has been modified
and carried forward.

City of Escalon 2023-2031 Housing Element - Appendix A p. 22 • Provide flexible
development standards,
such as decreased
setbacks or parking
requirements, for mixed use
developments with second
floor residential
development in commercial
areas and or mixed use or
residential projects in
commercial areas that
provide connectivity to
transit, encourage
alternative modes of
transportation, and have
proximity to services.
with Government Code
65915. The City has
received 2 more
applications for Planned
Development multifamily in C-2 zone. The
Planned Development
allows for flexible
development standards
in projects that do not
qualify for 65915.

Program 3-4 Infrastructure
Reimbursement Agreements
and Cost Participation.

The City will continue to encourage
developers to provide the
necessary long-range
infrastructure
associated with new development
through the filing of
development/reimbursement
agreements with developers. The
City will seek to find funding
Ongoing
The City has not
received an eligible
project under this
program.

Program has been modified
and carried forward.

City of Escalon 2023-2031 Housing Element - Appendix A p. 23 sources to off-set the cost of
infrastructure improvements
for very low and low income units
in order to encourage development
of affordable units.

Program 3-5 Housing Element
Monitoring Program
The City will prepare an annual
report describing progress
implementing the Housing Element
using the form developed by HCD
consistent with the requirements of
Government Code 65400.

Following City Council review,
submit this report to the
Department of Housing and
Community Development by April
1st annually.

Annually, by April 1
This program has been
implemented on an
annual basis through the
APR.

Program has been modified
and carried forward.

Program 3-6 Replacement of
Affordable Units
Consistent with the requirements
of Government Code Section
65583.2(g), development projects
on sites in the housing inventory
(Chapter 4) that have, or have had
within the past five years,
residential uses restricted to rents
affordable low or very low income
Ongoing
This program was not
implemented. No
affordable units were
converted to market rent.

Therefore, the
replacement of
affordable units was not
needed.

Program has been modified
and carried forward.

City of Escalon 2023-2031 Housing Element - Appendix A p. 24 households or residential uses
occupied by low or very low
income households, shall be
conditioned to replace all such
units at the same or lower
income level as a condition of any
development on the site and such
replacement requirements shall be
consistent with Section
65915(c)(3).

Program 4-1 Removal of
Constraints
Continue to analyze amendments
to the Zoning Ordinance, Escalon
Municipal Code, and City
procedures to ensure that the
amendments do not result in
constraints for special needs
groups, including seniors,
the disabled (consistent with
requirements of SB 520) including
developmentally disabled, large
families, farmworkers, and
homeless. The analysis will
address land use controls, permit
and processing procedures, and
building codes. If any constraints
are found in these areas, the City
Analysis on an ongoing
basis; handouts by June
2020
Implementation has
been successful.

Handouts and website
language were
developed and are in
use. The City has
developed handouts to
assist with disseminating
ADA information from
the building code. Staff
has continued to monitor
its Zoning Code for
potential constraints that
may hinder the
development of housing.

The City remains
committed to monitoring
and mitigating
Program has been modified
and carried forward.

City of Escalon 2023-2031 Housing Element - Appendix A p. 25 will initiate actions within six
months of the completion of the
evaluation to address them,
including removing the
constraints or providing reasonable
accommodation for housing
intended for persons with
disabilities.

In response to SB 520, the City will
also make dwellings adaptable and
accessible for disabled persons by
assigning funding priority, where
feasible, to housing rehabilitation
cases in which accessibility
improvements are planned, and
where such improvements are the
only ones necessary. The City
shall also continue to enforce ADA
compliance during all permit
processes for new construction
and rehabilitation.

The City shall prepare handouts to
provide information to all interested
parties regarding accommodations
in zoning, application of building
codes, and permit processes for
persons with disabilities and shall
make the handouts available at
City Hall public counter, Escalon
governmental
constraints.

City of Escalon 2023-2031 Housing Element - Appendix A p. 26 Branch Library, Community Center,
and on the City’s website.

Program 4-2 Special Needs
Housing Coordination
Coordinate with agencies and
organizations serving Escalon
residents, including the Valley
Mountain Regional Center,
Community Action Resources of
Escalon, Housing Authority of the
County of San Joaquin, and the
various service providers assisted
through the San Joaquin Urban
County and HOME Consortium, to
address housing and services for
special needs groups, including
seniors, disabled, developmentally
disabled, homeless, farmworkers,
and extremely low income
households, as needed and
feasible.

Refer households with special
needs, including seniors, disabled,
developmentally disabled,
homeless, and farmworkers, to the
service providers identified in
Chapter 5, Constraints and
Resources, and to the service
Ongoing
This program has been
successfully
implemented and will
continue. The City
provides handouts,
referrals, and information
to residents who come to
or call City Hall needing
these services. During
the course of the
planning period, 8
housing units for special
needs populations were
provided, including
seniors and disabled
households.

Approximately 30
households were
provided with referrals
and/or housing-related
services.

Program has been modified
and carried forward.

City of Escalon 2023-2031 Housing Element - Appendix A p. 27 providers listed in the San Joaquin
County Aging and Community
Services Resources Directory
updated regularly by the San
Joaquin County Human Services
Agency.

Continue to make a handout that
identifies available housing
programs and services for lower
income households and special
needs groups available at City
Hall, the library, and the City
website.

Program 4-3 Incentives for
Senior, Disabled (including
Developmentally Disabled), and
Large Family
Special Needs Housing
Continue to provide incentives for
special needs housing through
Zoning Code provisions that allow
eligible senior, disabled (including
developmentally disabled), and
large family housing projects to
receive up to two incentives,
including flexible development
standards, such as reduced
Ongoing
This program has been
implemented on an
ongoing basis. The City
has offered land and/or
reduced impact fees for
construction of a senior
housing project on City
property and for
Countrywood Cottages
and conducted
workshops on project
proposals.

Program has been modified
and carried forward.

City of Escalon 2023-2031 Housing Element - Appendix A p. 28 parking, setback, lot coverage, and
other standards.

Program 4-4 Seek Available
Funding
Seek and aggressively pursue
available State and Federal
assistance for City and non-profits
(CDBG, HOME, etc.) to develop
affordable housing for seniors,
large-families and households with
children and others with
specialized housing needs,
including farmworkers and
extremely low income households,
when there is a request from a
developer for an affordable
housing project appropriate for the
City. If no new affordable housing
construction projects are identified,
the City will pursue funding for
First Time Homebuyer, housing
rehabilitation, and other programs
that will provide housing
assistance but may not result in
the development of housing for
special needs groups.

Annually
This Program is
implemented annually
during funding cycles
and as applications are
introduced. The City did
not receive affordable
housing project
applications during the
cycle. The City continues
to seek first time
homebuyer funding, but
has not been successful.

No special needs
households were
assisted by this Program
during the planning
cycle.

Program has been modified
and carried forward.

City of Escalon 2023-2031 Housing Element - Appendix A p. 29 Program 4-5 Outreach to
Developers of Affordable and
Special Needs Housing
Encourage development of
affordable and multifamily housing,
including housing for special
needs, including but not limited to
seniors, disabled, developmentally
disabled, large families, and
farmworkers, and/or extremely low,
very low, and/or low income
households through outreach to
affordable housing developers.

As part of the City’s noticing
requirements for the San Joaquin
Urban County Annual Action Plan,
the City shall contact affordable
housing developers and special
needs service providers to solicit
interest in developing affordable
and/or special needs housing,
including senior housing and shall
provide information regarding any
available City funds for housing
production, such as Affordable
Housing In-Lieu Fees. The
outreach materials shall include a
list of incentives for affordable
housing, a list of incentives for
Annually
Due to limited staff
capacity, this program
was not implemented.

Program has been modified
and carried forward.

City of Escalon 2023-2031 Housing Element - Appendix A p. 30 senior housing, a summary of the
City’s housing needs, including the
City’s RHNA, the City’s inventory
of housing sites, and the map of
the City’s housing sites. Affordable
housing developers and operators
contacted should include Bridge
Housing, Mercy Housing, St. Anton
Partners, Domus Development,
Eden Housing, Heritage House,
and Bethany Home Society of San
Joaquin County.

Program 4-6 Parking Reductions
for Eligible Projects
Update Chapter 17.48 of the
Zoning Code to specify parking
reductions allowed under
Government Code Section
65915(p)(2) for qualified projects:

A project that qualifies for a density
bonus shall be allowed a reduced
parking requirement, inclusive of
handicapped and guest parking,
based on either the ratios identified
by the Zoning Code or the ratio
allowed, either for the entire
project or for individual units based
on unit size, under Government
Annually
The City has not
received any requests
for a reduction in
parking. The Zoning
Code was not updated
due to a lack of staff
resources and perceived
need.

Program has been modified
and carried forward.

City of Escalon 2023-2031 Housing Element - Appendix A p. 31 Code Section 65915(p). The City’s
density bonus provisions that allow
for qualified projects to request a
reduction in parking (which may
differ from the parking ratios
identified at Government Code
Section 65915(p)) will continue to
be allowed as an incentive
consistent with State law.

Program 4-7 Outreach to
Seniors
Prepare and maintain a list of
resources available to senior
citizens, including housing
resources, grant and loan
programs, and assistance
programs. The list shall be made
available at City Hall, Escalon
Branch Library, the Senior Center
and on the City’s website.

Within 12 months of
Housing Element
adoption
Program has been
successfully
implemented. It is also
posted on the City’s
social media page and
mailed to residents in the
utility newsletter.

Information regarding
available programs and
resources has been
made available on the
City’s website, as well as
at City Hall.

Program has been modified
and carried forward.

Program 5-1 Equal Housing
Opportunity
Refer all complaints of housing
discrimination to the San Joaquin
Fair Housing Association, or other
Ongoing
This program has been
successfully
implemented. The
Planning / Building /
Code Enforcement
department receive
Program has been modified
and carried forward.

City of Escalon 2023-2031 Housing Element - Appendix A p. 32 organization with commensurate
purpose, for action. The Planning
Department will continue to be
responsible for receiving
complaints in regard to housing.

The City will continue provide an
informational outreach program,
including handouts regarding fair
housing law and tenant rights.

Implement applicable
recommendations of the 2014 San
Joaquin Valley Fair Housing and
Equity Assessment (FHEA)
including the following:
• Consider the data and
findings in the FHEA to
inform policies and
programs related to
housing, housing choice,
neighborhood revitalization,
investment in
disadvantaged areas, job
creation, and workforce
investment, including
subsequent updates to the
Housing Element, Zoning
Code, and General Plan,
complaints and refer to
Fair Housing for follow
up. Approximately 5
complaints are received
annually and 15 referrals
were made during the
planning cycle.

City of Escalon 2023-2031 Housing Element - Appendix A p. 33 • Participate in regional
efforts to educate and
inform decision-makers and
the public on the benefit of
diverse neighborhoods.

Program 5-2 Removal of
Impediments to Fair Housing
Continue to review updates to the
San Joaquin County Impediments
to Fair Housing Study and
determine whether additional
programs/actions are necessary to
remove impediments. If additional
programs are necessary,
implement such programs within
one year of identifying the
impediment to fair housing.

Within one year of
analysis
This program was
completed. No additional
programs/actions were
identified.

Program has been modified
and carried forward as part
of a larger Fair Housing
program.

Program 6-1 Energy
Conservation and Efficiency
Promote energy efficiency and
conservation in residential
development through:
• Continued implementation
of the California Green
Building Code (CalGreen),
including compliance with
Tier 1 standards.

Ongoing
This program continues
to be successfully
implemented during
each code cycle. The
City adopts and
implements the updated
model codes every 3
years. Handouts and the
City’s website are
updated and remain
available.

Program has been modified
and carried forward.

City of Escalon 2023-2031 Housing Element - Appendix A p. 34 • Continued implementation
of the California Energy
Code.
• Support inclusion of
weatherization activities
including, but not limited to,
weatherization, siding, dual
pane windows, in the
Housing Rehabilitation
program.
• Support the various energy
efficiency and rebate
programs operated by
Modesto Irrigation District
and PG&E through
advertising availability of
these programs through
handouts at City Hall and on
the City’s website.

APPENDIX B: COMMUNITY OUTREACH
Appendix C contains a summary of the community outreach conducted, as well as a summary of the data gathered through the City of Escalon Housing Needs and Opportunities Survey. The Housing Needs and Opportunities Survey was made in both English and Spanish to ensure community members with limited English proficiency were also able to provide feedback on the existing and future housing needs in Escalon, as well provide feedback on desired solutions. The input provided serves as the foundation for the Housing Element.

Government Code 65583(c)(7) requires that “the local government shall make a diligent effort to achieve public participation of all economic segments of the community in the development of the housing element, and the program shall describe this effort.” This appendix documents how public engagement was sought and gathered during the update process, and how the input received from the Escalon community was incorporated into the preparation and content of the Housing Element.

B.1 Housing Element Community Outreach Efforts
Community outreach played a central role in the development of the 2023-2031 Escalon Housing Element. In order to inform the public regarding the Housing Element update, an information flyer with a link to the Housing Needs and Opportunities Community Opinion Survey (English and Spanish), as well as a copy of the paper survey was mailed out to all utility customers. Additionally, information was posted to the City’s website at https://www.cityofescalon.org/housing_element and a joint City Council and Planning Commission Housing Element Kickoff Workshop was held in hybrid format.

As the Housing Element update progressed, additional outreach activities and events were conducted including a joint City Council and Planning Commission Draft Housing Strategy Workshop that was held in hybrid format, emails containing updates were sent to the Housing Element mailing list, a stakeholder survey that was sent to over 75 housing development and service professionals to assess housing constraints and fair housing contributing factors, and bilingual flyers were posted at businesses and other locations frequently visited by the public to further promote the Housing Needs and Opportunities Community Opinion Survey.

During the public comment period, a Public Review Draft Open House was held in a hybrid format to answer questions from the public and provide an additional platform for members of the public to provide feedback on the Housing Element. The majority of comments received at the meeting were general questions regarding Housing Element law. One comment received at the meeting was a request that a map with all sites included in the inventory be added to help the public understand the distribution of sites across the City. As a result, a comprehensive map that depicts all sites included in the Sites Inventory was added to Section 3 of the Housing Element.

Housing Element Flyers

Escalon Newsletter

B.2 Public Workshops and Hearings
The Escalon City Council and Planning Commission hosted a series of informational workshops over the course of the Housing Element’s development, including the following:
• Public Workshop #1 – Housing Element Kick-Off – October 2, 2023 • Public Workshop #2 – Draft Housing Strategy – November 6, 2023 • Public Workshop #3 – Open House on Public Review Draft – December 4, 2023 • Public Review Period – November 15, 2023 to December 14, 2023 • Planning Commission and City Council Adoption Hearings – July and August 2026 B.3 Stakeholder Engagement
As the Housing Element update progressed, a survey was also sent to over 75 housing development professionals and providers to assess housing constraints and fair housing contributing factors.

B.4 Program Response to Community Housing Needs & Opportunities Survey
The table below showcases the topics raised in the Housing Needs & Opportunities Survey and the corresponding implementing programs, as applicable:

Topic Applicable Housing Element Program(s)
• Senior housing needed
• Independent senior housing and
housing types for persons with
disabilities
Program 2-2 The City will take an active
role in supporting the housing needs of
seniors.

Program 2-5 The City will continue to
seek available local, state, and federal
funding for affordable housing.

Program 5-5 Continue to ensure that
reasonable accommodation is provided
for persons with disabilities, including
developmental disabilities.
• Housing prices in a lower range
needed
Program 2-3 The City will establish
development standards to encourage the
development of missing middle housing
and multi-dwelling unit housing types on
a lower-density neighborhood scale.

Missing middle and multi-unit housing
types include accessory dwelling units
(separately covered in Program 2-4),

duplexes, triplexes, fourplexes,
townhomes, lot splits allowed under SB 9,
and small lot subdivisions allowed under
SB 684.
• Missing middle housing needed
• Allow single-family lots to be
developed into multiple units to
encourage families to age in place
• Accessory dwelling units (ADUs)
• Affordability for first-time
homebuyers
Program 2-3 The City will establish
development standards to encourage the
development of missing middle housing
and multi-dwelling unit housing types on
a lower-density neighborhood scale.

Missing middle and multi-unit housing
types include accessory dwelling units
(separately covered in Program 2-4),
duplexes, triplexes, fourplexes,
townhomes, lot splits allowed under SB 9,
and small lot subdivisions allowed under
SB 684.

Program 2-4 The City will implement a
suite of actions to address State law and
community input to increase the City’s
production of accessory dwelling units
(ADUs)
• Keep Escalon a smaller
community, and do not allow it to
grow like the surrounding cities
Comments are inconsistent with statutory
requirements and were not incorporated
into Housing Element Programs.
• Keep building single-family
residential and do not encourage
other types of development
Comments are inconsistent with statutory
requirements and were not incorporated
into Housing Element Programs.
• Reduce permitting fees needed Program 2-5 (B) Produce a fee deferral program for Residential Housing projects.

City of Escalon Housing Needs and Opportunities Survey
1 / 21

39.76% 66

51.81% 86

33.13% 55

46.99% 78

27.71% 46

33.73% 56

14.46% 24

18.67% 31

12.05% 20
Q1 The biggest housing needs facing Escalon today are (check all that apply):

Answered: 166 Skipped: 2
Total Respondents: 166
# OTHER (PLEASE SPECIFY) DATE
0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%
Needs housing
choices in
lower price...

Needs more
housing for
seniors
Needs
lower-cost
rental housing
Needs homes
that are
affordable t...

Needs housing
for people who
work here
Needs more
housing for
young famili...

Needs
intergeneration
al living...

All of
Escalon’s
housing need...

Other (please
specify)

ANSWER CHOICES RESPONSES
Needs housing choices in lower price range
Needs more housing for seniors
Needs lower-cost rental housing
Needs homes that are affordable to first-time homebuyers Needs housing for people who work here
Needs more housing for young families and workers
Needs intergenerational living options
All of Escalon’s housing needs are being met
Other (please specify)

City of Escalon Housing Needs and Opportunities Survey
2 / 21
1 Escalon needs more new affordable houses for the children of Escalon coming of age. 11/11/2023 7:50 AM 2 Needs ADU options 10/11/2023 5:03 PM
3 Allow housing and additional buildings on lots 10/3/2023 1:58 PM 4 Keep our area as it is! 9/28/2023 8:29 PM
5 Needs more housing for senior rental and for purchase mix 9/28/2023 8:20 PM 6 Escalon needs to stop any housing plans that would require sewer & water updates or expansion
9/28/2023 5:30 PM
7 Controlled growth has worked for Escalon - hopefully won't become another Riverbank 9/28/2023 5:23 PM 8 No socialism / government stay away 9/28/2023 5:21 PM 9 Rent is high everywhere. If we start building low income "affordable housing" we wll attract people from surrounding towns - we don't need that
9/28/2023 5:17 PM
10 Mother-in-law/granny flats attached? 9/28/2023 2:45 PM 11 our permit fees are outrageous 9/28/2023 2:17 PM
12 Keep Escalon small! This is why I live here. 9/27/2023 4:36 PM 13 Higher rent or mortgage is one slice of the pie - City of Escalon bill $283!! taxes $4000! Insurance $1200 hard to make it!
9/27/2023 12:00 PM
14 Senior housing 9/27/2023 11:10 AM
15 No additional changes are needed. Everything is acceptable even in these tough economic times. But budget for maintenance is welcomed.
9/8/2023 2:14 PM
16 Please keep Escalon small and as much as legally in the state of California do not do some of the things larger cities have done.
9/2/2023 9:00 PM
17 Escalon needs to allow more single family housing to build 8/14/2023 9:10 AM 18 Needs nicer estate housing with larger lots and larger homes. 8/11/2023 10:48 PM 19 Not sure if applies but as a single person it’s difficult to pay rent on 1 income. 8/11/2023 6:18 PM 20 Need homes with bigger backyards. 8/11/2023 4:53 PM

City of Escalon Housing Needs and Opportunities Survey
3 / 21

51.88% 83

26.25% 42

25.00% 40

41.88% 67

63.75% 102

13.13% 21
Q2 Escalon's housing needs in the coming 10 years will include (check all that apply):

Answered: 160 Skipped: 8
Total Respondents: 160
# OTHER (PLEASE SPECIFY) DATE
1 Children of parents will need more housing options to continue to live in Escalon and grow Escalon organically
11/11/2023 7:50 AM
2 As our seniors age we need affordable housing because we do not to leave our town, friends, family.Right now there isn't a place for us to stay except in our homes that we can not take care of anymore. A volunteer program lead by the youth to help care for our yards would be extremely helpful.
10/24/2023 11:58 AM
3 Housing needs are met 10/6/2023 1:03 PM
4 Don't price our houses so out of range that we have so many bay area people move in. 10/6/2023 10:38 AM 0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%
Housing priced
so that younger
Escalon...

Businesses
will need
housing...

Housing will
need to be
priced to...

Older homes
will be
deterioratin...

Our aging
population will
need...

Other (please
specify)

ANSWER CHOICES RESPONSES
Housing priced so that younger Escalon residents can afford to live here Businesses will need housing affordable to their workers Housing will need to be priced to attract new families to Escalon Older homes will be deteriorating and in need of repair Our aging population will need accessible, well-designed housing options Other (please specify)

City of Escalon Housing Needs and Opportunities Survey
4 / 21
5 Cancel or drastically reduce property tax for seniors 9/28/2023 5:21 PM 6 Don't mess with Escalon 9/28/2023 5:18 PM
7 We moved here 35 years ago as a young family from Manteca. Homes were a little higher here, but we chose to pay ore because it was safe, clean, small town with good schools. please don't try & cater to all of us we believe this will change the town's value. New developments should be the best housing not the cheapest. Our city needs to be focused more on enticing business, then housing will take
9/28/2023 5:17 PM
8 None of the above 9/28/2023 5:06 PM
9 Parking for any increase in housing. Repair city sewer lines. 9/28/2023 2:33 PM 10 Again, keep Escalon small. 9/27/2023 4:36 PM
11 Consider prefab housing parks 9/27/2023 12:01 PM
12 Leave Escalon as it is. Small! 9/27/2023 11:40 AM
13 Need to make city more business friendly - so people want to live 9/27/2023 11:39 AM 14 Careful growth, that thinks about our community in respect to traffic, sprawl, and the sense of knowing one' neighbor
9/27/2023 11:33 AM
15 Keep Escalon and priced the same don't lowe our value of homes 9/27/2023 11:22 AM 16 like Bethany home in Ripon 9/27/2023 11:10 AM
17 No additional changes are needed. Everything is acceptable even in these tough economic times. But budget for maintenance is welcomed.
9/8/2023 2:14 PM
18 People can choose to remodel their home on their own free will, they don’t need the city to make that decision for them.
9/4/2023 9:04 PM
19 more single family housing 8/14/2023 9:10 AM
20 Fine just the way it is 8/11/2023 8:39 PM
21 Homes that are nicer with bigger parcels. 8/11/2023 4:53 PM

City of Escalon Housing Needs and Opportunities Survey
5 / 21
Q3 Please rank your level of agreement with each of the following statements:

Answered: 164 Skipped: 4
It is
important to
preserve...

My housing
costs have
increased in...

Some seniors
need assistance
to remain in...

Some of the
older homes in
Escalon need

City of Escalon Housing Needs and Opportunities Survey
6 / 21
Escalon need...

Rental prices
in Escalon are
too high
There are not
enough housing
options in...

There are no
entry-level
homes to...

My children
can’t afford to
live here in...

City of Escalon Housing Needs and Opportunities Survey
7 / 21
Escalon needs
more housing
options for ...

People who
work in Escalon
can’t afford...

Escalon needs
to allow more
housing in...

Escalon needs
more mixed-use
development

City of Escalon Housing Needs and Opportunities Survey
8 / 21
Escalon should
reduce parking
requirements...

Escalon should
allow more
apartments t...

Escalon should
allow small
apartments...

Escalon needs
more housing in
commercial...

City of Escalon Housing Needs and Opportunities Survey
9 / 21
0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%
Strongly Di… Disagree Neutral / N… Agree
Strongly Ag…
Escalon needs
more housing
near the...

Escalon should
allow
fourplexes...

City of Escalon Housing Needs and Opportunities Survey
10 / 21

0.00%
0 2.56%
4 5.13%
8 33.33%
52 58.97%
92 156 1.51

1.91%
3 7.64%
12 20.38%
32 38.22%
60 31.85%
50 157 2.10

3.85%
6 8.33%
13 25.64%
40 39.10%
61 23.08%
36 156 2.31

3.23%
5 6.45%
10 29.68%
46 47.10%
73 13.55%
21 155 2.39

9.09%
14 10.39%
16 30.52%
47 24.68%
38 25.32%
39 154 2.53

9.68%
15 19.35%
30 19.35%
30 28.39%
44 23.23%
36 155 2.64

9.68%
15 19.35%
30 25.16%
39 27.10%
42 18.71%
29 155 2.74

7.69%
12 17.31%
27 37.18%
58 17.95%
28 19.87%
31 156 2.75

14.65%
23 19.11%
30 15.92%
25 31.85%
50 18.47%
29 157 2.80

8.28%
13 16.56%
26 38.22%
60 24.20%
38 12.74%
20 157 2.83

12.50%
20 26.88%
43 38.75%
62 17.50%
28 4.38%
7 160 3.26

18.47%
29 17.83%
28 38.85%
61 21.02%
33 3.82%
6 157 3.26

18.87%
30 16.35%
26 40.88%
65 19.50%
31 4.40%
7 159 3.26

30.57%
48 22.29%
35 16.56%
26 21.66%
34 8.92%
14 157 3.44

27.16%
44 24.69%
40 18.52%
30 25.31%
41 4.32%
7 162 3.45

15.09%
24 35.85%
57 37.74%
60 8.81%
14 2.52%
4 159 3.52

16.15%
26 35.40%
57 35.40%
57 11.18%
18 1.86%
3 161 3.53

28.13%
45 31.87%
51 15.63%
25 22.50%
36 1.88%
3 160 3.62

STRONGLY

DISAGREE

DISAGREE NEUTRAL /
NO

OPINION

AGREE STRONGLY
AGREE

TOTAL WEIGHTED

AVERAGE
It is important to preserve Escalon
neighborhoods
My housing costs have increased
in the last 5 years
Some seniors need assistance to
remain in their homes
Some of the older homes in
Escalon need rehabilitation
Rental prices in Escalon are too
high
There are not enough housing
options in Escalon
There are no entry-level homes to
purchase in Escalon
My children can’t afford to live here
in Escalon
Escalon needs more housing
options for all income levels
People who work in Escalon can’t
afford to live here
Escalon needs to allow more
housing in conjunction with
existing businesses
Escalon needs more mixed-use
development
Escalon should reduce parking
requirements where safety allows
Escalon should allow more
apartments to be built
Escalon should allow small
apartments throughout the city
Escalon needs more housing in
commercial corridors
Escalon needs more housing near
the Downtown Area
Escalon should allow fourplexes
throughout the city

City of Escalon Housing Needs and Opportunities Survey
11 / 21

43.61% 58

72.93% 97

12.03% 16

16.54% 22

43.61% 58
Q4 Please indicate what types of new housing you feel would be most successful in Escalon today:

Answered: 133 Skipped: 35
Total Respondents: 133
0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%
Accessory
dwelling units
(second...

Independent
senior housing
and resident...

Co-housing,
micro-units,
and single r...

Downtown
mid-rise (3-5
story)...

Missing middle
housing, like
townhouses a...

ANSWER CHOICES RESPONSES
Accessory dwelling units (second units/granny units/junior units) Independent senior housing and residential care facilities for seniors or persons with disabilities Co-housing, micro-units, and single room occupancy
Downtown mid-rise (3-5 story) apartments
Missing middle housing, like townhouses and low-rise multiplexes

City of Escalon Housing Needs and Opportunities Survey
12 / 21
Q5 What are some unique features of Escalon that can be housing opportunities for the community? For example:• Locations for multifamily housing • Detached garages and other accessory structures converted into housing• Large homes modified to accommodate more residents• Additional units on large lots• Commercial and industrial area converted to housing
Answered: 82 Skipped: 86
# RESPONSES DATE
1 Company housing options for seasonal workers, housing for seniors and families. Poised for growth, protect small town feel. Uniform look. Developer fees need to pay for new schools, parks and traffic concerns. Continue to preserve and develop Main Street area for small businesses and walkable access.
6/25/2024 11:42 AM
2 We have a lot of vacant buildings and can’t seem to get business to move in so why not rezone to residential. Also any additional new construction of housing developments should take careful consideration to preserve the integrity of the existing neighborhoods. I believe the quiet small town feel is the attraction to Escalon. If we start putting cookie cutter homes tightly packed, in addition to creating traffic issues then we will quickly end up like Manteca and Tracy which both have more than quadrupled in size and cost of living in the last 20 years.

Carefully plan and spread out development.
5/20/2024 5:37 PM
3 Allowing 4 houses per acre on rural plots, 1 new apartment complex for up and coming children coming of age
11/11/2023 7:50 AM
4 Do not convert commercial or industrial to housing, we need this property for its commercial and industrial use.
11/9/2023 12:30 AM
5 Detached garages and other accessory structures converted into housing 11/6/2023 3:15 PM 6 Better parking downtown. More vehicles are coming through from the commuters and moving out in the valley Lots of traffic on Jackson going out on 120 there are blind spots and they need more lights. Please make low income duplexes for Seniors/Disabled. My daughter lives in Escalon with my grandson and I’m not able to afford to move there with them. We only have a small two bedroom one bath house that they rent.
11/3/2023 11:47 AM
7 Detached garages and other structures converted into houses 10/30/2023 4:47 PM 8 Consider who should come take care of the aging population and adults. Job options are not that great for our children. Keep Escalon a family town. 10/24/2023 11:58 AM
9 More single family homes 10/22/2023 3:57 PM
10 Ease of adding additional units on lots for caring for aging seniors. We may be needing to build one in the near future.
10/11/2023 5:03 PM
11 Affordability 10/8/2023 1:36 PM
12 No changes needed 10/6/2023 1:03 PM
13 Our schools cant handle our influx of children. Classrooms are full! 10/6/2023 10:38 AM 14 I think we should allow for high density housing on the vacant lots located at the end of Main Street (between Vine and Reile). They are undeveloped and will most likely remain so because of the cost to bring sewer and water lines down Main Street, but if we allowed a developer to come in and build multifamily or apartments on those lots, they would be able to better afford those costs than someone trying to build themselves a single family home. 10/6/2023 9:25 AM
15 Response to Question 4: Single family homes with decent price range. No low income housing. 10/3/2023 2:29 PM

City of Escalon Housing Needs and Opportunities Survey
13 / 21
(5)A few commercial areas that could allow for 3 to 5 new homes. 16 Town needs to grow to provide more services. 10/3/2023 2:09 PM 17 Keep Escalon as close to possible-Not another Riverbank! Why do we need to grow to big! 10/3/2023 2:05 PM 18 small community is better & safe 9/28/2023 8:26 PM
19 1) Detached garages converted into living space, 2) additional tiny homes on sizeable lots 3) convert unused commercial buildings into residential spaces 9/28/2023 8:25 PM
20 None 9/28/2023 8:21 PM
21 We need to look at surrounding communities to see what works well, ie Ripon. modesto used to be a nice place to live, but now there are only small areas that are safe and clean. Let's plan carefully so Escalon stays a great place to live. I live in a large house alone because I could not find a small home in Escalon that wasn't in need of a ton of repairs. I have worked and lived here for over 50 years and I don't want to leave. Owning a home is important to me. So any senior housing that are just rentals would just be a big "No!" for me. It would help to have more small home options to purchase. Rental Properties need strict guidelines so owners are required to keep properties well-maintained. Also, the city needs to oversee all plans. Willow Heights is not acceptable. Baker Street Apartments have lots of police cars. We need clean and safe apartments for our residents. We need modern designs, not 1960's rectangular boxes and blacktop parking with little landscaping.
9/28/2023 8:20 PM
22 It's the small town environment that keeps is small Restaurants giftable stores like garden sit down restaurants/breakfast, nursery's, wine tasting, home decor. 1) Senior housing for those who want to be independent 2) 4 Plex's or 6 Plex units for young familys starting out 3) 55 + older gated community Please no more fast food! We need gathering restaurants for neighbors to meet each other. Not Fat food for our kids
9/28/2023 8:08 PM
23 Single family homes that are affordable; not huge 1500 sq.ft. 9/28/2023 8:02 PM 24 1) Allow for residents to use larger lots to build additional living units 2) Allow for more conversions of old industrial or comm building to be converted to living units (like across from post office) 3) Allow some of the larger homes to be converted into 2 living units 4) Quality apartments with studio options for young single professionals or couples that leave b/c there is no place for them to live 5) focus not on low income housing but focus on small living housing *how about a tiny house community!!!
9/28/2023 8:00 PM
25 Keep the present rules and regulations in place, with limited 75 annual building permits. Keep Escalon Small!
9/28/2023 7:54 PM
26 Keep building permits tight. The quality of Escalon has continued to be high due to careful planning and high restrictions. If paying the $ penalty for not having enough low rent, senior or "affordable" units, pay it and hold out as long as possible. Look what happened to beautiful Ripon as they went nuts to build out and have invited nothing but trouble. Building permits should only be for single family developments. Our schools now are able to accommodate comfortably yet remain highly rated. Our farming community does not need the riff-raff of lowincome, dense housing to change the flavor of our well-loved community. There's plenty of poor quality soils that can't support food products that can easily grow houses in communities nearer to the foothills. This whole bleeding-heart appeal won't fly here. 9/28/2023 7:52 PM
27 Small homes for first time homebuyers Downtown area would be nice for townhouses or midrise apartments. 9/28/2023 7:46 PM
28 Escalon will lose its close-knit community charm and small town safety if apartments, multifamily housing, fourplexes, duplexes, and any low-income units are built. The value of existing residences will go down and the population who make Escalon the successful utopia it is will move out.
9/28/2023 5:35 PM
29 Restoration of older & existing residential properties. I moved to Escalon 20 yrs ago because it was unique. It was not like the surrounding communities. Limited housing makes this community more exclusive and with that increases the quality of people in our neighborhoods.

Average people take care of their property in accordance with the area and more people participate in community events by percentage. Please don't change this town to mirror other towns in the Valley. This place is great, let's keep it that way. 9/28/2023 5:30 PM
30 Single family, nice homes. NO low income housing. 9/28/2023 5:25 PM

City of Escalon Housing Needs and Opportunities Survey
14 / 21
31 Controlled growth and preservation of Farmland will keep Escalon a great place to live 9/28/2023 5:23 PM 32 Zero growth / government stay away Reduce property tax for residence over 65 Zero growth keeps Escalon attractive
9/28/2023 5:21 PM
33 Leave it alone! Leave as is! 9/28/2023 5:18 PM
34 If we encourage new business, housing will be proposed by developers. The homes behind Taco Bell were supposed to be affordable, but look at that neighborhood - it's a mess. That is not what we want. The reason why some cannot afford to live here is because of the current economy. It is better to incentivize new, good businesses rather than proposing to micromanaging housing. That is putting the cart before the horse. We are a bedroom community & that's a good thing. Business brings revenue. Once we have a strong tax base then we can begin developing projects that draw people here. Parks, community facilities, police force that keeps our town safe. That will draw families to want to live here, not because we have affordable housing. Housing isn't the issue for us right now & that will work itself out once the economy changes. Business should be our priority. PS - opposed to rent control.

Discourages investment in properties.
9/28/2023 5:17 PM
35 When possible, facilitating and/or participating in down payment assistance, buy-down of interest rates and any other assistance programs for first-time home buyers and others. 9/28/2023 2:41 PM
36 This survey seems to be putting the cart before the horse. Invest in infrastructure/survey the residents about infrastructure issues before trying to make it possible to increase the City population. No one here wants investors building here w/out regard for the local homeowners + residents Questions are broad, not well-defined.
9/28/2023 2:33 PM
37 Our housing element is limited because way too much of the General Plan is allocated for commercial and industrial. Our permit fees are outrageous. 9/28/2023 2:17 PM
38 Leave Escalon alone! Keep it small! 9/28/2023 2:11 PM 39 None of The above 9/28/2023 6:31 AM
40 Unable to think of any "unique" features of Escalon. However there are some vacant parcels that could be considered for multifamily housing. The biggest problem Escalon has for building housing is the COST of infrastructure needed to accommodate the increase of demands on water, sewage, schools, and health services. To attract businesses to Escalon, the City needs to show that their growth plans are projected to take into consideration designs that show housing, business, travel and services aesthetically meshes together. 9/27/2023 4:48 PM
41 We need more sustainable business to attract outside shoppers/clients. No more dollar stores/smoke shops/liquor stores or fast food franchises 9/27/2023 4:41 PM
42 I do not want more/new housing opportunity! Leave Escalon small! 9/27/2023 4:36 PM 43 Senior living on a pay scale 9/27/2023 4:33 PM
44 Affordable apartments and rentals 9/27/2023 3:02 PM
45 1 - Single Bedroom senior housing studios 2 - property on John & First 3 - Auction yard property 4 - Escalon folks are frugal - worked hard & saved, they should be appreciated and listened to 5 - thank you for giving me the opportunity to vent 9/27/2023 11:49 AM
46 Let Escalon stay as is! 9/27/2023 11:40 AM
47 Reduce the permit costs We need more businesses - although not another Dollar type store.

We need to encourage our facilities - improve the town-use - like Ripon - invest in the town for the people that are living here now. Attract better businesses (unique ones) and you will attract more people. (Butler's Pantry for example)
9/27/2023 11:39 AM
48 Are this questions that the State sends you to ask? 3-5 story downtown apartments? Really Control growth - plan wisely -
9/27/2023 11:33 AM
49 Much of what families move to Escalon for is the small community feel. I believe the slow growth policy now in exisertence should continue. Otherwise we are inviting surrounding city problems homelessness, slums, theft etc.
9/27/2023 11:26 AM
50 If anything just seniors and residential, more rentals/apartments are just more problems to add to the community we don't have enough cops as is. Keep Escalon the same! Focus on 9/27/2023 11:22 AM

City of Escalon Housing Needs and Opportunities Survey
15 / 21
businesses
51 high end / large lots high and mid income 9/27/2023 11:16 AM 52 Build on empty lots 9/27/2023 11:12 AM
53 Less orchards, more multi-family housing 1 or 2 Bedrooms 2 Baths 9/27/2023 11:03 AM 54 Increase opportunities for multi unit projects in areas that would not impact current neighborhoods or businesses. Young and low income will stay and thrive in the community only if the community doesn’t change. Remember that income levels are fluid and those levels will grow into higher levels only if they are attractive to move into them. 9/21/2023 12:14 PM
55 No additional changes are needed. Everything is acceptable even in these tough economic times. But budget for maintenance is welcomed.
9/8/2023 2:14 PM
56 Not sure 9/6/2023 8:23 PM
57 Additional units on large lots. 9/5/2023 11:34 PM
58 Let’s keep the town small and not become the next Riverbank 9/5/2023 8:27 AM 59 People move to a small town for a reason, if they wanted to live around low income, they would move in Modesto or Stockton. Housing should not be equal, you get what you work for.

People work to have a nice house in Escalon, that shouldn’t be shadowed by people who don’t work and get free housing. Escalon is one of the unique communities in this area because of the fact that it’s still a close knit community and that’s because people have lived here for a very long time and have worked hard to preserve what their family started here. If you are a hard-working family, you can afford to live here and it is something you should make a goal to work towards, not given to you because then it’s not appreciated and respected. 9/4/2023 9:04 PM
60 Additional units on large lots 9/4/2023 10:36 AM
61 N/a 9/3/2023 8:30 PM
62 Multi dwelling housing. 9/2/2023 7:39 PM
63 Additional units on large lots. Multi generation homes. 9/1/2023 6:52 PM 64 All of the above. 9/1/2023 4:15 PM
65 Not sure 8/15/2023 1:42 PM
66 Looks to me like this survey is more about trying to turn escalon in some fake san Francisco euphoric downtown with multi family and use buildings than it is just allowing a small entry level subdivision, that would not only serve the so called need of seniors not being able to afford their large aging homes, but also 1st time buyers. But hey that's just common sense and the city of escalon seems to be quickly loosing that. 8/15/2023 6:24 AM
67 None of these. Need more single family housing. 8/14/2023 9:10 AM 68 Increase the ease/speed of permitting and fees to enlarge/remodel or add a room above a garage, or add a tiny house to a lot,
8/13/2023 7:32 PM
69 Just need affordable housing for the middle class. Middle class can not afford to purchase homes in Escalon right now.
8/12/2023 3:35 PM
70 Na 8/12/2023 2:03 PM
71 The last option. 8/12/2023 9:39 AM
72 Section 8 8/12/2023 7:59 AM
73 Granny flats would be a good start for seniors on fixed incomes. 8/12/2023 6:38 AM 74 ccccc 8/12/2023 5:31 AM
75 Commercial and industrial area converted to housing. 8/11/2023 11:41 PM 76 None, Escalon does not need creative housing. Nice single-family track housing 8/11/2023 10:48 PM 77 Additional units on large lots 8/11/2023 8:45 PM

City of Escalon Housing Needs and Opportunities Survey
16 / 21
78 There is plenty of housing. Fine as is. Do not want bay-area to move in. 8/11/2023 8:39 PM 79 With businesses closing use the land for housing instead of another fast food restaurant. 8/11/2023 6:18 PM 80 Homes with small parcels will not attract all type of buyers. 8/11/2023 4:53 PM 81 Need to have incentives to build on existing vacant lots. Need to build 50 homes per year minimum.
8/11/2023 4:15 PM
82 Commercial and industrial areas that get converted to housing. We have too many buildings that have been vacant far too long that could get converted easily. 8/11/2023 4:04 PM

STATE OF CALIFORNIA - BUSINESS, CONSUMER SERVICES AND HOUSING AGENCY GAVIN NEWSOM, Governor

DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT

DIVISION OF HOUSING POLICY DEVELOPMENT
651 Bannon Street, Suite 400
Sacramento, CA 95811
(916) 263-2911 / FAX (916) 263-7453
www.hcd.ca.gov
June 26, 2026
Jaylen French, Manager
Department of Development Services
City of Escalon
2060 McHenry Avenue
Escalon, CA 95320
Dear Jaylen French:

RE: City of Escalon’s 6th Cycle (2023-2031) Revised Draft Housing Element Thank you for submitting the City of Escalon’s (City) revised draft housing element received for review on May 20, 2026, along with revisions received on June 19, 2026.

The revisions were posted and made available to the public for seven days prior to review. Pursuant to Government Code section 65585, the California Department of Housing and Community Development (HCD) is reporting the results of its review.

The revised draft element, including revisions, meets the statutory requirements of State Housing Element Law (Gov. Code, § 65580 et seq), including findings that were described in HCD’s November 10, 2025 review. However, the housing element cannot be found in substantial compliance until the City has completed the necessary rezones (see below) to accommodate the Regional Housing Needs Allocation (RHNA). The housing element will substantially comply with State Housing Element Law when all necessary rezoning and the element are adopted, submitted to, and approved by HCD, in accordance with Government Code section 65585.

A jurisdiction that did not adopt a compliant housing element within 120 days from the statutory deadline (December 31, 2023) must rezone sites within one year of the statutory deadline and meet requirements pursuant to Government Code sections 65583, subdivision (c)(1)(A) and 65583.2, subdivisions (c), (h) and (i), as applicable. As this year has passed and Program 1-2 (Maintain Viable Sites) has not been completed, the housing element cannot be found in substantial compliance until rezoning has been completed to meet all statutory requirements.

Attachment 6

Jaylen French, Manager

Please be aware, the California appellate decision in Martinez v. City of Clovis held that when a local government employs an overlay zoning to accommodate its lower-income RHNA, both the base zone and the overlay zone must comply with the minimum density requirements of Government Code section 65583.2, subdivision (h). Furthermore, New Commune DTLA LLC v. City of Redondo Beach held that residential overlay zones cannot satisfy mandatory minimum density and residential use requirements of subdivision (h) when the underlying zoning allows for 100 percent nonresidential development on sites rezoned to accommodate the shortfall of lower-income RHNA.

The City should address impacts of these decisions on the current rezone strategy and adjust its recent rezoning accordingly to comply with section 65583.2, subdivision (h). (See Martinez v. City of Clovis 90 Cal.App.5th 193, 307 Cal.Rptr.3d 64 (2023); New Commune DTLA LLC v. City of Redondo Beach 115 Cal.App.5th 111, 337 Cal. Rptr. 3d 782 (2025).)
As a reminder, the City’s 6th cycle housing element was due December 31, 2023. As of today, the City has not completed the housing element process for the 6th cycle. The City’s 5th cycle housing element no longer satisfies statutory requirements. HCD encourages the City to expeditiously complete the rezone, adopt the housing element, and submit to HCD to regain housing element compliance.

Public participation in the development, adoption and implementation of the housing element is essential to effective housing planning. Throughout the housing element process, the City should continue to engage the community, including organizations that represent lower-income and special needs households, by making information regularly available and considering and incorporating comments where appropriate.

Please be aware, any revisions to the element must be posted on the local government’s website and to email a link to all individuals and organizations that have previously requested notices relating to the local government’s housing element at least seven days before submitting to HCD.

For your information, pursuant to Government Code section 65583.3, the City must submit an electronic sites inventory with its adopted housing element. The City must utilize standards, forms, and definitions adopted by HCD. Please see HCD’s housing element webpage at https://www.hcd.ca.gov/planning-and-communitydevelopment/housing-elements for a copy of the form and instructions. The City can reach out to HCD at [email protected] for technical assistance.

Several federal, state, and regional funding programs consider housing element compliance as an eligibility or ranking criteria. For example, the CalTrans Senate Bill (SB) 1 Sustainable Communities grant, the Affordable Housing and Sustainable Communities programs, and HCD’s Permanent Local Housing Allocation consider housing element compliance and/or annual reporting requirements pursuant to Government Code section 65400. With a compliant housing element, the City will meet housing element requirements for these and other funding sources.

Jaylen French, Manager

For your information, some general plan element updates are triggered by housing element adoption. HCD reminds the City to consider timing provisions and welcomes the opportunity to provide assistance. For information, please see the Technical Advisories issued by the Governor’s Office of Land Use and Climate Innovation at:
https://www.lci.ca.gov/planning/general-plan/guidelines.html.

HCD appreciates the efforts of the housing element update team throughout the housing element update and review. We are committed to assisting the City in addressing all statutory requirements of State Housing Element Law and welcome the opportunity to provide technical assistance during the adoption and rezone process. If you have any questions or need additional technical assistance, please contact Judith Hinh, of our staff, at [email protected].

Sincerely,
Paul McDougall
Senior Program Manager

STATE OF CALIFORNIA - BUSINESS, CONSUMER SERVICES AND HOUSING AGENCY GAVIN NEWSOM, Governor November 10, 2025
Jaylen French, Manager
Department of Development Services City of Escalon
2060 McHenry Avenue
Escalon, CA 95320
Dear Jaylen French:

RE: City of Escalon’s 6th Cycle (2023-2031) Revised Draft Housing Element Thank you for submitting the City of Escalon’s (City) revised draft housing element received for review on September 11, 2025. Pursuant to Government Code section 65585, the California Department of Housing and Community Development (HCD) is reporting the results of its review
The revised draft element addresses many of the statutory requirements described in HCD’s January 13, 2025 review; however, revisions will be necessary to substantially comply with State Housing Element Law (Gov. Code, § 65580 et seq), as follows:

1. Affirmatively further[ing] fair housing in accordance with Chapter 15 (commencing with Section 8899.50) of Division 1 of Title 2…shall include an assessment of fair housing in the jurisdiction. (Gov. Code, § 65583, subd. (c)(10)(A).) Promote and affirmatively further fair housing opportunities and promote housing throughout the community or communities for all persons regardless of race, religion, sex, marital status, ancestry, national origin, color, familial status, or disability, and other characteristics... (Gov. Code, § 65583, subd. (c)(5).) Identified Sites and Affirmatively Furthering Fair Housing (AFFH): HCD’s prior review found the element should analyze the income categories of identified sites with respect to location, the number of sites and units by all income groups and how that effects the existing patterns for all components of the assessment of fair housing (e.g., segregation and integration, access to opportunity). The review also found the analysis should be conducted at a geography smaller than census tracts (e.g., block group, planning area, neighborhoods, quadrants). In response, the element lists sites by income group and TCAC Resource Area and concludes the sites are primarily

DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT

DIVISION OF HOUSING POLICY DEVELOPMENT
651 Bannon Street, Suite 400
Sacramento, CA 95811
(916) 263-2911 / FAX (916) 263-7453
www.hcd.ca.gov
Attachment 7

Jaylen French, Manager

located in High and Highest Resource Areas. However, the entire City is primarily High and Highest Resource Areas which doesn’t offer much analysis of the location of the sites by income group or impacts on existing patterns of socio-economic characteristics. As noted in the prior reviews, the element must still analyze identified sites by income group at a geography smaller than census tracts (e.g., block group, planning area, neighborhoods, quadrants) and should consider all components of the assessment of fair housing such as median income, poverty and overpayment. This analysis should also incorporate local data and knowledge and other relevant factors (See Below). HCD will send sample analysis under separate cover.

Local Data and Knowledge, and Other Relevant Factors: HCD’s prior review found the analysis should incorporate local data and knowledge and other relevant factors to better understand fair housing issues. In response, the element included Table 17 and some other minor revisions but that information largely consists of additional federal data. Instead, the element should utilize local data and knowledge such as information from City officials or representatives to better understand disparities in access to opportunities or fair housing conditions between neighborhoods. For example, local data and knowledge should explain any differences between neighborhoods related to the quality and condition of parks, sidewalks, safe routes to school, active transportation, community amenities, grocery stores and air quality. To assist with this requirement, please see HCD’s prior sent guidance on local data and knowledge and other relevant factors.

Contributing Factors to Fair Housing Issues: Based on the outcomes of a complete analysis, the element should reassess and prioritize contributing factors to fair housing issues.

Programs: As noted above, the element requires a complete AFFH analysis.

Depending upon the results of that analysis, the City may need to revise or add programs. Goals and actions must specifically respond to the analysis and to the identified and prioritized contributing factors to fair housing issues and must be significant and meaningful enough to overcome identified patterns and trends.

Actions must have specific commitment, milestones, geographic targeting and metrics or numerical targets and, as appropriate, address housing mobility enhancement (housing choices and affordability across geographies), new housing choices and affordability in relatively higher opportunity or income areas (throughout the City), place-based strategies for community preservation and revitalization, and displacement protection.

2. Include an analysis and documentation of household characteristics, including level of payment compared to ability to pay, housing characteristics, including overcrowding, and housing stock condition. (Gov. Code, § 65583, subd. (a)(2).) Overpayment: HCD’s prior review found the element should analyze the number of lower-income households overpaying for housing by tenure (i.e., renter and owner) and incorporate or modify policies and programs as appropriate. The element was not revised to address this requirement. While the element includes Table 16 (Cost

Jaylen French, Manager

Burden and Housing Burdens by Tenure), it does not provide any accompanying analysis of lower-income households by tenure. For example, the element could discuss the tenure rate of lower-income households overpaying, compare that rate to other income groups, the severity of overpayment by tenure (e.g., greater than 50 percent), magnitude of the need and resources and strategies to address the housing need.

Housing Conditions: The element now explains the presence of one dilapidated unit and that the complaints about housing issues are more prevalent in older neighborhoods but must still estimate the number of units in need of rehabilitation.

For example, the analysis could include estimates from a recent windshield survey or sampling or estimates from code enforcement officials.

3. An analysis of potential and actual governmental constraints upon the maintenance, improvement, or development of housing for all income levels, including the types of housing identified in paragraph (1) of subdivision (c), and for persons with disabilities as identified in the analysis pursuant to paragraph (7), including… …site improvements… …and local processing and permit procedures... (Gov. Code, § 65583, subd. (a)(5).)
An analysis of potential and actual nongovernmental constraints upon the maintenance, improvement, or development of housing for all income levels, including… …the length of time between receiving approval for a housing development and submittal of an application for building permits for that housing development that hinder the construction of a locality’s share of the regional housing need in accordance with Government Code section 65584... (Gov. Code, § 65583, subd. (a)(6).)
Address and, where appropriate and legally possible, remove governmental and nongovernmental constraints to the maintenance, improvement, and development of housing, including housing for all income levels and housing for persons with disabilities... (Gov. Code, § 65583, subd. (c)(3).)
On/Off-Site Improvements: The element describes on- and off-site improvements but should also analyze impacts on housing costs and supply and add or modify programs, as appropriate. For example, the element should discuss typical costs and impacts on total development costs (e.g., percentage of total development costs).

Local Processing and Permit Procedures: HCD’s prior review found the element must still describe and analyze the City's permit processing and approval procedures for a typical development that is consistent with the general plan and zoning. In response, the element now explains multifamily development is permitted by right and subject to design guidelines. But the element should still list any approval findings and evaluate impacts on approval certainty for both the Site and Architectural Review and Design Guidelines.

Jaylen French, Manager

Growth Management Ordinance (GMO): The element generally was not revised to address this requirement. The element should still specifically evaluate scoring criteria for impacts on housing costs and supply, approval certainty and timing and add or modify programs to address identified constraints.

Approval Time: HCD’s prior review found the element must analyze the length of time between receiving approval for a housing development and submittal of an application for building permits and address any hinderance on the development of housing and include programs as appropriate. In response, the element now mentions the length of time between final entitlement and issuance of a building permit but should instead address the length of time between final entitlement and submittal of an application for building permits.

Programs: As noted above, the element requires a complete analysis of potential governmental and nongovernmental constraints. Depending upon the results of that analysis, the City may need to revise or add programs and address and remove or mitigate any identified constraints.

4. Identify actions that will be taken to make sites available during the planning period with appropriate zoning and development standards and with services and facilities to accommodate that portion of the city’s or county’s share of the regional housing need for each income level that could not be accommodated on sites identified in the inventory..Sites shall be identified as needed to facilitate and encourage the development of a variety of types of housing for all income levels, including… …emergency shelters, and transitional housing. (Gov. Code, § 65583, subd. (c)(1).) Program 1-2 (Action D) (Maintain Viable Sites): HCD’s prior review found the element continues to use Site 12 (APN 225-020-18) and should either rezone the site to meet statutory requirements or utilize the site for the moderate or above moderate-income RHNA and identify additional sites with appropriate zoning to accommodate the RHNA. Please see HCD’s prior reviews for additional information. In response, the element now acknowledges sites must be rezoned to be utilized toward the RHNA for lower-income households. However, rezoning must meet by right requirements pursuant to Government Code section 65583.2, subdivision (h) and (i). For example, the Program must commit to minimum densities and affordability and permitting housing development without discretionary action.

Program 1-2 (Action F) (Maintain Viable Sites): While the Program now commits to monitor RHNA production and implement alternative action, it should commit to when alternative actions will be completed.

Program 2-1 (Action J) (Zoning for a Variety of Housing Types): The Program should commit to revise the definition of emergency shelters and should clarify that emergency shelters will be permitted without discretionary action.

Jaylen French, Manager

5. Establish the number of housing units, by income level, that can be constructed, rehabilitated, and conserved over a five-year time frame. (Gov. Code, § 65583, subd. (b)(1 & 2).)
HCD’s prior review found rehabilitation and conservation objectives for all income groups should be increased to better reflect the housing needs of the community.

Please see HCD’s prior review for additional information. However, Table 4 (Quantified Objectives), on page 46 of the policy document, was not revised to address HCD’s findings.

The element will meet the statutory requirements of State Housing Element Law once rezones have been completed to meet all statutory requirements (see below) and the element has been revised, adopted, submitted to HCD and reviewed by HCD to comply with the above requirements pursuant to Government Code section 65585.

For your information, pursuant to Assembly Bill 1398 (Chapter 358, Statutes of 2021), if a local government does not adopt a compliant housing element within 120 days of the statutory deadline (December 31, 2023), then any rezoning to make prior identified sites available or accommodate the regional housing needs allocation (RHNA) shall be completed no later than one year from the statutory deadline pursuant to Government Code sections 65583, subdivision (c) and 65583.2, subdivision (c). As this year has passed, the housing element will remain out of compliance until all necessary rezoning has been completed.

As a reminder, the City’s 6th cycle housing element was due December 31, 2023. As of today, the City has not completed the housing element process for the 6th cycle. The City’s 5th cycle housing element no longer satisfies statutory requirements. HCD encourages the City to expeditiously revise the element as described above, adopt, and submit to HCD to regain housing element compliance.

Public participation in the development, adoption and implementation of the housing element is essential to effective housing planning. Throughout the housing element process, the City should continue to engage the community, including organizations that represent lower-income and special needs households, by making information regularly available and considering and incorporating comments where appropriate. Please be aware, any revisions to the element must be posted on the local government’s website and to email a link to all individuals and organizations that have previously requested notices relating to the local government’s housing element at least seven days before submitting to HCD.

For your information, pursuant to Government Code section 65583.3, subdivision (b), upon adoption of the housing element, the City must submit an electronic version of the sites inventory with its adopted housing element to [email protected].

Please note, the City must utilize standards, forms, and definitions adopted by HCD when preparing the sites inventory. Please see HCD’s housing element webpage at https://www.hcd.ca.gov/community-development/housing-element/index.shtml#element for a copy of the form and instructions. The City can reach out to HCD at

Jaylen French, Manager

[email protected] for technical assistance.

Several federal, state, and regional funding programs consider housing element compliance as an eligibility or ranking criteria. For example, the CalTrans Senate Bill (SB) 1 Sustainable Communities grant, the Affordable Housing and Sustainable Communities program, and HCD’s Permanent Local Housing Allocation consider housing element compliance and/or annual reporting requirements pursuant to Government Code section 65400. With a compliant housing element, the City will meet housing element requirements for these and other funding sources.

For your information, some general plan element updates are triggered by housing element adoption. HCD reminds the City to consider timing provisions and welcomes the opportunity to provide assistance. For information, please see the Technical Advisories issued by the Governor’s Office of Land Use and Climate Innovation at:
https://www.lci.ca.gov/planning/general-plan/guidelines.html.

HCD appreciates the hard work of the City in preparation and review of the housing element. We are committed to assisting the City in addressing all statutory requirements of State Housing Element Law. If you have any questions or need additional technical assistance, please contact Judith Hinh, of our staff, at [email protected].

Sincerely,
Paul McDougall
Senior Program Manager

STATE OF CALIFORNIA - BUSINESS, CONSUMER SERVICES AND HOUSING AGENCY GAVIN NEWSOM, Governor

DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT

DIVISION OF HOUSING POLICY DEVELOPMENT
951 Bannon Street, Suite 400
Sacramento, CA 95811
(916) 263-2911 / FAX (916) 263-7453
www.hcd.ca.gov
January 13, 2025
Jaylen French, Manager
Department of Development Services
City of Escalon
2060 McHenry Avenue
Escalon, CA 95320
Dear Jaylen French:

RE: City of Escalon’s 6th Cycle (2023-2031) Revised Draft Housing Element Thank you for submitting the City of Escalon’s (City) revised draft housing element received for review on November 15, 2024. Pursuant to Government Code section 65585, the California Department of Housing and Community Development (HCD) is reporting the results of its review.

The revised draft element addresses many statutory requirements described in HCD’s March 28, 2024 review; however, revisions will be necessary to substantially comply with State Housing Element Law (Gov. Code, § 65580 et seq). The enclosed Appendix describes the revisions needed to comply with State Housing Element Law.

As a reminder, the City’s 6th cycle housing element was due December 31, 2023. As of today, the City has not completed the housing element process for the 6th cycle. The City’s 5th cycle housing element no longer satisfies statutory requirements. HCD encourages the City to revise the element as described above, adopt, and submit to HCD to regain housing element compliance.

Public participation in the development, adoption and implementation of the housing element is essential to effective housing planning. Throughout the housing element process, the City should continue to engage the community, including organizations that represent lower-income and special needs households, by making information regularly available and considering and incorporating comments where appropriate. Please be aware, any revisions to the element must be posted on the local government’s website and to email a link to all individuals and organizations that have previously requested notices relating to the local government’s housing element at least seven days before submitting to HCD.

Attachment 8

Jaylen French, Manager

For your information, pursuant to Assembly Bill 1398 (Chapter 358, Statutes of 2021), if a local government does not adopt a compliant housing element within 120 days of the statutory deadline (December 31, 2023), then any rezoning to make prior identified sites available or accommodate the regional housing needs allocation shall be completed no later than one year from the statutory deadline pursuant to Government Code sections 65583, subdivision (c) and 65583.2, subdivision (c). Otherwise, the local government’s housing element will no longer comply with State Housing Element Law, and HCD may revoke its finding of substantial compliance pursuant to Government Code section 65585, subdivision (i). Please be aware, if the City does not adopt a compliant housing element within one year from the statutory deadline, the element cannot be found in substantial compliance until these rezones are completed.

Several federal, state, and regional funding programs consider housing element compliance as an eligibility or ranking criteria. For example, the CalTrans Senate Bill (SB) 1 Sustainable Communities grant, the Affordable Housing and Sustainable Communities program, and HCD’s Permanent Local Housing Allocation consider housing element compliance and/or annual reporting requirements pursuant to Government Code section 65400. With a compliant housing element, the City will meet housing element requirements for these and other funding sources.

For your information, some general plan element updates are triggered by housing element adoption. HCD reminds the City to consider timing provisions and welcomes the opportunity to provide assistance. For information, please see the Technical Advisories issued by the Governor’s Office of Planning and Research at:
https://www.opr.ca.gov/planning/general-plan/guidelines.html.

We are committed to assisting the City in addressing all statutory requirements of State Housing Element Law. If you have any questions or need additional technical assistance, please contact Judith Hinh, of our staff [email protected].

Sincerely,
Paul McDougall
Senior Program Manager
Enclosure

City of Escalon’s 6th Cycle (2023-2031) Revised Draft Housing Element Page 1 January 13, 2025

APPENDIX

CITY OF ESCALON
The following changes are necessary to bring the City’s housing element into compliance with Article 10.6 of the Government Code. Accompanying each recommended change, we cite the supporting section of the Government Code.

Housing element technical assistance information is available on HCD’s website at https://www.hcd.ca.gov/planning-and-community-development/hcd-memos. Among other resources, the housing element section contains HCD’s latest technical assistance tool, Building Blocks for Effective Housing Elements (Building Blocks), available at https://www.hcd.ca.gov/planning-and-community-development/housing-elements/buildingblocks and includes the Government Code addressing State Housing Element Law and other resources.

A. Housing Needs, Resources, and Constraints

1. Affirmatively further[ing] fair housing in accordance with Chapter 15 (commencing with Section 8899.50) of Division 1 of Title 2…shall include an assessment of fair housing in the jurisdiction. (Gov. Code, § 65583, subd. (c)(10)(A).) Enforcement and Outreach: As noted in the prior review, the element should discuss how the City complies with fair housing laws. For example, the element should explain how the City implements Government Code section 8899.50 which requires all subdivisions of the state to affirmatively furthering fair housing (AFFH) in all activities and programs relating to housing and community development. For more information, please see HCD’s prior review and guidance at https://www.hcd.ca.gov/planning-andcommunity-development/affirmatively-furthering-fair-housing.

Integration and Segregation: The element generally was not revised to address this requirements. Please see HCD’s prior review for additional information.

Disproportionate Housing Needs and Displacement Risk: The element generally was not revised to address this requirement. Please see HCD’s prior review for additional information.

Identified Sites and AFFH: While the element generally mentions the type of resource area where some sites are located and makes a brief conclusion of impacts on fair housing conditions, it should still analyze the income categories of identified sites with respect to location, the number of sites and units by all income groups and how that effects the existing patterns for all components of the assessment of fair housing (e.g., segregation and integration, access to opportunity). The analysis should also incorporate approved and pending projects and be conducted at a geography smaller than census tracts (e.g., block group, planning area, neighborhoods, quadrants). Please see HCD’s prior review for additional information.

City of Escalon’s 6th Cycle (2023-2031) Revised Draft Housing Element Page 2 January 13, 2025
Local Data and Knowledge, and Other Relevant Factors: The element generally was not revised to address this requirement. Please see HCD’s prior review for additional information. In addition, HCD will send guidance and samples under separate cover.

Contributing Factors to Fair Housing Issues: Based on the outcomes of a complete analysis, the element should re-assess and prioritize contributing factors to fair housing issues.

2. Include an analysis of population and employment trends and documentation of projections and a quantification of the locality's existing and projected needs for all income levels, including extremely low-income households. (Gov. Code, § 65583, subd. (a)(1).)
Include an analysis and documentation of household characteristics, including level of payment compared to ability to pay, housing characteristics, including overcrowding, and housing stock condition. (Gov. Code, § 65583, subd. (a)(2).) Analyze any special housing needs such as elderly; persons with disabilities, including a developmental disability; large families; farmworkers; families with female heads of households; and families and persons in need of emergency shelter. (Gov. Code, § 65583, subd. (a)(7).)
Overpayment: The element generally was not revised to address this requirement.

Please see HCD’s prior review for additional information.

Housing Conditions: While the element now explains some older homes may need rehabilitation, it must still include an estimate of the number of units in need of rehabilitation. Please see HCD’s prior review for additional information.

Housing Stock (Unit Types): The element generally was not revised to address this requirement. Please see HCD’s prior review for additional information.

3. An inventory of land suitable and available for residential development, including vacant sites and sites having realistic and demonstrated potential for redevelopment during the planning period to meet the locality’s housing need for a designated income level, and an analysis of the relationship of zoning and public facilities and services to these sites. (Gov. Code, § 65583, subd. (a)(3).)
Progress toward the Regional Housing Need Allocation (RHNA): While the element now discusses the affordability of pipeline projects, it must still demonstrate their availability or likelihood of development in the planning period. Specifically, the element should expand the description of status and address remaining steps to building permit issuance, any known barriers and likelihood the units will be built in the planning period, given any past trends of expiring entitlements.

City of Escalon’s 6th Cycle (2023-2031) Revised Draft Housing Element Page 3 January 13, 2025
Realistic Capacity: The element generally was not revised to address this requirement.

Please see HCD’s prior review for additional information.

Availability of Infrastructure: The element now explains total water and sewer capacity is available and planned to accommodate the RHNA, However, as noted in the prior review, the should also describe the existing or planned accessibility of infrastructure to identified sites and, if necessary, add or modify programs to address identified constraints.

Zoning for Lower-Income Households: The element was not revised to address this requirement. The element continues to use Site 12 (APN 225-020-18) with an allowable density of 15 units per acre that does not meet default densities. As noted in the prior review, densities of 15 units per acre have not been considered appropriate for developments of housing for lower-income households. As a result, the element should either rezone the site to meet statutory requirements or utilize the site for the moderate or above moderate-income RHNA and identify additional sites with appropriate zoning to accommodate the RHNA. The City may utilize an overlay zone to meet these requirements.

Nonvacant Sites: For your information, if the housing element relies upon nonvacant sites to accommodate more than 50 percent of the RHNA for lower-income households, the housing element must demonstrate that the existing use is not an impediment to additional residential development in the planning period. This can be demonstrated by providing substantial evidence that the existing use is likely to be discontinued during the planning period (Gov. Code, § 65583.2, subd. (g)(2).). Absent findings (e.g., adoption resolution) based on substantial evidence, the existing uses will be presumed to impede additional residential development and will not be utilized toward demonstrating adequate sites to accommodate the RHNA. Please see HCD’s Guidance memo (p. 27) for additional information: https://www.hcd.ca.gov/communitydevelopment/housing-element/housing-elementmemos/docs/sites_inventory_memo_final06102020.pdf.

Electronic Sites Inventory: Pursuant to Government Code section 65583.3, subdivision (b), upon adoption of the housing element, the City must submit an electronic version of the sites inventory with its adopted housing element to [email protected].

Please note, the City must utilize standards, forms, and definitions adopted by HCD when preparing the sites inventory. Please see HCD’s housing element webpage at https://www.hcd.ca.gov/community-development/housing-element/index.shtml#element for a copy of the form and instructions. The City can reach out to HCD at [email protected] for technical assistance.

Zoning for a Variety of Housing Types (Emergency Shelters): The element generally was not revised to address this requirement. Please see HCD’s prior review for additional information.

City of Escalon’s 6th Cycle (2023-2031) Revised Draft Housing Element Page 4 January 13, 2025

4. An analysis of potential and actual governmental constraints upon the maintenance, improvement, or development of housing for all income levels, including the types of housing identified in paragraph (1) of subdivision (c), and for persons with disabilities as identified in the analysis pursuant to paragraph (7), including land use controls, building codes and their enforcement, site improvements, fees and other exactions required of developers, and local processing and permit procedures... (Gov. Code, § 65583, subd. (a)(5).)
Land Use Controls: While the element now addresses multifamily heights and parking requirements, it must still demonstrate compliance with State Density Bonus Law (SDBL) and add or modify programs, as appropriate, to comply with recent changes to statutory requirements. Please see HCD’s prior review for additional information.

On/Off-Site Improvements: While the element now generally concludes site improvements are not excessive, it should still evaluate impacts on housing supply and costs such as typical costs and impacts on total development costs.

Local Processing and Permit Procedures: The element now addresses intersections between the Permit Streamlining Act and the California Environmental Quality Act, including streamlining determinations. However, the element must still describe and analyze the City's permit processing and approval procedures for a typical development that is consistent with the general plan and zoning. The analysis should address the type of permit, approval body, number of hearings, design guidelines (including the newly adopted guidelines) and approval findings and evaluate impacts on housing cost and supply and approval certainty.

Growth Management Ordinance (GMO): The element now describes the GMO and includes commitments to mitigate constraints on development. However, the element should also specifically evaluate scoring criteria for impacts on housing costs and supply, approval certainty and timing and add or modify programs to address identified constraints.

5. An analysis of potential and actual nongovernmental constraints upon the maintenance, improvement, or development of housing for all income levels, including… …length of time between receiving approval for a housing development and submittal of an application for building permits for that housing development that hinder the construction of a locality’s share of the regional housing need in accordance with Government Code section 65584... (Gov. Code, § 65583, subd. (a)(6).) Approval Time and Requests for Lesser Densities: While the element now addresses requests for lesser densities, it must still address the length of time between final approval and request for building permit for housing development. Please see HCD’s prior review for additional information.

City of Escalon’s 6th Cycle (2023-2031) Revised Draft Housing Element Page 5 January 13, 2025
B. Housing Programs

1. Identify actions that will be taken to make sites available during the planning period with appropriate zoning and development standards and with services and facilities to accommodate that portion of the city’s or county’s share of the regional housing need for each income level that could not be accommodated on sites identified in the inventory... …Sites shall be identified as needed to facilitate and encourage the development of a variety of types of housing for all income levels, including multifamily rental housing, factory-built housing, mobilehomes, housing for agricultural employees, supportive housing, single-room occupancy units, emergency shelters, and transitional housing. (Gov. Code, § 65583, subd. (c)(1).)
As noted in Finding A3, the element does not include a complete site analysis; therefore, the adequacy of sites and zoning were not established. Based on the results of a complete sites inventory and analysis, the City may need to add or revise programs to address a shortfall of sites or zoning available to encourage a variety of housing types. In addition, programs should be added or modified, as follows:
• Program 1-2(F) (Maintain Viable Sites): Given the reliance on religious institutional sites, Program 1-2(F) (Maintain Viable Sites) should specifically monitor the effectiveness of Programs to encourage development on religious institutional sites and pursue alternative measures (e.g., incentives, funding, identifying alternative sites) within a specified time. • Program 2-1(H) (Zoning for a Variety of Housing Types - Single Room Occupancy (SRO) Units): The Program should commit to establish development standards that encourage and facilitate the development of SROs.

2. The Housing Element shall contain programs which assist in the development of adequate housing to meet the needs of extremely low-, very low-, low- and moderateincome households. (Gov. Code, § 65583, subd. (c)(2).) Program 2-6 (Farmworker Housing): As noted in HCD’s prior review, the Program should be expanded based on the outcomes of a complete analysis such as identifying opportunities to integrate farmworkers into developments, offer incentives for housing for farmworkers, subsequent actions toward outcomes from meeting with surrounding jurisdiction, proactive marketing of existing programs, establishing partnerships with non-profit and affordable developers to identify housing opportunities and addressing housing and neighborhood conditions for existing farmworkers.

3. Address and, where appropriate and legally possible, remove governmental and nongovernmental constraints to the maintenance, improvement, and development of housing, including housing for all income levels and housing for persons with disabilities. The program shall remove constraints to, and provide reasonable accommodations for housing designed for, intended for occupancy by, or with supportive services for, persons with disabilities. (Gov. Code, § 65583, subd. (c)(3).)

City of Escalon’s 6th Cycle (2023-2031) Revised Draft Housing Element Page 6 January 13, 2025
As noted in Findings A4 and A5, the element requires a complete analysis of potential governmental and nongovernmental constraints. Depending upon the results of that analysis, the City may need to revise or add programs and address and remove or mitigate any identified constraints. In addition, the element should be revised, as follows:
• Program 4-1(A) (Removal of Constraints – GMO): The Program must commit to suspend the Growth Management Ordinance (GMO) to comply with the Housing Crisis Act (Gov. Code, § 66300, subd. (b)(1).).
• Program 5-5 (Reasonable Accommodation: The reasonable accommodation procedure contains constraints on housing for persons with disabilities.

Specifically, approval findings related to impacts on surrounding uses add an unnecessary and uncertain layer of discretion and act as a barrier to providing reasonable accommodation. Program 5-5 should specifically commit to remove this approval finding by a specified date early in the planning period.

4. Promote and affirmatively further fair housing opportunities and promote housing throughout the community or communities for all persons regardless of race, religion, sex, marital status, ancestry, national origin, color, familial status, or disability, and other characteristics... (Gov. Code, § 65583, subd. (c)(5).)
As noted in Finding B1, the element requires a complete AFFH analysis. Depending upon the results of that analysis, the City may need to revise or add programs. Goals and actions must specifically respond to the analysis and to the identified and prioritized contributing factors to fair housing issues and must be significant and meaningful enough to overcome identified patterns and trends. Actions must have specific commitment, milestones, geographic targeting and metrics or numerical targets and, as appropriate, address housing mobility enhancement (housing choices and affordability across geographies), new housing choices and affordability in relatively higher opportunity or income areas (throughout the City), place-based strategies for community preservation and revitalization, and displacement protection.

C. Quantified Objectives

Establish the number of housing units, by income level, that can be constructed, rehabilitated, and conserved over a five-year time frame. (Gov. Code, § 65583, subd. (b)(1 & 2).)
Rehabilitation and conservation objectives for all income groups should be increased to better reflect the housing needs of the community. Please see HCD’s prior review for additional information.

City of Escalon’s 6th Cycle (2023-2031) Revised Draft Housing Element Page 7 January 13, 2025
D. Public Participation
Local governments shall make a diligent effort to achieve public participation of all economic segments of the community in the development of the Housing Element, and the element shall describe this effort. (Gov. Code, § 65583, subd.(c)(9).).

The element generally was not revised to address this requirement. As noted in the prior review, the element must also summarize the input and describe how the input was considered and incorporated into the element, including any input as a result of future public participation efforts.

STATE OF CALIFORNIA - BUSINESS, CONSUMER SERVICES AND HOUSING AGENCY GAVIN NEWSOM, Governor

DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT

DIVISION OF HOUSING POLICY DEVELOPMENT
2020 W. El Camino Avenue, Suite 500
Sacramento, CA 95833
(916) 263-2911 / FAX (916) 263-7453
www.hcd.ca.gov
March 27, 2024
Jaylen French, Manager
Department of Development Services
City of Escalon
2060 McHenry Avenue
Escalon, CA 95320
Dear Jaylen French:

RE: City of Escalon’s 6th Cycle (2023-2031) Draft Housing Element Thank you for submitting the City of Escalon’s (City) draft housing element received for review on December 29, 2023. Pursuant to Government Code section 65585, the California Department of Housing and Community Development (HCD) is reporting the results of its review. In addition, HCD considered comments from David Kellogg pursuant to Government Code section 65585, subdivision (c).

The draft element addresses many statutory requirements; however, revisions will be necessary to substantially comply with State Housing Element Law (Gov. Code, § 65580 et seq). The enclosed Appendix describes the revisions needed to comply with State Housing Element Law.

As a reminder, the City’s 6th cycle housing element was due December 31, 2023. As of today, the City has not completed the housing element process for the 6th cycle. The City’s 5th cycle housing element no longer satisfies statutory requirements. HCD encourages the City to revise the element as described above, adopt, and submit to HCD to regain housing element compliance.

Public participation in the development, adoption and implementation of the housing element is essential to effective housing planning. Throughout the housing element process, the City should continue to engage the community, including organizations that represent lower-income and special needs households, by making information regularly available and considering and incorporating comments where appropriate. Please be aware, any revisions to the element must be posted on the local government’s website and to email a link to all individuals and organizations that have previously requested notices relating to the local government’s housing element at least seven days before submitting to HCD.

Attachment 9

Jaylen French, Manager

For your information, pursuant to Assembly Bill 1398 (Chapter 358, Statutes of 2021), if a local government does not adopt a compliant housing element within 120 days of the statutory deadline (December 31, 2023), then any rezoning to make prior identified sites available or accommodate the regional housing needs allocation shall be completed no later than one year from the statutory deadline pursuant to Government Code sections 65583, subdivision (c) and 65583.2, subdivision (c). Otherwise, the local government’s housing element will no longer comply with State Housing Element Law, and HCD may revoke its finding of substantial compliance pursuant to Government Code section 65585, subdivision (i). Please be aware, if the City does not adopt a compliant housing element within one year from the statutory deadline, the element cannot be found in substantial compliance until these rezones are completed.

Several federal, state, and regional funding programs consider housing element compliance as an eligibility or ranking criteria. For example, the CalTrans Senate Bill (SB) 1 Sustainable Communities grant, the Affordable Housing and Sustainable Communities program, and HCD’s Permanent Local Housing Allocation consider housing element compliance and/or annual reporting requirements pursuant to Government Code section 65400. With a compliant housing element, the City will meet housing element requirements for these and other funding sources.

For your information, some general plan element updates are triggered by housing element adoption. HCD reminds the City to consider timing provisions and welcomes the opportunity to provide assistance. For information, please see the Technical Advisories issued by the Governor’s Office of Planning and Research at:
https://www.opr.ca.gov/planning/general-plan/guidelines.html.

We are committed to assist the City in addressing all statutory requirements of State Housing Element Law. If you have any questions or need additional technical assistance, please contact Joanna Chang, of our staff, at [email protected].

Sincerely,
Paul McDougall
Senior Program Manager
Enclosure

City of Escalon’s 6th Cycle (2023-2031) Draft Housing Element Page 1 March 28, 2024

APPENDIX

CITY OF ESCALON
The following changes are necessary to bring the City’s housing element into compliance with Article 10.6 of the Government Code. Accompanying each recommended change, we cite the supporting section of the Government Code.

Housing element technical assistance information is available on HCD’s website at https://www.hcd.ca.gov/planning-and-community-development/hcd-memos. Among other resources, the housing element section contains HCD’s latest technical assistance tool, Building Blocks for Effective Housing Elements (Building Blocks), available at https://www.hcd.ca.gov/planning-and-community-development/housing-elements/buildingblocks and includes the Government Code addressing State Housing Element Law and other resources.

A. Review and Revise
Review the previous element to evaluate the appropriateness, effectiveness, and progress in implementation, and reflect the results of this review in the revised element. (Gov. Code, § 65588 (a) and (b).)
The element must include a program-by-program review including a quantification or explanation of progress and evaluation of effectiveness of programs in achieving objectives and how programs will be adjusted in the current planning cycle. Particularly, in many cases for progress in implementation, the element explains the program “…has been implemented on an ongoing basis.” Instead, the element should discuss actual results or outcomes in relation to the program’s objectives then evaluate whether the program was effective.

In addition, as part of the evaluation of programs in the past cycle, the element must also provide an explanation of the effectiveness of goals, policies, and related actions in meeting the housing needs of special needs populations (e.g., elderly, persons with disabilities, large households, female-headed households, farmworkers, and persons experiencing homelessness). Based on the outcomes of this analysis, the element should add or modify programs.

B. Housing Needs, Resources, and Constraints

1. Affirmatively further[ing] fair housing in accordance with Chapter 15 (commencing with Section 8899.50) of Division 1 of Title 2…shall include an assessment of fair housing in the jurisdiction. (Gov. Code, § 65583, subd. (c)(10)(A).) Enforcement and Outreach: The element explains various fair housing laws but should also discuss how the City complies with fair housing laws. In addition, the element should discuss any past or current fair housing lawsuits, findings, settlements, judgements, or complaints.

City of Escalon’s 6th Cycle (2023-2031) Draft Housing Element Page 2 March 28, 2024
Integration and Segregation: The element includes some data on integration and segregation but should also discuss local patterns (within the City) related to concentrations of familial status and persons with disabilities.

Disproportionate Housing Needs and Displacement Risk: The element includes some general information on housing conditions but should also evaluate those needs, impacts and patterns within the City. Specifically, the element should discuss any areas of potentially higher needs of rehabilitation and replacement. The element should utilize local data and knowledge such as code enforcement officials to assist this analysis.

Identified Sites and Affirmatively Furthering Fair Housing (AFFH): The element generally concludes that identified sites are spread throughout the City and primarily located in higher resource areas but should include analysis to support these conclusions or draw other conclusions. The analysis should address the income categories of identified sites with respect to location, the number of sites and units by all income groups and how that effects the existing patterns for all components of the assessment of fair housing (e.g., segregation and integration, access to opportunity).

The analysis should also incorporate approved and pending projects and discuss whether the distribution of sites improves or exacerbates fair housing conditions. If sites exacerbate conditions, the element should identify mitigating program actions.

Local Data and Knowledge, and Other Relevant Factors: The element must include local data, knowledge, and other relevant factors to discuss and analyze any unique attributes about the City related to fair housing issues. The element should complement federal, state, and regional data with local data and knowledge where appropriate to capture emerging trends and issues, including utilizing knowledge from local and regional advocates and service providers. Also, the element must include other relevant factors that contribute to fair housing issues in the jurisdiction. For instance, the element can analyze historical land use and investment practices or other information and demographic trends.

Contributing Factors to Fair Housing Issues: Based on the outcomes of a complete analysis, the element should re-assess and prioritize contributing factors to fair housing issues.

2. Include an analysis of population and employment trends and documentation of projections and a quantification of the locality's existing and projected needs for all income levels, including extremely low-income households. (Gov. Code, § 65583, subd. (a)(1).)
Include an analysis and documentation of household characteristics, including level of payment compared to ability to pay, housing characteristics, including overcrowding, and housing stock condition. (Gov. Code, § 65583, subd. (a)(2).) Analyze any special housing needs such as elderly; persons with disabilities, including a developmental disability; large families; farmworkers; families with female heads of households; and families and persons in need of emergency shelter. (Gov. Code, § 65583, subd. (a)(7).)

City of Escalon’s 6th Cycle (2023-2031) Draft Housing Element Page 3 March 28, 2024
Extremely Low-Income Households (ELI): The element must quantify the total number of projected ELI households. The projected housing need for ELI households can be calculated by using available census data to determine the number of very low-income households that qualify as ELI households or presume that 50 percent of the regional housing need allocation (RHNA) for very low-income households qualify as ELI households.

Overpayment: While the element identifies the total number of households overpaying for housing (p. 4-8), it must analyze the number of lower-income households overpaying for housing by tenure (i.e., renter and owner) and incorporate or modify policies and programs as appropriate.

Housing Conditions: The element must analyze the condition of the existing housing stock and estimate the number of units in need of rehabilitation and replacement. For example, the analysis could include estimates from a recent windshield survey or sampling or estimates from code enforcement officials.

Housing Costs: While the element includes information on the median home value based on American Community Survey data, it should consider other data sources to better reflect market conditions.

Housing Stock (Unit Types): The element must quantify and analyzes the number and proportion of housing units by type. An analysis should address trends and how disproportions of housing types can affect choices and affordability.

Special Housing Needs (Farmworkers): While the element includes some general data on farmworkers, it should also utilize information from the Office of Education regarding migrant student programs. In addition, the analysis should address trends, characteristics, disproportionate needs, effectiveness of resources and strategies, magnitude of the housing need, including disproportionate housing need and the effectiveness of past policies, programs, and funding to help address those gaps. The analysis may utilize past farmworker housing studies and other studies generally applicable to their special housing needs. For example, the element could utilize a recent study conducted by University California at Merced that is available at https://clc.ucmerced.edu/sites/clc.ucmerced.edu/files/page/documents/fwhs_report_2.2. 2383.pdf. Based on the outcomes of the analysis, the element should add or modify programs to address this special housing need in the region.

3. An inventory of land suitable and available for residential development, including vacant sites and sites having realistic and demonstrated potential for redevelopment during the planning period to meet the locality’s housing need for a designated income level, and an analysis of the relationship of zoning and public facilities and services to these sites. (Gov. Code, § 65583, subd. (a)(3).)
Progress toward the RHNA: While the element may utilize pending, approved, or built (pipeline) units toward the RHNA since June 30, 2023, it must also demonstrate their affordability and availability in the planning period. Regarding affordability, the element

City of Escalon’s 6th Cycle (2023-2031) Draft Housing Element Page 4 March 28, 2024
must describe the methodology for the planned 18 units affordable to lower-income households based on actual or anticipated sales price, rent or other mechanisms that ensure affordability (e.g., deed-restrictions). Regarding availability, the element indicates the status of pipeline projects as planned along with anticipated occupancy but should also discuss remaining steps to building permit issuance, any known barriers and likelihood the units will be built in the planning period.

Realistic Capacity: The element utilizes minimum densities to determine the realistic capacity of the sites then accounts for the likelihood of 100 percent nonresidential development by multiplying a factor, based on trends, by the minimum density for sites with nonresidential zones. This is an acceptable methodology. However, the element appears to calculate the residential capacity for Sites 11, 12 and 13 utilizing the total acreage even though the total acreage is not anticipated to develop. Instead, for these sites, the element should apply the methodology to the developable acreage.

Availability of Infrastructure: Though the element states that Escalon has adequate infrastructure to accommodate the development of its RHNA (p. 3-65), it should clarify whether there is sufficient total water capacity (existing and planned) to accommodate the RHNA. In addition, the element should also describe the existing or planned accessibility of infrastructure to identified sites and, if necessary, add or modify programs to address identified constraints.

The element (Program 3-1 (B)) – Neighborhood Improvements) indicates that the City will continue to prioritize water and sewer service for developments with units affordable to lower-income households. However, the element should clarify whether a written procedure is available to grant priority service and if not, modify Program 3-1 to establish a procedure by a specified date early in the planning period.

Zoning for Lower-Income Households: Pursuant to Section 65583.2 (c)(3)(A) and (B), the element must identify densities appropriate to encourage and facilitate the development of housing for lower-income households. The element may utilize a statutorily prescribed density (default density) where no analysis is required or provide analysis based on factors such as market demand, financial feasibility, and development experience within zones. While the element utilizes a default density for most sites, it does not appear to utilize default densities for Site 12 (APN 225-020-18).

As a result, the element should either provide rezone the site to meet statutory requirements, utilize the site for the moderate or above moderate-income RHNA or provide analysis to demonstrate the appropriateness of the zoning. Based on HCD experience, while the element may provide analysis, densities of 15 units per acre have not been considered appropriate for developments of housing for lower-income households.

Environmental Constraints: While the element generally describes existing environmental hazards that may constrain housing development within the City (pp. 3- 66-67), it must describe how these constraints relate to identified sites, including whether the constraints preclude development in the planning period. In addition, the element should examine any other known constraints or condition that preclude development in the planning period. Example of other known constraints or conditions

City of Escalon’s 6th Cycle (2023-2031) Draft Housing Element Page 5 March 28, 2024
include shape, access, easements, property conditions, environmental overlays, Williamson Act contracts, contamination and airport and other compatibility issues.

Electronic Sites Inventory: Pursuant to Government Code section 65583.3, subdivision (b), upon adoption of the housing element, the City must submit an electronic version of the sites inventory with its adopted housing element to [email protected].

Please note, the City must utilize standards, forms, and definitions adopted by HCD when preparing the sites inventory. Please see HCD’s housing element webpage at https://www.hcd.ca.gov/community-development/housing-element/index.shtml#element for a copy of the form and instructions. The City can reach out to HCD at [email protected] for technical assistance.

Zoning for a Variety of Housing Types:
• Employee Housing: The element must demonstrate zoning is consistent with the Employee Housing Act (Health and Safety Code, § 17000 et seq.), specifically, sections 17021.5, 17021.6 and 17021.8. While the element describes consistency with section 17021.5, it should also discuss consistency with section 17021.8. Specifically, section 17021.8 requires that a development is subject to a streamlined, ministerial approval process and is not subject to a conditional use permit (CUP) if the development is an eligible agricultural employee housing development. Based on a complete analysis, the element should add or modify programs.
• Emergency Shelters: The element states that the City will amend its zoning code to permit emergency shelters without discretionary action in a zone that allows residential uses. However, the element should describe capacity in the proposed zone(s) and demonstrate sufficient capacity to accommodate the need for emergency shelters including capacity for at least one emergency shelter. The analysis of capacity should describe acreage, parcel sizes, uses, potential for redevelopment, if applicable, and proximity to transportation and services then utilize the statutory methodology to demonstrate sufficient capacity. Based on the outcomes of this analysis, the element should amend Program 2-1 (Zoning for a Variety of Housing Types), including revising the definition of emergency shelters, amending a zone that allows residential uses and establishing appropriate development standards.
• Single Room Occupancy (SRO) Units: The element must identify a zone(s) that allow SROs and demonstrate zoning, development standards and permit procedures encourage the use or add or modify programs as appropriate.

4. An analysis of potential and actual governmental constraints upon the maintenance, improvement, or development of housing for all income levels, including the types of housing identified in paragraph (1) of subdivision (c), and for persons with disabilities as identified in the analysis pursuant to paragraph (7), including land use controls, building codes and their enforcement, site improvements, fees and other exactions required of developers, and local processing and permit procedures... (Gov. Code, § 65583, subd. (a)(5).)

City of Escalon’s 6th Cycle (2023-2031) Draft Housing Element Page 6 March 28, 2024
Land Use Controls: The element must identify and analyze all relevant land use controls, and potential constraints on a variety of housing types (e.g., multifamily rental housing, mobilehomes, transitional housing). In particular, the analysis should address multifamily heights and parking requirements, including guest parking and impacts on studios. The analysis should address impacts on housing cost and supply and ability to achieve maximum densities.

In addition, the element should demonstrate compliance with State Density Bonus Law (SDBL), including eligibility requirements, density bonuses, concessions, parking reductions and waiver or modification processes and add or modify programs to ensure compliance.

Codes and Enforcement: The element briefly mentions the City enforces compliance with the 2022 building code but should also list and analyze any local amendments for impacts on housing costs and supply and evaluate enforcement type (e.g., proactive, complaint-based) for impacts on lower-income and special needs households.

On/Off-Site Improvements: The element describes on- and off-site improvements but should also analyze impacts on housing costs and supply and add or modify programs, as appropriate.

Fees and Exaction: While the element cumulatively displays impact fees on a per unit basis, it should also include planning and processing fees and analyze impacts on development costs individually and cumulatively. For example, the analysis should address the water connection fee which nearly represents half of total fees. Based on the outcomes of this analysis, the element should add or modify programs, as appropriate.

Local Processing and Permit Procedures: The element must describe and analyze the City’s permit processing and approval procedures for a typical development that is consistent with the general plan and zoning. The analysis should address the type of permit, approval body, number of hearings, design guidelines (including the newly adopted guidelines) and approval findings and evaluate impacts on housing cost and supply and approval certainty.

In addition, the element should address public comments on this revised draft submittal and discuss compliance with the Permit Streamlining Act and intersections with California Environment Quality Act (CEQA) and timing requirements, including timely exemption, and streamlining determinations and add or modify programs as appropriate.

Housing for Persons with Disabilities (Reasonable Accommodation): The element briefly references procedures to request reasonable accommodation (p. 5-32). However, the element should also describe the policies and decision-making criteria such application procedures, fees, and approval findings, and analyze any potential constraints on housing for persons with disabilities.

City of Escalon’s 6th Cycle (2023-2031) Draft Housing Element Page 7 March 28, 2024
Inclusionary Housing: The element must describe and analyze the City’s Affordable Housing Ordinance requirements and their impacts as potential constraints on the development of housing for all income levels, specifically on housing supply and cost.

The analysis must evaluate the inclusionary policy’s implementation framework, including availability of incentives, relationship with SDBL and alternative means of compliance that may include, but are not limited to, in-lieu fees, land dedication, off-site construction, or acquisition and rehabilitation of existing units. The City could also engage the development community to facilitate this analysis.

Growth Management Ordinance (GMO): The element mentions the GMO but should fully describe the ordinance including limits or caps on permits, eligibility or scoring criteria, approval body, approval procedures, carryover, allocation expirations, limits on allocations, carryover of allocations, exemptions, and any other relevant requirements.

Then, the element should evaluate the impacts of the GMO on housing costs and supply, timing, and the ability to achieve the RHNA. Based on the outcomes of this analysis, the element should add or modify programs to address identified constraints.

5. An analysis of potential and actual nongovernmental constraints upon the maintenance, improvement, or development of housing for all income levels, including… …the cost of construction, the requests to develop housing at densities below those anticipated in the analysis required by subdivision (c) of Government Code section 65583.2, and the length of time between receiving approval for a housing development and submittal of an application for building permits for that housing development that hinder the construction of a locality’s share of the regional housing need in accordance with Government Code section 65584... (Gov. Code, § 65583, subd. (a)(6).) Construction Costs: The element includes some general discussion pertaining to land costs and availability of financing (p. 4-30) but should also discuss construction costs, including impacts on housing costs and supply.

Approval Time and Requests Lesser Densities: The element must include analysis of requests to develop housing at densities below those identified, the length of time between receiving approval for a housing development and submittal of an application for building permits that potentially. The element must address any hinderance on the development of housing and include programs as appropriate.

C. Housing Programs

1. Identify actions that will be taken to make sites available during the planning period with appropriate zoning and development standards and with services and facilities to accommodate that portion of the city’s or county’s share of the regional housing need for each income level that could not be accommodated on sites identified in the inventory... …Sites shall be identified as needed to facilitate and encourage the development of a variety of types of housing for all income levels, including multifamily rental housing, factory-built housing, mobilehomes, housing for agricultural employees, supportive housing, single-room occupancy units, emergency shelters, and transitional housing. (Gov. Code, § 65583, subd. (c)(1).)

City of Escalon’s 6th Cycle (2023-2031) Draft Housing Element Page 8 March 28, 2024
As noted in Finding B3, the element does not include a complete site analysis; therefore, the adequacy of sites and zoning were not established. Based on the results of a complete sites inventory and analysis, the City may need to add or revise programs to address a shortfall of sites or zoning available to encourage a variety of housing types. In addition, programs should be added or modified, as follows:
• Program 1-2(C) (Maintain Viable Sites): The Program should clarify that permitting multifamily developments with 20 percent affordability will also include sites identified in prior planning period, as noted in the element (p. 3-61). • Program 1-2(F) (Maintain Viable Sites): Given the reliance on religious institutional sites, the Program should specifically monitor the effectiveness of Programs in encouraging development and pursue alternative measures within a specified time.
• Program 2-1(D) (Zoning for a Variety of Housing Types): The Program should clarify that the City’s accessory dwelling unit ordinance (ADU) will be revised to ensure compliance with State ADU law, if necessary, upon review by HCD within a timely manner (e.g., within six months).

2. The Housing Element shall contain programs which assist in the development of adequate housing to meet the needs of extremely low-, very low-, low- and moderateincome households. (Gov. Code, § 65583, subd. (c)(2).) The element should add or modify programs to assist in the development of housing for lower-income and special needs households, as follows:
• Program 2-5 (Affordable Housing Funding and Incentives): The Program should specifically commit to identify development opportunities at least every other year.
• Program 2-6 (Farmworker Housing): The Program should be expanded based on the outcomes of a complete analysis such as identifying opportunities to integrate farmworkers into developments, offer incentives for housing for farmworkers, subsequent actions toward outcomes from meeting with surrounding jurisdiction, proactive marketing of existing programs, establishing partnerships with nonprofit and affordable developers to identify housing opportunities and addressing housing and neighborhood conditions for existing farmworkers. • Program 4-2(C) (Housing Outreach and Stakeholder Engagement): The Program should be revised with discrete timing (e.g., at least every other year). • Program 4-2(E) (Housing Outreach and Stakeholder Engagement): The Program should go beyond outreach with stakeholders and provide education, facilitating partnerships and assisting with entitlement processes.

3. Address and, where appropriate and legally possible, remove governmental and nongovernmental constraints to the maintenance, improvement, and development of housing, including housing for all income levels and housing for persons with disabilities. The program shall remove constraints to, and provide reasonable accommodations for housing designed for, intended for occupancy by, or with supportive services for, persons with disabilities. (Gov. Code, § 65583, subd. (c)(3).)

City of Escalon’s 6th Cycle (2023-2031) Draft Housing Element Page 9 March 28, 2024
As noted in Findings B4 and B5, the element requires a complete analysis of potential governmental and nongovernmental constraints. Depending upon the results of that analysis, the City may need to revise or add programs and address and remove or mitigate any identified constraints.

In addition, Program 2-1(E)(Zoning for a Variety of Housing Types) should specifically commit to permit group homes for seven or more persons, regardless of licensing, in all zones allowing residential uses and address the CUP as a constraint by replacing or modifying procedures or zoning to permit group homes for seven or more persons similar to other residential uses of the same type in the same zone.

4. Promote and affirmatively further fair housing opportunities and promote housing throughout the community or communities for all persons regardless of race, religion, sex, marital status, ancestry, national origin, color, familial status, or disability, and other characteristics... (Gov. Code, § 65583, subd. (c)(5).)
As noted in Finding B1, the element requires a complete AFFH analysis. Depending upon the results of that analysis, the City may need to revise or add programs. Goals and actions must specifically respond to the analysis and to the identified and prioritized contributing factors to fair housing issues and must be significant and meaningful enough to overcome identified patterns and trends. Actions must have specific commitment, milestones, geographic targeting and metrics or numerical targets and, as appropriate, address housing mobility enhancement (housing choices and affordability across geographies), new housing choices and affordability in relatively higher opportunity or income areas (throughout the City), place-based strategies for community preservation and revitalization, and displacement protection.

D. Quantified Objectives
Establish the number of housing units, by income level, that can be constructed, rehabilitated, and conserved over a five-year time frame. (Gov. Code, § 65583, subd. (b)(1 & 2).)
The element includes quantified objectives by income category that can be constructed, rehabilitated. However, rehabilitation objectives should be increased to better reflect the housing needs of the community and conservation objectives should be added.

Conservation objectives can be a wide array of activities that are intended to conserve housing or promote tenant stability. Examples include Programs 3-3 (Conservation of Affordable Units and Mobile Homes), 3-4 (Energy Conservation), 5-3 (Anti-Displacement Actions), 5-4 (Housing Choice Vouchers) and 5-6 (Code Enforcement).

City of Escalon’s 6th Cycle (2023-2031) Draft Housing Element Page 10 March 28, 2024
E. Public Participation
Local governments shall make a diligent effort to achieve public participation of all economic segments of the community in the development of the Housing Element, and the element shall describe this effort. (Gov. Code, § 65583, subd.(c)(9).) While the element includes a general summary of the public participation process (Appendix C), it must also summarize the input and describe how the input was considered and incorporated into the element.

Rural Roots, Justice for All
[Office Address] • [Office City], CA [Office ZIP] • Tel: [Office Phone] • Fax: [Office Fax] • TTY: 1-800-735-2929 • crla.org
June 19, 2026
City of Escalon
Community Development Department
2060 McHenry Ave
Escalon, CA 95320
Submitted electronically to [email protected] RE: City of Escalon’s Draft 6th Cycle Housing Element
Dear Escalon Housing Element Staff:

California Rural Legal Assistance, Inc. (CRLA) writes to submit these comments on the City of Escalon’s Draft 6th Cycle Housing Element (Draft Housing Element) published June 12, 2026. CRLA is a nonprofit organization that provides legal assistance for low income and disadvantaged residents. We represent residents from the Almond Grove Mobile Home Park (Almond Grove MHP) who would like to ensure affordable and safe housing for all mobile home park owners and residents, including low-income people and seniors.

California Housing Element Law was created in recognition of the duty of local and state governments to provide for the housing needs of “all economic segments of the community.”1 This mandate requires the City of Escalon (City) to account not only for the needs of low-income households, but also to account for the special housing needs of populations such as seniors that experience particular housing needs and vulnerabilities.2 In 2019, California passed SB 686, which builds upon and clarified the extent of this mandate by establishing the duty of every jurisdiction to Affirmatively Further Fair Housing (AFFH) through its Housing Element. The duty to AFFH requires jurisdictions to take active steps to combat segregation and advance fair housing needs.3 Integral to this duty is the requirement for jurisdictions to develop place-based strategies to encourage community revitalization, preserve existing affordable housing, and protect existing residents from displacement.4
We recognize and appreciate the commitments the City has included in its Draft Housing Element to address the needs of the senior, mobile home owner population of Almond Grove MHP. The City rightly acknowledges that Almond Grove is one of Escalon’s primary affordable 1 Cal. Gov. Code section 65580
2 Cal Gov. Code section
3 Cal. Gov. Code section 8899.50
4 Cal. Gov. Code section 65583(c)(10)(A)(v)
Attachment 10

[Addressee Name]
RE:

June 19, 2026

housing options available to seniors.5 We are pleased to see the inclusion of Program 3-3 and the actions the City has committed to taking in order to support seniors and mobile home residents in the area.

While we support these policies, the actions and timelines currently included in the Draft Housing Element are not sufficient to address the urgent risk of displacement facing the seniors of Almond Grove. As the Housing Element notes, Almond Grove is a senior park6 where many residents are on fixed incomes. Yet, Iin the past 5 years, Almond Grove residents have experienced yearly and escalating rent increases, including increases in the past year of over 30% for some residents. Compounding this financial pressure, a significant number of the mobile homes in Almond Grove were built prior to 1976 and fail to conform the current HUD construction standards, rendering them impossible or extremely difficult to move. These mounting financial concerns loom over the health and well-being of Almond Grove’s seniors, and they are faced with increasingly difficult questions about whether they will be able to continue to afford to stay in homes they already own.

There are several viable policy options to which the City of Escalon should include in its Housing Element that would reduce the fear, financial pressure, and high risk of displacement Almond Grove residents are facing, and to ensure that it complies with Housing Element and fair housing laws. In particular,
I. The City Must Develop and Implement a Mobile Home Park Zoning Designation to Preserve the City’s Existing Affordable Housing Stock.

II. The City Must Create a Senior Overlay Zone to Apply to Escalon’s Senior Mobile Home Parks in Order to Preserve Existing Affordable Housing Stock and Address the Housing Needs of Seniors within Its Jurisdiction.

III. The City Must Amend the Timeline for Program 3-3, Action (D), to Ensure that Residents will Experience the Intended Benefits of the Program During the Planning Period.

IV. The City Must Commit to Developing a Mobile Home Rent Control Policy to Fulfill its Duty to Affirmatively Further Fair Housing.

We respectfully urge the City to adopt the following policies that are urgently needed to preserve affordable and safe housing for low-income and senior mobile home owners who call Escalon home:
5 Revised FHA with HCD Subsequent Draft (2026-06-11) at 86 (PDF 87). https://cdnsm5- hosted.civiclive.com/UserFiles/Servers/Server_10745808/File/Government/Departments/Development%20Services/ Planning/Housing%20Element/Revised%20FHA%20with%20HCD%20Subsequent%20Draft%20(2026-06-11).pdf 6 Id. at 21, 67 (PDF 21, 68).

[Addressee Name]
RE:

June 19, 2026

I. The City Must Create a Mobile Home Park Zoning Designation to Preserve the City’s Existing Affordable Housing Stock.

One of the fundamental requirements of Housing Element law is that jurisdictions must zone to accommodate a variety of housing types catering to all income levels.7 As stated above, the duty to Affirmatively Further Fair Housing under the Housing Element law also requires jurisdictions to develop place-based strategies to encourage community revitalization, preserve existing affordable housing, and protect existing residents from displacement.8 One of the most straightforward place-based strategies to preserve existing affordable housing options is the establishment of a mobile home park zoning designation. As other jurisdictions have noted,9 having a distinct mobile home park designation requires park owners seeking closure to first justify a General Plan amendment and zone change to the Planning Commission and City Council, as well as complying with state regulations governing mobile home park closures. This procedural safeguard is critical to ensure the longevity of mobile home parks as an affordable senior housing option. Jurisdictions across the state have adopted mobile home park zoning designations as components of their affordable housing preservation strategies.10
While the City of Escalon’s zoning code permits mobile home parks to exist in several of its existing zoning designations, the City lacks a specific mobile home park designation.

Moreover, according to information available on the City of Escalon’s website, the current zoning designation of Almond Grove Mobile Home Park is R-1 (Low-Density Residential).11 The City of Escalon’s zoning code currently does not allow mobile home parks in R-1 zones.12 This poses an urgent risk to residents on top of the already significant risk of displacement from rising rent costs.

In order to preserve affordable housing for Escalon seniors, the City must commit to developing a Mobile Home Park zoning designation to apply to Escalon’s mobile home parks.

To achieve this, we recommend that the City amend Program 2-1 of the Draft Housing Element by adding the following Action:
7 Cal. Gov. Code section 65583
8 Cal. Gov. Code section 65583(c)(10)(A)(v)
9 See, e.g., City of Calabasas 2021-2029 Housing Element at V-29 (PDF 42). https://www.hcd.ca.gov/housingelements/docs/calabasas-6th-adopted102621.pdf 10 See, e.g., id.; see, also, City of Sunnyvale 5th Cycle Housing Element, Goal B(12) at 116 (PDF 122), https://www.hcd.ca.gov/housing-elements/docs/sunnyvale_5th_adopted122214.pdf; Redwood City 6th Cycle Housing Element (2023), Program H2-7 at page H-32 (PDF 37) https://ccag.ca.gov/wp-content/uploads/2023/01/7- A3-RWC_HCD_Submittal_HousingElement-1.pdf
11 City of Escalon Zoning Map, City of Escalon Development Services Department, accessed June 19, 2026 https://cdnsm5-
hosted.civiclive.com/UserFiles/Servers/Server_10745808/File/Government/Departments/Development%20Services/ Planning/11x17-Zoning-6-2-06.pdf
12Escalon Municipal Code section 17.11.040
https://www.codepublishing.com/CA/Escalon/#!/html/Escalon17/Escalon1711.html

[Addressee Name]
RE:

June 19, 2026

 Action (K): Amend the City’s Zoning Code to create a Mobile Home Park zoning designation (MHP) and rezone all existing mobile home parks within the City’s jurisdiction consistent with this designation.
 Timeframe: December 31, 2026.

II. The City Must Create a Senior Overlay Zone to Apply to Escalon’s Senior Mobile Home Parks in Order to Preserve Existing Affordable Housing Stock and Address the Housing Needs of Seniors within the Jurisdiction.

Housing Element law requires jurisdictions to analyze the special housing needs of populations such as seniors and persons with disabilities.13 Jurisdictions are further required to analyze existing assisted housing developments that may change from low-income housing uses during the next 10 years and the impacts of these potential changes on the total number of units available to seniors.14 These requirements are integral parts of the Housing Element’s broader aim of preserving affordable housing options for vulnerable populations with specific housing needs.

The City recognizes Almond Grove as one of its two senior mobile home parks.15 While Almond Grove is not an assisted housing development, it provides similar housing opportunities to seniors, many of whom also have disabilities and suffer from the same suite of housing vulnerabilities stemming from their health concerns and fixed income status. It is impossible to fully analyze the needs of Escalon seniors, or create policies capable of addressing their needs, without accounting for the displacement factors impacting Almond Grove mobile home owners.

Mobile home park owners are incentivized to reduce the percentage of seniors occupying senior parks in order to obtain higher profits possible from tenants who are not on fixed incomes.

Across the state, predatory rent increases at mobile home parks that have traditionally been occupied by seniors are forcing seniors out of their parks, allowing park owners to lease increasing numbers of units in senior parks to non-seniors in order to disrupt the senior designation the park traditionally held. This process has already begun at Almond Grove mobile home park, where some non-seniors have already been allowed to move in. This phenomenon poses a direct risk to the continuing availability and affordability of senior housing in Escalon.

In many places where senior housing has been at risk of being converted, jurisdictions have adopted Senior Overlay Zones to preserve the existing senior use.16 These zones provide protection for existing senior housing uses by limiting residential occupancy in the zone to seniors. Senior Overlay Zones can include out exceptions to allow live-in caretakers such as the 13 Cal. Gov. Code section 65583(a)(7)
14 Cal. Gov. Code section 65583(a)(9)
15 15 Revised FHA with HCD Subsequent Draft (2026-06-11) at 21, 67 (PDF 21, 68). 16 See, e.g., City of Yucaipa Municipal Code section 85.040315 https://codelibrary.amlegal.com/codes/yucaipaca/latest/yucaipadevelopmentcode_ca/0-0-0-4156; City of Huntington Beach Zoning Code Chapter 228 SR Senior Residential Overlay District https://mhphoa.com/ca/huntingtonbeach/docs/chapter-228-sr-senior-residential-overlay-district.pdf; San Mateo Municipal Code 27.61.040 https://law.cityofsanmateo.org/us/ca/cities/san-mateo/code/27.61.030.

[Addressee Name]
RE:

June 19, 2026

children of the senior residents to reside there as well as “qualified permanent residents,”17 ensuring that seniors in the park can still receive any additional care they require. They can also include carve-outs for current occupants who are not seniors to ensure that no residents are displaced by the creation of the zone.18
In order to prevent the park from losing its senior designation and to preserve Almond Grove MHP as a local affordable housing option, the City must commit to creating a Senior Mobile Home Park Overlay. To achieve this, we recommend that the City amend Program 2-2, which addresses Senior Housing, to include the following additional Action:
 Program 2-2, Action (D): Amend the City’s Zoning Code to create a Senior Mobile Home Park Overlay District where at least 80% of the spaces are occupied by, or intended for occupancy by, at least one person who is 55 years of age or older.
 Timeframe: December 31, 2026.

III. The City Must Amend the Timeline for Program 3-3, Action (D), to Ensure that Residents will Experience the Intended Benefits of the Program During the Planning Period.

Under the Housing Element, jurisdictions must create programs and policies with timelines and specific commitments to ensure that they have a “beneficial impact” during the planning period.19 Ensuring that housing programs and policies have a beneficial and meaningful impact is a key facet of demonstrating that a jurisdiction is taking “active steps” to combat segregation and preserve affordable housing within its area.20 As we noted above, we appreciate the inclusion of Program 3-3 in the Housing Element as a means of preserving mobile home owner housing opportunities in Escalon. We acknowledge, in particular, the intention of Action (D) to meaningfully expand and strengthen the City of Escalon’s existing mobile home conversion procedures to better protect mobile home residents. However, in light of the high displacement risk facing Almond Grove residents, the timeframe for completing Action (D) by May 2027 is not short enough to ensure that residents will have the opportunity to benefit from the policy.

In order for Action (D) of program 3-3 to achieve its aim and ensure the mobile home owners and seniors experience the beneficial impacts intended by this program, the timeline for Action (D) must be shortened. To achieve this, we recommend the following amendment to the timeframe for Program 3-3, Action (D):
 Timeframe: Action (D) December 31, 2026.
17 See Cal. Civ. Code section 51.3.
18 City of Yucaipa Municipal Code section 85.040320
https://codelibrary.amlegal.com/codes/yucaipaca/latest/yucaipadevelopmentcode_ca/0-0-0-4156 19 Cal. Gov. Code section 65583(c)
20 See Cal. Gov. Code section 8899.50.

[Addressee Name]
RE:

June 19, 2026

IV. The City Must Commit to Developing A Mobile Home Rent Control Policy to Fulfill its Duty to Affirmatively Further Fair Housing.

The duty to Affirmatively Further Fair Housing is a requirement intended to create more integrated, “inclusive communities, free from barriers that restrict access to opportunity” through meaningful actions that “address significant disparities in housing needs.” To achieve this, the duty to Affirmatively Further Fair Housing requires not only that jurisdictions take active steps to promote fair housing, but that jurisdictions “take no action inconsistent” with this duty.21 In California, there is no statewide rent control to protect mobile homeowners from rent increases. Up to twice a year, the rent for mobile homeowners can increase by an amount without limit. As a result of this absent ceiling, mobile homeowners, despite having made the investment to own and take care of their own homes, can be forced out of their parks and even be forced to sell the homes they purchased by rent hikes. Examples of this phenomenon can be found throughout California.22
Over the past few years, the vacancy rate in Almond Grove has increased as rents have continued to rise and many seniors living there have felt they have no choice but to sell their homes to avoid being displaced against their will by the next rent increase. While the adoption of the policies mentioned in previous sections are critical steps to safeguard against the conversion of the park, the only way to meaningfully insulate Almond Grove residents from the high and escalating displacement risk stemming from these rent increases is the adoption of a Rent Stabilization Ordinance. Many jurisdictions around the state have adopted rent stabilization ordinances specific to mobile home parks, in recognition of mobile homeowners’ unique vulnerability to displacement.23 Mobile home rent stabilization ordinances introduce stability and moderation in rent increase levels that protects residents while also allowing for the needs of park owners to gradually raise rent to cover reasonable costs of operation and maintenance as they rise over time.

The lack of rent stabilization for mobile homeowners is the primary factor contributing to the high risk of displacement for Almond Grove, and one of the most significant factors contributing to the disparity in housing needs between mobile home park residents and other Escalon residents. Without mobile home rent stabilization, this disparity will only persist and continue to grow, alienating and disadvantaging the seniors who live in Almond Grove and increasing the community’s level of segregation. The City’s duty to “take no action inconsistent” with their obligation to affirmatively further fair housing therefore obligates the City to develop and implement a Mobile Home Rent Stabilization Ordinance. To achieve this, 21 Cal. Gov. Code section 8899.50(b)(1)
22 See, e.g., Commission raises rent at Fresno mobile home park, but residents still say it’s a win, Pablo Orihuela, Fresnoland, November 23, 2023, https://www.kvpr.org/local-news/2023-11-23/commission-raises-rent-at-fresnomobile-home-park-but-residents-still-say-its-a-win; Embattled former Trail’s End mobile home park in northeast Fresno is set to close, Dympna Ugu-Oju, The Fresno Bee, April 19, 2023, https://www.fresnobee.com/fresnoland/article274491381.html 23See, e.g., City of Fresno, Ordinance 87-170 (1987)
https://documents.fresno.gov/WebLink/DocView.aspx?id=20919078&dbid=0&repo=LF-Repository&cr=1

[Addressee Name]
RE:

June 19, 2026

we recommend the addition of the following Action to Draft Housing Element Program 5-3, for Anti-Displacement Actions:
 Action (E): Develop and implement a Mobile Home Rent Stabilization Ordinance to protect mobile home park residents from excessive rent increases and preserve mobile home ownership as an affordable housing option in Escalon.
 Timeframe: December 31, 2026.

I. Conclusion
In order to fulfill its obligation to affirmatively further fair housing by preserving existing affordable housing and protecting residents from displacement, the City of Escalon must amend the Draft Housing Element to include the policies described above in order to preserve Almond Grove as affordable housing for Escalon seniors and protect Almond Grove residents.

We appreciate the opportunity to comment on Escalon’s Housing Element, and the time and work the City has put into preparing it. If you have any questions about any of the information presented or the issues faced by Almond Grove residents, we would be happy to discuss this further.

Sincerely,
_____________________________________________
Nick Jensen
Directing Attorney
California Rural Legal Assistance, Inc.
[email protected]

July 18, 2026
Via email: [email protected]
California Department of Housing and Community Development Division of Housing Policy Development
2020 W. El Camino Avenue, Sacramento, CA 95833
Re: City of Escalon Revised 3rd Subsequent Draft Housing Element (June 2026) — Public Comment: Requested Corrections to Sites Inventory and RHNA Credit Tables
Dear Housing Element Review Team:

Bold Communities submits this comment on the City of Escalon's Revised 3rd Subsequent Draft Housing Element, currently under HCD review. We are the sponsor of a pending 80-unit, 100% affordable housing development at 1090 E. California Street (the Draft Housing Element's Section 3.3.1 “Vacant Sites” #2 and #3), and we write to provide three factual updates that would strengthen the accuracy of the sites inventory and the City's RHNA credit analysis. The City's public review window has closed; we understand comments may be directed to HCD during the State's review.

1. Draft Housing Element Table 8 (Planned, Approved, and Pending Projects) omits a pending 80-unit affordable project. City of Escalon Planning Application No. 26-817 proposes an 80-unit, 100% affordable multifamily development at 1090 E. California Street (the “Bold Project”), first submitted to the City in December 2025 and resubmitted June 15, 2026 pursuant to Government Code §65913.4 (SB 423). The application is in completeness review under the Permit Streamlining Act, with a resubmittal responding to the City's July 10, 2026 Notice of Incomplete Application in preparation. The Bold Project comprises 79 units deed-restricted for lower-income households, plus a manager unit, including a farmworker set-aside, with tax-exempt bond financing preserved under CDLAC Application No. 25-855. Draft Housing Element Table 8 (in Section 3.2.2 “Planned, Approved, and Pending Projects”) currently credits projects with "Planned" and "In Hearing" status; this pending application appears eligible for inclusion on the same basis. Its addition would increase the City's lower-income RHNA credits from 24 to approximately 103 units and reduce the lower-income shortfall shown in Table 9 (Section

3.2.3 “Units Credited Toward RHNA”) from 122 to approximately 43 units — correspondingly reducing the rezoning otherwise required prior to certification under Government Code §65583.2 and AB 1398.

2. Draft Housing Element Table 10 (Section 3.3.1 “Vacant Sites”) / Figure 3 (found on page 57) reflect an outdated parcel configuration for Sites #2 and #3. The inventory identifies the East California Street site as APNs 225-100-10, -11, and -12, totaling 1.87 acres with a realistic capacity of 26 units. Former inventory Sites #2 and #3 have since been reconfigured through City of Escalon Lot Merger No. 24-793 (Document No. 2024-080196) and Lot Line Adjustment No. LLA 24-794, recorded December 23, 2024 as Document No. 2024-116407, San Joaquin County Official Records. The Bold Project site now comprises APNs 225-100-10 and 225-100-24, totaling approximately 3.0 acres (see attached map from the County of San Joaquin Assessor's Office). The site is currently under contract to Bold Escalon LP with close of escrow scheduled for no later than July 23, 2026. We recommend the inventory be updated to reflect current Assessor parcel data, acreage, and the 80-unit capacity demonstrated by the pending application.

3. The Draft Housing Element Sites #1–3 “RHNA Level” detail table assigns Sites #2 and #3 inconsistent income categories. The RHNA Level detail table found on page 57 of the Draft Housing Element designates sites #1-3 as "Above Moderate (Market-Rate) & Moderate." The pending Bold Project would develop sites #2 and #3 with 100% affordable and deed-restricted housing for lower-income households, earning between 30% and 80% Area Median Income. We recommend the sites’ RHNA income level reflect Lower Income, consistent with the application on file with the City.

These updates are offered to support an accurate inventory and the City's certification effort. The Bold Project is precisely the type of development the City’s Draft Housing Element contemplates for this site — deed-restricted, deep-affordability housing on land the City has designated High Density Residential — and its inclusion materially improves the City's compliance position. We would be glad to provide application materials, the unit mix, and affordability documentation to assist HCD's or City staff's review.

Sincerely,
Michael Miller
President, Bold Communities
[email protected]
cc: City of Escalon Housing Element Update Team ([email protected]) Dana Sayles / Mandi Ojeda, Three6ixty

THIS MAP IS FOR ASSESSMENT PURPOSES

ONLY AND IS NOT FOR THE INTENT OF

INTERPRETING LEGAL BOUNDARY RIGHTS,

ZONING REGULATIONS AND/OR LEGALITY
OF LAND DIVISION LAWS.

ESCALION MAP 1 225-10
All Rights Reserved
Copyright County of San Joaquin
Assessor Mapping/GIS 2025
County of
San Joaquin, CA
BK. 225 PG. 10
R.M. = Recorded Subdivision
Map
P.M. = Recorded Parcel
Map
R.S. = Recorded Survey
Map
LEGEND
Example of a Standard
Assessors Parcel Number (APN)
Book Page or
Block
Parcel
Number
000-000-000-000
Assessors Book Boundary
Williamson Act Parcel
San Joaquin County
Assessors Parcel
Number Issued Per
Roll Year

MAPPING/GIS

DISCLAIMER
The sole purpose of this document is for the assessment and collection of County property taxes. County makes no representation or warranty, express or implied, about the completeness, accuracy, reliability or authenticity of the information set forth in this document. Therefore, this document should not be relied upon to determine the legal ownership of any specific parcel(s), nor to facilitate any real property transaction(s) between private parties. County is not liable for any loss or damage whatsoever arising from or in connection with the use of or reliance upon this document(s).

S. 1° 26' W.

S. 89° 50' E.

S. 1° 26' E.

N. 0° 10' E.
235.00'

97.50'
100.00'
134.08'
N. 1° 27' W.

N. 89° 50' W.

S. 89° 50' E.

78.14' 87.37'
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67.90'
348.23'
235.09'
117.50'

70.41' 68.42' 117.50'
117.50'
S. 0° 10' W.

S. 0° 25' W. 235.00'
24 25
26 27

61.43'
75(80)

54.62' 64.29' 59.00'
R=733.28'
L=367.94'
L=234.21'
R=691.78'

49.37' N.52°45'W.

76.33' N.49°34'W.
334.66'
S. 46° 25' E.

N. 89° 46' W. 611.94' N. 89° 37' W. 241.22'

28.15' 374.38'
270.54'
N. 1° 21' E.

24.50'

24.64'
111.38'
S. 78° 25' E.
107.23'
139.48'
129.29'
S. 1° 26' E.
(N. 1° 21' E.)
100.00'
100.00'

60.00'

69.57' 60.00' 110.00' 112.95'

47.52' 47.77'
110.80'
S.46°26'E.

47.70'

47.51'

47.12'

46.72'

46.60'

20.06'

48.50'

29.00'
S. 33° 7' E.

S. 38° 34' E.

S.41°40'E.

S.43°57'E.

S. 46° 21' E.

S. 46° 16' E.

S.46°33'E.

N.47°22'W.

7.77'
S.89°50'E.
100'
100'
101.43M
332.79'
N. 46° 5' W.

N. 46° 14' W.
125.08 METERS
(410.39')
103.29'
L=12.45'
R=49.21'

23.60'
147.19'
145.37'
N. 4° 17' E.

L=127.30'
R=1916.33'
N. 89° 26' W.

82.79'
R=5035.42'
L=19.97'
L=38.36'
R=5039.09'
L=57.92'
R=5039.09'
(2.13')
(2.11')
(90.76')
S. 46° 6' E.
(R=32.80')
(L=48.65')
N. 89° 26' E.
(R=171.20')
(L=19.48')
121.10'
S. 1° 4' E.
162.00'
N. 48° 48' W.

92.88'
S. 89° 13' W.

S. 89° 13' W.

L=2.71'

2.00 ACS.
19 9
7 8
10 20
5 17
18 1
23 YOSEMITE AVENUE
(NEGLEY CUT-OFF)

OKLAHOMA AVENUE
PLAZA AVE.

McHENRY AVE.

CITY OF

ESCALON

CITY OF

ESCALON

BURLINGTON NORTHERN
& SANTA FE RAILROAD

COMAPNY
SEC. 32
SEC. 5
A 219-382
PT. BEARS
S.1°14'E., 1025 FT.

FROM CENTER LINE
OF LATERAL "B"

IRRIGATION CANAL
(HWY. 120)

JAMES STREET

ROSINA STREET

CALIFORNIA STREET

ESCALON AVENUE
JAMES
STREET

PIONEER
STREET
JOHN
STREET

DANIELS
STREET

HIGHWAY
ROUTE
NO. 120
UNION

PACIFIC

RAILROAD
CO.

A A
A
A
A
A
A
A
843-39-27
PAR. 5
SBE# 804-39-11G
PRA. 21
22512504 22512703
22512104 22512308 22512303 22512102
22506036
22511005
22512702
22511018
22511004
22511001
22512701
22506035
22512505
22512103 22512301 22512302 22512101
22509025 22509024 22509023 22509022
22509018 22509017
22509026 22509021
22507023
22509016
22516026
22509028 22509027 22509020 22509019
22509015
22516004 22509014
22509004 22509005 22509006 22509007
22509013
22516003
22509003 22509008
22516002
22509002
22509012
22509011
22509010
22509009
22516001 22509001
22507033
22508011
22508020
22530078 22530083
22530077
22530084
22508013
22508015
22502020
0 20 40 60 80 100
1"=100'
REF_NAME
A-R.S. BK. 28 PG. 050
Internal
Use
ROLL PAR # PAR #
10-11 22
17-18 23
26-27 27

ITEM NO. 6

COUNCIL AGENDA ITEM
FOR AUGUST 10, 2026
Prepared By: Trevin W. Barber, Development & Community Services Manager Date: August 10, 2026
Subject: Conduct a Public Hearing to Introduce and Waive First Reading of Ordinance No. 2026-xxx Amending Title 17 of the Escalon Municipal Code to Comply with State Law and Implement the 2023-2031 Housing Element Update Recommendation:

Conduct a public hearing to consider adoption of Ordinance 2026-03 amending Title 17 of the Escalon Municipal Code to comply with State Law and implement the 2023-2031 Housing Element Update.

Background:

The Housing Element is one of the seven mandated elements of the General Plan, and the only element that must be updated on a set schedule, consistent with the establishment of Regional Housing Needs Allocations (RHNA), which are published at eight-year intervals. The City of Escalon Planning Commission unanimously recommended adoption of the 2023-2031 Housing Element Update and Zoning Code Amendments at successive hearings on July 14, 2026. The City Council considered adoption of the Housing Element at a prior hearing held on August 10, 2026.

HCD’s review letter, received on June 26, 2026, found the City’s Housing Element document substantially complies with the requirements of Housing Element law, and indicated that full compliance with Housing Element law would require zoning code amendments to implement the Housing Element.

In the last few years, the Legislature has passed multiple housing bills that prescribe new requirements for Housing Elements and new “by-right” requirements for housing projects. By-right requirements primarily require cities to approve certain housing development projects compatible with local zoning rules. Some provisions of these laws reduce land use control for cities without a certified Housing Element. Staff’s goal for this Housing Element update is to meet the requirements established by the California Department of Housing and Community Development (HCD), preserve the City’s discretionary land use control to the maximum extent possible and bring forward meaningful local goals, policies and programs that support housing at all levels in Escalon.

The Zoning Code is the primary tool used to implement the City’s General Plan. The Housing Element of the General Plan is planned for adoption in July 2026, and it includes 22 programs to be implemented, including both existing or ongoing programs and new programs. The Housing Element sets forth a schedule of implementation for these Programs, with due dates ranging from 2026 through 2031.

Housing Element Programs 1-2, 2-1 and 4-3 list specific code changes, some of which are required to be completed immediately to achieve Housing Element compliance and some to be completed by

December 2026.

Typically, a jurisdiction would have one to three years to complete initial implementation programs, including required code changes, but due to the City’s statutory due date the City is required to complete all initial code amendments alongside adoption of the Housing Element for HCD to certify the City’s Housing Element after adoption. The City’s statutory deadline to adopt its 2023-2031 Housing Element was December 31, 2023. If the City had adopted the Housing Element Update within 120 days of the statutory deadline, the City would have had a deadline of December 31, 2024, to implement the required code changes included in the attached Resolution (Exhibit 1). As both deadlines have passed, the City is required to bring both the Housing Element Update and Zoning Code Changes concurrently, for HCD to certify the City’s Housing Element and achieve compliance with Housing Element law. Achievement of compliance with Housing Element programs and timelines is in the City’s interest to retain funding and local land use control.

Discussion:

Proposed Code Amendments
This set of proposed code amendments will address a variety of the City’s housing objectives and provide legal consistency between the General Plan and Zoning. The amendments will update the Zoning Code to comply with changes in state laws and the Housing Element; encourage higher density development near jobs and transit by enacting an overlay zone for housing on religious institution sites; and clarify development standards for higher-density housing and for accessory dwelling units (ADUs). The Sections of the Code to be changed and the basis for each change are further outlined in Table 1, below:

Table 1: Summary of Zoning Code Amendments to Implement Housing Element Description of Change Basis for Change Zoning Code Sections to be Changed
Changes to List of Permitted
Uses Table to add
“Supportive Housing” as a
permitted use by right in byright use in R-3, C-2, and CM Zones and amend its definition in the “Definitions”
section.

Required by State Laws
and listed as Programs
in the City’s Housing
Element.

Section 17.11.040 (List of Permitted
Uses Table); Section

17.81 (Definitions)
(Ordinance Exhibits A and B)
Changes to List of Permitted
Uses Table to add "Low
Barrier Navigation Centers"
as a permitted use by-right in
R-3, C-2, and C-M and add
its definition to the
“Definitions” section.

Required by State Laws
and listed as Programs
in the City’s Housing
Element.

Section 17.11.040 (List of Permitted
Uses Table); Section

17.81 (Definitions)
(Ordinance Exhibits A and B)
Changes to List of Permitted
Uses Table to amend
"Employee Housing” and
amend its definition to the
Required by State Laws
and listed as Programs
in the City’s Housing
Element.

Section 17.11.040 (List of Permitted
Uses Table); Section

17.81 (Definitions)
(Ordinance Exhibits A and B)

“Definitions” section.

Changes to Section 17.41.140
(Accessory Dwelling Units)
Required by State Laws
and listed as Programs
in the City’s Housing
Element.

Section 17.41.140 (Accessory
Dwelling Units) (Ordinance Exhibit
C)
Changes to List of Permitted
Uses Table to amend
“Residential Care Facilities"
to apply objective design
standards to facilities serving
seven or more clients.

Required by State Laws
and listed as Programs
in the City’s Housing
Element.

Section 17.11.040 (List of Permitted
Uses Table) (Ordinance Exhibit A)
Changes to List of Permitted
Uses Table to amend
“Manufactured Homes" to
ensure they are subject to
same standards as other
single-family residential uses.

Required by State Laws
and listed as Programs
in the City’s Housing
Element.

Section 17.11.040 (List of Permitted
Uses Table) (Ordinance Exhibit A)
Changes to Section 17.81.070
(Definitions) to amend
definition of “Family” and
ensure occupancy standards
comply with fair housing law.

Required by State Laws
and listed as Programs
in the City’s Housing
Element.

Section 17.81 (Definitions)
(Ordinance Exhibit B)
Adopt a (Religious Institution
Overlay) District.

Housing Element
Program required by
HCD.

Section 17.33 (Religious Institution
Overlay District) (Ordinance Exhibit
G)
Changes to Section 17.43.020
(Number of off-street spaces
required) to create a
minimum parking
requirements table and update
residential parking minimums
to comply with State law.

Required by State Laws
and listed as Programs
in the City’s Housing
Element.

Section 17.43.020 (Number of offstreet spaces required) and Section

17.81 (Definitions)
(Ordinance Exhibits E and B)
Changes to Section 17.48
(Density Bonus) to reflect
updates to State law.

Required by State Laws
and listed as Programs
in the City’s Housing
Element.

Section 17.48 (Density Bonus)
(Ordinance Exhibit D)
Changes to Section 17.16 to
allow Housing Element reuse
sites by-right per Government
Code Section 65583.2.

Required by State Laws
and listed as Programs
in the City’s Housing
Element.

Section 17.16 (R-3 or Multiple-Family
Residential District)
(Ordinance Exhibit F)
As shown in Table 1 above, each of the Zoning Code changes in this package of Code Amendments are required and prescribed by State laws and to accommodate the Housing Element Sites Inventory.

The analysis below describes each of the Zoning Code Amendments by topic.

Residential Land Uses and Related Definitions

State law requires certain residential uses that accommodate special needs populations to be allowed by-right in residential zones. Specifically, Supportive Housing (also known as Permanent Supportive Housing) and Residential Care Facilities must be allowed by right in all zones where residential uses are permitted. Related definitions have been added/modified, as shown on Ordinance Exhibit A, to differentiate between Large Residential Community Care Facilities (commercial memory care facilities, for example), which still require a Use Permit, and Residential Community Care Homes, which take the form of a residential unit and must be allowed by-right.

Low-Barrier Navigation Centers are defined in Government Code Section 65660 as “a Housing First, low barrier, temporary, service-enriched shelter focused on helping homeless individuals and families to quickly obtain permanent housing.” State law requires that Low Barrier Navigation Centers be allowed in commercial zones that allow residential uses and areas zoned for mixed use; this change has also been added to the List of Permitted Use Table (Ordinance Exhibit A), and the State definition of Low Barrier Navigation Center has been added to the Definitions section (Ordinance Exhibit B).

State law requires employee housing of no more than 36 beds in group quarters or 12 units or less designed for use by a single family or household to be considered an agriculture use and permitted in accordance with Health and Safety Code Sections 17021.5 and 17021.6, and the proposed amendments describe this in the List of Permitted Use Table (Ordinance Exhibit A). The definition of “employee housing” has been modified, as shown on Ordinance Exhibit B.

State law requires residential care facilities that serve seven or more clients be permitted in all residential zones and only be subject to objective development standards consistent with State law, and this has been reflected in the List of Permitted Uses Table (Ordinance Exhibit A).

State law requires manufactured homes to be permitted in the same zones and subject to the same development standards as other single-family residential uses, pursuant to Government Code Section 65852.3. A footnote was added to the List of Permitted Uses Table to clarify this change (Ordinance Exhibit A).

Fair housing laws require the definition of “family,” for the purposes of occupancy standards, to include on or more persons that are not necessarily related by blood, marriage, or adoption, in a household arrangement that complies with fair housing laws, and these changes are reflected in the Definitions Section (Ordinance Exhibit B).

Accessory Dwelling Units
Several recent State laws require jurisdictions to allow junior accessory dwelling units (JADUs) within all single-family dwellings, remove the owner-occupancy requirement for JADUs with their own sanitation facilities, and charge any impact fees proportionately to the livable square footage of the ADU. These changes are reflected in the Accessory Dwelling Units Section (Ordinance Exhibit C).

Religious Institution Overlay (RIO) District
An Overlay District is a special type of zoning tool that places an additional layer of incentives or regulations over the base zoning district. Escalon utilizes several Overlay District, including the

Historic and the Floodplain Management Overlay Districts. Upon adoption, the Religious Institution Overlay (RIO) District could be applied over the applicable parcels owned by religious institutions as defined in the ordinance and would allow certain residential uses in addition to the uses allowed by the base district. In the instance of the Religious Institution Overlay District, specified residential uses would be allowed instead of, or in addition to, uses allowed in the base zone. For example, if a commercial business is allowed by the base district subject to the granting of a use permit, that commercial business would continue to be allowed with a use permit under the RIO District. The RIO District is additive and does not reduce the allowable uses on a site to which it is applied. The RIO Overlay is proposed to be applied to the parcels indicated in Section 3 of the Housing Element.

The proposed changes are included in Chapter 17.33 (Ordinance Exhibit G).

The proposed Religious Institution Overlay (RIO) implements the requirements of Senate Bill 4 (Wiener, 2023), which authorizes qualifying affordable housing developments on property owned by independent institutions of higher education and religious institutions, subject to specified affordability and development standards. The overlay establishes local procedures and development standards to facilitate implementation of State law while ensuring consistency with the City's Zoning Ordinance. Full analysis of religious institution sites included in the City’s Sites Inventory are detailed in Section 3.3.3 of the Adopted Housing Element, and the RIO implements Housing Element Program 1-2(D).

Staff recommend that the Religious Institution Overlay (RIO) District be adopted into the Zoning Code with this package of Code Amendments. Consistent with the Planning Commission resolution recommending adoption of the Zoning Code Amendments to the City Council, input from HCD informed revisions made to the RIO for consistency with State law.

Parking
State law regulates the amount of parking a City can require for several residential uses. The proposed amendments to Chapter 17.43 (Parking) include utilizing the maximum parking requirements established in Government Code Section 65915 for all multifamily projects and create a parking requirements table; establish parking requirements for emergency shelters in compliance with Government Code Section 65583; and allow separate rental or sale of parking spaces and residential units (unbundled parking); and establish parking standards for residential developments subject to the provisions of the Religious Institution Overlay District, as provided in the attached Exhibit E.

Environmental Review
Staff Recommends the Escalon City Council adopt an ordinance exempting the project from CEQA and amending Title 17 of the Escalon Municipal Code to implement State laws and the Housing Element Update.

Public Outreach
The City provided a notice of public hearing, published in the Escalon Times on July 22, 2026, provided email notification of the hearing to interested parties, and mailed the notice to parcels withing 300 feet of parcels subject to proposed zoning code amendments.

Next Steps
If the City Council approves the ordinance, the code amendments will be submitted to HCD concurrent to their 60-day review of the Adopted Housing Element. Based on HCD’s findings, nonsubstantive revisions may be necessary to respond to HCD comments.

Conclusion
City staff have reviewed the Housing Element Update and find that it is internally consistent with the City Escalon General Plan and substantially complies with State Housing Element Law. City staff have reviewed the proposed code amendments and find that the proposed changes implement both the Housing Element and State law.

The City Council is being asked to review and adopt the attached Zoning Code Amendments.

Fiscal Impact:

No fiscal impact. Consultant staff time for preparation of the Zoning Code changes to implement the Housing Element was included in the Housing Element Update budget.

Attachments:

Ordinance Introduced and First Reading Waived (Action at Second Hearing) 1) Ordinance 2026-03: Zoning Code Text Amendments to Implement the City’s Housing Element Update
2) Ordinance Exhibits

CITY OF ESCALON

CITY COUNCIL
ORDINANCE NO. XXX

AN ORDINANCE OF THE CITY COUNCIL OF THE CITY OF ESCALON AMENDING TITLE 17 OF THE CITY OF ESCALON MUNICIPAL CODE TO IMPLEMENT THE

ESCALON HOUSING ELEMENT INCLUDING ADOPTION OF AN OVERLAY ZONE

TO ALLOW HOUSING ON RELIGIOUS INSTITUTION SITES, AND TO MAKE

CHANGES TO THE ACCESSORY DWELLING UNIT SECTION, THE DENSITY

BONUS SECTION, THE LIST OF PERMITTED USES, THE DEFINITIONS, AND THE

PARKING SECTION TO IMPLEMENT STATE LAWS
WHEREAS, the City of Escalon, California (“City”) is a municipal corporation, duly organized under the constitution and laws of the State of California; and WHEREAS, State Housing Element Law (Government Code Sections 65580 et seq.) requires that the City Council adopt a Housing Element for the eight-year period 2023-2031 to accommodate the City’s regional housing need allocation (“RHNA”); and WHEREAS, to comply with State Housing Element Law, the City of Escalon is pursuing adoption of its 2023-2031 Housing Element Update; and
WHEREAS, the Housing Element includes a schedule of actions to implement adopted policies and programs to address the City’s housing needs; and WHEREAS, the proposed amendments would implement the schedule of actions included in the Housing Element and amend the municipal code to comply with State Housing Law, including compliance with Accessory Dwelling Unit (ADU) law, State Density Bonus Law (SDBL), and allowing by-right development on certain identified Housing Element sites; and WHEREAS, the statutory deadline for the City to adopt its 2023-2031 Housing Element Update was December 31, 2023; and
WHEREAS, the City did not adopt a compliant Housing Element within 120 days of the statutory deadline, therefore, pursuant to Assembly Bill 1398, the deadline for the City to complete any rezoning to accommodate the regional housing needs allocation (RHNA) was one year after the statutory deadline to adopt a compliant Housing Element; and WHEREAS, pursuant to State Housing Element Law (Government Code Sections 65580 et seq.) the City’s Housing Element will remain out of compliance until all necessary rezoning has been completed; and
WHEREAS, facilitating housing development and supporting affordable and accessible housing are identified as goals of the City of Escalon in the 2023-2031 Housing Element; and Attachment 1

WHEREAS, Programs 2-1 and 4-3 of the 2023-2031 Housing Element identify code amendments intended to support the aforementioned goals; and WHEREAS, on July 14, 2026, the Planning Commission held a duly-noticed public hearing and considered the staff report, recommendations by staff, and public testimony concerning this proposed Ordinance. Following the public hearing, the Planning Commission voted to forward the Ordinance to the City Council with a recommendation in favor of its adoption; and
WHEREAS, on August 10, 2026, the City Council held a duly-noticed public hearing to consider the Ordinance, including: (1) the public testimony and agenda reports prepared in connection with the Ordinance, (2) the policy considerations discussed therein, and (3) the consideration and recommendation by the City’s Planning Commission; and WHEREAS, all legal prerequisites to the adoption of the Ordinance have occurred.

NOW, THEREFORE, the City Council of the City of Escalon does ordain as follows:

SECTION 1. Incorporation. The recitals above are each incorporated by reference and adopted as findings by the City Council.

SECTION 2. CEQA. Under the California Environmental Quality Act (“CEQA”), further review is not required for adoption of an ordinance by a city implementing a schedule of actions contained within a certified housing element. Therefore, adoption of the Ordinance is statutorily exempt from CEQA in that it implements State Housing Element Law.

SECTION 3. General Plan. The City Council hereby finds that the adoption of the Ordinance is consistent with the General Plan as a matter of law under Government Code Section 66314(c).

SECTION 4. Code Amendments. Title 17 of the Escalon Municipal Code is hereby amended as follows:

1. The Land Use Table in Section 17.11.040 (List of Permitted Uses and Uses Permitted by Conditional Use Permit) is amended to add “Supportive housing” and “Low Barrier Navigation Centers” as permitted uses in the R-3, C-2, and C-M zones; “Emergency shelters” as a permitted use in the R-3 zone, as provided in the attached Exhibit A.

2. Title 17 (Zoning) is amended to add a new Chapter 17.33 to establish the Religious Institution Overlay (RIO) District and establish standards for residential projects proposed within the district, and the Zoning Map is amended to apply the RIO District designation to three identified sites, as provided in the attached Exhibit G.

3. Section 17.41.140 (Accessory Dwelling Units) is amended to allow JADUs within all single-family dwellings and ensure ADU/JADU requirements comply with State law, as provided in the attached Exhibit C.

4. Chapter 17.43 (Parking) is amended to use the maximum parking requirements established in Government Code Section 65915 for all multifamily projects and create a parking requirements table; establish parking requirements for emergency shelters in compliance with Government Code Section 65583; allow separate rental or sale of parking spaces and residential units (unbundled parking); and establish parking standards for residential developments subject to the provisions of the Religious Institution Overlay District, as provided in the attached Exhibit E.

5. Chapter 17.48 (Density Bonus) is amended to reflect updates to State law, as provided in the attached Exhibit D.

6. Chapter 17.81 (Definitions) is amended to add or amend the following definitions in their alphabetical orders, as provided in the attached Exhibit B:
a. Employee Housing
b. Family
c. Low Barrier Navigation Center
d. Supportive Housing

7. Section 17.11.040 (List of Permitted Uses and Uses Permitted by Conditional Use Permit) is amended to add “Personal Use Residential Food Gardening” as a permitted accessory use in zoning districts, as provided in the attached Exhibit A. “Personal use residential food gardening, including in‑ground gardens, raised beds, planter boxes, and edible landscaping, is permitted as an accessory use to any lawful development.” SECTION 5. Effective Date. This Ordinance takes effect 30 days after its adoption.

SECTION 6. Publication. The City Clerk is directed to certify the adoption of this Ordinance and post or publish this Ordinance as required by law.

SECTION 7. Custodian of Records. The custodian of records for this Ordinance is the City Clerk and the records comprising the administrative record are located at Escalon City Hall.

SECTION 8. Severability. If any provision of this Ordinance or its application to any person or circumstance is held to be invalid by a court of competent jurisdiction, such invalidity has no effect on the other provisions or applications of the Ordinance that can be given effect without the invalid provision or application, and to this extent, the provisions of this Ordinance

are severable. The City Council declares that it would have adopted this Ordinance irrespective of the invalidity of any portion thereof.

PASSED, APPROVED AND ADOPTED by the City Council of the City of Escalon, California, at a special meeting of the City Council held on the 10th day of August, 2026 by the following vote:

AYES:

NOES:

ABSENT:

ABSTAIN:
________________________________
Andrew Hagan, Mayor
ATTEST:
________________________________
Michele Bates, Deputy City Clerk
APPROVED AS TO FORM:
________________________________
Andreas Booher, City Attorney

Chapter 17.11 is amended to read as follows:

LIST OF PERMITTED USES

AND USES PERMITTED BY CONDITIONAL USE PERMIT
Sections:

17.11.010 Purpose.

17.11.020 Clarification of ambiguity.

17.11.030 Other uses.

17.11.040 List of permitted uses and uses permitted by conditional use permit by zoning district.

17.11.010 Purpose.

The chart incorporated into this chapter is to be used in determining what uses are permitted and what uses are permitted only upon approval of a conditional use permit. (Ord. 571 § 3, 2018; Ord. 495 § 1, 2005)

17.11.020 Clarification of ambiguity.

If ambiguity arises concerning the compatibility of a particular use within the meaning and purpose of this title, it shall be the duty of the city planner to interpret this title in light of all pertinent facts. (Ord. 571 § 3, 2018; Ord. 495 § 1, 2005)

17.11.030 Other uses.

The planning commission shall have the authority to determine other uses to be similar in nature to the permitted or conditional uses specified in EMC 17.11.040 when requested by the city planner. (Ord. 571 § 3, 2018; Ord. 495 § 1, 2005)

17.11.040 List of permitted uses and uses permitted by conditional use permit by zoning district.

R-E R-1 R-2 R-3 C-1 C-2 C-M M-1 M-2 O PF
Residential Uses
Accessory buildings and uses P P P P N N N N N N N
Attachment 2

R-E R-1 R-2 R-3 C-1 C-2 C-M M-1 M-2 O PF
Boardinghouse N N N C C C N N N N N
Home occupation/business/office P P P P P P P P P N N
Manufactured structure
(residential)
P1 P1 P1 P6 P2 P2 P2 N N N N
Mobile home park N N N C C N N N N N N
Multiple-family dwellings N N N P C2,
4 P5 C2,
4 N N N N
Residential condominium N N P P C2,
4 P5 C2,
4 N N N N
Accessory dwelling unit P P P P P P P N N N N
Single-family dwellings on existing
lots less than 6,000 square feet

N P P P N N N N N N N
Single-family dwelling P P P P6 P2 P2 P2 N N N N
Two-family dwellings N N P P P2 P2 P2 N N N N
Two-family dwelling on corner lot
where entrances front on opposite
streets

P P P P N N N N N N N
Supportive housing N N N P N P P N N N N
Low Barrier Navigation Centers N N N P N P P N N N N
Model home centers C C C C C C C N N N N
Garage sales P P P P T T T T T N N
Emergency shelters N N N CP N N C P7 P7 N N

R-E R-1 R-2 R-3 C-1 C-2 C-M M-1 M-2 O PF
Personal Use Residential Food
Gardening

P P P P P P P P P P P
Employee housing P P P P6 P2 P2 P2 N N N N
Supportive housing Permitted subject to the same requirements and standards as residential uses of the same type (e.g.,
single-family dwelling, multiple-family dwellings, etc.).

Transitional housing Permitted subject to the same requirements and standards as residential uses of the same type (e.g.,
single-family dwelling, multiple-family dwellings, etc.).

Community Service
Art, dance, music or craft
studios/school

N N N N P P P C C N N
Church, other institutions for
religious observance

C C C C C C C C C N N
Club, lodge, hall, fraternal
organization

N N N C C C C C N N N
Communication facility/tower C N N C C C C P P C P
Convalescent facility N N N C C C C C C N N
Small family day care P3 P3 P3 P3 N N N N N N N
Large family day care P3 P3 P3 P3 P3 P3 P3 N N N N
Galleries, arts and crafts N N N N N P P P N N N
Golf course C N N N N N N N N C C

R-E R-1 R-2 R-3 C-1 C-2 C-M M-1 M-2 O PF
Hospital C N N N N C C C C N N
Park, playground P P P P C C C C C P P
Private sports recreation club N N N N N C C C C C C
Public building: police, fire,
community center, library

C C C C C C C C C N C
Public utility service yard, station,
facility

C C C C C C C C C N C
Publicly owned historic sites C C C C C C C C C N N
Residential care facility, large P12
C
P12
C
P12
C
P12
C

N C C C C N N
Residential care facility, small P P P P P2 P2 P2 N N N N Schools, public or private, nursery
school

C C C C N C C C C N N
Vocational or trade school N N N N N C C C C N N
Commercial
Antiques N N N N P P P N N N N
Commercial recreation and
amusement establishment

N N N N C C C C C C N
Christmas tree lots/pumpkin sales N N N N T T T T T C N Financial institutions N N N N P P P N N N N

R-E R-1 R-2 R-3 C-1 C-2 C-M M-1 M-2 O PF
Hotel N N N N N C C N N N N
Motel N N N N N C C N N N N
Outdoor entertainment, only in
conjunction with another approved
use

N N N N N C C N N P P
Personal service N N N N P P P P N N N
Restaurant, 41 seats or more N N N N C C C C C N N
Restaurant, limited to up to 40
seats

N N N N P P P P P N N
Restaurant, fast food N N N N C C C C C N N
Retail sales, new N N N N P P P N N N N
Retail sales, used N N N N N P P N N N N
Sale of alcoholic beverages for
consumption off premises

N N N N P P P N N N N
Sale of alcoholic beverages for
consumption on premises as part
of restaurant

N N N N P P P C C N N
Sale of alcoholic beverages for
consumption on premises without
food service (bar/nightclub)

N N N N N C C C N N N
Shopping center N N N N C C C N N N N
Supermarket/grocery N N N N P P C C N N N
Theater N N N N C C C C N N N

R-E R-1 R-2 R-3 C-1 C-2 C-M M-1 M-2 O PF
Video/movie/music rental N N N N P P P P N N N
Services
Ambulance N N N N N C C P P N N
Appliance repair, small N N N N N P P P P N N
Carpet, furniture cleaning N N N N N P P P P N N
Equipment, vehicle, light/heavy,
truck or trailer rental
N N N N N C11 P P P N N
Laundromat, self-service for public N N N N P P P P P N N Laundry/dry cleaning N N N N N P P P P N N
Mini-storage N N N N N C C P P N N
Photography studio N N N N P P P N N N N
Temporary structures for use
during construction

P P P P P P P P P N N
Office Uses
Business or professional N N C C P P P P P N N
Medical, etc. N N C C P P P N N N N
Industrial Uses

R-E R-1 R-2 R-3 C-1 C-2 C-M M-1 M-2 O PF
Agricultural services, except those
that produce noxious odors

N N N N N N P P P N N
Building material sales and/or
storage

N N N N N N C P P N N
Contracting N N N N N C10 P P P N N
Food processing, including dairy
products, poultry and small game

N N N N N N N C P N N
Industry, general: uses such as
major manufacturing, major
assembly

N N N N N N N N P N N
Industry, limited: uses such as
equipment repair, limited
manufacturing, machinery repair,
paint supplies, janitorial services

N N N N N C P P P N N
Laboratory, research facility N N N N N N P P P N N
Maintenance and repair facility N N N N N N N P P N P
Outdoor storage N N N N N N C P P N N
Plant nurseries N N N N P P P P P N N
Warehousing N N N N N N P P P N N
Wholesale activities N N N N N N P P P N N
Automobile Related

R-E R-1 R-2 R-3 C-1 C-2 C-M M-1 M-2 O PF
Alternating use of off-street parking
spaces

N N N N C C C C C N N
Car wash N N N N N C P P P N N
Farm equipment sales and service N N N N N C P P P N N
Marine and boat sales and service N N N N N C C P P N N Motor vehicle body repair and
painting

N N N N N C C C N N N
Motor vehicle repair and service
(garage), major

N N N N N C N P P N N
Motor vehicle repair and service
(garage), minor

N N N N N C P P P N N
Motor vehicle sales, service and
related activities

N N N N N C C C N N N
Motor vehicle tires and accessories N N N N N C P P N N N Recreational vehicle and
equipment storage yard

N N N N N C P P P N P
Recreational vehicle sales and
service

N N N N N C P P P N N
Recycling facility, light, drop-off N N N N N C P P P N C Recycling facility, processing,
drop-off

N N N N N N N N P N C
Service station N N N N P P P P P N N
Truck terminal N N N N N N N P P N N

R-E R-1 R-2 R-3 C-1 C-2 C-M M-1 M-2 O PF
Other
Adult entertainment facility N N N N N N N C N N N
Artisan beverage maker N N N N N C C P P N N
Brewery, large N N N N N C C P P N N
Brewery, micro N N N N N C C P P N N
Brewery, small N N N N N C C P P N N
Brewery, tap or tasting room N N N N N C C P P N N
Brewpub N N N N N C C P P N N
Cemeteries, columbarium,
mausoleum

C N N N N C C N N N N
Craft distiller N N N N N C C P P N N
Kennel, overnight, vacation
boarding – Animals

N N N N N C C C C N N
Mortuary and funeral services C N N N N C C C N N N
Off-site directional sign N N N N P8 P8 P8 P P N N
Parking structures or facilities N N N N C C C C C N N
Pet grooming N N N N P P P P N N N
Printing, photocopying,
lithographic

N N N N P P P P P N N

R-E R-1 R-2 R-3 C-1 C-2 C-M M-1 M-2 O PF
Shipping/cargo/metal storage
containers
P9 P9 P9 P9 T T T T T T T
Temporary residence during
construction of permanent
residence

C C C C N N N N N N N
Veterinary hospital without
overnight boarding

N N N N C C C P P N N
Winery N N N N N C C P P N N
Winery, micro N N N N N C C P P N N
Winery, tasting room N N N N N C C P P N N
C – Requires approval of a conditional use permit
P – Permitted (other planning approvals may be required) T – Temporary use land permit required
N – Entry in a column means that the listed use is not permitted Special Conditions. The following special conditions apply to the uses indicated by the corresponding number on the above table.

1. Manufactured homes must be certified under the National Manufactured Housing Construction and Safety Standards Act of 1974 (42 USC 5401 et seq.) on a permanent foundation. Manufactured homes shall be permitted in the same manner, in the same zones, and subject to the same development standards as other single-family residential uses, consistent with Government Code Section 65852.3.

2. Residences in Non-R District. Residential uses in any commercial zoning district shall comply with the development regulations applicable in the R-3 district; no residential use is allowed on the ground floor of any commercial building in any non-R district unless the project is approved under the planned development zoning district process.

3. Small family day care homes must meet requirements of the Health and Safety Code Section 1597.45; large family day care homes must meet requirements of Health and Safety Code Section 1597.46.

4. Condominium and townhouse developments can be approved only under the planned development zoning district process in the C-1 and C-M zones.

5. Multifamily residential allowed as a permitted use with a preliminary development plan.

6. Single-family units in the R-3 zoning district are limited to a single-family unit that is: (a) replacing an existing single-family unit on a one-for-one basis; (b) on an existing lot of 6,000 square feet or less; or (c) part of a housing development with the majority of units affordable to extremely low-, very low-, and/or low-income households.

7. Emergency shelters are a permitted use subject to the standards established under Chapter 17.50A EMC.

8. Subject to sign permit approval.

9. Permitted up to 30 days in residential zoning districts.

10. May be approved by the city planner if operating indoors only; if operation of business is proposed outside of building, conditional use permit is required.

11. The business location shall have direct access for commercial vehicles onto a street identified as a designated truck route, in accordance with EMC 10.08.020.

12. The permitting requirements and development standards applicable to residential care facilities (7 or more persons) shall apply when located within a residential structure where the use is permitted by right in the underlying zone district. (Ord. 582 § 3, 2020; Ord. 580 § 1 (Exh. A), 2019; Ord. 577 § 5, 2019; Ord. 575 § 3, 2019; Ord. 571 § 3, 2018; Ord. 557 § 1 (Att. A), 2016; Ord. 530 Att. A, 2011; Ord. 527 § 7, 2010)

Chapter 17.81.060 is amended to read as follows:

17.81.070 “E” definitions.
"Eaves" means roof projections, which extend beyond the exterior wall plane of a building. "Emergency shelter" means housing with minimal supportive services for homeless persons that is limited to occupancy of six months or less by a homeless person. No individual or household may be denied emergency shelter because of an inability to pay. "Employee housing" means housing providing accommodations for six or fewer employees a dwelling, structure, portion of a structure, or other premises, including any accommodations or facilities used in connection with the housing, that is maintained, operated, or used as living quarters for the housing of five (5) or more employees, whether provided by an employer, labor contractor, or other person, including housing provided with or without charge, rent, or other compensation. Employee housing includes, but is not limited to, permanent, temporary, seasonal, or migrant employee housing accommodations, as defined and regulated by applicable provisions of the California Health and Safety Code. Employee housing providing accommodations for six (6) or fewer employees shall be treated as a single-family home and shall be permitted in all zones that allow single-family residences, subject to the same standards and permit requirements as a single-family residence.
"Entrance, primary" means the primary entrance to a building. "Equipment rental" means a business whose primary activity is the renting of tools, equipment, and other devices.

Exterior Sign. See EMC § 17.42.020.

Chapter 17.81.070 is amended to read as follows:

17.81.070 “F” definitions.
“Family” means one or more persons occupying a premises and living as a single housekeeping unit, whether or not related by blood or marriage., as distinguished from a group occupying a hotel, club, fraternity or sorority house. A family shall be deemed to include necessary servants.
“Farm equipment/marine sales and services” means an establishment providing farm or marine supplies, equipment, and minor service.

“Fence” means a vertical barrier of any material, or combination of materials, constructed to enclose or screen a lot or a portion of a lot. Also includes “wall or solid hedge or landscaping screen.”
“Financial/real estate services” means a category of businesses and services including banks, savings and loan associations, thrifts, real estate brokerages, land title companies, escrow companies, and stock and bond offices.
“Floor area ratio (FAR)” means the ratio between the total floor area of a building or buildings located on a lot and the area of that lot in gross square feet. (See illustration.) “Floor area, total” means the sum of the gross horizontal areas of all floors of a building measured from the exterior faces of the exterior walls or perimeters of horizontal surfaces if such horizontal areas are partially or wholly unenclosed.

“Foster family home” means a state-licensed residential facility providing 24-hour care for six or fewer foster children, which is zoned, leased, or rented and is the residence of the foster parent or parents, including their family, in whose care the children have been placed.
“Front wall” means the wall of the building nearest the street upon which the building faces, but excluding certain architectural features as specified in this title. “Funeral and interment services” means a building or part thereof used for human funeral services. Such building may contain space and facilities for: a chapel; embalming and the performance of other services used in preparation of the dead for burial; the performance of autopsies and other surgical procedures; the storage of caskets, funeral urns and other related funeral supplies; and the storage of funeral vehicles, but shall not include facilities for cremation. (Ord. 495 § 1, 2005)
Chapter 17.81.130 is amended to read as follows:

17.81.130 “L” definitions.
“Laboratories” means establishments providing medical or dental laboratory services or establishments providing photographic, analytical or testing services. “Landscaping” means the planting and maintenance of trees, shrubs, lawns, and other ground cover or material, including inorganic accessory materials utilized to access or complement the vegetation.
“Livestock farming” means keeping of farm animals for use, for propagation, or for intended profit or gain and without limiting the generality of the foregoing includes: dairy and beef cattle, horses, swine, sheep, laying hens, chicken and turkey broilers, turkeys, goats, geese, mink and rabbits.
“Lot” means land occupied or to be occupied by a building and its accessory buildings, or by a dwelling group and its accessory buildings, together with such open spaces as are required under the provisions of this title and having its principal frontage on a street. “Lot” includes the word “plot.”
“Lot area” means the total horizontal area included within lot lines.