Gilroy City Council
May 1, 2023

9.2 p. 439 of 1163
Housing Needs Assessment ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 79
Based on HUD’s 2014-2018 CHAS data shown in Table 35, 47.4 percent of elderly households in Gilroy are in one of the lower-income categories. Santa Clara County had a slightly smaller percentage of elderly households within the lower-income categories, at 45.8 percent.

Table 35: Income Distribution, Elderly Households, 2018 Income
Gilroy Santa Clara
County
Number % Number %
Less than or equal to 30% of HAMFI 980 20.2% 39,300 19.7% Greater than 30% but less than or equal to 50% of HAMFI 695 14.3% 26,085 13.1% Greater than 50% but less than or equal to 80% of HAMFI 625 12.9% 26,380 13.2% Greater than 80% of HAMFI 2,555 52.6% 108,105 54.1%
Total 4,855 100% 199,870 100%
Source: HUD 2014-2018 CHAS data.

Table 36 displays the percentage of the elderly population and their disability status. Of people aged 65 and above, 11.3 percent have one type of disability and 16.5 percent have two or more disabilities. The City and County have similar percentages of elderly individuals with disabilities, at 27.8 and 30.7 percent, respectively.

Table 36: Elderly People with Disabilities, 2019
Disability Status
# of Elderly
People with a
Disability
% of
People
Age 65+
# of Elderly
People
with a Disability
% of
People
Age 65+
Gilroy Santa Clara County
With one type of disability 669 11.3% 31,527 12.4%
With two or more types of
disability
978 16.5% 46,455 18.3%
Total, Elderly with a Disability 1,647 27.8% 77,982 30.7% Source: ACS 2019 Table C18108.

Table 37 provides a summary of housing problems experienced by elderly households in Gilroy. According to the 2014-2018 CHAS data, 61.6 percent of all elderly households experience some type of housing problem. This includes 81.3 percent of elderly renters and

54.5 percent of elderly owners. The increasing number of elderly persons in the population is creating a demand for more affordable and accessible housing.

The City will address the needs of the elderly population through Program E - 6, which will develop incentives for senior housing in the City. Program E - 6 will also remove potential zoning constraints to the development of senior housing. The City will conduct a study to determine if reduced parking standards for senior housing are appropriate and, based on the

9.2 p. 440 of 1163
Housing Needs Assessment ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 80
findings of the study, may revise the Zoning Ordinance to reduce said parking standards for senior housing. In addition, the Gilroy Senior Center provides access to a variety of support services at the center, including the YMCA Nutrition program, which serves lunch Monday to Friday; free legal services through Senior Adults Legal Assistance; and information and assistance with social security, housing, and employment matters through Sourcewise Community Resources Solutions. Through CDBG and the Housing Trust/PLHA Funds, the City allocated funds for Meals on Wheels and Rebuilding Together Silicon Valley’s Rebuilding Home Repair, Rehabilitation and Accessibility Modification Program. Also, Santa Clara County owns the Gateway Senior Apartments, a 75‐unit affordable senior housing complex with approximately half of the units reserved for special needs seniors.

Table 37: Elderly Households by Housing Problems and Tenure, 2018 Housing Problem Type Renters Owners Total (Elderly
Households)
% with any Housing Problem 81.3% 54.5% 61.6%
% with Cost Burden 29.5% 15.7% 19.4%
% with Severe Cost Burden 29.1% 20.0% 22.4%
Total 843 2,350 3,193
Source: 2014-2018 HUD CHAS data.

Large Households
State housing law defines large households as households with five or more members. Large households are considered a special needs group based on the limited availability of adequately sized, affordable housing units. Large households may have lower incomes, which could result in the overcrowding of smaller units. Table 38 displays household size by tenure for both Gilroy and the County. In 2019, there were 3,916 large households, representing 24.3 percent of all households in Gilroy. Compared to the County as whole, Gilroy has almost double the percentage of large households (24.3 versus 12.4 percent). The disproportionately high number of large households may indicate a need for larger units in Gilroy to accommodate large households. The City is including Program E - 11 to prioritize funds to assist in the development of housing to serve special needs households, such as large families.

The 5th Cycle Program H-4.A (Housing for Large Families) has been consolidated with 6th Cycle Program A - 12 to include incentives beyond density bonus state law for developments that include housing for large households.

9.2 p. 441 of 1163
Housing Needs Assessment ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 81
Table 38: Large Households by Tenure, 2019
Number of
Persons in
Unit
Owner
Occupied %
Renter
Occupied % Total
Gilroy
Five 1,239 58.6% 876 41.4% 2,115
Six 636 60.7% 412 39.3% 1,048
Seven or
more
405 53.8% 348 46.2% 753
Total Large
Households
2,280 58.2% 1,636 41.8% 3,916
% of Total
Households
23% 26.3% 24.3%
Total
Households 9,914 61.5% 6,212 38.5% 16,126
Santa Clara County
Five 26,406 57.9% 19,190 42.1% 45,596
Six 10,802 58.0% 7,822 42.0% 18,624
Seven or
more
8,684 56.6% 6,650 43.4% 15,334
Total Large
Households
45,892 57.7% 33,662 42.3% 79,554
% of Total
Households

12.7% 12.1% 12.4%
Total
Households 361,105 56.4% 279,110 43.6% 640,215
Source: 2019 ACS B25009.

Based on HUD’s 2015-2019 CHAS data shown in Table 39, 51.1 percent of large households in Gilroy are in one of the lower-income categories. Santa Clara County had a smaller percentage of large households within the lower income categories, at 42.9 percent. The City is including Program E - 11 to prioritize funds to assist in the development of affordable housing and to serve special needs households, such as large families.

9.2 p. 442 of 1163
Housing Needs Assessment ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 82
Table 39: Income Distribution, Large Households, 2015-2019 Income
Gilroy Santa Clara
County
Number % Number %
Less than or equal to 30% of HAMFI 1,025 15.1% 16,429 11.9% Greater than 30% but less than or equal to 50% of HAMFI 1,100 16.2% 20,250 14.7% Greater than 50% but less than or equal to 80% of HAMFI 1,340 19.7% 22,410 16.3% Greater than 80% of HAMFI 3,320 48.9% 78,600 57.1%
Total 6,785 100% 137,689 100%
Source: HUD 2015-2019 CHAS data.

Table 40 provides a summary of housing problems experienced by large households in Gilroy by tenure. As previously noted, the types of housing problems include overcrowding, overpayment, and housing lacking kitchen or plumbing facilities. CHAS data from 2014-2018 indicates that 49.2 percent of large households experience at least one of these housing problems, including 72.4 percent of large renter households and 30.3 percent of large owner households.

Currently, less than 10 percent of the City’s rental housing stock has four or more bedrooms (refer to Table 24), resulting in a high percentage of large family households that are forced to live in overcrowded situations. To address this need, the Housing Element includes Program A - 12 that will adopt incentives beyond density bonus state law for developments that include housing for large households.

Table 40: Large Households by Housing Problems and Tenure, 2018 Renters Owners Total (Large Households)
% with any Housing Problem 72.4% 30.3% 49.2%
% with Cost Burden 23.2% 12.6% 17.4%
% with Severe Cost Burden 24.3% 6.9% 14.7%
Total Large Households 1,360 1,665 3,025
Source: 2014-2018 HUD CHAS data.

Female-Headed Households
Female-headed households are a special needs group because they experience comparatively low rates of homeownership, lower incomes, and high poverty rates. Table 41 shows the number of female-headed households by tenure. In 2019, 16.2 percent of households in Gilroy were female-headed households. Of the 2,616 female-headed households in Gilroy, 1,410 had children under 18 living with them, while 1,206 had no children present. Gilroy has more

9.2 p. 443 of 1163
Housing Needs Assessment ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 83
approximately six percent more female-headed households than the County, where 10 percent of households in the County are female-headed households.

In Gilroy, 33 percent of female-headed households with children under 18 were below the poverty line, (approximately 465 households).
9 This is significantly higher than the poverty rate
in Santa Clara County, which is 6.6 percent.

Table 41: Female-Headed Households by Tenure, Gilroy, 2019 Household Type
Owner Occupied Renter Occupied
Total
% of Total
Households
Number % Number % (16,126)
Female
householder, no
spouse present,
with children
under 18
377 2.3% 1,033 6.4% 1,410 8.7%
Female
householder, no
spouse present,
without children
639 4% 567 3.5% 1,206 7.5%
Total 1,016 6.3% 1,600 9.9% 2,616 16.2%
Source: ACS 2019 Table B25115.

Homeless/Unhoused Population
In 2022, the County of Santa Clara, in conjunction with Applied Survey Research, conducted the 2022 Santa Clara County Homeless Census and Survey. This survey is conducted every two years in the last ten days of January. The 2022 Santa Clara County Homeless Census and Survey was performed using HUD-recommended practices for counting and surveying the homeless.

The Point-in-Time Homeless Count identified a total of 10,028 persons experiencing homelessness in Santa Clara County in 2022, an increase of 3 percent from the count conducted in 2019. Table 42 summarizes sheltered and unsheltered homeless persons in Santa Clara County jurisdictions. There were 814 homeless persons surveyed in Gilroy in January 2022, including 606 sheltered and 208 unsheltered persons. 9 US Census Bureau, American Community Survey 5-year Data (2015–2019), Table B17010.

9.2 p. 444 of 1163
Housing Needs Assessment ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 84
Table 42: 2022 Santa Clara County Homeless Census and Survey Homeless Population Sheltered Unsheltered Total
Gilroy 606 208 814
Campbell 216 0 216
Cupertino 102 0 102
Los Altos 65 0 65
Los Altos Hills 0 0 0
Los Gatos 58 0 58
Milpitas 249 25 274
Monte Sereno 0 0 0
Morgan Hill 60 0 60
Mountain View 206 140 346
Palo Alto 263 0 263
San Jose 4,975 1,675 6,650
Santa Clara 375 65 440
Saratoga 0 0 0
Sunnyvale 279 106 385
Source: Santa Clara County Office of Supportive Housing, October 29, 2022.

Local Data
According to one of the City of Gilroy’s Quality of Life Officers, a majority of unhoused individuals are Hispanic, consistent with the overall population of Gilroy. Based on his observations, unhoused persons in Gilroy mostly reside in creek areas, including for example Miller creek. Many unhoused persons also reside near the IOOF bridge. Although most of the observed unhoused persons are physically able to move around by either walking or riding a bicycle, they do not generally migrate to hillside areas or edges of the City where there are fewer businesses or access to food. Furthermore, based on his observations, a very large majority of the unhoused are mentally challenged, whether it be self-induced from drugs, or because they are mentally ill. The Quality of Life Officer also stated that less than 20 percent of the unhoused persons he encounters take advantage of available services.

Table 43 lists emergency shelters and transitional housing in Gilroy.

The Countywide services and shelter provider, HomeFirst Services, provides a 24/7 shelter for adults at the Gilroy shelter. The Gilroy shelter provides sleeping accommodations, meals, restrooms, showers, mobile laundry, and case management support services via South County Compassion Center staff. It has a capacity of serving 100 persons.

9.2 p. 445 of 1163
Housing Needs Assessment ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 85
The Arturo Ochoa Migrant Center is used as an emergency shelter during the cold weather season from mid-December through mid-March. It provides 128 shelter beds and has the capacity to house 35 unhoused families with a dependent child under the age of 18. St.

Joseph’s Family Center manages the shelter and referral process. Walk-ins or families without a referral from a designated community partner are not accepted and 5-7 spots are reserved for Here4You call center hotline referrals. EAH Housing is contracted for day-to-day property management operations and site security.

According to conversations with service providers, if the weather is manageable, unhoused individuals express a strong reluctance to use the service. The service providers stress the need for a permanent emergency shelter as well as shelter or housing for single adults who do not exhibit mental illness or substance abuse disorders.

The City of Gilroy provides annual funds to homelessness prevention support and services through the PLHA. For FY 22-23 and FY 23-24: St. Joseph’s Family Center received $180,000 to provide emergency rental and utility assistance, as well as training and employment readiness to prepare individuals that are homeless or at risk of homelessness. Community Agency for Resources Advocacy and Services received $40,000 to provide rental and deposit assistance. South County Compassion Center received $80,000 to provide services to unhoused Gilroy residents and to connect them with services that can help them attain permanent housing. Through its CDBG-CV funds, the City provided an additional $287,309 in support to Saint Joseph's Family Center's Rental Assistance program.

9.2 p. 446 of 1163
Housing Needs Assessment ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 86
Table 43: Homeless Facilities in or Adjacent to Gilroy
Facility Name Type of Facility Target Population
Number of
Shelter Beds or
Families Served
Gilroy Shelter Emergency
Shelter Adults Only 100
Arturo Ochoa
Migrant
Center10
(adjacent to
Gilroy)
Cold Weather
Shelter Households with a dependent under 18 35 families La Isla Pacifica
Confidential
Emergency
Shelter
Women victims of intimate partner
abuse and their children under 16 years
old (16 and up, on a case-by-case basis)
14 Glenview, El
Invierno, and
Walnut
Transitional
Shelter Single Individuals 25
Source: City of Gilroy, County of Santa Clara.

Farmworkers
Farmworkers are defined as persons whose primary incomes are earned through seasonal agricultural work. The demographics on farm laborers in all California markets are collected and reported on a regional or countywide basis. The data collected includes income, household status, and length of time the laborers work in each area.

There are generally three classifications:
• Migrant workers who move from place to place, planting and harvesting; and • Annual workers who generally work in the same agricultural area year after year for nine or ten months and spend the rest of the year in their home country; and • Permanent workers who are employed most of the year in one location and may collect unemployment for the remainder of the year.

Traditionally, Gilroy has been home to many agricultural businesses and industries; however, the increase in the retail and service trade and the expansion of the City as a “bedroom community” for northern Silicon Valley jobs continues to reduce the role of agriculture. Many of these farms are located in the southern areas of the County, in the regions surrounding Gilroy. The majority of farmworkers, almost 80 percent, work on farms with more than 10 employees.
10 The Arturo Ochoa Migrant Center is located slightly outside city bounds, but serves Gilroy residents.

9.2 p. 447 of 1163
Housing Needs Assessment ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 87
The US Department of Agriculture conducts a Census of Agriculture every five years. As indicated in Table 44, there were an estimated 4,175 farmworkers in the County working on 359 farms in 2017. This represents a decrease of 1,414 farmworkers compared to the 2007 study, when there were 5,589 farmworkers.

The 2019 ACS estimates indicate that 2.9 percent of Gilroy is employed in the agriculture and natural resource industry, a decrease from 4.6 percent in 2012.11 Table 44: Number of Santa Clara County Farmworkers and Farms, 2017 Farm /Worker Type Farmworkers Farms
Farm Size
Farms with less than 10 employees 847 293
Farms with more than 10 employees 3,328 66
Length of Employment of Workers
Workers working 150 days or more 2,418 -
Workers working less than 150 days 1,757 -
Source: 2017 Census of Agriculture, Table 7.

The California Department of Conservation’s Important Farmland Finder indicates that the vicinity to the east and south of the Gilroy City limits includes large amounts of prime farmland, farmland of local or statewide importance, and unique farmland.12 The presence of such farmland indicates a need for farmworker housing to support those who work on farmland in and around the City.

Due to the seasonal nature of agricultural work and relatively low wages, farmworker households often have a difficult time securing safe, habitable, and affordable housing.

Eden Housing manages three housing developments within Gilroy City limits, providing 56 housing units for farmworkers:
• 14 units at The Trees
• 24 apartments at Aspen Grove
• 18 units at Maple Gardens
The Rodriguez Migrant Labor Camp, which houses 37 seasonal farmworkers, is privately owned, and is also located just outside of the City limits.

Eden Housing also operates the Arturo Ochoa Migrant Center, located just outside Gilroy City limits. The center functions as a migrant camp from April through November each year, 11 US Census Bureau, American Community Survey (2015–2019), Table C24030. 12 California Department of Conservation. California Important Farmland Finder. https://maps.conservation.ca.gov/DLRP/CIFF/

9.2 p. 448 of 1163
Housing Needs Assessment ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 88
providing housing for 100 farmworker families within 33 three-bedroom and 67 two-bedroom apartments.

Local Data
In November and December 2022, the City of Gilroy worked with staff from the Ochoa Migrant Camp to survey resident farmworkers. Twenty-six (26) surveys were completed by the farmworkers with assistance from bilingual staff at the Migrant Camp.

The top three housing issues identified by farmworkers was difficulty paying rent, mortgage, or down-payment (26), followed by insufficient housing supply (11) and homelessness (6).

Respondents also identified issues regarding length of rental leases and the need for temporary housing.

Additionally, the primary issues limiting housing options for farmworker respondents included insufficient money available for the deposit (24), and credit history or low credit scores (8). The City of Gilroy modified Programs E - 7 and E - 11 to help facilitate needed housing for farmworkers who work in and surrounding Gilroy.

The Gilroy Zoning Ordinance makes available zoning to accommodate various housing types to address the needs of farmworkers. Manufactured and modular homes are permitted byright in all residential zoning districts; boarding and rooming houses are allowed in all residential zoning districts with a conditional use permit; and multifamily units are allowed in the R3 and R4 residential zoning districts by right. Currently, the City’s Zoning Ordinance is not consistent with the Employee Housing Act;
13 therefore, as part of this Housing Element update,
the City is including Program E - 8 to revise the Zoning Ordinance in 2023.

Extremely Low-Income Households
Extremely low-income households in Gilroy are defined as households with income less than 30 percent of the Santa Clara County AMI. The provisions of Government Code Section 65583 (a)(1) require quantification and analysis of existing and projected housing needs of extremely low-income households. In 2018, 16.1 of Gilroy households were within the extremely lowincome category, a decrease from 18.9 percent in 2012.

An overcrowded housing unit is defined by the US Census Bureau as a housing unit occupied by more than one person per room (excluding bathrooms, kitchen, hallway, and closet space).

Occupancy by more than 1.5 persons per room constitutes severe overcrowding.

Overcrowding can affect public facilities and services, reduce the quality of the physical environment, and create conditions that contribute to deterioration of the housing stock.

Table 45 provides a summary of overcrowding rates experienced by extremely low-income households in Gilroy compared to other income levels. Households in Gilroy experience overcrowding at a higher rate than those in the County. Extremely low-income owner-occupied households experience overcrowding at a similar rate to low-income owner-occupied 13https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=HSC&division=13.&title=&part=1.&chapter=1.&article

9.2 p. 449 of 1163
Housing Needs Assessment ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 89
households, but at a higher rate than other owner-occupied households. Extremely lowincome renter-occupied households experience overcrowding at a lower rate than very lowand low-income renter-occupied households.

Overcrowding can indicate that a community does not have an adequate supply of affordable housing and/or variety of suitable housing units to meet the needs of the community. In the 5th cycle, the City included program H.2-G to encourage the development of extremely lowincome housing, and the City will continue to encourage developers to include extremely lowincome units in their housing projects. The City is also including Programs A - 6, A - 7, A - 8, and A -15 to promote the construction of and incentivize the affordability of ADUs. Affordable ADUs provide an alternative housing supply to allow for housing mobility in higher opportunity areas. The City will develop an inclusionary housing policy under Program A - 11 and incentives to create extremely low-income units under an incentives beyond density bonus state law Program A - 12.

Table 45: Overcrowding by Income Level, 2019
Housing Income Range Households Number of People per Room Overcrowding
(>1 person per
room)
Severe
Overcrowding
(>1.5 persons per
room)
Number Number % Number %
City of Gilroy: Owner Households
Less than or equal to 30% of HAMFI 880 70 8.0% 20 2.3%
Greater than 30% but less than or
equal to 50% of HAMFI 1,024 44 4.3% 4 0.4%
Greater than 50% but less than or
equal to 80% of HAMFI 1,385 115 8.3% 35 2.5%
Greater than 80% but less than or
equal to 100% of HAMFI 1,295 20 1.5% 0 0.0%
Greater than 100% of HAMFI 5,334 99 1.9% 4 0.1%
Total 9,918 348 3.5% 63 0.6%
City of Gilroy: Renter Households
Less than or equal to 30% of HAMFI 2,195 375 17.1% 200 9.1% Greater than 30% but less than or
equal to 50% of HAMFI
1,300 310 23.9% 125 9.6%
Greater than 50% but less than or
equal to 80% of HAMFI
1,160 255 22.0% 40 3.5%

9.2 p. 450 of 1163
Housing Needs Assessment ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 90
Housing Income Range Households Number of People per Room Overcrowding
(>1 person per
room)
Severe
Overcrowding
(>1.5 persons per
room)
Number Number % Number %
Greater than 80% but less than or
equal to 100% of HAMFI
570 55 9.7% 25 4.4%
Greater than 100% of HAMFI 975 135 13.9% 80 8.2%
Total 6,200 1130 18.2% 470 7.6%
Santa Clara County: Owner Households
Less than or equal to 30% of HAMFI 34,600 975 2.8% 280 0.8% Greater than 30% but less than or
equal to 50% of HAMFI
33,095 1,870 5.7% 345 1.0%
Greater than 50% but less than or
equal to 80% of HAMFI
38,665 2,155 5.6% 510 1.3%
Greater than 80% but less than or
equal to 100% of HAMFI
31,345 1,665 5.3% 585 1.9%
Greater than 100% of HAMFI 223,395 5,530 2.5% 1,130 0.5% Total 361,100 12,195 3.4% 2,850 0.8%
Santa Clara County: Renter Households
Less than or equal to 30% of HAMFI 64,310 9,360 14.6% 3,830 6.0% Greater than 30% but less than or
equal to 50% of HAMFI
40,810 9,000 22.1% 3,705 9.1%
Greater than 50% but less than or
equal to 80% of HAMFI
37,760 7,305 19.3% 2,400 6.4%
Greater than 80% but less than or
equal to 100% of HAMFI
26,915 4,000 14.9% 1,520 5.6%
Greater than 100% of HAMFI 109,315 10,360 9.5% 4,320 4.0% Total 279,110 40,025 14.3% 15,775 5.7%
Source: 2015-2019 CHAS data
Table 46 provides a summary of housing problems experienced by extremely low-income households in Gilroy. Disproportionate housing needs are determined by finding trends in housing problems in the population by race, household size, or household age. A housing unit is considered substandard or having a housing problem if it has one or more of the following housing conditions:

9.2 p. 451 of 1163
Housing Needs Assessment ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 91
• Housing unit lacks complete kitchen facilities
• Housing unit lacks complete plumbing facilities
• Housing unit is overcrowded
• Household is cost burdened
Extremely low-income renter-occupied households experience both overpayment and overcrowding. According to 2014–2018 CHAS data provided by HUD, 79.7 percent of extremely low-income households experience at least one type of housing problem. Housing rehabilitation and repair may be more of a cost burden on lower-income households, which may lead to a higher proportion of housing problems. To enhance the quality of existing neighborhoods, the City is including Program C - 2 to utilize Community Development Block Grant (CDBG) funds, as available, to assist in the improvement of substandard housing. The City is also including Program E - 11 to prioritize funds to assist special needs households, such as extremely low-income households, farmworkers, large families, seniors, and persons with disabilities.

Table 46: Extremely Low-Income Households with Housing Problems, 2018 Income Level Renters % Owners % Total %
Household Income < 30% MFI 1,990 625 2,615
With any Housing Problem 1,610 80.9% 475 76.0% 2,085 79.7% With a Cost Burden 30-50% 360 18.1% 70 11.2% 430 16.4%
Cost Burden > 50% 1,230 61.8% 400 64.0% 1,630 62.3%
Source: HUD 2014-2018 CHAS data.

Summary of Housing Needs
An analysis of the housing needs in the City of Gilroy reveals a number of trends, such as an increased need for housing large households and farmworkers. Additionally, compared to the County, Gilroy has a lower median income and larger percentage Hispanic or Latino population.

9.2 p. 452 of 1163
92 CITY OF GILROY

HOUSING ELEMENT
6TH CYCLE

AFFIRMATIVELY FURTHERING FAIR HOUSING

9.2 p. 453 of 1163
Affirmatively Furthering Fair Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 93
Affirmatively Furthering Fair Housing
Introduction, Outreach, and Assessment
Introduction
Assembly Bill (AB) 686 requires a jurisdiction’s housing element to provide an analysis of contributing factors to fair housing issues and to commit to actively and meaningfully affirmatively further fair housing. This analysis includes an assessment of fair housing enforcement, outreach activities, integration and segregation, racially and ethnically concentrated areas of affluence and poverty, disparities in access to opportunities, disproportionate housing needs, and any other contributing factors that serve as impediments to fair housing. The assessment also analyzes the extent to which the identified Regional Housing Needs Allocation (RHNA) sites affirmatively further fair housing.

Public Outreach
The City of Gilroy solicited community input throughout the Housing Element update planning process in a variety of ways. The main strategies to gather public participation are summarized below.

Outreach Activities
Community members were engaged using the following methods:
• Survey available in hard copy and online in both English and Spanish • Stakeholder focus groups
• Webpage on City website
• Email list
• City newsletter
• Community workshops
• Joint City Council and Planning Commission study session • Utility billing mailing insert
• Public hearings
Organizations Contacted and Consulted
Organizations contacted and interviewed included:
• Housing & Neighborhood Revitalization Committee
• St. Joseph's Family Center
• Gilroy Historical Society

9.2 p. 454 of 1163
Affirmatively Furthering Fair Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 94
• Rebuilding Together Silicon Valley
• Project Sentinel
• Gilroy Compassion Center
• Live Oak Adult Day Services
• Silicon Valley at Home
• South County Collaborative
• League of Women Voters
• Aperto Property Management
• Housing Choices
• Health Trust
• Visit Gilroy
• MidPen Housing
• Garlic World
• CARAS South County
• Eden Housing
• Gilroy Unified School District Migrant Education Program Housing Element Update Website
The City created the Housing Element update webpage on the City’s website to provide:
• Background and information on the Housing Element process; • Link to the Housing Element update survey;
• Documents related to the Housing Element, including the first public review draft, dated September 12, 2022, the October 31, 2022 revised daft as submitted to the California Department of Housing and Community Development (HCD) following the 30-day public comment period, and the second public review draft revised in response to HCD comments;
• Recordings of the community workshop presentations in English and Spanish; • Notification to the public of future events; and
• Notification and interest sign-up lists and pathways for residents to get involved in the process and to provide comments or questions to the project team or City representatives.

9.2 p. 455 of 1163
Affirmatively Furthering Fair Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 95
Stakeholder Interviews
The City reached out to 40 individuals and groups who represented service providers, nonprofits, and other stakeholders to participate in focus group interviews about the housing needs and issues in Gilroy. Out of the 40 individuals and groups that were contacted, 25 people participated in the focus groups. Four focus groups were held: Tuesday, March 29, 2022, at 1:00 PM; Tuesday, April 5, 2022, at 1:00 PM; Thursday, April 7, 2022, at 1:00 PM; and Tuesday, April 12, 2022, at 10:00 AM. Hosting the focus group on four different days provided multiple opportunities to accommodate different schedules. The stakeholders who participated discussed a variety of concerns, including:
• Need for incentives to support farmworker housing;
• Need for more education and outreach to inform residents of housing law and affordable housing;
• Need for emergency, short-term stay housing, and senior housing at the extremely low-income area median income (AMI);
• Disparity of housing and quality of infrastructure and amenities between the east side and west side of the City;
• Disparity of incomes between Gilroy and the County AMI, as the City’s AMI was $33,871 less (24%) in 2020;
• Challenges and lack of support for homeownership; and • Need to incentivize accessory dwelling unit (ADU) construction.

The participants had varying perspectives informed by their involvement and familiarity with Gilroy, but increased services, education and support, equitable development and investment, and a lack of extremely low-income housing were the most consistent and prevalent issues covered.

Public Workshops
Prior to releasing the first public draft of the Housing Element, the City held two bilingual virtual public workshops. The meetings were held on Wednesday, March 30, 2022, at 6:00 PM and Tuesday, June 28, 2022, at 6:00 PM to present information on the Housing Element update and gather public input. Sixty-one members of the community participated in the workshops and provided feedback via live polling and questions and answers on the Housing Element update process including housing needs, the potential RHNA sites, draft goals, and programs.

Presentation slides were in English and Spanish. Live Spanish interpretation was provided, recorded, and posted on the project webpage for both workshops.

Following release of the first public draft, the City held a third virtual public workshop on Tuesday, September 27, 2022, at 6:00 PM. The presentation provided a high-level overview of the draft Housing Element chapters and appendices, and the overall goals and programs, and then a brief description of some of the programs that could potentially have the highest impact

9.2 p. 456 of 1163
Affirmatively Furthering Fair Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 96
on housing production, removal of governmental constraints, and meeting special housing needs. The meeting also included a question-and-answer session with public attendees.

The public workshops were held at 6:00 PM on weekdays to accommodate a typical work schedule. Materials and video recordings of the presentations in English and Spanish were made available on the Gilroy Housing Element webpage on the City’s website for those who could not attend, or who wanted to review the materials and meetings at their leisure.

Study Session
An in-person bilingual joint public study session with the City Council and Planning Commission was held on Monday, August 29, 2022, at 6:00 PM. This bilingual meeting included a summary of proposed housing programs to address the identified needs of the community and a map of properties that are currently vacant or underutilized that may provide an opportunity for redevelopment with new housing. The meeting included comments from the public and a question-and-answer session with the Council and Planning Commission.

Spanish interpretation and translation were provided. The meeting recording and the presentation slides in both English and Spanish were posted on the project webpage.

Public Hearings
Following the release of the first public draft, the City held two in-person public hearings. The public hearings were held Monday, October 17, 2022, at 6:00 PM (City Council) and Thursday, October 20, 2022, at 6:00 PM (Planning Commission). The purpose of the meetings was to give the public and the City’s decision makers another opportunity to provide comments and suggestions prior to sending the draft to HCD for its review.

Public hearings held on April 20, 2023 (Planning Commission) and May 1, 20223 (City Council) gave the public and the City’s decision makers an opportunity to review and comment on Housing Element revisions made in response to HCD’s comments.

Housing Element Survey (general population)
Another component of the outreach effort was the Housing Element survey, posted on the City’s website from April 2022 through August 2022, and promoted through a myriad of channels for the furthest outreach. The survey was available in both English and Spanish. As of August 2, 2022, a total of 367 English and 143 Spanish completed surveys were received, with 248 (34%) respondents being homeowners, 125 (17%) being renters, 191 (35%) of respondents being white or Caucasian, and 236 (44%) being Hispanic or Latino. 14 Responses
to the survey primarily revealed concerns from residents regarding:
• Difficulty paying rent, mortgage, or down payment;
14 Note: 510 total surveys were completed to varies degrees of completeness. Respondents did not answer every question; therefore percentages represent the percentage of respondents to each question not total number of survey respondents.

9.2 p. 457 of 1163
Affirmatively Furthering Fair Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 97
• Homelessness; and
• Insufficient housing supply including affordable housing.

Respondents also believe that the greatest housing needs are lower- and middle-income workforce housing and affordable housing. The survey results show strong support for more affordable housing while some respondents feel the City is growing too much and thus did not support more development. Most of the survey and stakeholder responders believe that there are not enough services or housing to support individuals who fall within the extremely lowincome designation. Stakeholder interviewees and 94 percent of survey respondents supported the adoption of an inclusionary housing ordinance.

Housing Element Survey (focused outreach)
In addition to posting the housing element survey on the City website, City staff conducted a focused bilingual survey effort for farmworkers, youth, and seniors. Hard copy and online surveys were distributed between November 2022 and the end of January 2023. ▪ Farmworker Outreach. Twenty-six (26) surveys were completed. The top three housing issues identified by farmworkers was difficulty paying rent, mortgage, or downpayment (26), followed by insufficient housing supply (11) and homelessness (6).

Respondents also identified issues regarding length of rental leases and a need for temporary housing.
▪ Youth Outreach. Eight (8) surveys were completed. The top housing issues identified by this group was difficulty paying rent, mortgage, or down-payment; overcrowding; homelessness; and lack of suitable housing types. Responses also reflected the desire for the City to implement programs to require affordable housing units in new developments and assist residents with finding available housing. ▪ Seniors Outreach. Nineteen (19) surveys were completed. The top three housing issues identified by seniors were difficulty paying rent, mortgage, or down-payment (12), followed by lack of suitable housing types (9), and insufficient housing supply (7).

Respondents identified requiring affordable housing units in new developments (10) and access to low-cost pre-designed plans for ADUs as potential programs to improve housing access in Gilroy.

Focused Stakeholder Meetings
Between December 2022 and February 2023, City staff met with Gilroy’s youth, seniors, and the intellectually and developmentally disabled (I/DD) community. On December 12, 2022, City staff attended the Gilroy Youth Commission meeting to discuss the Housing Element update, answer questions, and gather feedback from youth in attendance (~15 to 18 years old). On January 25, 2023, City staff made a presentation to seniors at the Gilroy Senior Center, informing them about the Housing Element and gathering feedback. On January 24, 2023, the City held a virtual meeting with Housing Choices and intellectually and developmentally disabled (I/DD) stakeholders (primarily parents of I/DD children and I/DD adults), informing

9.2 p. 458 of 1163
Affirmatively Furthering Fair Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 98
them about the Housing Element and gathering verbal feedback. On February 15, 2023, the City also met with and gathered verbal feedback from I/DD residents, caregivers, and staff at Villa Esperanza, a facility that provides low-income apartment units and services for persons with disabilities.

Findings
Most focus group attendees and survey respondents support the provision of more assistance, financial or otherwise, to the extremely low-income population in finding housing.

City Overview
Much of the fair housing analysis is based upon census data provided at the census tract level.

Gilroy has a total of 11 census tracts. Figure 7 displays the census tracts in the City and the RHNA sites within those census tracts; however, several of the census tracts are not solely in Gilroy and have large portions in neighboring jurisdictions. As a result, demographic information for these census tracts reflects neighboring communities, as well as Gilroy. The west tracts have more open space and agriculture, so the population as a whole is generally more concentrated in the east, which may skew data perception. Several of the tracts include more land and more households in adjacent jurisdictions other than in Gilroy. These external households are included in the census data, which may affect the displayed maps.

Until 2018, a large portion of the Downtown Specific Plan area and several properties west of downtown were designated as a Neighborhood Revitalization Strategy Area by the US Department of Housing and Urban Development (HUD). A number of capital improvements, youth activities, neighborhood beautification projects, and other downtown revitalization efforts were pursued during this time.15 The downtown area in Gilroy is also identified as a Priority Development Area in the Association of Bay Area Governments’ Plan Bay Area 2050.

The AFFH section also considers the effects that the selected RHNA sites may have on fair housing. Selected RHNA sites are primarily in the eastern portion of the City, while pipeline projects are more evenly distributed throughout Gilroy. Pipeline projects are defined as pending projects (proposed, entitled, permits issued) that had not received certificates of occupancy as of June 30, 2022. The sites inventory includes a mix of vacant and non-vacant sites, selected for their access to resources, suitability for multifamily housing, and proximity to upcoming plans for community revitalization, including the planned high speed rail station, parking management plan, Downtown Specific Plan update, and currently funded place-based improvements. Additionally, non-vacant sites were selected based on their likelihood to develop during the 6th Cycle and the extent to which the existing use may preclude development.

The City is including Program F - 3 for place-based improvements in the downtown area. The City is also including programs to encourage ADU development in the western portion of the 15 Neighborhood Revitalization Strategy Area Renewal Request for 2013-2018. https://www.cityofgilroy.org/DocumentCenter/View/9045/NRSA-Strategy-Renewal-Request-for-2013-2018

9.2 p. 459 of 1163
Affirmatively Furthering Fair Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 99
City to promote housing mobility and increased housing opportunities (Program A - 6).16 To encourage a variety of housing types throughout the City, a program to create a ministerial permit process for triplexes and quadplexes that meet objective design standards is included (Program A - 10). SB 9 facilitates the creation of up to four housing units, comprised of a duplex with an ADU and a junior ADU or two primary units plus an ADU and a junior ADU.

Program A - 10 provides more flexibility than SB 9 by allowing triplexes and fourplexes as an alternative design to a traditional duplex with an ADU or a junior ADU. This program will also encourage the development of middle-income housing throughout the City, including highresource areas primarily comprised of detached single-family residences.

Figure 7: Census Tracts and RHNA Sites, 2022
Source: HCD AFFH Data Viewer
As noted in Table 47. Gilroy is split between the Low, Moderate, and High Opportunity categories, with the intersecting tracts in the west being considered a Racially Concentrated Area of Affluence (RCAA) and the tracts in the east containing a Racially and Ethnically 16 ADUs are calculated on a citywide basis and are not represented on the sites maps

9.2 p. 460 of 1163
Affirmatively Furthering Fair Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 100
Concentrated Area of Poverty (R/ECAP)
17 . These are relative rankings based on composites of the environmental, economic, and education scores. Of the 2,053 RHNA sites, including pipeline projects and opportunity sites, 23 percent of units are in Low Resource tracts, 71 percent of units are in Moderate Resource tracts, and 6 percent of units are in High Resource tracts.

Eight (8) of the eleven census tracts that intersect Gilroy have the majority of their area located inside City limits, Of the eight (8) tracts mostly in the City, 41 percent of units are in the tract with the second highest median income. Both High Resource tracts, 5125.03 and 5122, have a large portion of their land area as rural and undeveloped. Due to the large quantities of open space in these tracts, they have disproportionately high environmental TCAC scores (see the California Tax Credit Allocation Committee (TCAC) section for more information). Tract 5122 has an environmental resource category of 91, while the education resource category is scored at 27. The disproportionately high environmental score of this majority rural, open space, steep tract skews the overall opportunity category towards High Resource. This indicates that disparities between the developable area that is actually within the City bounds and the Low and Moderate Resource opportunity areas of the City may be smaller than indicated. In fact, educational opportunity is significantly higher in the R/ECAP, with an index of 40.

Less than 25 percent of the RHNA units are in the R/ECAP. The majority of the lower-income pipeline RHNA sites are in higher opportunity areas outside of the R/ECAP. It is unlikely that the location of proposed RHNA opportunity sites will exacerbate any fair housing conditions.

The City encourages development and redevelopment in the older Downtown R/ECAP, as this is an efficient area with transit, employment, and services. These tracts are also where participants of the focus groups and local housing service providers, specifically advocated for new housing. The High Resource areas of Gilroy in the northwestern tracts are newly developed, single-family, steep and hilly, and not likely to develop or redevelop. This area is the most distant from transit, employment, and services and would not likely score well for affordable housing financing. Despite mapped disparities in opportunity indices, lower-income residents have greater access to job and transit opportunities in the lower resource areas.

The City is including a number of programs to increase housing types and opportunities in higher resource areas of the City. These efforts go beyond sites that are included on the Opportunity Site List and help improve housing choice and mobility, by providing opportunities to increase the number and type of dwelling units in lower density residential zones. Program A - 10 will encourage the development of missing middle housing throughout the City, including high-resource areas primarily comprising detached singlefamily residences. Through Program A - 10, the City will allow triplexes and fourplexes on corner lots in the R1 and R2 zones with a minimum lot size of 6,000 square feet. This includes approximately 1,106 parcels as shown in Figure 33. SB 9 facilitates the creation of up to four 17 HUD defines R/ECAP as areas where the percentage of the population that is non-White is over 50 percent and the percentage of households with incomes below the poverty line is over 40 percent. Alternatively, a neighborhood can be a R/ECAP if it has a poverty rate that exceeds 40 percent or is three or more times the average tract poverty rate for the metropolitan/micropolitan area, whichever threshold is lower.

9.2 p. 461 of 1163
Affirmatively Furthering Fair Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 101
housing units, comprised of a duplex with an ADU and a junior ADU or two primary units plus an ADU and a junior ADU. Program A - 10 provides more flexibility than SB 9, by allowing triplexes and fourplexes as an alternative design to a traditional duplex with an ADU or a junior ADU. Program A - 10 will also encourage the development of middle-income housing throughout the City, including high-resource areas primarily comprising detached singlefamily residences. Program G - 5 includes the creation of informational and promotional pamphlets regarding opportunities to develop duplexes, triplexes, and quadplexes in the City.

The pamphlets will be provided online, at City Hall, and at informational booths where housing resources are provided. Program A - 6 includes targeted ADU outreach to the single-family neighborhoods.

In the R-1 zone, there are approximately 1,067 parcels with single-family homes on corner lots greater than 6,000 square feet. Allowing triplexes and quadplexes by right on these corner lots could allow for an additional 3,201 units. These units are primarily in the moderate and high resource areas of the City and thus would allow for increased capacity for housing and increased flexibility for middle-income housing in the R1 zone. Of these 1,067 parcels, 361 are in the high resource TCAC category, 664 are in the moderate resource category, and 42 are in the low resource category. Program A - 10 would also apply to approximately 39 corner lots with single-family homes in the R2 zone. Of these 39 parcels, 22 are in the moderate resource category, and 17 are in the low resource category.

9.2 p. 462 of 1163
102
Table 47: Comparison of Fair Housing with Respect to Location Census
Tract
RHNA
Units1
(% Total)
Total
Household
s
2 Total
Population
2 TCAC
Composite
Category
Median
Household
Income
% with a
Disability
% of
Children in
FHH
CalEnviroS
creen
Percentile
% NonWhiteR/ECAP
Present
Census Tracts Mostly Inside of Gilroy
5125.03 116
(6%)
2,567 9,452 High
Resource
$135,863 5.9% 8.2% 15.9 45.8
No
5125.05 211
(10%)
2,058 8,373 Moderate
Resource
$77,481 8.3% 16.2% 32.7 75.5
No
5125.06 156
(8%)
1,779 7,443 Moderate
Resource
$54,770 11.3% 26.1% 56.3 83.0
No
5125.08 19
(1%)
2,644 8,007 Moderate
Resource
$74,032 11.2% 15.6% 52.1 65.7
No
5125.09 216
(11%)
1,239 5,244 Moderate
Resource
$79,306 6.5% 5.8% 38.8 70.2
No
5125.1 846
(41%)
2,270 7,352 Moderate
Resource
$85,960 10.0% 25.4% 29.4 61.9
No
5126.03 376
(18%)
971 4,563 Low
Resource
$37,301 9.5% 30.9% 90.8 91.2
Yes
5126.04 112
(5%)
1,161 4,854 Low
Resource
$35,297 6.0% 23.6% 75.8 91.2
Yes
Census Tracts Mostly Outside of Gilroy
5126.02 0 805 2,377 Low
Resource
$64,375 13.0% 37.7% 78.0 58.1 No

9.2 p. 463 of 1163
Affirmatively Furthering Fair Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 103
Census
Tract
RHNA
Units1
(% Total)
Total
Household
s
2 Total
Population
2 TCAC
Composite
Category
Median
Household
Income
% with a
Disability
% of
Children in
FHH
CalEnviroS
creen
Percentile
% NonWhiteR/ECAP
Present
5124.01 0 1,427 4,782 Moderate
Resource
$107,599 13.1% 17.2% 42.4 55.2 No
5122 1 1,612 3,895 High
Resource
$124,130 6.1% 12.8% 13.4 33.8 No
Note:
1) Includes opportunity sites and pending projects.
2) Includes all households in the tract, including those not within the bounds of the City of Gilroy.

9.2 p. 464 of 1163
Affirmatively Furthering Fair Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 104
Fair Housing Enforcement and Outreach Capacity
Fair housing enforcement and outreach capacity refers to the ability of a locality and fair housing entities to disseminate information related to fair housing laws and rights and provide outreach and education to community members. Enforcement and outreach capacity also includes the ability to address compliance with fair housing laws, such as investigating complaints, obtaining remedies, and engaging in fair housing testing.

Project Sentinel provides fair housing counseling services for the City of Gilroy. The City publishes the availability of both tenant/landlord counseling and fair housing services via its website. In the fiscal years 2022-2023 and 2023-2024, the City of Gilroy allocated $80,000 in total funds to two Project Sentinel programs: Fair Housing and Landlord/Tenant Counseling and Dispute Resolution. The funds are provided through the Permanent Local Housing Allocation (PLHA) fund, which is administered by Santa Clara County’s Office of Supportive Housing.

Project Sentinel is a nonprofit organization that provides a variety of fair housing resources and services in Northern California, including resources for tenants, property managers, and service providers, dispute resolution, and housing counseling. Annually, Project Sentinel processes over 10,000 initial contacts; handles over 400 housing discrimination complaints and over 1,700 landlord tenant and community dispute cases; counsels over 750 homeowners; and provides monthly workshops on housing topics.

Local Data
On March 8, 2023, staff from Project Sentinel provided information for the Housing Element update related to fair housing activity in the City of Gilroy. Project Sentinel has received 256 calls on behalf of the City of Gilroy since 2017 and has managed 139 cases on behalf of the City since 2015. Over the approximately 7- to 8-year period, 32 cases cited different terms/conditions, 15 cited eviction, 46 cited reasonable accommodation or modifications/accessibility, 16 cited coercion or intimidation/harassment, and 20 cited a refusal to rent. The remaining cases cited either repairs not being completed, a hostile environment, or being falsely denied. As shown in Table 48, over 60 percent of the cases since 2015 (86 cases) were filed by residents in the extremely low income (0 to 30% AMI) category.

Residents from all age categories have filed cases, with no strong patterns identified (Table 49). Of the cases, seven (7) were filed by Black households, 109 were submitted by White households, two (2) were submitted by Native American households, and six (6) were submitted by other or multiple racial identifying households (Table 50).

9.2 p. 465 of 1163
Affirmatively Furthering Fair Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 105
Table 48: Dispute Cases by Income Category, 2015-2022
Income Category
of Complainant 2015 2016 2017 2018 2019 2020 2021 2022
0-30% 5 14 18 8 17 11 6 7
31-50% 3 1 1 3 3 - 2 -
51-80% 10 1 1 - 2 - - 2
80% + 3 1 4 - 1 - - 1
N/A - - - - 3 10 1 -
Totals 21 17 24 11 26 21 9 10
Source: Project Sentinel, 2023.

Table 49: Dispute Cases by Age, 2015-2022
Age of
Complainant 2015 2016 2017 2018 2019 2020 2021 2022
<30 3 1 5 2 3 2 1 1
30-40 9 5 4 4 2 6 1 2
41-50 4 3 5 1 4 - 1 4
51-60 2 1 4 - 2 1 3 3
61-70 - 4 3 4 7 1 1 -
71-80 1 1 2 - 2 - 1 -
>80 1 2 1 - - - - -
N/A 1 - - - 6 11 1 -
Totals 21 17 24 11 26 21 9 10
Source: Project Sentinel, 2023.

9.2 p. 466 of 1163
Affirmatively Furthering Fair Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 106
Table 50: Dispute Cases by Race, 2015- 2022
Race of
Complainant 2015 2016 2017 2018 2019 2020 2021 2022
White 21 15 19 10 19 9 6 10
Black - 1 3 - 1 1 1 -
Native American - 1 - - 1 - - -
Other/MultiRacial - - 2 1 2 - 1 -
N/A - - - - - 11 1 -
Totals 21 17 24 11 23 21 9 10
Source: Project Sentinel, 2023.

The City is including Program F - 1 to coordinate with Project Sentinel to conduct a workshop to inform residents of income protection and state rent control laws. Additionally, under Program F - 1, the City will continue to coordinate outreach efforts to inform landlords and tenants of recent change to state law. The City is including Program F - 2 to commit to work with the Fair Housing Provider to track number of households assisted in Gilroy annually.

Under Program G - 8, the City will develop a Housing Help Center webpage to provide a centralized resource for tenants and landlords to receive information on local laws, assistance to apply for rent relief, and legal aid. This webpage will consolidate existing information on the City’s website with additional information provided by local service providers to best serve the needs of the Gilroy community.

The Department of Housing and Urban Development’s Office of Fair Housing and Equal Opportunity (FHEO) enforces fair housing by investigating complaints of housing discrimination. Over the 7- to 8- period from 2013-2021, there were 15 fair housing inquiries filed with FHEO on behalf of the City of Gilroy. Three (3) inquiries referenced disability concerns, one (1) inquired on race, and the remaining 11 were found to have no identity-based inquiries. Of these inquiries, nine (9) were found to have no valid case of fair housing discrimination, five (5) failed to respond or continue further with the inquiry process, and one (1) resulted in other disposition. There are no outstanding lawsuits or complaints regarding fair housing in the City.

Integration and Segregation
Race and Ethnicity
Figure 8 shows the racial and ethnic majority by census tract in the City of Gilroy. As illustrated, the western half of the City has a slim (<10%) to sizeable (10%–50%) White majority, while the eastern half of the City has areas with sizeable (10%–50%) to predominant (> 50%) Hispanic majorities. The tracts with Hispanic majorities have larger low- to moderate-income populations and a higher quantity of female-headed households than the majority White

9.2 p. 467 of 1163
Affirmatively Furthering Fair Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 107
tracts. The City is including a program to increase Spanish language engagement in order to target outreach to the Hispanic population (Program G - 7). The area with the predominant Hispanic majority also contains a R/ECAP. HUD defines R/ECAP as areas where the percentage of the population that is non-White is over 50 percent and the percentage of households with incomes below the poverty line is over 40 percent. Alternatively, a neighborhood can be a R/ECAP if it has a poverty rate that exceeds 40 percent or is three or more times the average tract poverty rate for the metropolitan/micropolitan area, whichever threshold is lower.

Regionally, there is a common correlation between wealth and race, which may help explain the racial/income concentrations in the City. The City has a significantly larger Hispanic population (57.6 percent) in comparison to the County (25.1 percent). Gilroy has a much smaller Asian/Asian Pacific Islander (API) population (9 percent) compared to the County (37 percent), and a slightly smaller non-Hispanic White population (28 percent) compared to the County (32 percent).

Figure 8: Racial and Ethnic Majority, 2010
Source: HCD AFFH Data Viewer
As shown in Figure 9, there are no block groups in the City with a non-White population less than 41 percent. The area with the highest non-White percentage is also the area with the

9.2 p. 468 of 1163
Affirmatively Furthering Fair Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 108
R/ECAP. In the City, newer developed single-family housing is primarily available in the west, while the multifamily, more affordable housing opportunities are primarily available in the east of the City, where there is a larger non-White population. As of 2019, 72 percent of the City was non-White while 68 percent of the County was non-White, indicating that the overall distribution of the non-White population is similar between the City and the region as a whole.

Figure 9: Percentage of the Population that is Non-White, 2018 Source: HCD AFFH Data Viewer
Figure 10 compares the RHNA units with the percentage of the population that is non-White.

While many sites are in the downtown area, where there is a large non-White population, this area is where the City is targeting revitalization, and placed-based improvements, which includes plans for significant investment, further economic development, and a future high speed rail station.

The City is including Program F - 5, Displacement Prevention Policy, to ensure that existing residents are protected from displacement. Program F - 2 includes multilingual tenant counseling through a partnership with Project Sentinel. The City is also including programs to encourage development opportunities throughout the City, including Program G - 3 for ADU

9.2 p. 469 of 1163
Affirmatively Furthering Fair Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 109
outreach focused in the western portion of the City, Program A - 11 for adoption of an inclusionary housing policy, and Program A - 10 allowing triplexes and fourplexes that meet objective design standards to be approved ministerially on corner lots in the R1 and R2 zones.

SB 9 facilitates the creation of up to four housing units, comprised of a duplex with an ADU and a junior ADU or two primary units plus an ADU and a junior ADU. Program A - 10 provides more flexibility than SB 9 by allowing triplexes and fourplexes as an alternative design to a traditional duplex with an ADU or a junior ADU. Program A - 10 will also encourage the development of middle-income housing throughout the City, including high-resource areas primarily comprised of detached single-family residences. The City is also including a program to incentivize affordable ADU production, specifically focusing outreach to households in the western area of the City (Program A - 8).

Figure 10: Percent non-White Comparison of RHNA Units
Dissimilarity Index – Race and Ethnicity
Segregation is defined by the census as the spatial distributions of different groups among units in a metropolitan area.
18 Segregation can be quantified by using the dissimilarity index.

The dissimilarity index measures the distribution of two groups in a city and assigns a score 18 Measures of Residential Segregation. https://www.census.gov/topics/housing/housing-patterns/guidance/appendix-b.html 0%
5%
10%
15%
20%
25%
30%
35%
40%
40-60% 60-80% 80-100%
Percent of RHNA Units
Percent of the Population that is Non-White by Block Group Lower Moderate Above Moderate

9.2 p. 470 of 1163
Affirmatively Furthering Fair Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 110
between 1 and 100. The level of segregation is determined by assessing what percentage of residents of a census block would have to move for each block to have the exact same population of said group. A score of zero (0) reflects a fully integrated environment; a score of 100 (or 100%) reflects full segregation. Therefore, a higher dissimilarity index indicates higher concentrations of the indicated ethnic groups in areas of the City, when compared to the White population distribution. A lower dissimilarity index implies higher integration, and a more even distribution of each ethnicity when compared to the White population. The formula for this calculation is provided by the HCD AFFH Guidance Document.

The categories for the dissimilarity index on a scale of 1-100 are as follows:
• <30: Low Segregation
• 30 – 60: Moderate Segregation
• >60: High Segregation
Figure 11 provides the dissimilarity index values in Gilroy, indicating the level of segregation between White residents and residents who are non-White, Black, Hispanic, or Asian. In 2020, there was moderate segregation between the Hispanic and White populations and low segregation between the Black and White populations, and between the Asian and White populations. A moderate dissimilarity index of 35.41 in the figure below means that 35.41 percent of Gilroy’s Hispanic or White residents would need to move to a different census block to create balanced integration between Hispanic and White residents. Segregation at the City level is much lower than Santa Clara County as a whole.

Figure 11: Dissimilarity Index for Race
Source: HUD AFFH Data tool.
0 10
20 30
40 50
60 Non-White/White
Black/White
Hispanic/White
Asian/White
Non-White/White
Black/White
Hispanic/White
Asian/White
Gilroy San Jose-Sunnyvale-Santa Clara Region
1990 2000 2010 2020

9.2 p. 471 of 1163
Affirmatively Furthering Fair Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 111
Income
The dissimilarity index can also be used to calculate income segregation, using the same scale as above. The segregation between below-moderate and above-moderate income groups is moderate. Regionally in the Bay Area, segregation is also moderate.

Table 51: Dissimilarity Index for Income
2010 2015
Below 80% AMI
/ Above 80%
AMI
Below 50% AMI
/ Above 120%
AMI
Dissimilarity
Below 80% AMI
/ Above 80%
AMI
Dissimilarity
Below 50% AMI
/ Above 120%
AMI
Dissimilarity
Gilroy 31.5 46.2 41.6 53.3
Bay Area 28.7 36.6 27.4 35.1
Source: Association of Bay Area Governments AFFH Data Report.

As shown in Figure 12, the area with a large low-to-moderate income population is also the area with a predominant Hispanic majority, and largest non-White population. This area is also where the R/ECAP is located. There is a large low- to moderate-income population in the area with more multifamily housing. Income often correlates with housing type—i.e., large singlefamily areas generally have higher incomes. Compared to the region, Gilroy has a lower median income and a higher income disparity.

While a large percentage of the RHNA opportunity sites are in the area with the highest concentration of the low- to moderate-income population, this area also falls within downtown Gilroy, which provides residents with close access to transit, resources, and employment opportunities. The anticipated development of the future high-speed rail station is also expected to increase economic investment in the downtown. The Housing Element includes programs to help ensure redevelopment of nonresidential sites downtown and to minimize displacement. Programs include the creation of an inclusionary housing ordinance (Program A - 11), allowing 100% residential uses in the Downtown Expansion District (Program E - 12), multilingual tenant support in partnership with Project Sentinel (Program F - 2), and a displacement prevention policy (Program F - 5).

The City also has an affordable housing portfolio available to lower-income households, including ownership and rental units. The below market-rate units are administered by HouseKeys through Programs C - 1, C - 4, and C - 5, which include monitoring of units at risk of converting to market rate and resale/rent control on BMR units. There are over 400 units in the BMR program.

The City is including programs to encourage development opportunities in the western portion of the City that are not captured by the sites inventory. Programs include ADU tracking and monitoring (Program A - 6), adoption of an inclusionary housing policy (Program A - 11), allowing triplexes and fourplexes to be approved ministerially on corner lots in R1 and R2 zones (Program A - 10), and an incentives beyond density bonus state law policy (Program

9.2 p. 472 of 1163
Affirmatively Furthering Fair Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 112
A - 12). The City is also including a program to incentivize affordable ADU production, specifically focusing outreach to households in the western area of the City (Program A - 8), and a program to replace the ADU deed restriction requirement with an owner affidavit form that does not require recordation at the County, and increase the allowable ADU floor area from 1,000 square feet to 1,200 square feet (Program A - 15).

Figure 12: Low to Moderate Income Population and RHNA Sites, 2011-2015 Source: HCD AFFH Data Viewer
Figure 13 shows the percentage of RHNA units compared to the percent of each block group that is in the low- to moderate-income category. The lower- and moderate-income RHNA sites are proposed in the areas with a larger low- to moderate-income population to provide new housing opportunities without displacing current residents from their neighborhoods.

9.2 p. 473 of 1163
Affirmatively Furthering Fair Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 113
Figure 13: Low to Moderate Income Population Comparison of RHNA Units Figure 14 shows the number of households with income levels similar to the income ranges provided by the HCD Income Limits. The moderate-income category has the largest percentage of the population, while the very low-income category has the smallest population.

The remaining income categories have relatively comparable population sizes without extreme discrepancies.
0%
5%
10%
15%
20%
25%
30%
35%
40%
45%
0-25% 25-50% 50-75% 75-100%
Percent of RHNA Units
Percent of the Population that is Low to Moderate Income by Block Group Lower Moderate Above Moderate

9.2 p. 474 of 1163
Affirmatively Furthering Fair Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 114
Figure 14: Households per Income Level, 2021
Source: 2021 ACS Table B19001
According to US Census 2015-2019 American Community Survey estimates, the median household income for Gilroy was $101,616. This is about 18 percent lower than the Santa Clara County median household income of $124,055.

Figure 15 shows median household income by census block group. In Gilroy, the highest median household incomes are located in the western portion of the City, where there is more single-family zoning and open space. The lowest median incomes are in the central and eastern portions of the City, including downtown, which is the oldest area of the City.

The west tracts have more open space and agriculture, so the population as a whole is generally more concentrated in the east, which may skew data perception. Additionally, the block groups in the western region of Gilroy have the majority of their acreage outside of the City of Gilroy, making it likely that the small portion of tracts within the City are not primarily responsible for overall trends. Newer single-family development primarily occurs in the west and are often more expensive than older small homes in the downtown areas, which correlates with higher income households in these newer western areas. The data collected through Program A - 6 (ADU Tracking and Monitoring) will help inform the City’s efforts in Program A - 8 (Incentives for Affordable ADUs), to promote housing mobility and increased housing opportunities, including ADU production, in the western portion of the City. 3,392
2,218
3,672
4,174
3,567
0 500
1,000
1,500
2,000
2,500
3,000
3,500
4,000
4,500
≤ $49,999 $50,000 - $74,999 $75,000 - $124,999 $125,000 - $199,999 > $200,000

9.2 p. 475 of 1163
Affirmatively Furthering Fair Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 115
Figure 15: Median Household Income, 2019
Source: HCD AFFH Data Viewer
Figure 16 shows the change in the population under the federal poverty line by census tract from 2010–2014 to 2015–2019. Poverty is defined by incomes falling below the annually defined thresholds for family size by the Census. Poverty levels in the eastern area, where the downtown R/ECAP is located, decreased significantly over this period. From 2010 to 2014, 30- 40 percent of households in the eastern downtown R/ECAP area were living in poverty.

Between 2015 and 2019, the percentage decreased significantly, with less than 20 percent, and in some cases less than 10 percent, of residents in this area living in poverty. Similarly, the number of impoverished residents in southern Gilroy decreased between 2010 and 2019, with less than 10 percent of these residents currently living in poverty. The 2015–2019 map shows lower levels of poverty Citywide and increased geographic parity. The 2015–2019 map also shows that pipeline projects and proposed RHNA Opportunity sites are spread throughout the City with more pipeline projects in the west and proposed RHNA sites in the east. It is the intent of the City’s placed based improvements and revitalization efforts in the downtown R/ECAP area to further minimize poverty by providing safe affordable housing choices to residents living in this area.

9.2 p. 476 of 1163
Affirmatively Furthering Fair Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 116
Figure 16: Poverty Status, 2010-2014 and 2015-2019
Source: HCD AFFH Data Viewer
Figure 17 displays the distribution of housing choice vouchers in the City. The Santa Clara County Housing Authority (SCCHA) is the regional Public Housing Authority for the City of Gilroy and administers the Housing Choice Voucher (HCV) program (also known as Section 8). The HCV program is a 100 percent federally funded rental subsidy for low-income households living in privately owned rental units. The City does not own any public housing; however, the SCCHA owns and manages affordable housing units in Gilroy and throughout the County of Santa Clara. Santa Clara County owns the Gateway Senior Apartments, a 75‐unit affordable senior housing complex with approximately half of the units reserved for special needs seniors. Many of the seniors in this housing complex use housing choice vouchers. There is little housing choice voucher use in the west side of the City. The majority of housing choice voucher usage is in the R/ECAP, where there is more multifamily housing and rental apartments.

9.2 p. 477 of 1163
Affirmatively Furthering Fair Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 117
Figure 17: Housing Choice Vouchers
Source: HCD AFFH Data Viewer
Familial Status
Figure 18 shows the percentage of children that are living in female-headed households with no spouse by census tract. It also shows pipeline projects and proposed RHNA Opportunity sites. In 2019, 2,616 households, or 16.2 percent of the total households in Gilroy, were femaleheaded households, which is about 6 percent higher than in the County, at 10 percent. There is no tract with a significant concentration of children in female-headed households. As shown in Figure 19, RHNA pipeline and opportunity sites are distributed throughout the City and are not expected to impact fair housing concerns based on familial status. For example, 27.4 percent of the RHNA units are located in tracts where 0-20% of children are living in femaleheaded households with no spouse.

9.2 p. 478 of 1163
Affirmatively Furthering Fair Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 118
Figure 18: Children in Female-Headed Households and RHNA Sites Source: HCD AFFH Data Viewer

9.2 p. 479 of 1163
Affirmatively Furthering Fair Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 119
Figure 19: Female Headed Households Comparison of RHNA Units As shown in Figure 20, areas with high concentrations of children in married-couple households are also areas with large numbers of single-family households. In Gilroy, 30.5 percent of households are married-couple households with children present, compared to

26.6 percent countywide. RHNA pipeline and opportunity sites are distributed throughout the City and are not expected to impact fair housing concerns based on familial status. 0%
10%
20%
30%
40%
50%
60%
70%
80%
0-20% 20-40%
Percent of RHNA Units
Percent of Children in Female-Headed Households by Tract Lower Moderate Above Moderate

9.2 p. 480 of 1163
Affirmatively Furthering Fair Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 120
Figure 20: Children in Married-Couple Households
Source: HCD AFFH Data Viewer
Persons with Disabilities
The US Census Bureau provides information on the number of persons with disabilities of varying types and degrees. According to the US Census Bureau, a person is considered to have a disability if they have difficulty performing certain functions or difficulty with certain social roles. Affordability of appropriate housing and access, both within the home and to/from the home site, are the primary challenges for persons with disabilities. Access often requires specially designed dwelling units. Additionally, housing locations near public facilities and public transit are important for these special needs group. The 2019 American Community Survey estimates that 8 percent of Gilroy, 8 percent of Santa Clara County, and 10 percent of the Bay Area region have a disability.19
The types of disabilities included in the Census are:
19 US Census Bureau, American Community Survey 5-year Data (2015–2019), Table B18101

9.2 p. 481 of 1163
Affirmatively Furthering Fair Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 121
• Hearing difficulty: deaf or has serious difficulty hearing • Vision difficulty: blind or has serious difficulty seeing even with glasses • Cognitive difficulty: has serious difficulty concentrating, remembering, or making decisions
• Ambulatory difficulty: has serious difficulty walking or climbing stairs • Self-care difficulty: has difficulty dressing or bathing • Independent living difficulty: has difficulty doing errands alone, such as visiting a doctor’s office or shopping
Figure 21 shows an estimate of the number of Gilroy residents with disabilities by type of disability and age group. The most prevalent types of disability are cognitive, ambulatory, and independent living difficulty. Note that individuals may have more than one type of disability.

Ambulatory issues are the highest reported disability countywide. A large population with walking difficulty creates a need for single-story housing, elevators, transit access, wheelchair access, larger homes for live-in help, and proximity to health facilities.

Figure 21: Disability Characteristics, Gilroy, 2019
Source: 2019 ACS B18108.

Figure 22 shows that the disabled population is relatively evenly distributed throughout Gilroy.

There were no significant changes in location or concentration of those with a disability from 2010–2014 to 2015–2019. There is no area of the City with an extreme concentration of persons with disabilities. The area in the east of the City with a larger low- to moderate-income population and larger non-White population does have a slightly larger disabled population, though the difference is minimal. Furthermore, the west tracts have more open space and 0 500
1,000
1,500
2,000
2,500
Hearing
Difficulty
Vision
Difficulty
Cognitive
Difficulty
Ambulatory
Difficulty
Self Care
Difficulty
Independent
Living
Difficulty
Population by Age
Disability Type
<18 years old 18-64 years old ≥65 years old

9.2 p. 482 of 1163
Affirmatively Furthering Fair Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 122
agriculture, so the population is generally more concentrated in the east, which may skew data perception. A larger or more concentrated disabled population may indicate a greater need for access to health care. However, health care facilities are also more concentrated in the areas to the east.

Figure 22 also shows pipeline and proposed RHNA Opportunity sites in the context of persons with a disability. As shown in Figure 23, the RHNA sites are relatively evenly distributed between areas with higher and lower concentrations of the disabled population. For example,

50.3 percent of the RHNA units are located in the area where 0-10% of the population has a disability. As such, the sites are not expected to cause fair housing concerns as they relate to residents with a disability.

Figure 22: Population with a Disability, 2010-2014 and 2015-2019 Source: HCD AFFH Data Viewer

9.2 p. 483 of 1163
Affirmatively Furthering Fair Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 123
Figure 23: Population with a Disability Comparison of RHNA Units Local Data
On January 24, 2023, in collaboration with Housing Choices, the City held a virtual meeting with intellectually and developmentally disabled (I/DD) stakeholders (primarily parents of I/DD children and I/DD adults), with representatives from Housing Choices and the San Andreas Regional Center in attendance.

I/DD participants expressed a need for extremely low-income housing since I/DD individuals generally rely on social security income. The City is including Programs A - 6, A - 7, and A - 8 to promote the construction of and incentivize the affordability of ADUs. Affordable ADUs provide I/DD individuals and their caregivers an alternative housing supply. Program A - 11 (inclusionary housing policy) and Program A - 12 (incentives beyond Density Bonus state law) will help facilitate the production of extremely low-income households and housing mobility for the I/DD community in higher opportunity areas. The City is also including Program E - 11 to prioritize funds to assist special needs households, such as persons with disabilities.

I/DD participants also expressed a need for project-based vouchers. The City is including Programs A - 8 and D – 3, which include providing financial assistance for homeowners who build ADUs with an affordability restriction or commitment to offering project-based vouchers. 0%
10%
20%
30%
40%
50%
60%
0-10% 10-20%
Percent of RHNA Units
Percent of the Population with a Disability by Tract
Lower Moderate Above Moderate

9.2 p. 484 of 1163
Affirmatively Furthering Fair Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 124
The City will notify interested residents and provide technical assistance to residents who need help applying to the Santa Clara County Housing Authority (SCCHA) voucher program.

Another identified need was housing and services for both independent living and supportive living skills. For many in need of independent living assistance, ADUs may serve as a caregiver unit. The City is including Program A - 7 to develop an ADU program that includes pre-designed “model” plans for ADUs that meet zoning, building, and fire codes. This will decrease the cost of ADU construction for potential caregiver units. Additionally, per Program E - 10, the City will evaluate and revise its reasonable accommodation standards and procedures as they pertain to potential constraints to accommodating persons with disabilities.

Findings
Overall, the City of Gilroy has higher concentrations of non-White and low- to moderateincome residents in the eastern portion of the City. This area saw a reduction over time in households under the federal poverty level, from 30-40 percent in 2010-2014 to either 10-20 percent or less than 10 percent in 2015-2019. This area is also where housing choice voucher use primarily occurs. Many of the proposed RHNA Opportunity sites are located in this area, which includes placed-based improvements in the Downtown Specific Plan area, including the future high-speed rail station. The selected RHNA sites are not anticipated to cause displacement or worsen patterns of segregation. The City is including programs to address needs in the downtown. These programs include an inclusionary housing policy (A - 11), multilingual tenant outreach in partnership with Project Sentinel (F - 1), a displacement prevention ordinance (F - 5), and place-based improvements in this area (F - 3).

Much of the western portion of Gilroy was developed relatively recently, leaving few vacant or underdeveloped sites that would likely be redeveloped during the 2023-2031 eight-year planning cycle. Furthermore, most of the remaining undeveloped parcels on the west side do not meet the size requirements for lower-income units. However, the City is including programs to encourage development opportunities in the western portion of the City, including an ADU tracking and monitoring (Program A - 6), adoption of an inclusionary housing policy (A - 11) to provide integrated and affordable housing, and allowing triplexes and fourplexes meeting objective design standards to be approved ministerially on corner lots in the R1 and R2 zones (Program A - 10). The City is also including a program to incentivize affordable ADU production, specifically focusing outreach to households in the western area of the City (Program A - 8).

Racially and Ethnically Concentrated Areas of Poverty and Affluence R/ECAPs
HUD defines R/ECAPs as areas where the percentage of the population that is non-White is over 50 percent and the percentage of households with incomes below the poverty line is over 40 percent. Alternatively, a neighborhood can be a R/ECAP if it has a poverty rate that exceeds 40 percent or is three or more times the average tract poverty rate for the metropolitan/micropolitan area, whichever threshold is lower.

9.2 p. 485 of 1163
Affirmatively Furthering Fair Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 125
Gilroy has a R/ECAP in Census Tracts 5126.03 and 5126.04. The tracts are shown in Figure 25 along with the proposed RHNA sites by their income levels. The tracts include the Downtown Specific Plan area and the future high-speed rail station, which will increase access to transit options and employment centers for potential residents. Existing and proposed transit bring the opportunity for transit-oriented development to the R/ECAP area. The downtown area has excellent proximity to commercial and employment resources and opportunities. Additionally, placing new housing sites in this area allows lower-income residents to stay in their neighborhood and take advantage of new, high-quality housing with new amenities. The location of RHNA sites in the R/ECAP will not exacerbate or create any additional R/ECAPs.

Figure 26 compares the percent of RHNA units within the R/ECAP area by their income levels, illustrating that the majority of the RHNA units are located in non-R/ECAP areas. About 24.7 percent of units from pipeline projects and potential RHNA Opportunity sites are proposed in the R/ECAP. Less than 30 percent of lower-income units are in the R/ECAP. This area is also designated for higher density housing options in a smart growth pattern with access to transit, employment, and service uses and facilities. Furthermore, planning for more affordable units in this area will help minimize displacement of existing residents when older properties are redeveloped.

Less than 25 percent of the RHNA units are in the R/ECAP. The City encourages development and redevelopment in the older downtown R/ECAP, as this is an efficient area with transit, employment, and services. These tracts are also where participants of the focus groups and local housing service providers specifically advocated for new housing. The High Resource areas of Gilroy in the northwestern tracts are newly developed, single-family, steep and hilly, and less likely to develop or redevelop. This area is the most distant from transit, employment, and services and would likely not score well for affordable housing financing. Despite mapped disparities in opportunity indices, lower-income residents have greater access to job and transit opportunities in the lower resource area. Placed based improvements planned and currently financed for this area and other Programs, efforts, and opportunities described below will improve conditions rather than exacerbate existing conditions.

As a part of the 2040 General Plan update, the City adopted an Environmental Justice Element focused on the eastern portion of the City, including the R/ECAP. The Environmental Justice Element includes programs to improve the quality of life in the R/ECAP.

The two census tracts that make up the R/ECAP are also qualified Opportunity Zones as designated by the Tax Cuts and Jobs Act of 2017. Opportunity Zones are designated census tracts where new investments may be eligible for preferential tax treatment. The Opportunity Zones designator helps spur economic investment by providing tax incentives that defer or eliminate federal taxes through a temporary deferral, step-up in basis, or permanent exclusion. These census tracts are also qualified census tracts in the New Market Tax Credit program, which incentivizes community development and economic growth by using tax credits.

The City is including multiple programs to ensure that the sites in the R/ECAP improve conditions rather than exacerbate existing conditions. These include place-based

9.2 p. 486 of 1163
Affirmatively Furthering Fair Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 126
improvements (Program F - 3), a displacement prevention policy (Program F - 5), increased outreach in downtown areas (Program G - 4), and fair housing support through partnerships with Project Sentinel (Programs F - 1 and F - 2).

Place-based improvements in 2023 include the $3.9 million grant through the California Department of Transportation’s Clean California Local Grant Program for the Historic Downtown in Gilroy. Improvements anticipated from the grant include:
• Gourmet Alley between 4th and 7th: pedestrian and bicycle-friendly markings, new signage, new benches, new trees, repaving of alley in decorative stamped asphalt, new trash enclosures and trash receptacles, additional lighting. • Railroad Street between 4th and 7th: pedestrian and bicycle-friendly markings, new trash receptacles for pedestrians, new signage, additional lighting, new benches, new fencing.
• Clean Up and Media Campaign: cleanup days for alleys, anti-littering campaign.

Other place-based improvements in the Downtown include:
• The Downtown Façade Improvement and Blight Removal Program, which includes providing a 50%/50% matching grant of up to $5,000 to property owners and tenants within a portion of Downtown to assist with exterior improvements to the façade, or face, of the building. These improvements may include new paint, building surface treatment, awnings, windows, doors, and other improvements that can help improve the exterior of a building. The maximum grant award amount may be increased to $10,000 if the project includes blight removal activities approved by the City.
• The Downtown Building and Planning Permit Fee Reduction Policy. This includes a 50% rebate of up to $5,000 for all City-related building and planning fees. This is available to any downtown business or property owner that pulls a permit for buildings along Monterey Road between First and Tenth Streets.

As shown in Figure 24, the City is using CDBG funding to improve the quality of life, infrastructure, neighborhood conditions, and ADA improvements throughout the City, including in the R/ECAP. Pavement rehabilitation is being targeted at:
• Hanna Street from Welburn Avenue to its northern terminus • El Toro Drive from Hanna Street to La Coche Way
• Glenwood Drive from Welburn Avenue to El Cerrito Way
• La Paloma Way from Wren Avenue to Welburn Avenue
Additionally, curb ramps are being installed at the following street corners:
• La Paloma Way / Chiesa Drive
• Welburn Avenue/ Carmel Street
• El Cerrito Way / Glenwood Drive
• Welburn Avenue / Glenwood Drive

9.2 p. 487 of 1163
Affirmatively Furthering Fair Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 127
• El Toro Drive / Hanna Street
• El Toro Drive / La Coche Way
• Hanna Street / Welburn Avenue
• Hanna Street / Sherwood Drive
• Hanna Street / Arnold Drive
Figure 24: Infrastructure Improvements

9.2 p. 488 of 1163
Affirmatively Furthering Fair Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 128
Local Data
In March 2023, the City’s code enforcement officers noted that improvements to sidewalks are being made throughout the City, without an area of concentration. The code enforcement officers also noted that community amenities such as health clinics and hospitals are concentrated in the eastern areas of the City, making these resources accessible to those in the R/ECAP area. They also noted that transit routes are more accessible on the east side, where the R/ECAP is located, and is only minimally accessible in the higher resource western areas of the City. Grocery stores are well distributed throughout the City, including the eastern R/ECAP area.

Figure 25: R/ECAPs in the City and Vicinity
Source: HCD AFFH Data Viewer
As shown in Figure 26, the majority of the RHNA units are located in non-R/ECAP areas. The City is including multiple programs to ensure that the units that are included in the R/ECAP improve conditions rather than exacerbate existing conditions.

9.2 p. 489 of 1163
Affirmatively Furthering Fair Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 129
Figure 26: Presence of a R/ECAP Comparison of RHNA Units Racially Concentrated Areas of Affluence
HUD defines RCAAs as areas where the percentage of the population in a tract that is White is over 1.25 times the average percentage of the population that is White in the given Council of Governments (COG) region and median income is 1.5 times higher than the COG or State AMI, whichever is lower.

The City of Gilroy has an RCAA area along the western portions of the City. The west tracts have more open space and agriculture, so the population as a whole is generally more concentrated in the east, which may skew data perception. Additionally, these census tracts have the majority of their acreage outside of the City of Gilroy, making it likely that the small portion of tracts within the City are not primarily responsible for this overall designation. However, newer single-family development primarily occurs in these areas. Newer large homes are often more expensive than older small homes in the downtown areas, which correlates with higher income households in these newer areas. The data collected through Program A - 6 (ADU Tracking and Monitoring) will help inform the City’s efforts in Program A - 8 (Incentives for Affordable ADUs), to promote housing mobility and increased housing opportunities including ADU development in the western portion of the City.
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
Not a R/ECAP R/ECAP
Percent of RHNA Units
Presence of a R/ECAP by Tract
Lower Moderate Above Moderate

9.2 p. 490 of 1163
Affirmatively Furthering Fair Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 130
Figure 27: RCAAs Vicinity and RHNA Sites
Source: HCD AFFH Data Viewer
Disparities in Access to Opportunities
California Tax Credit Allocation Committee (TCAC)
One tool that can be used to analyze disparities in access to opportunities is the California Tax Credit Allocation Committee’s (TCAC) Opportunity Area scores. These were prepared by a task force commissioned by the TCAC and HCD to identify areas statewide whose economic, educational, and environmental characteristics support positive outcomes for low-income families. The map is updated annually. Opportunity maps are made for three domains:
economic, environmental, and education. Each map uses categorical indicators to determine its individual score. A composite score and resource designation combining all three designations is then assigned to each block group.

To determine the final resource category, the top 20 percent of overall scores in a county are labeled as highest resource and the next 20 percent of scores are labeled as High Resource.

Then, any area that is considered segregated and that has at least 30 percent of the population

9.2 p. 491 of 1163
Affirmatively Furthering Fair Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 131
living below the federal poverty line is labeled as an area of High Segregation and Poverty. Any remaining uncategorized areas in the County are evenly divided between Moderate Resource and Low Resource areas. The rationale and metric for each indicator is described in more detail in current guidance documents for the California TCAC program. 20 Additional information
regarding these indicators in Gilroy are provided on the following pages.

Economic Indicators
Economic indicators include poverty, adult education, employment, job proximity, and median home value. The scores for Gilroy are shown in Figure 28. Gilroy has more positive economic scores in the west, and less positive scores in the eastern parts of the City. The less positive scoring area includes the R/ECAP, while the more positive scoring area contains single-family homes. The more positive scoring area also has some open space, which may slightly skew results. The City is located far away from major regional job centers. For this reason, the City also trends lower in score when compared to the region as a whole. 20 https://www.treasurer.ca.gov/ctcac/opportunity/2022/2022-hcd-methodology.pdf

9.2 p. 492 of 1163
Affirmatively Furthering Fair Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 132
Figure 28: TCAC Economic Score, 2021
Source: HCD AFFH Data Viewer
Education Indicators
Education indicators include math and reading proficiencies of fourth graders, high school graduation rates, and the student poverty rate. The entirety of Gilroy is served by the Gilroy Unified School District, which includes 11 elementary schools, 6 middle schools, and 6 high schools. According to Great Schools, 31 percent of schools in the district are rated below average, 44 percent are rated average, and 25 percent are rated above average.21 The Gilroy Unified School District has a Migrant Education Program which aims to ensure that all migrant students experience a high-quality education. This program includes actions to ensure that migrant children who move among the states are not penalized by disparities among the states in curriculum, help students overcome language barriers, and more.22 21 Great Schools, Gilroy Unified School District Summary. https://www.greatschools.org/california/gilroy/gilroy-unified-schooldistrict/#summary_rating 22 Migrant Education Program. https://www.gilroyunified.org/departments/educational-services/migrant-education

9.2 p. 493 of 1163
Affirmatively Furthering Fair Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 133
As shown in Figure 29, most of the City has less positive education outcome scores, with the northmost areas being positive. Additionally, the above average poverty rates in the City have a negative effect on TCAC educational scores, as poverty rates are included in this calculation.

Figure 29: TCAC Education Score
Source: HCD AFFH Data Viewer
Environmental Indicators
The environmental domain utilizes CalEnviroScreen (CES) 3.023 pollution indicators and values (see below for more discussion on CES). As shown in Figure 30, the scores vary throughout the City, with environmental outcomes becoming less positive as the tracts move eastward. The tracts bisected by the 101 Highway have lower outcomes, potentially due to pollution from freeway proximity. Pesticides, hazardous waste, solid waste, and impaired water are the highest scoring pollutants in the area, which may be contributions from the large agriculture industry in the City.
23 Note that the 2021 TCAC environmental score relies on CES 3.0, rather than the updated CES 4.0.

9.2 p. 494 of 1163
Affirmatively Furthering Fair Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 134
Figure 30: TCAC Environmental Score
Source: HCD AFFH Data Viewer
TCAC Composite Score
Figure 31 displays the 2022 TCAC composite score for the City. The vast majority of the City is in the moderate or low resource area. A corner of the City is a part of a large census tract that is high resource. The portions of this tract in the City contain mostly hillside open space and the Gilroy Gardens Family Theme Park, along with two single-family neighborhoods. A large portion of the population in the census tract lives outside of the City.

The downtown area has access to regional transit, employment opportunities, and social resources. Furthermore, through the 2040 General Plan and the Downtown Specific Plan, the City is focusing growth and economic development to revitalize the downtown area.

Investments in the area, including the future construction of a high-speed rail station are expected to increase access to opportunity and increase resources in the low resource area of the City. As such, the majority of RHNA opportunity sites are located in the downtown, which is currently considered a low resource area.

9.2 p. 495 of 1163
Affirmatively Furthering Fair Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 135
Place-based improvements in the downtown area includes the $3.9 million grant through the California Department of Transportation’s Clean California Local Grant Program for the Historic Downtown in Gilroy. Improvements anticipated from the grant include:
• Gourmet Alley between 4th and 7th: pedestrian and bicycle-friendly markings, new signage, new benches, new trees, repaving of alley in decorative stamped asphalt, new trash enclosures and trash receptacles, additional lighting. • Railroad Street between 4th and 7th: pedestrian and bicycle-friendly markings, new trash receptacles for pedestrians, new signage, additional lighting, new benches, new fencing.
• Clean Up and Media Campaign: cleanup days for alleys, anti-littering campaign.

Other place-based improvements in the Downtown include:
• The Downtown Façade Improvement and Blight Removal Program, which includes providing a 50%/50% matching grant of up to $5,000 to property owners and tenants within a portion of Downtown to assist with exterior improvements to the façade, or face, of the building. These improvements may include new paint, building surface treatment, awnings, windows, doors, and other improvements that can help improve the exterior of a building. The maximum grant award amount may be increased to $10,000 if the project includes blight removal activities, approved by the City.
• The Downtown Building and Planning Permit Fee Reduction Policy. This includes a 50% rebate of up to $5,000 for all City-related building and planning fees. This is available to any downtown business or property owner that pulls a permit for buildings along Monterey Road between First and Tenth Streets.

Many of the pipeline projects, including low- and moderate-income units, are located in the moderate resource areas of the City. The City is also including programs to encourage development in the Moderate Resource area of the City. Programs include targeted ADU outreach to the single-family neighborhoods (Program A - 6), and ministerial approval of triplexes and fourplexes on corner lots in the R1 and R2 zones throughout the City (Program A - 10). The City is also adopting an inclusionary housing ordinance (Program A - 11), a program to develop incentives beyond density bonus state law (Program A - 12), and a program to allow flexibility for the non-residential portion of mixed-use projects that accommodate extremely low-income and Special Needs Households in the First Street Corridor (Program E - 12).

9.2 p. 496 of 1163
Affirmatively Furthering Fair Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 136
Figure 31: TCAC Composite Score and RHNA Sites
Source: HCD AFFH Data Viewer
As shown in Figure 32, the majority of RHNA sites in the City are in low or moderate resource areas, with a large majority of above moderate pipeline projects in the moderate resource area. The area of the City with the highest resource category is about half open space. As the majority of the City is moderate resource, distributing RHNA sites of a variety of income in areas of these categories is unlikely to exacerbate any conditions or make any negative changes to the resource designation. Just over 30 percent of the City is low resource, and 24.7 percent of RHNA sites are located in the low resource area.

9.2 p. 497 of 1163
Affirmatively Furthering Fair Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 137
Figure 32: TCAC Designation Comparison of RHNA Units
Increasing Housing Opportunities in Higher Resource Areas The City is including several programs to increase housing types and opportunities in higher resource areas of the City. These efforts go beyond sites that are included on the Opportunity Site List and help improve housing choice and mobility, by providing opportunities to increase the number and type of dwelling units in lower density residential zones. Program A - 10 creates a ministerial approval process for triplexes and fourplexes on corner lots in the R1 and R2 zones to encourage the development of middle-income housing in high-resource areas primarily comprising detached single-family residences. Under Program E - 12, the City will allow flexibility for the non-residential portion of mixed-use projects that accommodate extremely low-income and Special Needs Households in the First Street Corridor. Program G - 5 includes the creation of informational and promotional pamphlets regarding opportunities to develop duplexes, triplexes, and quadplexes in the City. The pamphlets will be provided online, at City Hall, and at informational booths where housing resources are provided. Program A - 6 includes targeted ADU outreach to the single-family neighborhoods.

The missing middle policy would apply to approximately 1,106 total parcels in the R1 and R2 zones, as shown in Figure 33.In the R-1 zone, approximately 1,067 parcels have single-family homes on corner lots greater than 6,000 square feet. Allowing triplexes and quadplexes by right on these corner lots could allow for an additional 3,201 units. These units are primarily 0%
10%
20%
30%
40%
50%
60%
70%
80%
Low Resource Moderate Resource High Resource
Percent of RHNA Units
TCAC Composite Category by Census Tract
Lower Moderate Above Moderate

9.2 p. 498 of 1163
Affirmatively Furthering Fair Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 138
in the moderate and high resource areas of the City, so this would allow for increased capacity for housing in these zones and increased flexibility for missing middle housing in the R1 zone.

Of these 1,067 parcels, 361 are in the high resource TCAC category, 664 are in the moderate resource category, and 42 are in the low resource category. Program A - 10 would also apply to approximately 39 corner lots with single-family homes in the R2 zone. Of these 39 parcels, 22 are in the moderate resource category, and 17 are in the low resource category.

Figure 33: Existing Single-Family Homes on Corner Lots in R1 and R2 Zones Source: City of Gilroy
Access to Opportunities, Regional Comparisons
HUD has developed a series of indices for fair housing analysis to assist cities in identifying disparities in access to opportunity. The following indicators are scored on a scale from zero to 100.
24 24 HUD Affirmatively Furthering Fair Housing Data and Mapping Tool (AFFH-T) Data Documentation

9.2 p. 499 of 1163
Affirmatively Furthering Fair Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 139
• Low Poverty Index: The low poverty index captures poverty at the census tract level. The higher the score, the less exposure to poverty. • School Proficiency Index: The school proficiency index uses the performance of fourth-grade students on state exams to describe which areas have higher and lower performing schools. The higher the score, the higher the school system quality.
• Labor Market Index: The labor market index measures the relative intensity of labor market engagement and human capital. The index is calculated using employment levels, labor force participation, and education attainment. The higher the score, the higher the labor market participation in a neighborhood. • Transit Index: The transit index is based on estimates of transit trips taken by a three-person, single-parent family with income at 50 percent of the median income for renters for the region. The higher the index, the more likely that the residents use public transit.
• Low Transportation Cost Index: The low transportation cost index is calculated based on estimates for a three-person, single-parent family with income at 50 percent of the median income for renters for the region. More specifically, this index considers transportation costs as a percentage of income for this household type. The higher the index, the lower the cost of transportation. • Jobs Proximity Index: The jobs proximity index quantifies the accessibility of a given residential neighborhood as a function of its distance to all job locations within a region. Larger employment centers are more heavily weighted. The higher the index, the better access to employment opportunities. • Environmental Health Index: The environmental health index summarizes potential exposure to a variety of toxins that are harmful to human health. The higher the index, the less exposure to toxins.

As shown in Table 52, the most variation between different ethnicities in Gilroy is seen in the low poverty index, with the Hispanic population at 41.0 while the Asian and White populations score 60.1 and 57.7, respectively. The labor market index also shows variation, with the Hispanic population at 43.7, while the Asian population scores 59.0.

Compared to the wider Santa Clara County region as a whole, Gilroy scores lower in all index categories for all groups, indicating the City may have less access to resources when compared to the County as a whole. This means that Gilroy generally has more exposure to poverty and lower performing elementary school students. Gilroy scores are about the same as the region’s scores in the low transportation cost index. Gilroy also has a lower score in the environmental health index, indicating higher exposure to toxins than the region. Additionally, scores in job proximity are much lower than in the region, which is likely due to the City’s distance from tech industry jobs in the region, since the City is located in the southern portion of the County.

9.2 p. 500 of 1163
Affirmatively Furthering Fair Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 140
Table 52: Opportunity Indicators25
Low Poverty
Index
School
Proficiency
Index
Labor Market
Index
Transit Index
Low
Transportatio
n Cost Index
Jobs Proximity
Index
Environmental
Health Index
Gilroy
White 57.7 59.5 57.8 55.4 88.6 16.4 39.1
Black 54.1 62.5 54.8 55.1 88.8 16.9 39.1
Hispanic 41.0 58.4 43.7 55.3 90.8 21.1 38.9
Asian 60.1 62.4 59.0 55.3 88.3 15.8 39.0
Native American 45.1 59.4 46.8 54.9 90.4 20.9 39.0
Santa Clara County
White 81.1 81.9 82.2 68.1 91.2 52.8 58.8
Black 72.9 74.1 74.2 73.4 93.1 57.1 53.5
Hispanic 65.3 58.9 61.9 64.5 91.3 43.2 54.6
Asian 82.0 85.3 83.3 71.4 91.4 51.7 61.6
Native American 70.9 69.4 68.4 67.2 91.8 50.6 56.7
Source: Decennial Census; American Community Survey; Great Schools; Common Core of Data; School Attendance Boundary Information System; Local Affordability Index; Longitudinal Employer Household Dynamics; National Air Toxics Assessment Transportation
Access to adequate transportation and a variety of transit options can help illustrate disparities in access to opportunities. The Valley Transportation Authority (VTA) serves Santa Clara County, and there is also a commercial shuttle service available from the San Francisco and San Jose airports. Both public transportation and Highway 101 provide access from Gilroy to north Santa Clara County. The City is the southernmost stop on the Caltrain, which operates commute service to the Santa Clara Valley, San Francisco Peninsula, and San Francisco.

Amtrak’s Capitol Corridor line runs a thruway line from San José to Santa Barbara with a stop in Gilroy. The Monterey-Salinas Transit Line 55 stops in Gilroy and provides rush hour service between San José and Monterey. The San Benito County Express provides intercounty bus service from Gilroy to Hollister and San Juan Bautista.

Transit routes in Gilroy are shown in Figure 34. The VTA provides service to Gavilan College with bus lines along Luchessa Avenue and Santa Theresa Boulevard. The City also has a full network of bike lanes which connect all elementary, middle, and high schools in the area. 25 HUD Affirmatively Furthering Fair Housing. https://egis.hud.gov/affht/

9.2 p. 501 of 1163
Affirmatively Furthering Fair Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 141
A future high-speed rail station is proposed in downtown Gilroy at the existing Caltrain station on Monterey Street between 7th and 9th Streets. This station will be a transit hub for southern Santa Clara County and provide additional transit access for the community. Many RHNA sites have been chosen specifically for their proximity to existing and proposed transit.

The City will work with California High Speed Rail to develop a station area plan for the proposed station through Program A - 13. The existing transit and proposed high speed rail bring the opportunity to create transit-oriented development in the downtown area.

Figure 34: Transit Route Map
Source: Valley Transportation Authority, 2022

9.2 p. 502 of 1163
Affirmatively Furthering Fair Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 142
CalEnviroScreen 4.0
CES 4.0 is a tool that identifies communities in California that are disproportionately burdened by pollutants. Factors used to identify communities include ozone, particulate matter, drinking water contaminants, pesticide use, lead, diesel particulates, asthma rates, and linguistic isolation. A higher score indicates a higher effect of pollutants for the area.

The CES scores for the City of Gilroy in Figure 35 show that highest scores occur in the eastern half of the City, where the R/ECAP is located. CES scores are lower in the west. The areas bisected by the 101 Highway have less positive outcomes, potentially due to pollution from freeway proximity. Pesticides, hazardous waste, solid waste, and impaired water are the highest scoring pollutants in the area, which may be attributed to both permitted and unpermitted contributions from the large agriculture industry in the City. The lower density western portion of Gilroy contains steeply sloped areas and low-density development, and large open areas that significantly limit development, contributing to lower CES scores.

Figure 35: CES Percentile and RHNA Sites
Source: HCD AFFH Data Viewer.

9.2 p. 503 of 1163
Affirmatively Furthering Fair Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 143
As shown in Figure 36, RHNA pipeline and opportunity sites are distributed throughout both the lower and higher scoring areas of the City. For example, 41.2 percent of RHNA units are located in a tract in the 20-30% CalEnviroScreen Percentile. Although the Downtown Specific Plan area contains the highest CES scores in the City, RHNA sites in this area will provide potential residents with access to transit and employment resources, including a new future high speed rail station.

Figure 36: CalEnviroScreen Percentile Comparison of RHNA Units Findings
Overall, the City of Gilroy is largely of lower and moderate resource. The City has lower scores in opportunity metrics compared to the County as a whole. As such, many of the RHNA sites are located in a low-resource area (see Figure 31), which includes the Downtown Specific Plan area. The low resource area is also where housing choice voucher use primarily occurs. While pipeline projects are more evenly distributed throughout the City, proposed RHNA sites in the downtown area will provide potential residents the best access to services, employment resources, and transit, including the future high-speed rail station.

The City is including Program F - 3 to ensure that the RHNA site selection will improve access to place-based improvements in lower-resource areas, such as the $3.9 million grant in the historic downtown. The grant funding is for streetscape improvements, including new 0%
5%
10%
15%
20%
25%
30%
35%
40%
45%
10-20% 20-30% 30-40% 50-60% 70-80% 90-100%
Percent of RHNA Units
CalEnviroScreen Percentile by Tract
Lower Moderate Above Moderate

9.2 p. 504 of 1163
Affirmatively Furthering Fair Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 144
pedestrian and bicycle-friendly paving/markings, lighting, signage, benches, street trees, and waste receptacles. The Housing Element also includes a displacement prevention program (Program F - 5), tenant mediation program (Program F - 2), and targeted funding such as Housing Rehabilitation (Program C - 2), CDBG funding (Program D - 5), and the Permanent Local Housing Allocation (PLHA) Fund (Program D - 1).

Additionally, other programs in the Housing Element are intended to spur housing development in the moderate- and high-resource areas of the City. This includes a program that geographically targets ADU education (Program G - 3), development of an inclusionary housing policy (Program A - 11), development of a density bonus program that goes beyond state law (Program A - 12), and ministerial approval of triplexes and quadplexes that meet objective design standards (Program A - 10).

Disproportionate Housing Needs
Substandard Housing
Disproportionate housing needs are determined by finding trends in housing problems in the population by race, household size, or household age. A housing unit is considered substandard or having a housing problem if it has one or more of the following housing conditions:
• Housing unit lacks complete kitchen facilities
• Housing unit lacks complete plumbing facilities
• Household is cost burdened
• Housing unit is overcrowded
Large and elderly households are often more likely to experience housing problems. A large household is a household with three or more children, but is also often calculated as a household with five or more people. An elderly household is calculated as any household with a person over 62 years of age.

Black and Native American renters experience housing problems at the highest rate, around 75 percent, while only about 25 percent of both Asian and White owners experience housing problems. Rates of housing problems for Hispanic owners vary between the City (35.1%) and the County (41.8%), while rates of housing problems for Hispanic renters are relatively comparable between the City (68.1%) and the County (67.4%). In 2018, there was no Pacific Islander population in the City, which indicates why Figure 37 reads that 0 percent of that population experiences housing problems.

9.2 p. 505 of 1163
Affirmatively Furthering Fair Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 145
Figure 37: Housing Problems by Tenure and Race/Elderly/Housing Size Source: HUD CHAS Data, 2018
Cost burden is when a household spends more than 30 percent of its monthly income on housing costs such as rent, mortgage, or utilities. Large households have more costs to support more people, and may experience cost burden or a lack of excess funds to amend housing problems. Elderly households may be on a fixed income, which affects excess funds necessary for maintenance in an older home bought before retirement.

Figure 38: Cost Burden by Tenure and Race/Elderly/Housing Size Source: HUD CHAS Data, 2018
Overpayment by both owners and renters has decreased in Gilroy over time in most areas of the City. The area with the highest levels of overpayment is the same area that has low environmental scores and higher levels of poverty. Overpayment in the City occurs at a similar, though slightly higher level than in the County, with 38 percent of households experiencing a 0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
White Black Asian Nat Am Pac
Islander
Hispanic Elderly Large All
Owner-Occupied Renter-Occupied Santa Clara County
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
White Black Asian Nat Am Pac
Islander
Hispanic Elderly Large All
Owner-Occupied Renter-Occupied Santa Clara County

9.2 p. 506 of 1163
Affirmatively Furthering Fair Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 146
cost burden Citywide, compared to 34.2 percent in the County. In both cases, renters have higher rates of overpayment than owners.

Figure 39: Overpayment by Owners
Source: HCD AFFH Data Viewer
Figure 40: Overpayment by Renters
Source: HCD AFFH Data Viewer
Local Data
Per conversations with the City’s Code Enforcement officers in March 2023, the areas with housing conditions in potentially higher need of rehabilitation and replacement are the areas with the oldest housing stock in Gilroy. As shown in Figure 41, housing stock in the eastern portion of the City is generally older and there are more households experiencing overcrowding. The City is including multiple place-based programs to promote improvement in the eastern, older portions of the City, including place-based improvements (Program F - 3), a displacement prevention policy (Program F - 5), increased outreach in downtown areas

9.2 p. 507 of 1163
Affirmatively Furthering Fair Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 147
(Program G - 4), and fair housing support through partnerships with Project Sentinel (Programs F - 1 and F - 2). Code Enforcement officers also noted that the eastern or downtown areas of Gilroy have better access to transit than the newer neighborhoods in the west.

Figure 41: Year Structure Built
Source: County Assessor data and Michael Baker International Overcrowding
A household is considered overcrowded when there is more than one person per room, including living and dining rooms but excluding bathrooms and kitchens. Overcrowding can affect public facilities and services, reduce the quality of the physical environment, and create conditions that contribute to deterioration of the housing stock. Additionally, overcrowding can indicate that a community does not have an adequate supply of affordable housing and/or variety of suitable housing units to meet the needs of the community.

In Gilroy, areas with high concentrations of overcrowding are in areas with high levels of poverty and low economic opportunity, where the R/ECAP is located. Overcrowding is only slightly more prevalent in Gilroy (9.2%) than in the County (7.8%), as a whole. Overcrowding is more prevalent for renters than owners both in the City and regionwide.

9.2 p. 508 of 1163
Affirmatively Furthering Fair Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 148
Figure 42: Overcrowded Households
Source: HCD AFFH Data Viewer
Table 53 summarizes overcrowding in Gilroy by tenure. Approximately 1,482 households, roughly 9.2 percent of all households in Gilroy, were experiencing overcrowding in 2019. This included 347 owner-occupied households and 1,135 renter-occupied households. Instances of overcrowding vary by tenure, with renters experiencing higher levels of overcrowding than owners.

9.2 p. 509 of 1163
Affirmatively Furthering Fair Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 149
Table 53: Overcrowding, 2019
Source: HUD CHAS Data, 2018
Homelessness
Table 54 lists emergency shelters and transitional housing in and adjacent to Gilroy.

The Countywide services and shelter provider HomeFirst Services provides a 24/7 shelter for adults at the Gilroy shelter. The Gilroy shelter provides sleeping accommodations, meals, restrooms, showers, mobile laundry, and case management support services via South County Compassion Center staff. It has a capacity of serving 100 persons.

The Arturo Ochoa Migrant Center is used as an emergency shelter during the cold weather season from mid-December through mid-March. It provides 128 shelter beds and has the capacity to house 35 unhoused families with a dependent child under the age of 18. St.

Joseph’s Family Center manages the shelter and referral process. Walk-ins or families without a referral from a designated community partner are not accepted and 5-7 spots are reserved for Here4You call center hotline referrals. EAH Housing is contracted for day-to-day property management operations and site security.

According to conversations with service providers, if the weather is manageable, unhoused individuals express a strong reluctance to use the service. The service providers stress the need for a permanent emergency shelter as well as shelter or housing for single adults who do not exhibit mental illness or substance abuse disorders.

The City of Gilroy provides annual funds to homelessness prevention support and services through the PLHA. For FY 22-23 and FY 23-24: St. Joseph’s Family Center received $180,000 to provide emergency rental and utility assistance, as well as training and employment readiness to prepare individuals that are homeless or at risk of homelessness. Community Agency for Resources Advocacy and Services received $40,000 to provide rental and deposit assistance. South County Compassion Center received $80,000 to provide services to unhoused Gilroy residents and to connect them with services that can help them attain Jurisdiction Persons per
Room
Owners Renters Total
Overcrowded
Households
% of
Total
Overcrowded
Households
% of
Total
Overcrowded
Households
% of
Total
Gilroy

1.01 to 1.50 285 1.8% 665 4.1% 950 5.9%
>1.50 62 0.4% 470 2.9% 532 3.3%
Total
Overcrowded 347 2.2% 1,135 7.0% 1,482 9.2%
Santa Clara
County

1.01 to 1.50 7,526 1.2% 21,951 3.4% 29,477 4.6%
>1.50 2,340 0.4% 17,983 2.8% 20,323 3.2%
Total
Overcrowded 9,866 1.6% 39,934 6.2% 49,800 7.8%

9.2 p. 510 of 1163
Affirmatively Furthering Fair Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 150
permanent housing. Through its CDBG-CV funds, the City provided an additional $287,309 in support to Saint Joseph's Family Center's Rental Assistance program.

Table 54: Homeless Facilities in or Adjacent to Gilroy
Facility Name Type of Facility Target Population
Number of
Shelter Beds or
families served
Gilroy Shelter Emergency
Shelter Adults Only 100
Arturo Ochoa
Migrant
Center26
(adjacent to
Gilroy)
Cold Weather
Shelter Households with a dependent under 18 35 families La Isla Pacifica
Confidential
Emergency
Shelter
Women victims of intimate partner
abuse and their children under 16 years
old (16 and up, on a case-by-case basis)
14 Glenview, El
Invierno, and
Walnut
Transitional
Shelter Single Individuals 25
Source: City of Gilroy, County of Santa Clara.

In 2022, the County of Santa Clara, in conjunction with Applied Survey Research (ASR), conducted the 2022 Santa Clara County Homeless Census and Survey. This survey is conducted every two years in the last 10 days of January. The 2022 Santa Clara County Homeless Census and Survey was performed using HUD-recommended practices for counting and surveying the homeless population. The Point-in-Time Homeless Count identified a total of 10,028 persons experiencing homelessness in Santa Clara County in 2022, an increase of 3% from the count conducted in 2019. Table 55 summarizes sheltered and unsheltered homeless persons in Santa Clara County jurisdictions. There were 814 homeless persons surveyed in Gilroy in January 2022, including 606 sheltered and 208 unsheltered persons. 26 The Arturo Ochoa Migrant Center is located slightly outside City bounds, but serves Gilroy residents.

9.2 p. 511 of 1163
Affirmatively Furthering Fair Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 151
Table 55: 2022 Santa Clara County Homeless Census and Survey Homeless Population Sheltered Unsheltered Total
Gilroy 606 208 814
Campbell 216 0 216
Cupertino 102 0 102
Los Altos 65 0 65
Los Altos Hills 0 0 0
Los Gatos 58 0 58
Milpitas 249 25 274
Monte Sereno 0 0 0
Morgan Hill 60 0 60
Mountain View 206 140 346
Palo Alto 263 0 263
San Jose 4,975 1,675 6,650
Santa Clara 375 65 440
Saratoga 0 0 0
Sunnyvale 279 106 385
Source: Santa Clara County Office of Supportive Housing, 10-29-22 Local Data
In March 2023, the City reached out to South County Compassion Center, who noted concentrations of the homeless population in the center of Gilroy, between Monterey Avenue and Highway 101, which is the R/ECAP area. Similar to comments made by the City’s Quality of Life officer, they noted that there is not much migration of the population beyond these areas into the primarily residential neighborhoods. Specifically, there are concentrations of the homeless population in Tomkins Encampment, the IOOF bridge area, Garlic Farm, San Ysidro Park, and Christmas Hill. The homeless population in this area primarily travel by biking or walking, and 70 have an Uplift pass for public transportation.

Place-based improvements in these areas include the $3.9 million grant through the California Department of Transportation’s Clean California Local Grant Program for the Historic Downtown in Gilroy. Improvements anticipated from the grant include:
• Gourmet Alley between 4th and 7th: pedestrian and bicycle-friendly markings, new signage, new benches, new trees, repaving of alley in decorative stamped asphalt, new trash enclosures and trash receptacles, additional lighting.

9.2 p. 512 of 1163
Affirmatively Furthering Fair Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 152
• Railroad Street between 4th and 7th: pedestrian and bicycle-friendly markings, new trash receptacles for pedestrians, new signage, additional lighting, new benches, new fencing.
• Clean Up and Media Campaign: cleanup days for alleys, anti-littering campaign.

Other place-based improvements in the Downtown include:
• The Downtown Façade Improvement and Blight Removal Program, which includes providing a 50%/50% matching grant of up to $5,000 to property owners and tenants within a portion of Downtown to assist with exterior improvements to the façade, or face, of the building. These improvements may include new paint, building surface treatment, awnings, windows, doors, and other improvements that can help improve the exterior of a building. The maximum grant award amount may be increased to $10,000 if the project includes blight removal activities, approved by the City.
• The Downtown Building and Planning Permit Fee Reduction Policy. This includes a 50% rebate of up to $5,000 for all City-related building and planning fees. This is available to any downtown business or property owner that pulls a permit for buildings along Monterey Road between First and Tenth Streets.

The City is including Program G - 6 which includes educating the public on homelessness, consolidating information on resources for the unhoused population on a dedicated webpage, and restarting monthly meetings of the unhoused service providers group.

Permanent Local Housing Allocation Fund
The City had historically allocated funding for services related to housing and homelessness through its Housing Trust Fund (HTF). The City Council approved the replacement of the HTF with the Permanent Local Housing Allocation (PLHA) Fund, making more funds available for public services addressing basic needs and homelessness prevention. Although the HTF will no longer be made available for public service programs or rehabilitation purposes, it will continue to be used to partially cover staff and consulting service costs to monitor affordable rental and ownership agreements until the money is depleted.

The PLHA Fund spans a five-year period and will make available $1.4 million. The City is contracting with Santa Clara County’s Office of Supportive Housing to administer the programs under the PLHA Consortium Agreement. Table 56 displays funding approved by the City Council for FY 22-23 and FY 23-24.

9.2 p. 513 of 1163
Affirmatively Furthering Fair Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 153
Table 56: Permanent Local Housing Allocation Funds for FYs 2022-2024 Agency Funded Services Funding
Amount
St. Joseph’s Family Center
Emergency rental assistance, utility
assistance, and other supportive
programs that help diminish the risk of
becoming homeless
$110,000
St. Joseph’s Family Center
Training and employment readiness to
prepare individuals that are homeless
or at risk of homelessness for stability
and greater self-sufficiency
$70,000
Project Sentinel
Fair housing services and investigates
complaints to address housing
discrimination for Gilroy residents
$40,000
Project Sentinel
Landlord-tenant counseling and
dispute resolution program to help
resolve housing conflict and protect
Gilroy residents from displacement
$40,000
The Health Trust
Meals to low income and homebound
seniors at risk of food insecurity,
allowing them to remain in their homes
$54,000
South County Compassion Center
Services to unhoused Gilroy residents
to meet their basic needs and to
connect them with services that can
help them attain permanent housing
$80,000
Community Agency for Resources
Advocacy and Services
Rental and deposit assistance to
prevent homelessness for Gilroy
families and individuals
$40,000
Silicon Valley Independent Living Center
Counseling for Gilroy residents with
disabilities, emergency rental
assistance, and housing search services
to obtain safe, affordable, and
accessible long-term housing
$40,000
Source: City of Gilroy, 2021.

Displacement
The Urban Displacement Project at the University of California, Berkeley, developed a map of “sensitive communities” where residents may be particularly vulnerable to displacement in the event of increased redevelopment and drastic shifts in housing cost. Sensitive communities are defined based on the following set of criteria:
• The share of very low-income residents is above 20 percent.

9.2 p. 514 of 1163
Affirmatively Furthering Fair Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 154
• The census tract must also meet two of the following criteria:
o The share of renters is above 40 percent.
o The share of people of color is above 50 percent.
o The share of very low-income households (50 percent AMI or below) that are severely rent burdened is above the county median.
o The census tract, or areas in close proximity, have been experiencing displacement pressures. Displacement pressure is defined as:
▪ The percentage change in rent in a selected census tract, divided by county median rent increases OR
▪ Median rent in a selected census tract, minus median rent for all surrounding tracts, divided by median rent for all tracts in county (rent gap).

Figure 43 shows the areas vulnerable to displacement as identified by the Urban Displacement Project. The center of the City, including the downtown area in the east, is considered vulnerable to displacement. Areas north and south of the City show similar risk.

The City is attempting to meet its RHNA without displacing existing residents by identifying vacant and underutilized sites that do not have existing residential uses. Therefore, the City’s RHNA strategy is not anticipated to exacerbate risk of displacement. Instead, it is expected to counteract this vulnerability and minimize displacement by planning for and providing new housing opportunities for all income levels in areas with greater risk of displacement.

Additionally, the City is including a displacement prevention policy (Program F - 5), adopting an inclusionary housing policy (Program A - 11), and providing multilingual tenant support to further minimize the risk of displacement in the City (Programs F - 1 and F - 2).

9.2 p. 515 of 1163
Affirmatively Furthering Fair Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 155
Figure 43: Communities Vulnerable to Displacement
Source: HCD AFFH Data Viewer
Findings
Overall, the City of Gilroy experiences housing problems at a similar or lower rate than the region as a whole, while rates of cost burden or overpayment are higher. However, the percentage of the population experiencing overpayment has decreased over time.

Overcrowding citywide occurs at a similar rate regionally but is more prevalent in the R/ECAP area, potentially indicating a need for larger units or shared multiplexes in the R/ECAP area.

The City is including Program F - 3, a place-based improvement program, to ensure that the RHNA site selection will improve access to resources in the R/ECAP area. Primarily vacant sites were chosen in the R/ECAP area, allowing residents to find available housing in their own neighborhood and to help prevent displacement due to gentrification of older housing stock.

Additionally, Program E - 12 is included to allow stand-alone residential projects in in the Downtown Expansion District to provide further opportunities for affordable housing choices.

9.2 p. 516 of 1163
Affirmatively Furthering Fair Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 156
Other Contributing Factors
Historic Immigration and Land Use Patterns
Gilroy got its start in 1850 as a stagecoach stop for passengers traveling to San Francisco.

During the 1850s, a nucleus of houses and small businesses were constructed along Monterey Road, the old El Camino Real. The railroads connected Gilroy with San José in 1869, and Gilroy incorporated with the State as a charter city in 1870. At that time, Gilroy had a population of 1,625 residents.

The original City began development in what is now considered the downtown area. Portions of the downtown are designated as the Downtown Historic District, which is intended to foster the historic downtown as a unique commercial resource. As is typical, these older areas and older housing tend to be lower cost than newer areas and newer housing. These older city centers also tend to have the most multifamily and rental housing as these were the most efficient land use patterns at the time of development. As a result, the older areas often have higher proportions of affordable housing without subsidies and lower-income households.

Similarly, today’s new housing will be more affordable than housing built in 10 or 20 years.

In 1936, the City of Gilroy zoned the city into five distinctive districts: Single Family Residences; Multiple Family Residences; Business Districts; Industrial Districts; and Residential-Agricultural.

The single-family district was located between Hanna, Princevalle, First, and Seventh Streets.

The multiple-family residence district, which constituted an area approximately double that designated for single-family residences, was located between Eigleberry and Hanna Streets, and First and Tenth Streets as well as a section to the east of Monterey Street between Old Gilroy and Lewis Street.27
Residential development in Gilroy during the postwar period continued in the pattern established by early subdivision developers. Like many other cities in California, Gilroy’s population continued to grow in the decade following the close of World War II, and the need for residential development required more space than the remaining undeveloped areas within the City limits could allow. To house Gilroy’s many incoming residents, annexation of new territory by the mid-1950s was essential to keep pace with the steadily rising demand for housing.

By 1960, the population of Gilroy had soared to 7,348 persons, from 4,951 persons recorded in 1950. The influx of people to the City required even more newly annexed areas devoted to residential developments as well as supporting infrastructure like schools, parks, churches, and commercial centers. In 1965, the City annexed 750 acres of land, effectively increasing the area of the City by 50 percent during that year alone.28 Many of these annexed regions were developed into modern residential neighborhoods.
27 Eugene Lewis Conrotto. The Urbanization of the Southern Santa Clara Valley: Gilroy. (Gilroy, CA: Gilroy Historical Museum, 1951).
28 San Jose Mercury-News. 1966.

9.2 p. 517 of 1163
Affirmatively Furthering Fair Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 157
The City expanded as the agricultural industry expanded, but in the late twentieth century, the economy shifted from agriculturally based to an urban service-oriented community.29 This change in economy contributed to the growth of the City. Christmas Hill Park began construction in 1964.30 By 1970, when the population of Gilroy had nearly doubled within the decade to 12,665 persons, there were approximately 3,000 residences.31 Several single-family homes were built in the surrounding neighborhoods in the following years, leading to the highest rates of population growth in the City’s history in the 1970s and 1980s. The newer areas of the City are in the moderate resource category as the infrastructure and housing is more recently developed. The City continues to expand to the west with the recent Hecker Pass and Glen Loma Specific Plan areas.

Historically, other cities in Santa Clara County had racial covenants, which led to thriving immigrant communities settling in the City of Gilroy. This first included the Chinese population, which settled in Gilroy after immigrating to the United States to build railroads and work in gold mines, tobacco fields, and orchards.32 Since the migrations of the Chinese population to the central county, the Latino population has been largely responsible for the thriving businesses in Gilroy. Over 50 percent of Gilroy’s current population is Hispanic.

The City has taken multiple steps to encourage economic revitalization and growth in the older, downtown areas of the City. The two tracts that are designated as R/ECAPs are each classified as an Opportunity Zone by the federal government and are eligible for a number of tax-based incentives. In 2022, Gilroy was awarded a $3.9 million grant for improvements in the historic downtown area. In 2020, 2021 and 2023, the City operated a Downtown Improvement Incentive Program which included reductions on development fees and a grant to help fund minor façade improvements for businesses downtown. The City continues to partner with organizations such as Visit Gilroy, the Gilroy Downtown Business Association, and the Gilroy Chamber of Commerce to promote economic development in downtown Gilroy.

The City has also created several programs to encourage affordable housing and affordableby-design housing in the higher resource western areas of the City. Program A-10 (Missing Middle / Middle Income Housing) will allow triplexes and fourplexes on corner lots in the R-1 and R-2 districts that currently include single-family homes. Programs A - 11 (Inclusionary Policy) and A - 12 (Incentives Beyond Density Bonus State Law) will facilitate deed-restricted affordable housing opportunities in the City’s higher resource / higher income areas. Program E - 12 (Mixed-Use Corridor Flexibility) will allow flexibility for the non-residential portion of mixed-use projects that accommodate extremely low-income and Special Needs Households along the First Street Corridor. In addition, there are several programs intended to increase the number of ADUs in the higher resource western area of the City, including Program A - 6 29 A Brief History of Gilroy. https://www.cityofgilroy.org/381/History-of-Gilroy 30 The Mercury News, Gilroy Timeline. https://www.mercurynews.com/2007/02/05/gilroy-timeline/ 31 Gilroy Chamber of Commerce. “Standard Industrial Survey Report: Gilroy, Santa Clara County, California.” (Gilroy, CA: Gilroy Chamber of Commerce, March, 1969). Gilroy Historical Museum. 32 Gilroy Dispatch. https://gilroydispatch.com/immigrants-play-big-part-in-gilroy-history/

9.2 p. 518 of 1163
Affirmatively Furthering Fair Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 158
(ADU Tracking and Monitoring), A - 7 (ADU Pre-Designed Plans), A - 8 (Financial Incentives for Affordable ADUs), A - 15 (ADU Ordinance Updates), and G - 3 (ADU Education).

Urban Growth Boundary
Per the City’s General Plan, “The Urban Growth Boundary (UGB) applies to land within the Planning Boundary/Sphere-of-Influence that is intended for urbanization at some point in the future. The UGB indicates the extent and direction of the City's future urban expansion and capital improvements planning. Lands outside the UGB are to be preserved for rural and agricultural uses” (p. LU-15).

In 2016, voters passed Measure H, resulting in the UGB. The intent of the UGB is to protect agriculture and open space in the surrounding areas outside of the UGB. Urban development is not allowed outside of the UGB; only uses allowed in the open space designation per the General Plan are allowed. Until December 31, 2040, lands outside the UGB can only be redesignated by a vote of the people, except for the following exceptions in which “the City Council determines that doing so is necessary to comply with State law regarding the provision of housing for all segments of the community” and makes each of the following findings based on substantial evidence, per the General Plan:
• That the land proposed to be brought within the UGB and/or re-designated is immediately adjacent to: (i) the existing UGB; and (ii) available water and sewer connections; and
• That the proposed development will consist primarily of low and very low-income housing pursuant to the Housing Element of this General Plan; • That there is no existing vacant or undeveloped residentially designated land within the UGB to accommodate the proposed development and it is not feasible to accommodate the proposed development by re-designating lands within the UGB for low- and very low-income housing; and
• That the proposed development is necessary to comply with State law requirements for the provision of low- and very low-income housing and the area of land within the proposed development will not exceed the minimum area necessary to comply with State law.” (p. LU-22)
An analysis by the City attorney at the time of the vote estimated that this would yield a reduction of 2,929 potential units compared to the City’s previous General Plan and 4,344 units to the draft General Plan update at the time.33
The City also has an Urban Service Area (USA). The USA is the land to which the City is committed to providing basic infrastructure and services for urban development. The USA is 33City Attorney’s Impartial Analysis of Measure H. https://sccvote.sccgov.org/sites/g/files/exjcpb1106/files/E110%20- %20Measure%20H.pdf

9.2 p. 519 of 1163
Affirmatively Furthering Fair Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 159
generally coterminous with the UGB. The USA is reviewed and amended by the Local Agency Formation (LAFCO).

Fair Housing Issues, Contributing Factors, and Meaningful Action The City has adopted goals and actions that specifically address the contributing factors identified in the AFFH analysis. While the City views all contributing factors as important, higher priority was given to factors that limit fair housing choice and/or negatively impact fair housing, per Government Code section 65583(c)(10)(A)(iv).

Table 57 on the following page displays the identified fair housing issue, contributing factor, actions taken to address the contributing factor, and priority level for each issue. Relevant programs are referenced in the action column for each contributing factor.

9.2 p. 520 of 1163
160
Table 57: Fair Housing Issues, Contributing Factors, and Proposed Action Identified Fair
Housing Issue
Contributing
Factor Action Priority
Disproportionate
Housing Needs
Risk of
displacement in
downtown
Lack of missing
middle housing
Lack of affordable
housing for
special needs
groups (large
households,
seniors,
farmworkers)
• ADU education targeting high resource areas (A - 6)
• Incentives for affordable ADUs (A - 8)
• Facilitate Missing Middle / Middle Income Housing (A - 10) • Coordination with Santa Clara County Office of Supportive Housing (A - 14) • Permit streamlining (B - 5)
• Incentivize micro-units (E - 5)
• Develop incentives for housing for seniors, farmworkers, and large families (E - 6) • Development and conservation of housing for farmworkers (E - 7) • Development and Rehabilitation of Housing for Persons with Disabilities (E - 10) • Housing for Extremely Low Income and Special Needs Households (E - 11) • Allow 100% Residential in the Downtown Expansion District and allow flexibility for First Street Mixed-Use Corridor projects that accommodate extremely low-income and Special Needs Households (E - 12)
• Fair housing counseling (F - 2)
• Place-based economic investments in downtown (F - 3)
• Displacement prevention ordinance (F - 5)
High
Access to
Opportunities
Presence of a
R/ECAP
Lower access to
opportunities
than the County
as a whole
• Facilitate Missing Middle / Middle Income Housing (A - 10) • Adoption of inclusionary housing policy (A - 11)
• Incentives beyond Density bonus state law (A - 12)
• SB 9 Processing (A - 16)
• Permit streamlining (B - 5)
• Source of income protection / housing mobility (F - 1) • Place-based economic investments in downtown (F - 3)
High

9.2 p. 521 of 1163
Affirmatively Furthering Fair Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 161
Identified Fair
Housing Issue
Contributing
Factor Action Priority
Lack of missing
middle / middle
income housing
• Targeted outreach in higher resource areas (F - 4)
Integration and
Segregation
East/west income
segregation
Lack of
inclusionary
housing policy
• Incentives for affordable ADUs (A - 8)
• Facilitate Missing Middle / Middle Income Housing (A - 10) • Adoption of inclusionary housing policy (A - 11) to require development of affordable housing on the west side
• Creation of incentives beyond density bonus state law (A - 12) to encourage development of affordable housing on the west side
• Source of income protection (F - 1)
Medium
Outreach and
Enforcement
Capacity
Access to
materials in
appropriate
languages
Lack of education
and outreach in
the R/ECAP area
City staff capacity
• Fair housing counseling (F - 2)
• Targeted outreach in moderate and high resource areas (F - 4) • Interagency collaboration for lower cost housing (G - 1) • Community access to housing information program (G - 5) • Unhoused population education and outreach (G - 6)
• Bilingual engagement (G - 7)
Low

9.2 p. 522 of 1163
162
Table 58 provides a detailed overview of actions included in Housing Element Programs that are aimed at affirmatively furthering fair housing. The table separates the actions by their identified fair housing issue and priority level. It summarizes the specific commitment, timeline, geographic targeting, and metric for each program.

Table 58: AFFH Actions Matrix
HE Programs or
Other Activities Specific Commitment Timeline Geographic Targeting 2023 – 2031 Metric Disproportionate Housing Needs
A - 6: ADU
Tracking and
Monitoring
Continuously track the number of building permits issued for ADUs. The City will also review geographic distributions of ADUs biennially. If the average ADU production is less than 25 units in years 2023, 2024, and 2025, the City will update the ADU strategy by the end of 2026. In this case, the City will hold a focus group event with local stakeholders in spring or fall 2026. The purpose of the collaborative meeting will be to identify appropriate ADU programs to help increase production. If necessary, the City will identify additional RHNA sites in No Net Loss Inventory, as discussed in Program A - 1.

Track ADU permits as they are
submitted. Review ADU
strategies annually as part of the
Annual Progress Report process.

Hold a focus group event with
local stakeholders in spring or
fall 2026 if average ADU
production is less than 25 in
years 2023, 2024, and 2025.

Identify additional programs or
sites within six months of
shortfall.

High Resource Areas Increase the number of new ADUs permitted in the City from an average of approximately 15.75 (2018-2021) to an average of approximately 25.

A - 8: Financial
Incentives for
Affordable ADUs
Upon securing funding, the City will develop a financial assistance program for homeowners who build ADUs with an affordability restriction or commitment to offering housing choice vouchers.

If ADU production is lower than anticipated, the City will evaluate ADU impact fees as a potential constraint for affordable housing and update them as necessary to ensure the fees are consistent with regional trends and do not unreasonably constrain ADU development. This effort will complement Program A-6 (ADU Tracking and Monitoring)
The City will review successful programs from other cities or the Housing Trust of Silicon Valley and contact Community Development Financial Institutions for potential partnerships.

After program funding is
secured and sufficient for the
intended purpose. Evaluate the
effect of impact fees on ADU
development by Q4 end of 2026
if ADU production is lower than
anticipated in year 2025
High Resource Areas Outreach to provide information to 30 households annually.

A - 10: Facilitate
Missing Middle /
Middle Income
Housing
Amend the City Code to allow triplexes, and fourplexes to be approved ministerially on corner lots with a minimum 6,000 sf lot size in the R1 and R2 zones (approximately 1,106 lots) so long as the project complies with objective design standards.

This Program provides more flexibility than SB 9, by allowing triplexes or fourplexes, in lieu of a duplex with an ADU and a junior ADU. This program will also encourage the development of missing middle housing throughout the City, including highresource areas primarily comprising detached single-family residences.

Update the City’s SB 9 policy and website to reflect the changes allowed under this program. Create an informational and promotional pamphlet regarding opportunities to develop triplexes and fourplexes on corner lots in R1 and R2 zones.

Provide the pamphlet online, at City Hall, and at informational booths where housing resources are provided (see Program G - 5).

By end of Q4 2024. Citywide Increased production and reduced permitting time and cost for triplexes and fourplexes. Facilitate construction of 50 missing middle (duplex, triplex, quadplex) housing units over the 6 th
Cycle planning period.

9.2 p. 523 of 1163
Affirmatively Furthering Fair Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 163
HE Programs or
Other Activities Specific Commitment Timeline Geographic Targeting 2023 – 2031 Metric A - 14:

Coordination
with Santa Clara
County Office of
Supportive
Housing
The City will continue its partnership with Santa Clara County Office of Supportive Housing regarding development of affordable housing at the property at 8th and Alexander. This includes the offer of impact fee waivers through a memorandum of understanding approved by the Gilroy City Council and the County Board of Supervisors in September 2022. Next steps include community engagement and working on the City’s priorities for the site (e.g., targeted income / special needs groups).

Continual partnership
throughout the planning period.

Anticipated completion of
project by the end of 2028.

Citywide Development of affordable housing on the 8
th and Alexander
property by the end of 2028.

B - 5: Permit
Streamlining
As a part of the 2023 comprehensive Zoning Ordinance update, the City is pursuing changes to streamline the permitting process, including but not limited to:
• Creating a ministerial use permit process; and
• Creating a more transparent and streamlined process for reviewing and approving applications involving a historic resource (e.g., residential addition).
• Streamlining the Planned Development approval process, so that projects that do not require a zoning amendment or General Plan amendment can be approved by the Planning Commission rather than requiring review and approval by both the Planning Commission and City Council.

Additionally, the City will ensure it adheres to newly passed legislation surrounding permit streamlining, such as AB 2234.

Concurrent with the
comprehensive Zoning
Ordinance update, end of Q4
2023.

Citywide Decreased permit processing time.

E - 5: Incentivize
Micro-Units
Ensure that provisions for efficiency units are consistent with AB 352 (2017), concurrent with the comprehensive Zoning Ordinance update by the end of Q4 2023.

Revise the Zoning Ordinance to establish development standards for micro-units, create incentives for micro-unit production, and remove barriers to micro-unit development, by the end of 2025.

By end of Q4 2023 and 2025. Citywide Adopt the policy.

E - 6: Reduced
Parking
Requirements
for Senior
Housing
The City shall conduct a study to determine if reduced parking standards for senior housing is appropriate in Gilroy. Based on the findings of the study, the City may revise the Zoning Ordinance, as necessary, to reduce parking standards for senior housing.

The passing of AB 2097 will reduce constraints to senior housing development as it prohibits any minimum parking requirement on any residential, commercial, or other development project located within one half-mile of public transit.

By end of Q4 2026. Citywide Conduct study and revise Zoning Ordinance, as necessary.

E - 7:

Development
and
Conservation of
Housing for
Farmworkers
In 2022, the City partnered with the Santa Clara County Office of Supportive Housing, to facilitate lower-income housing on a County owned property by waiving development impact fees for the project.

The City shall continue to partner with the Santa Clara County Office of Supportive Housing and various nonprofit organizations to explore and implement ways of providing affordable farmworker housing, including identification of state and federal funding opportunities.

At least once a year, the City will forward information about surplus City-owned land and other development opportunities to the Santa Clara County Office of Supportive Ongoing throughout planning
period
Citywide Preserve and maintain the 3 farmworker housing developments (56 units) and Ochoa Migrant Center (100 units).

9.2 p. 524 of 1163
Affirmatively Furthering Fair Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 164
HE Programs or
Other Activities Specific Commitment Timeline Geographic Targeting 2023 – 2031 Metric Housing, affordable housing developers, and service providers who may be interested in developing more farmworker housing in Gilroy. The City will also provide this information at the annual developer roundtable and to individuals on the housing developer list, created through Program G - 1 E - 10
Development
and
Rehabilitation of
Housing for
Persons with
Disabilities
As part of the 2023 comprehensive Zoning Code update, the City will evaluate reasonable accommodation standards and procedures and the permit requirements for residential care homes (i.e., group homes) in medium- and higher-density residential zones. The City will revise, as necessary, regulations that act as potential constraints to accommodating persons with disabilities.

By end of Q4 2023. Citywide Evaluate and revise as necessary reasonable accommodation standards and procedures and permit requirements for
residential care homes.

E - 11: Housing
For Extremely
Low Income and
Special Needs
Households
The City will facilitate and support affordable housing by meeting with potential affordable housing developers and homeless service providers to identify development opportunities, provide site information, assist in the entitlement processes, and consider on a case-by-case basis other incentives, including but not limited to fee deferrals and modification of standards.

As included in Program G - 1, the City will conduct proactive outreach to specifically include developers of housing for special needs and low-income households in the annual developer roundtable.

Additionally, the City will pursue funding sources, such as use of PLHA funds, to assist special needs households, such as extremely low-income households, farmworkers, large families, seniors, and persons with disabilities, including developmental disabilities. The City will consider using PLHA funding for eligible activities, including the predevelopment, development, acquisition, rehabilitation and preservation of affordable housing.

As applications are received.

Annual developer roundtable.

Pursue funding sources as they
are made available.

Citywide Outreach to affordable housing developers at least bi-annually (4 times over the planning period) when PLHA funds become available.

E - 12:

Downtown
Expansion
District and First
Street Mixed-Use
Corridor
Flexibility
The City will develop a process to allow 100% residential projects in the Downtown Expansion District. The City will also create a process that allows flexibility in the type of non-residential uses allowed in the new First Street Mixed-Use Corridor, subject to certain criteria. In exchange for this flexibility, the City may require that a certain percentage of units are dedicated to extremely low-income households, farmworkers, persons with disabilities, or other identified groups. The intent of this program is to facilitate and encourage housing for extremely low income and special needs households.

Amendments by end of Q4 2025 Downtown Expansion
District, First Street
Mixed-Use Corridor
Adopted zoning amendments. Facilitation of 100 units using the adopted process in the planning period.

F - 2: Fair
Housing
Counseling
The City shall continue to provide funds to and contract with a non-profit agency to provide fair housing assistance including landlord/tenant counseling.

The City shall disseminate information about fair housing assistance through pamphlets in City-owned buildings and other public locations (e.g., City Hall, Library, post office, other community facilities) and by posting information on the City website. Pamphlets will be made available in English and Spanish.

Annual or biennial award of
funds. Provision of pamphlets by
Q4 2024.

Downtown Work with Fair Housing Provider to track number of households assisted in Gilroy annual. Provide information to 30 households annually.

9.2 p. 525 of 1163
Affirmatively Furthering Fair Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 165
HE Programs or
Other Activities Specific Commitment Timeline Geographic Targeting 2023 – 2031 Metric F - 3: PlaceBased
Improvements in
Downtown
Gilroy
Develop programs and strategies to create place-based improvements through investments in the public right of way. Specific actions include:
• As part of the $3.9 million Clean California Grant, the City will renovate and beautify a portion of Gourmet Alley and Railroad Street within the downtown area with: pedestrian and bicycle-friendly markings along each block; improvements to the stormwater drainage system; additional landscaping and lighting; new benches; cleanup days for the alleys; and an anti-littering campaign.
• As a part of downtown revitalization, the City will construct a new downtown parking lot that will also serve as a community resource for a Farmers Market and community events in the downtown.
• As a part of the CIP, to support economic development in the downtown, complete Automall Parkway Pavement Rehabilitation including reconstruction of 20 curb ramps, addition of Class II bike lanes, and repair and replacement of deteriorated curb and gutter (estimated $2.4 million) • As a part of the CIP, to support pedestrian infrastructure in the DTSP area, install and upgrade ADA curb ramps in Downtown Gilroy. In March 2023 the City Council awarded a contract to conduct ADA curb ramp improvements at nine locations in and around Downtown Gilroy. • The Downtown Façade Improvement and Blight Removal Program, which includes providing a 50%/50% matching grant of up to $5,000 to property owners and tenants within a portion of Downtown to assist with exterior improvements to the façade, or face, of the building. These improvements may include new paint, building surface treatment, awnings, windows, doors, and other improvements that can help improve the exterior of a building. The maximum grant award amount may be increased to $10,000 if the project includes blight removal activities, approved by the City. • The Downtown Building and Planning Permit Fee Reduction Policy. This includes a 50% rebate of up to $5,000 for all City-related building and planning fees. This is available to any downtown business or property owner that pulls a permit for buildings along Monterey Road between First and Tenth Streets
Streetscape and infrastructure
improvements will be completed
pursuant to the City’s CIP
schedule.

The Clean California Grant
project must be completed by
June 30, 2024.

Construction of the parking lot
with community event space
should be complete by the end
of 2023.

Downtown Construction of one parking lot with a community event space; reconstruction of 20 curb ramps.

F - 5:

Displacement
Prevention
Policy
Adopt a displacement prevention policy. Organize a focus group of organizations with experience in displacement prevention policies (e.g., SV@Home) and complete an analysis of best practices in jurisdictions that are similar to Gilroy. Measures that are being considered for inclusion in the policy are “tenant option to purchase agreements” for redevelopment projects meeting specified thresholds, a just cause eviction ordinance, and relocation agreements.

Through Program B-7, the City will amend the Zoning Ordinance to require that any demolished residential units on the Sites Inventory be replaced pursuant to Government Code Section 65583.2(g).

Hold focus group and complete
analysis by end of Q4 2025.

Adopt policy by end of Q4 2026.

Areas denoted above as
having vulnerability to
displacement
Adopt the policy.

Access to Opportunities

9.2 p. 526 of 1163
Affirmatively Furthering Fair Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 166
HE Programs or
Other Activities Specific Commitment Timeline Geographic Targeting 2023 – 2031 Metric A - 10: Facilitate
Missing Middle /
Middle Income
Housing
Amend the City Code to allow triplexes, and fourplexes to be approved ministerially on corner lots with a minimum 6,000 sf lot size in the R1 and R2 zones (approximately 1,106 lots) so long as the project complies with objective design standards.

This Program provides more flexibility than SB 9, by allowing triplexes or fourplexes, in lieu of a duplex with an ADU and a junior ADU. This program will also encourage the development of missing middle housing throughout the City, including highresource areas primarily comprising detached single-family residences.

Update the City’s SB 9 policy and website to reflect the changes allowed under this program. Create an informational and promotional pamphlet regarding opportunities to develop triplexes and fourplexes on corner lots in R1 and R2 zones.

Provide the pamphlet online, at City Hall, and at informational booths where housing resources are provided (see Program G - 5).

By end of Q4 2024. Citywide Increased production and reduced permitting time and cost for triplexes and fourplexes. Facilitate construction of 50 missing middle (duplex, triplex, quadplex) housing units over the 6 th
Cycle planning period.

A - 11:

Inclusionary
Housing Policy
Conduct an inclusionary housing feasibility study to identify appropriate inclusionary requirements that will not constrain housing production. Review the City’s existing Neighborhood District Policy and former RDO Exemption Policy as a benchmark for developing the inclusionary requirements (e.g., resale controls, minimum term [years of affordability], minimum percentage of units that must be restricted as affordable, minimum percentage within each affordability category).

Develop an affordable housing policy to establish inclusionary housing requirements so that specified new developments reserve a percentage of the total units for lowerand moderate-income households or pay an in-lieu of housing fee for projects below the threshold for inclusionary housing, such as smaller projects that cannot feasibly construct affordable housing. The inclusionary housing ordinance will include a requirement that the developer market the below market-rate units and accessible/adaptable units.

By the end of 2024. Citywide Increased production of affordable housing within the City, including housing choice and mobility for lower-income
households. Prioritize use of in-lieu fees to develop affordable housing options in higher resource areas of the City.

A - 12: Incentives
Beyond Density
Bonus State Law
Study and consider adopting a density bonus ordinance above and beyond the minimum requirements of state law. Specifically consider additional incentives for households with special housing needs such as large households, extremely low income households, farmworkers, and households with members with intellectual or developmental disabilities. In lieu of adopting a separate density bonus policy, the City could structure the Inclusionary Policy (A - 11) like a density bonus program with incentives that are tiered by level of affordability provided.

By end of Q4 2025. Citywide Adoption of Zoning Ordinance amendment; Increased housing choice and mobility for special needs households.

A - 16: SB 9
Processing
In conjunction with Program A-10 (Facilitate Missing Middle / Middle Income Housing), the City will update its SB 9 webpage to highlight the streamlined process for approving SB 9 applications. The City will also create and post step-by-step, user friendly instructions for processing SB 9 units and lot splits in Gilroy.

The Planning Department will hold informational meetings with the building division and engineering/land development division to review the streamlined process to ensure the City complies with state law.

By end of Q4 2024. Citywide Update SB 9 webpage; create instructions for processing SB 9 units and lot splits; hold informational meetings with building and engineering/land development divisions.

9.2 p. 527 of 1163
Affirmatively Furthering Fair Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 167
HE Programs or
Other Activities Specific Commitment Timeline Geographic Targeting 2023 – 2031 Metric B - 5: Permit
Streamlining
As a part of the 2023 comprehensive Zoning Ordinance update, the City is pursuing changes to streamline the permitting process, including but not limited to:
• Creating a ministerial use permit process; and
• Creating a more transparent and streamlined process for reviewing and approving applications involving a historic resource (e.g., residential addition).
• Streamlining the Planned Development approval process, so that projects that do not require a zoning amendment or General Plan amendment can be approved by the Planning Commission rather than requiring review and approval by both the Planning Commission and City Council.

Additionally, the City will ensure it adheres to newly passed legislation surrounding permit streamlining, such as AB 2234.

Concurrent with the
comprehensive Zoning
Ordinance update, end of Q4
2023.

Citywide Decreased permit processing time.

F - 1: Source of
Income
Protection
Within one year, coordinate with Project Sentinel to conduct a meeting/workshop to inform residents of sources of income protection and state rent control laws such as AB 1482.

Continue to coordinate outreach efforts to inform landlords and tenants of recent changes to state law that prevent source of income discrimination, including allowance of housing choice vouchers (HCVs) to establish a renter’s financial eligibility.

Informational outreach by end
of Q4 2024
Outreach to 50 landlords or
tenants annually.

Downtown Conduct workshop with residents.

F - 3: PlaceBased
Improvements in
Downtown
Gilroy
Develop programs and strategies to create place-based improvements through investments in the public right of way. Specific actions include:
• As part of the $3.9 million Clean California Grant, the City will renovate and beautify a portion of Gourmet Alley and Railroad Street within the downtown area with: pedestrian and bicycle-friendly markings along each block; improvements to the stormwater drainage system; additional landscaping and lighting; new benches; cleanup days for the alleys; and an anti-littering campaign.
• As a part of downtown revitalization, the City will construct a new downtown parking lot that will also serve as a community resource for a Farmers Market and community events in the downtown.
• As a part of the CIP, to support economic development in the downtown, complete Automall Parkway Pavement Rehabilitation including reconstruction of 20 curb ramps, addition of Class II bike lanes, and repair and replacement of deteriorated curb and gutter (estimated $2.4 million) • As a part of the CIP, to support pedestrian infrastructure in the DTSP area, install and upgrade ADA curb ramps in Downtown Gilroy. In March 2023 the City Council awarded a contract to conduct ADA curb ramp improvements at nine locations in and around Downtown Gilroy. • The Downtown Façade Improvement and Blight Removal Program, which includes providing a 50%/50% matching grant of up to $5,000 to property owners and tenants within a portion of Downtown to assist with exterior improvements to the façade, or face, of the building. These improvements Streetscape and infrastructure
improvements will be completed
pursuant to the City’s CIP
schedule.

The Clean California Grant
project must be completed by
June 30, 2024.

Construction of the parking lot
with community event space
should be complete by the end
of 2023.

Downtown Construction of one parking lot with a community event space; reconstruction of 20 curb ramps.

9.2 p. 528 of 1163
Affirmatively Furthering Fair Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 168
HE Programs or
Other Activities Specific Commitment Timeline Geographic Targeting 2023 – 2031 Metric may include new paint, building surface treatment, awnings, windows, doors, and other improvements that can help improve the exterior of a building. The maximum grant award amount may be increased to $10,000 if the project includes blight removal activities, approved by the City.

The Downtown Building and Planning Permit Fee Reduction Policy. This includes a 50% rebate of up to $5,000 for all City-related building and planning fees. This is available to any downtown business or property owner that pulls a permit for buildings along Monterey Road between First and Tenth Streets F - 4: Housing
Mobility and
Choice in Higher
Opportunity
Areas
Improve housing mobility and choice, especially in higher opportunity areas of the City through the follow actions:
• Allow triplexes and quadplexes that meet objective design standards to be approved ministerially on corner lots in the R1 and R2 zones (Program A-10). • Adopt an inclusionary housing policy (Program A-11)
Adopt a incentives beyond density bonus state law policy to include incentives for special needs households (Program A-12)
By Q2 2025. Higher Opportunity
Areas
Adopt density bonus and inclusionary housing policies.

Integration and Segregation
A - 8: Financial
Incentives for
Affordable ADUs
Upon securing funding, the City will develop a financial assistance program for homeowners who build ADUs with an affordability restriction or commitment to offering housing choice vouchers.

If ADU production is lower than anticipated, the City will evaluate ADU impact fees as a potential constraint for affordable housing and update them as necessary to ensure the fees are consistent with regional trends and do not unreasonably constrain ADU development. This effort will complement Program A-6 (ADU Tracking and Monitoring)
The City will review successful programs from other cities or the Housing Trust of Silicon Valley and contact Community Development Financial Institutions for potential partnerships.

After program funding is
secured and sufficient for the
intended purpose. Evaluate the
effect of impact fees on ADU
development by Q4 end of 2026
if ADU production is lower than
anticipated in year 2025
High Resource Areas Outreach to provide information to 30 households annually.

A - 10: Facilitate
Missing Middle /
Middle Income
Housing
Amend the City Code to allow triplexes, and fourplexes to be approved ministerially on corner lots with a minimum 6,000 sf lot size in the R1 and R2 zones (approximately 1,106 lots) so long as the project complies with objective design standards.

This Program provides more flexibility than SB 9, by allowing triplexes or fourplexes, in lieu of a duplex with an ADU and a junior ADU. This program will also encourage the development of missing middle housing throughout the City, including highresource areas primarily comprising detached single-family residences.

Update the City’s SB 9 policy and website to reflect the changes allowed under this program. Create an informational and promotional pamphlet regarding opportunities to develop triplexes and fourplexes on corner lots in R1 and R2 zones.

Provide the pamphlet online, at City Hall, and at informational booths where housing resources are provided (see Program G - 5).

By end of Q4 2024. Citywide Increased production and reduced permitting time and cost for triplexes and fourplexes. Facilitate construction of 50 missing middle (duplex, triplex, quadplex) housing units over the 6 th
Cycle planning period.

9.2 p. 529 of 1163
Affirmatively Furthering Fair Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 169
HE Programs or
Other Activities Specific Commitment Timeline Geographic Targeting 2023 – 2031 Metric A - 11:

Inclusionary
Housing Policy
Conduct an inclusionary housing feasibility study to identify appropriate inclusionary requirements that will not constrain housing production. Review the City’s existing Neighborhood District Policy and former RDO Exemption Policy as a benchmark for developing the inclusionary requirements (e.g., resale controls, minimum term [years of affordability], minimum percentage of units that must be restricted as affordable, minimum percentage within each affordability category).

Develop an affordable housing policy to establish inclusionary housing requirements so that specified new developments reserve a percentage of the total units for lowerand moderate-income households or pay an in-lieu of housing fee for projects below the threshold for inclusionary housing, such as smaller projects that cannot feasibly construct affordable housing. The inclusionary housing ordinance will include a requirement that the developer market the below market-rate units and accessible/adaptable units.

By the end of 2024. Citywide Increased production of affordable housing within the City, including housing choice and mobility for lower-income
households. Prioritize use of in-lieu fees to develop affordable housing options in higher resource areas of the City.

A - 12: Incentives
Beyond Density
Bonus State Law
Study and consider adopting an affordable housing incentives policy above and beyond the minimum requirements of density bonus state law. Specifically consider additional incentives for households with special housing needs such as large households, extremely low-income households, farmworkers, and households with members with intellectual or developmental disabilities. In lieu of adopting a separate incentives / density bonus policy, the City could structure the Inclusionary Policy (A - 11) like a density bonus program with incentives that are tiered by level of affordability provided.

By end of Q4 2025. Citywide Adoption of Zoning Ordinance amendment; increased housing choice and mobility for special needs households.

F - 1: Source of
Income
Protection
Within one year, coordinate with Project Sentinel to conduct a meeting/workshop to inform residents of sources of income protection and state rent control laws such as AB 1482.

Continue to coordinate outreach efforts to inform landlords and tenants of recent changes to state law that prevent source of income discrimination, including allowance of housing choice vouchers (HCVs) to establish a renter’s financial eligibility.

Informational outreach by end
of Q4 2024. Annual education
and outreach to landlords and
tenants.

Downtown Outreach to 50 landlords or tenants annually.

Outreach and Enforcement Capacity
F - 2: Fair
Housing
Counseling
The City shall continue to provide funds to and contract with a non-profit agency to provide fair housing assistance including landlord/tenant counseling.

The City shall disseminate information about fair housing assistance through pamphlets in City-owned buildings and other public locations (e.g., City Hall, Library, post office, other community facilities) and by posting information on the City website. Pamphlets will be made available in English and Spanish.

Annual or biennial award of
funds. Provision of pamphlets by
end of Q4 2024.

Downtown Annual or biennial award of funds. Provision of pamphlets by Q2 2024. Work with Fair Housing Provider to track number of households assisted in Gilroy annually. Provide information to 30 households annually.

F - 4: Housing
Mobility and
Choice in Higher
Opportunity
Areas
Improve housing mobility and choice, especially in higher opportunity areas of the City through the follow actions:

By Q2 2026. Higher Opportunity
Areas
Adopt density bonus and inclusionary housing policies.

9.2 p. 530 of 1163
Affirmatively Furthering Fair Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 170
HE Programs or
Other Activities Specific Commitment Timeline Geographic Targeting 2023 – 2031 Metric • Allow triplexes and quadplexes that meet objective design standards to be approved ministerially on corner lots in the R1 and R2 zones (Program A-10). • Adopt an inclusionary housing policy (Program A-11)
• Adopt an incentives beyond density bonus state law policy to include incentives for special needs households (Program A-12)
G - 1:

Collaboration
with
Development
Community
The City shall continue to cultivate new and existing relationships, throughout the planning period, with for-profit and non-profit development companies working in the area of affordable housing, facilitating collaborative approaches to affordable housing development.

Invite affordable housing developers and developers of housing for special needs households to the annual developer roundtable meeting.

The City will create a list of housing developers, including developers of affordable and special needs housing. The list will be used for the annual developer roundtable (or equivalent), and to advertise development opportunities, funding opportunities, and other educational and engagement efforts in the City.

Collaboration with other
agencies on an annual basis.

Countywide Host an annual developer roundtable (or equivalent) meeting.

Participation of at least four developers of affordable and special needs housing in the annual meeting. Creation of developer interest list by end of Q4 2024.

G - 5: Housing
Outreach and
Information
The City shall provide information about housing assistance, fair housing, housing resources, and housing programs through a wide variety of outreach methods such as:
• Conducting workshops and webinars by partnering with community-based organizations to inform residents of housing resources, assistance programs, and funding opportunities, on a monthly basis on average. • Disseminating information about fair housing in City-owned buildings and other public locations (e.g., City Hall, Library, post office, other community facilities) and by posting information on the City website. Pamphlets will be made available in English and Spanish.
• Advertising housing assistance information on the City website, through the compilation of resources for rental assistance, down payment assistance, and other means of retaining existing housing or acquiring a new home. • Coordinating with the City’s Fair Housing Service Provider to provide resources and information at a housing resources event in the DTSP area.

Update the City website with
housing information as new
resources become available.

Annual housing event in the
DTSP area.

Conduct community outreach
workshops on housing
resources on a monthly basis on
average.

Downtown Specific Plan
Area
Provision of housing resources and information through at least three different mediums. All information made available in English and Spanish. Annual housing event in the DTSP.

Outreach with 150 households annually.

G - 6: Unhoused
Population
Education and
Outreach
The City will develop a program to educate the public on the unhoused population and homelessness as well as advertise resources that available for the unhoused population. Specifically, the program will include:
• Creation of a dedicated webpage with information on unhoused resources and efforts.
• Development of printed collateral for distribution at City Hall and by code enforcement officers in the field.
• Gathering information on resources that exist in the City and County for the unhoused population and promote the information at City Hall and on the City’s y end of Q4 2025; monthly
meetings of the unhoused
service providers group.

City-wide, Eastern Gilroy,

R/EACAP
Minimum of 3 medium of outreach. Scheduled service provider meetings throughout the planning period.

9.2 p. 531 of 1163
Affirmatively Furthering Fair Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 171
HE Programs or
Other Activities Specific Commitment Timeline Geographic Targeting 2023 – 2031 Metric website. This information will also be provided through the various outreach methods in Program G - 5.
• Revamping the unhoused service providers network which consists of monthly meetings with direct unhoused service providers in the City. The network serves to increase collaboration and partnership among service providers and the City, to connect the unhoused with services. The monthly meetings serve to coordinate with service providers regarding the needs of the unhoused community, inform and coordinate with events, and collaborate on outreach efforts.

G - 7: Bilingual
Engagement
Given the City’s large Hispanic population, the City will increase Spanish language engagement within city services and through translation of outreach materials and interpretation of housing opportunities. Translation of outreach materials is included in both programs G - 3 and G - 5.

In August 2022 the City expanded its collective bargaining bilingual pay system to increase the number of bilingual staff available to assist the Spanish-speaking community. The City will advertise its collective bargaining unit bilingual pay benefits to attract new staff that can converse with the City’s Spanish speaking population.

Immediately upon adoption of
the Housing Element.

Eastern Gilroy, R/EACAP Minimum of 3 medium of outreach. Monthly service provider meetings throughout the planning period.

G - 8: Help
Center Webpage
In partnership with local nonprofit organizations, the City will develop a Housing Help Center webpage to provide a centralized resource for tenants and landlords to receive information on local laws, assistance to apply for rent relief, and legal aid.

This webpage will consolidate existing information on the City’s website with additional information provided by local service providers to best serve the needs of the Gilroy community.

By end of Q4 2024 Citywide The City will advertise the Housing Help Center to at least 100 residents each year through the City’s community outreach efforts.

9.2 p. 532 of 1163
Constraints on Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 172

CITY OF GILROY

HOUSING ELEMENT
6TH CYCLE

CONSTRAINTS ON HOUSING

9.2 p. 533 of 1163
Constraints on Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 173
Constraints on Housing
There are a wide variety of factors that influence whether, where, when, how, and what type of housing is constructed. While many factors enable, guide, and even incentivize housing construction, almost all also pose some sort of limitation or constraint as well. Land use policies and regulations are necessary but, by definition, establish limits on growth and development. These limits work with, influence, and are balanced by market forces.

There are generally two types of constraints: governmental and nongovernmental.

Governmental constraints include the policies, regulations, and procedures that directly affect housing. This includes the goals, policies, and programs of the General Plan and the development standards and requirements of the Zoning Ordinance and other land use ordinances. Nongovernmental constraints include those factors that are beyond the direct control and authority of the City.

This section identifies and evaluates those factors that may pose significant constraints or burdens that may limit or constrain the production of housing to meet local and regional housing needs and the goals and objectives of the General Plan. Such constraints, particularly those that limit the construction of or fair access to affordable housing, must be addressed with clear, measurable, and timely programs.

Governmental Constraints
Governmental constraints can limit or deter the operations of the public, private, and nonprofit housing development sectors, make it difficult to meet the demand for housing, and limit housing supply in a region. Such constraints can limit access to housing mobility and housing choice or prevent lower-income segments of the population from having adequate housing opportunities. Governmental constraints may include, but are not limited to, land use controls, development standards, local processing and procedures, and permitting fees.

Land Use Controls
General Plan
The City of Gilroy adopted an updated General Plan in November 2020. The Gilroy 2040 General Plan is a comprehensive, long-range general policy document that expresses the community’s vision and establishes eight guiding principles for development. One of the guiding principles includes encouraging a mix of housing types to create diverse neighborhoods to meet the needs of all residents. Among other efforts, the Gilroy 2040 General Plan allows for an increase in housing by creating a new Mixed-Use land use designation and removing the maximum density specified for the High-Density Residential land use area. The Land Use Element of the General Plan identifies the location, distribution, density, and intensity of land use within the City. The Environmental Impact Report (EIR) for

9.2 p. 534 of 1163
Constraints on Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 174
the 2040 General Plan analyzed the development potential of the plan for up to 6,477 new housing units and an additional population of 19,756.34 Figure 44: Gilroy Land Use Map
There are seven residential land use designations in the Gilroy General Plan, as follows:
• Hillside Residential (HR): This designation is generally applied to developable hillside areas with slopes of 10 percent to 30 percent. Developments in these areas must follow special design and siting criteria to preserve the sensitive hillside environment together with the views and vistas of surrounding hillsides, hilltops, and ridgelines. The permitted density is 0 to 4 dwelling units per net acre (du/ac).

The implementing zone is the Residential Hillside (RH) district. • Low Density Residential (LDR): This is the most common residential land use designation in Gilroy. It is applied to areas of predominantly single-family detached dwellings, with typical lot sizes ranging from 5,000 square feet to 7,000 square feet.

Appropriate residential uses include single-family detached homes and secondary (“accessory”) dwelling units (ADU) that comply with City standards. The permitted density is 3–8 du/ac. The implementing zones are R1 and R2. 34Final Gilroy 2040 General Plan EIR. https://www.cityofgilroy.org/DocumentCenter/View/11308/Draft-EIR---Gilroy-2040-GeneralPlan-?bidId=

9.2 p. 535 of 1163
Constraints on Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 175
• Medium Density Residential (MDR): This designation is intended primarily for multifamily attached structures (townhomes, condominiums, and apartment buildings). Buildings are typically two to three stories tall. This designation is typically applied to transition areas between lower-density neighborhoods and higher-density developments or commercial areas. The permitted density is 8–20 du/ac. The implementing zone is R3. While the R3 zone currently only allows 8–16 du/ac, it will be updated in the comprehensive zoning update to allow for 8–20 du/ac (Program B - 2).
• High Density Residential (HDR): This designation allows higher density attached housing types (apartments and condominiums), often within walking distance of commercial areas. The predominant housing type is multifamily dwellings, such as apartments or condominiums, with buildings typically comprising two or more stories. The permitted density is 20+ du/ac, with no maximum density or floor area ratio (FAR) requirements. The implementing zone is R4. The R4 zone currently allows for 20–30 du/ac, and the upper limit will be removed in the ongoing comprehensive Zoning Ordinance update to ensure consistency with the General Plan (see Program B - 2).
• Mixed Use (MU): The purpose of this designation is to encourage a mix of retail, office, and high-density residential uses. Mixed use could also include mixed-use commercial (e.g., retail and office). Multi-story structures and more intense uses should be located at major intersections and lower intensity uses, adjacent to neighborhoods. Street-level frontage of mixed-use projects shall be developed with pedestrian-oriented, typically commercial, uses. Residential uses can be integrated on the same site with other uses in either a vertical or horizontal design. Standalone residential uses are not allowed. The permitted density is a minimum of 20 and a maximum of 30 du/ac. The implementing zones are within the Downtown Specific Plan area and the mixed-use corridor along First Street. As a part of its comprehensive code update, the City is in the process of creating a zoning district for the mixed-use First Street corridor with the anticipated completion in 2023 (Program B - 2). Any mixed-use development within the First Street mixed-use corridor will be entitled in accordance with the development standards set forth in the Zoning Ordinance and the density allowance per the 2040 General Plan. The design of projects will be subject to the City’s existing objective development design standards until the First Street Corridor mixed-use design and development standards are adopted.
• Rural County (RC): The purpose of this designation is to preserve rural residential, hillside, and productive agriculture land uses located outside areas planned for urban development. Allowed uses include rural residential, grazing, active agricultural production, associated agricultural processing, sales, and support uses.

Typical building types include low-intensity structures associated with farming and agricultural processing and sales. One single dwelling unit per parcel is allowed. The implementing zone is RR.

9.2 p. 536 of 1163
Constraints on Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 176
• Neighborhood District (ND High, ND Low): The purpose of these designations is to encourage compact, complete, neighborhood-style development. Traditional single-family uses will comprise a substantial portion of these districts. Commercial and medium- to high-density residential uses should be clustered to form neighborhood centers. Neighborhood District High and Low may use a Neighborhood Commercial (NC) designation to designate land in neighborhood centers to encourage low-intensity commercial uses that cater directly to residents in the immediate neighborhood. The 0–7 du/ac category is intended for singlefamily detached dwellings with varying lot sizes. The 7–9 du/ac category is intended for a combination of two-family and some single-family detached dwellings. The 9– 16 du/ac category is intended to accommodate a combination of small-lot and attached single-family dwellings, as well as multifamily dwelling options. The 16–30 du/ac category is intended to provide a variety of attached single-family and multifamily residential styles of development. The implementing zone is ND. o The Neighborhood District land use designation is generally applied to vacant land that is currently outside the City’s Urban Service Area (USA) but within the City’s Urban Growth Boundary (UGB) area. The UGB area applies to land within the Planning Boundary/Sphere-of-Influence that is intended for urbanization at some point in the future. There are two designated neighborhood districts, one in the north and one in the south, that are currently outside of the USA. The City is in the process of requesting approval from the Santa Clara County Local Agency Formation Commission (LAFCO) to bring approximately 54 acres of unincorporated county land into the City’s USA. The land is located just outside City limits to the north. The City also received a preliminary application for a USA amendment for land located just outside City limits to the south. If the USA is amended and the land is eventually annexed into the City (a lengthy two-step process), the property would be subject to the City’s inclusionary policies for the Neighborhood District.
o Each Neighborhood District development is required to construct a minimum of 15 percent of its units at affordable prices. Specific requirements regarding the level of affordability were contained in the City’s Residential Development Ordinance (RDO) policy. However, this policy is no longer in effect due to state legislation (e.g., Senate Bill [SB] 330) and the implementing ordinance will be repealed in accordance with Program B - 1. To ensure compliance with state law, and provide more comprehensive affordability benchmarks, Program A - 5 is included to review and revise the Neighborhood District Policy. Program A - 11 will include analyzing potential adoption of an Inclusionary Housing Policy that would apply to properties outside the Neighborhood District planning area. o Table 59 displays the target densities for both low and high Neighborhood District designations. Neighborhood Districts include the Hecker Pass Specific Plan area and the Glen Loma Ranch Specific Plan area, which are both under development in the planning period. The rows denote the maximum or

9.2 p. 537 of 1163
Constraints on Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 177
minimum percentages of the land area within this land use designation that must fall within the specified density.
o Neighborhood District target densities and inclusionary requirements may act as a potential constraint to housing; however, the City has found that they do not discourage development. As a part of Program A - 5, the City is revising Neighborhood District standards to no longer rely on the RDO and is updating the Neighborhood District’s inclusionary housing policy.

Table 59: Neighborhood District Target Densities
0-7 du/ac 7-9 du/ac 9-16 du/ac 16-30 du/ac
Low 82% max. 5% min. 10% min. 3% min.

High 60% max. 5% min. 25% min. 10% min.

Source: City of Gilroy 2040 General Plan.

Hecker Pass Specific Plan
The Hecker Pass Specific Plan projects the development of 521 housing units. The Specific Plan designates three “clusters” for residential development: North Cluster (57 units), West Cluster (205 units), and East Cluster (259 units). The Specific Plan aims to provide a variety of housing types in each cluster, but offers some flexibility in how that variety is achieved. The Specific Plan gradually transitions the intensity of development from the Village Green project into the Specific Plan area, with more intensive development on the eastern side of the plan as it moves from rural to urban. The Hecker Pass Specific Plan was approved before inclusionary housing policies were adopted, and thus was not subject to the Neighborhood District Policy’s affordable housing requirement.

Glen Loma Ranch Specific Plan
The Glen Loma Ranch Specific Plan area is approximately 392 acres located between Santa Teresa Boulevard and the Uvas Creek corridor. The project includes a maximum of approximately 1,693 residential units in up to 17 neighborhoods comprising detached singlefamily residences, attached townhomes, apartments, and senior-only units. Under the Neighborhood District Policy, 15.1 percent of units will be affordable to very low-, low-, and moderate-income households.

Downtown Specific Plan
The Downtown Specific Plan contains six districts with the purpose of creating a pedestrianoriented and economically vibrant downtown. Adopted in 2005, the Downtown Specific Plan anticipated potential for development of 1,576 new residential units over 20 years. Mixed uses and residential development above the ground floor are encouraged in the Downtown Specific Plan. The Downtown Specific Plan allows 100 percent commercial use in all of its zones. Mixeduse residential is encouraged but not required and could include mixed-commercial (e.g., retail and office). Although 100 percent commercial use is allowed, City staff have not seen a demand

9.2 p. 538 of 1163
Constraints on Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 178
for new 100 percent commercial projects. The exception to this is new commercial uses occupying existing commercial buildings that don’t require significant upgrades. Residential dwelling units are permitted by-right in all Downtown Specific Plan districts on the second story and above.

Downtown Historic District(DHD)
This district is suitable for the improvement and maintenance of existing commercial structures or the conversion to or construction of new mixed-use development. Residential mixed-use projects are encouraged. The Downtown Historic District allows commercial and mixed-use projects, both of which have a maximum FAR of 2.5. The minimum density for the residential component of mixed-use projects is 20 du/ac. Residential units are permitted byright on the second story or above in the Downtown Historic District. A conditional use permit is required for residential uses on the first floor.

Downtown Expansion District (DED)
This district is suitable for the improvement and maintenance of existing commercial structures or the construction of or conversion to new mixed-use development. Residential mixed-use projects are encouraged. The Downtown Expansion District allows commercial and mixed-use projects, both of which have a maximum FAR of 2.5. The minimum density for the residential component of mixed-use projects is 20 du/ac. Residential units are permitted byright on the second story or above in the Downtown Expansion District. A conditional use permit is currently required for residential uses on the first floor.

Approximately 29.9 percent of the very low-income opportunity site units and approximately

44.9 percent of the moderate-income opportunity site units are located in the City’s Downtown Expansion District (20.4% and 44.9%) and First Street Corridor District (9.5% and 0%). To increase the likelihood that sufficient RHNA units are built in these two districts, the City added Program E - 12 (Downtown Expansion District and Mixed-Use Corridor Flexibility). This Program will allow 100 percent residential projects in the Downtown Expansion District and flexibility for non-residential units in the First Street Mixed Use Corridor, should projects meet certain criteria or provide housing for special needs groups (e.g., extremely low-income).

Civic/Cultural Arts District (CCA)
This district is suitable for the development of new multi-use civic, cultural and civic-serving uses. The Civic/Cultural Arts District also allows commercial and mixed-use projects.

Residential mixed-use projects are encouraged but not required. Residential units may be allowed on the ground floor if they are located between Eigleberry Street and Church Street and behind a business. From Monterey Street to Church Street, commercial and mixed-use projects have a maximum FAR of 1.5, and from Church Street to Dowdy Street there is a maximum FAR of 1.0.

9.2 p. 539 of 1163
Constraints on Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 179
Transitional District (TD)
This district is suitable for the conversion of existing residential structures to commercial uses and for the development of new mixed-use and stand-alone residential projects. Commercial and mixed-use projects have a maximum FAR of 1.5. Stand-alone residential projects are at most 20 du/ac.

Cannery District (CD)
This district is suitable for the development of new mixed-use and stand-alone residential projects. Commercial and mixed-use projects have a FAR of 2.0. The minimum density for the residential component of mixed-use projects is 20 du/ac. Stand-alone residential projects must develop at a density ranging from 20 to 40 du/ac.

Gateway District(GD)
This district is suitable for the development of new mixed-use and stand-alone residential projects. Commercial and mixed-use projects have a maximum FAR of 0.75. Stand-alone residential projects can be developed at 30 du/ac.

Downtown Specific Plan Development Standards
Table 60 displays the allowable densities and development standards in each of the Downtown Specific Plan districts. The districts also generally have very permissive development standards, including zero-foot minimum setbacks, and height limits of 50 feet or 4 stories in all areas not fronting Railroad Street.

The passing of Assembly Bill (AB) 2097 will reduce constraints to development as it prohibits any minimum parking requirement on any residential, commercial, or other development project located within one half-mile of high-quality public transit. Prior to the passage of AB 2097, the Downtown Specific Plan area already had lower parking requirements than other residential areas in the City. For projects not subject to AB 2097, the parking requirements for residential units are 1 space per unit and 1 guest space per 6 units for units that are up to 800 square feet. If greater than 800 square feet, the requirement is 1.5 spaces per unit and 1 guest space per 4 units. Parking standards are often a potential constraint to development.

However, in Gilroy, they are appropriate and not excessive, given Gilroy’s suburban context outside urban job centers to the north.

9.2 p. 540 of 1163
180
Table 60: Downtown Specific Plan Development Standards
District
Lot
Requirements
Lot Size in
Square Feet
(min)
Yard Requirements
(Setbacks in Feet Measured from Property Line)
(min/max)
Height
Requirements
(max)
FAR Density
Building Form
Front
Side
(Adjacent
to Street)
Side (All
Other Side
Yards)
Rear Feet6 Stories7
Street Front
Building
Height
(Min Feet)
Third and
Fourth Floor
Setback
Required
Downtown
Historic
District (DHD)
N/A 0/15 0/101 0/none2 0
3 /none 50 4 2.5 20 du/ac
(min) 25 Yes
Downtown
Expansion
District (DED)
N/A 0/15 0/101 0/none2 0
3 /none 50 4 2.5 20 du/ac
(min) 25 Yes
Civic/Cultural
Arts District
(CCA)
N/A 0/none 0/none1 0/none2 0/none 50 4 - N/A8 25 Yes
Transitional
District (TD) N/A - - - - 40 3 1.55
20 du/ac
(max) N/A No
Cannery
District (CD) N/A 0/15 10/none1 0/10 0/none 50 4 2.05
20-40 du/ac
(min/max) 25 No
Gateway
District (GD) N/A 15/none 15/none 15/none 10/none 40 3 0.755 30 du/ac
(max) N/A No

9.2 p. 541 of 1163
Constraints on Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 181
Table 61: Downtown Specific Plan Development Standards (Special Circumstances) District
Eigleberry Street to Church Street Church Street to Dowdy Street East of Eigleberry Street West of Eigleberry Street Front
Side
(Adjac
ent to
Street)
Side (All
Other
Side
Yards)
Rear Front
Side
(Adjac
ent to
Street)
Side
(All
Other
Side
Yards)
Rear Front
Side
(Adjac
ent to
Street)
Side
(All
Other
Side
Yards)
Rear Front
Side
(Adjac
ent to
Street)
Side
(All
Other
Side
Yards)
Rear
Civic/Cultural
Arts District
(CCA)
0/10 10/non
e
0/10 10/non
e
20/non
e
10/non
e
10/non
e
10/non
e
- - - - - - - -
Transitional
District (TD) - - - - - - - - 0/15 10/none
1 0/none
2 0/5 154
/none
10/non
e
5/none 10/no
ne
Source: City of Gilroy Zoning Ordinance
1 To be reviewed for vehicular sight distance.
2 To be reviewed by staff to ensure compliance with urban design principles. 3 Rear yard setback for parcels east of Monterey Street, between Lewis and Seventh is 51 feet to accommodate drive access and parking. 4 Ten-foot setback to property line allowed with a porch. 5 Use floor area ratio to determine project size for commercial and mixed-use development and use residential density to determine project size for stand-alone residential development. Residential use is only allowed as part of a mixed use development within the DHD, DED and CCA districts. Standalone (multifamily) residential development is only allowed within the CD, GD and TD districts. See Article XIV for additional specifications. 6 The planning division manager may approve architectural features such as tower elements, elevator service shafts, and roof access stairwells which extend up to 10 percent above the height limit.
7 New buildings should be no more than two stories higher or lower than neighboring buildings. If higher or lower buildings are desired, the massing should be stepped so as to create a smooth transition.
8 No min/max density. See Downtown Specific Plan for additional specifications. Residential apartments, townhomes, and live/work units above/behind ground floor are only allowed between Eigleberry Street and Church Street

9.2 p. 542 of 1163
Constraints on Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 182
Zoning Ordinance
The Zoning Ordinance, Chapter 30 of the Gilroy City Code, is the primary tool for implementing the land use designations in the Gilroy 2040 General Plan. The Zoning Ordinance provides controls over land use. The following discussion represents standards in the Gilroy Zoning Ordinance as of April 2023. In conformance with the 2040 General Plan and current state housing law, a comprehensive update of the Zoning Ordinance is anticipated to be complete by the end of 2023. As such, some existing standards identified in this analysis will be updated with the new Zoning Ordinance and in accordance with state law. Known instances are noted and the appropriate programs are referenced. Existing residential development standards are shown in Table 62.

The City’s General Plan allows for a range of densities and housing types to meet the needs of all income levels. AB 2348 established “default” density standards. If a local government has adopted density standards consistent with the established population criteria, sites with those density standards are accepted as appropriate for accommodating the jurisdiction’s share of regional housing need for lower-income households. Pursuant to AB 2348 and the 2020 decennial census, Gilroy is considered a “jurisdiction within a metropolitan county” with a “default” density for affordable units of 30 du/ac. Densities of at least 30 du/ac are allowed in the High-Density Residential zone and Neighborhood District. Densities of 30 du/ac are also allowed in the First Street mixed-use corridor and specified Downtown Specific Plan designations, described above.

Table 62 displays the existing residential standards as outlined in the City’s Zoning Ordinance as of April 2023. Note that there are instances where state law may supersede the current standards in the Zoning Ordinance. If there is a conflict, state law supersedes the Zoning Ordinance, and staff will process development applications accordingly. For instance, SB 9 applies to many parcels in the R1 zone and allows them to have up to four units, though the current maximum density is one dwelling unit per lot. SB 9 facilitates the creation of up to four housing units, comprised of a duplex with an ADU and a junior ADU or two primary units plus an ADU and a junior ADU. Program A - 10 provides more flexibility than SB 9, by allowing triplexes and fourplexes as an alternative design to a traditional duplex with an ADU or a junior ADU. This program will also encourage the development of missing middle housing throughout the City, including high-resource areas primarily comprising detached singlefamily residences. A discussion of SB 9 is located in the Senate Bill 9 section of this constraints chapter. Furthermore, the City has a dedicated webpage that provides SB 9 information (e.g., more permissive development standards) to the public and potential applicants.

Residential Densities
The Zoning Ordinance will be updated in 2023 so that development standards permit the allowed densities under the 2040 General Plan. To facilitate consistency, the consultant who prepared the City’s new General Plan is also preparing the Zoning Ordinance update.

9.2 p. 543 of 1163
Constraints on Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 183
Planned Development Exceptions
Most single-family residential projects are approved ministerially, while, hillside residential single-family and multifamily residential projects that comply with objective development and design standards can generally be approved through an administrative staff review process, without the need for public hearings. However, applicants can request smaller lot sizes, increased height, and decreased setbacks (for example) through the Planned Development process, which is outlined in the Zoning Ordinance. The Planned Development process allows for more economical and efficient land use through diversification in development standards for buildings, structures, and open spaces. Public hearings are required in exchange for this flexibility.

Lot Size
The Zoning Ordinance will be updated in 2023 to be consistent with the lot sizes described in the 2040 General Plan. For example, the typical lot size for the low-density single-family residential land use designation in the 2040 General Plan ranges from 5,000 square feet to 7,000 square feet.

Height Limits
The City has two types of height limits in residential districts: a maximum height measured in stories and an absolute height. Height limits in the R3 zone are 3 stories or 45 feet. For the R4 zone, the height limits are 6 stories or 75 feet, whichever is less. Parking garages that are aboveground would count toward the story limit, while those that are belowground do not.

The height limits do not constrain development from reaching their prescribed General Plan densities (8-20 du/ac for medium density sites and 20+ du/ac for high density sites).

Setbacks
All residential zones have setbacks, which are the minimum distances between a structure and a lot line. Setbacks in Gilroy are largely uniform between the residential zones, with 26-foot front setbacks, 6- to 12-foot interior side setbacks, 21-foot street side setbacks, and 15-foot rear setbacks. While all setbacks reduce the amount of land that is developable on a site, the setbacks do not constrain projects from reaching the maximum housing density in a zone.

Floor Area
The City of Gilroy does not regulate residential floor area, other than for ADUs. The ADU Ordinance will be updated in 2023 (and in future years) to be compliant with current state law.

Although not required by state law, the City will increase the allowable floor area for ADUs from 1,000 square feet to 1,200 square feet through Program A - 15.

Lot Coverage
The City of Gilroy does not regulate residential lot coverage, other than restricting the amount of paving in the front yard to 50 percent maximum.

9.2 p. 544 of 1163
Constraints on Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 184
Table 62: Residential Standards (2022)
District
Lot Requirements
Lot Size in Square
Feet (Lots Using
Street Standards
Adopted in
February 2006)1
Yard Requirements
(Minimum Setbacks in Feet. Property Lines Adjacent to Streets Measured from the Face of Curb)
Height
Requirements Density
Front
Front (Lots on
Bulb of Cul-desac)
Side
(Adjacent to
a Street)
Side (All
Other Side
Yards)
Rear
Rear (Yards
Backing onto
Street)
Feet Stories Maximum Density Units per
Acre
A1 20 acres 262 222 21 12 156 26 35 2 Maximum of one dwelling unit per lot RR 2.5 acres 262 222 21 12 156 26 30 2 Maximum of one dwelling unit per lot R1 6,660 sf 262 222 21 6
3 156 26 35 2
Maximum of one dwelling unit
per lot (not including units permitted
through SB 9)
3 – 7.25
R2 8,8804sf 262 222 21 6
3 156 26 35 2
One dwelling unit per 4,000 square
feet of land to a maximum of two
units per lot
3 – 9
R3 8,880 sf 262 222 21 12 156 26 455 3
One dwelling unit per two 2,722
square feet of lot area 8 – 16
R4 13,320 sf 262 222 21 12 156 26 755 6
One dwelling unit per 1,452 square
feet up to a maximum site area of
2,178 square feet per unit
20 – 30
HR N/A + + + + + + 30 2
Determined by the average slope
with a maximum of two acres/unit
ND* * * * * * * * * * * *
Source: Gilroy City Code Chapter 30.
1 See Zoning Ordinance for lot size requirements for lots using street standards adopted prior to 2006. 2 Garage vehicular entrances shall be set back from the property line such that they have a minimum 18-foot-long driveway measured from the back of the sidewalk. 3 For dwellings located within new subdivisions (after the effective date of the ordinance codified in this chapter), containing five or more lots, the total width of the two side yards for any one lot in an R1 or R2 district must equal 12 feet. For structures in existence on the effective date of the ordinance codified in this chapter, a 6-foot side yard setback shall be maintained, unless a smaller side yard has been allowed by a variance, planned unit development, or preexisting, nonconforming use. 4 7,000 square feet for preexisting lots created prior to September 15, 1983; 6,000 square feet for one single-family dwelling. 5 For R3 and R4 lots proposed to be developed with one single-family residence as the primary use, the height of the residential dwelling unit shall not exceed two stories and 35 feet.

9.2 p. 545 of 1163
Constraints on Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 185
6 Rear yard setbacks may be reduced to 10 feet to accommodate a 5-foot encroachment for rear yard patio covers. * Residential site and building requirements shall be established by the master plan or specific plan for the neighborhood district area in which the property is located. + All setback requirements shall be as specified in the planned unit development (PUD) approval which shall be obtained according to the provisions of section 30.50.50.

9.2 p. 546 of 1163
Constraints on Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 186
Parking
The provision of parking is a significant cost for all forms of development. High parking requirements reduce the potential land available for development and increase the cost of development. Table 63 displays the parking requirements for residential developments in Gilroy. Parking requirements often pose a potential constraint on development. However, construction of recent developments, including below market-rate units, demonstrate that Gilroy’s existing parking requirements are appropriate and are not an unreasonable constraint.

In addition to these minimum standards, Gilroy has a maximum parking requirement. Per Gilroy City Code Section 30.31.30 (a), the maximum parking requirement is 10 percent above those listed in the parking schedule, and any parking spaces beyond the 10 percent must be offset with an equal amount of landscaping.

Table 63: Residential Parking Standards (2022)
Type of Residential Development Required Parking Spaces (off street) Single- and two-family dwellings Two stalls per dwelling unit, one of which shall be a covered carport or garage (each space must be at least 10 feet by 20 feet).

Multiple family dwellings One and one-half stalls per one-bedroom or two-bedroom dwelling unit and two stalls for each unit having three or more bedrooms or rooms which could be used as bedrooms, plus one stall for every four units for guests. One stall for each unit shall be covered with a garage or carport.

Accessory dwelling units (detached) One stall per unit* Downtown Specific Plan Residential Parking Requirements Residential units < or equal to 800 sq. ft One space per unit plus one guest space per six units Residential units > 800 sq. ft. 1.5 spaces per unit plus one guest space per four units Source: Gilroy City Code Chapter 30.
* A parking stall will not be required for an accessory dwelling unit that meets any of the following criteria:

1. The accessory dwelling unit is created as a result of the conversion of existing area of the single-family residence or existing permitted single-family residential accessory structure.

2. An existing single-family residential garage, carport, or parking structure is converted or demolished to accommodate an accessory dwelling unit in the same location.

3. The accessory dwelling unit is within 0.5-mile walking distance of a public transit station, such as a bus stop or train station.

4. The property is in an architecturally and historically significant historic district.

5. On-street parking permits are required in the area but not offered to the occupant of the residential accessory dwelling unit.

6. A car share vehicle is located within one block of the accessory dwelling unit.

Cumulative Effect of Development Standards
The City of Gilroy has permissive standards for development, especially in its Downtown Specific Plan area. The cumulative effect of development standards is not likely to constrain the ability of developers to achieve densities on site development. This is evident in the entitled

9.2 p. 547 of 1163
Constraints on Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 187
and pending projects analysis (see Table 79). Additionally, many recent projects have been developed at the City’s standards and were able to achieve moderate and high densities.

Multifamily developments in R4 and Downtown Specific Plan Zone areas have consistently been approved or constructed to the maximum density (or higher pursuant to state Density Bonus Law or other provisions). Recently proposed or approved developments include:
• A four-story, 120-unit affordable development on 3.4-acre parcel in the R4 zone (35 du/acre)
• A 100-unit affordable development on a 3.9-acre parcel in the R4 zone (25 du/acre) • A 75-unit development on a 1.86-acre parcel in the Gateway District in the Downtown Specific Plan (40 du/acre)
• A 120-unit development on a 3.9-acre parcel in the R4 zone (30.8 du/acre) • A 268-unit development in the Downtown Expansion District in the Downtown Specific Plan on 6.8 acres (38.7 du/acre)
• A preliminary proposal for a 94-unit affordable development in the Downtown Gateway District on 2.9 acres (32.4 du/acre)
These and other entitled and pending projects include a total of 62 very low-, 401 low-, and 3 moderate-income units.

Developers, residents, and other stakeholders participated in the public engagement process for the Housing Element Update and provided suggestions for several aspects of the City’s development standards that could be changed to facilitate the production of housing. These included removing parking minimums, rezoning nonresidential areas to allow residential development, and increased density.

In the effort to reduce and/or eliminate constraints identified in Gilroy’s land use controls, the City will study and consider adopting a density bonus above state law (A - 12), amend the Zoning Ordinance to ensure that the General Plan maximum densities are achievable by the implementing zones (B - 2), review and revise development standards to ensure objectivity (B - 6), and evaluate development standards for all zones including the Downtown Specific Plan zones for potential constraints (B - 7). Program A - 10 (Missing Middle / Middle Income Housing) was amended to allow triplexes and fourplexes on corner lots in the R-1 and R-2 districts with a minimum 6,000 sf lot size. Under Program A - 15 (ADU Ordinance Updates), the City will replace the ADU deed restriction requirement with an owner affidavit form that does not require recordation at the County and increase the allowable ADU floor area from 1,000 square feet to 1,200 square feet. Program E - 12 (Downtown Expansion District and Mixed-Use Corridor Flexibility) was added to allow 100 percent residential projects in the Downtown Expansion District and flexibility for non-residential uses in the First Street Mixed-Use Corridor, should projects meet certain criteria or provide housing for special needs groups (e.g., extremely low-income).

9.2 p. 548 of 1163
Constraints on Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 188
Density Bonus
California Government Code Sections 65915 through 65918, known as the density bonus law, were enacted to encourage developers to build affordable housing by requiring local governments to provide meaningful incentives in exchange for those affordable units.

The City implements density bonuses through Section 30.46.40 of the Gilroy City Code. This section of the Gilroy City Code references and incorporates the state density bonus law. The City is fully compliant with state density bonus law, and knows how to properly implement it if requested by a developer. Multiple projects have utilized the density bonus, including the Jemcor Apartments (130 units), the Hecker Pass Apartments (100 units), and the First and Kern Apartments (120 units).

The City is including Program A - 12 to study and adopt a density bonus policy beyond what is required by state law to further encourage development of affordable housing. The program will specifically consider additional incentives for households with special needs such as large households, extremely low-income households, households with developmentally disabled individuals, and farmworker households.

Providing for a Variety of Housing Types
Table 64 shows the allowed uses within residential zones in the City’s Zoning Ordinance. In some instances, state law also affects the uses that are allowed in a zone. If there is a conflict, state law supersedes the Zoning Ordinance. For instance, SB 9 applies to many parcels in the R1 zone, and allows them to have up to four units, inclusive of an ADU and a junior ADU. A discussion of SB 9 is located in the Senate Bill 9 section of this constraints chapter.

As discussed in the following section, ADUs and junior ADUs are allowed in all residential zoning districts under Section 30.54 of the City’s Zoning Ordinance. Single-family residential zoning includes four districts: A1, RR, RH, and R1. Single-family units are permitted as a matter of right in all single-family residential districts. Single-family dwellings are permitted as a matter of right in all multifamily residential districts, except for mixed-use zones in the Downtown Specific Plan area. Single-family development in the R3, R4 and RH zones has the potential to prevent the achievement of the planned densities.

Multifamily residential zoning includes the R2, R3, and R4 districts. Duplexes are permitted as a matter of right in the R2, R3, and R4 districts. Duplexes are also allowed in the R1 district on corner lots of a certain size, when meeting certain conditions; however, this existing standard has been superseded by current state law (SB 9), which is more permissive. Condominiums and townhouses are permitted as a matter of right in the R3 and R4 districts; they are also permitted in the RH district when conforming to the density limits through clustering. Multiple family buildings are permitted as a matter of right in R3 and R4 districts.

The City of Gilroy has also established a Neighborhood District zone. Land in the Neighborhood District may be used as specified by a Master Plan or Specific Plan adopted for each Neighborhood District area. In addition to including 15 percent of the units as affordable,

9.2 p. 549 of 1163
Constraints on Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 189
each development must provide compatible uses such as parks, schools, and neighborhoodserving commercial facilities.

The City is including several programs in the Housing Element to further encourage a variety of housing types across the City. One of these programs includes adoption of an affordable housing policy to encourage and incentivize development of affordable housing (Program A - 12). Another program may incentivize the production of missing middle housing, by allowing ministerial approvals for triplexes and fourplexes on corner lots in R1 and R2 zones that comply with the City’s objective design standards (Program A - 10). SB 9 facilitates the creation of up to four housing units, comprised of a duplex with an ADU and a junior ADU or two primary units plus an ADU and a junior ADU. Program A - 10 provides more flexibility than SB 9, by allowing triplexes and fourplexes as an alternative design to a traditional duplex with an ADU or a junior ADU. This program will also encourage the development of missing middle housing throughout the City, including high-resource areas primarily comprising detached single-family residences. Additionally, the City is considering a program to incentivize micro-units (Program E - 5).

9.2 p. 550 of 1163
Constraints on Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 190
Table 64: Residential Use Table (2022)
Housing Types Permitted A1 RR R1 R2 R3 R4 RH ND
Accessory Dwelling Unit1-- X X X X X X *
Condominiums -- -- -- -- X X X *
Duplex -- -- X
2 X X X -- *
Mobile Home Park -- -- C C X X -- *
Multi-Family Building -- -- -- -- X X -- *
Residential Care Homes (> 6 Residents) -- C C C C C C * Residential Care homes (≤ 6 residents) -- X X X X X X * Single-Family Dwelling or Modular Home X
4 X X X X X X *
Townhouse** -- -- -- -- X X X *
Emergency Shelters C C C C C C C *
Supportive and Transitional Housing3 X X X X X X X *
Source: City of Gilroy Zoning Ordinance, Section 11. 10.

Notes:

X = Unconditionally Permitted; C = Permitted only with conditional use permit granted by planning commission; -- Not permitted * = Refer to master plan or specific plan adopted for the neighborhood district area in which the property is located. **= Program B - 7 is included to remove reference of condominium ownership in the definition of Townhome. 1 Accessory dwelling unit(s) and/or junior accessory dwelling units may be allowed subject to compliance with the regulations prescribed in Article LIV. 2 Notwithstanding units permitted by SB 9, a duplex dwelling is permitted when all of the following conditions are met:
(a) The duplex dwelling shall be located on a corner lot only; and (b) The corner lot shall have a minimum area of 8,000 square feet and be so designated for a duplex unit on a tentative and final map; and (c) The duplex shall not increase the overall density within any given land subdivision beyond the maximum of 7.25 dwelling units per net acre. 3 Supportive and/or transitional housing that serves more than six individuals, provides on-site services, and is licensed by the state as a group home shall only be allowed upon the granting of a conditional use permit.
4 One residential dwelling unit may be permitted on an A1-zoned parcel that has a minimum size of 20 acres or more. Subdivision of land for further development is not permitted without rezoning to another zoning district that implements the General Plan land use map.

9.2 p. 551 of 1163
Constraints on Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 191
Accessory Dwelling Units
ADUs provide additional housing opportunities for people of all ages and economic levels. The City of Gilroy permits ADUs on any residential parcel in any zoning district that permits residential or residential mixed-use development.

The City submitted its current ADU ordinance (Chapter 30.54) to the state in 2020 and worked with the state to ensure its compliance with state law at that time. The City will continue to work with the state to ensure future updates to the ADU ordinance (Program A - 15) remain in compliance when the legislature makes changes to ADU regulations (e.g., Government Code Section 65852.2).

The City is also including multiple programs to monitor, incentivize, and encourage ADU development across the City. This includes monitoring and tracking ADUs and their affordability (Program A - 6), adopting a set of pre designed plans (Program A - 7), financial incentives for ADUs restricted to lower-income households (Program A - 8), and encouraging the development of ADUs through education and marketing (Program G - 4). In addition, through Program A - 15 (ADU Ordinance Updates), the City will replace the ADU deed restriction requirement with an owner affidavit form that does not require recordation at the County and increase the allowable ADU floor area from 1,000 square feet to 1,200 square feet.

Senate Bill 9
Effective January 1, 2022, SB 9 requires ministerial approval of a housing development with no more than two primary units in a single-family zone, the subdivision of a parcel in a singlefamily zone into two parcels, or both. The City adopted two objective design standard policies for SB 9 projects on December 13, 2021, and revised them effective April 4, 2022, following additional interpretation by the state. Consistent with state law, the adopted standards are purely objective in nature, providing information to property owners on the SB 9 process and associated standards in Gilroy. The City’s SB 9 2-Unit Objective Design Standards Policy and the SB 9 Lot Split Objective Design Standards Policy both closely follow state law. The City website has readily available information regarding ADU and SB 9 applicability and standards.

The City’s SB 9 Policy and website will be updated under Program A - 10 noted below.

SB 9 facilitates the creation of up to four housing units, comprised of a duplex with an ADU and a junior ADU or two primary units plus an ADU and a junior ADU. The City is including Program A - 10 to provide more flexibility than SB 9 by allowing triplexes and fourplexes as an alternative design to the traditional duplex with an ADU or a junior ADU. This program will also encourage the development of missing middle housing throughout the City, including highresource areas primarily comprising detached single-family residences.

Emergency Shelters
An emergency shelter is housing with minimal supportive services for unhoused persons that is limited to occupancy of 180 days or less per calendar year by an unhoused person. No individual or household may be denied emergency shelter because of an inability to pay.

9.2 p. 552 of 1163
Constraints on Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 192
The City’s emergency shelter requirements are currently provided in the Performance Standards section of the Zoning Ordinance (Chapter 30.41) and the Residential Use Tables in Section 30.11.10. Current City Code does not meet state law requirements (Government Code Section 65583) and will therefore be amended through Program E - 3. These zoning amendments will be processed during the same meeting in which the City is adopting the Housing Element Update. The proposed zoning amendment will modify the definition of emergency shelters to include other interim interventions, including, but not limited to, a navigation center, bridge housing, and respite or recuperative care.

Currently, emergency shelters may be permitted in any zone with a conditional use permit; however, emergency shelters in the agriculture and residential zoning districts may only serve families. Through Program E - 3, the City will allow emergency shelters by-right in the City’s R4 and new mixed-use zone along First Street by removing the conditional use permit requirement in those zones. Program E - 3 will also remove the reference to families and amend standards related to on-site management, waiting and intake areas, and parking based on the number of staff only.

Based on the 2022 Point-in-Time Count, an estimated 208 homeless persons are located in Gilroy. At 200 square feet per bed, 208 beds could be accommodated in facilities totaling approximately 41,600 square feet of floor area to accommodate the City’s estimated unsheltered need.

The City has sufficient properties in the R4 and mixed-use zones to accommodate Gilroy’s unsheltered population. The R4 zone covers just over 16 acres on 25 parcels, including five sites and 13.7 acres currently identified in the sites inventory. The R4 zone is located in the transit accessible areas of the City and is within walking distance to support services (e.g., South County Compassion Center and Saint Joseph’s Family Center Food Center). The First Street Mixed-Use zone district encompasses approximately 71 acres on 87 parcels, including four sites and 3.1 acres currently identified in the sites inventory. The mixed-use zone is located along the First Street corridor, which contains a range of services. Surrounding uses and permissive development standards in the R4 and forthcoming mixed-use zone will make it feasible to develop or convert existing structures to shelter use in these two zones. In addition to the development of vacant parcels in the R4 and mixed-use zone, adaptive reuse of existing structures is another option for establishing shelter facilities without redevelopment of the properties. Low Barrier Navigation Centers Low barrier navigation centers (LBNC) are service-enriched shelters that are focused on moving individuals into more permanent housing. LBNCs provide temporary housing while case managers connect individuals experiencing homelessness to shelter, public benefits, and health services. Under the Housing for Homeless Act (2019), local governments are required to allow LBNCs by-right in areas zoned for mixed uses and nonresidential zones that permit multifamily uses.

Gilroy does not currently explicitly allow LBNCs in any zone, though this would not prevent their development if an application for one were received. Per Program E - 4, the City will

9.2 p. 553 of 1163
Constraints on Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 193
amend its Zoning Ordinance pursuant to Government Code Section 65583 to allow for LBNCs by-right in areas zoned for mixed uses and nonresidential zones that permit multifamily uses.

Modular Homes
The permitting of modular, or manufactured, housing on foundations is subject to the same development standards as conventional single-family units, consistent with Government Code Section 65852.3. The City of Gilroy permits modular homes by right in all residential zones that permit single-family dwellings by right.

Transitional and Supportive Housing
Supportive or transitional housing that serves up to six individuals is allowed by right in all residential zones. Supportive or transitional housing that serves more than six individuals, provides on-site services, and is licensed by the state as a group home is allowed in any zone upon the granting of a conditional use permit. While the conditional use permit may be a potential constraint on the development of group homes with more than six residents, the City has added Program E - 13 which will amend its Zoning Ordinance pursuant to Government Code Section 65651 to allow supportive housing by-right in zones where multifamily and mixed uses are permitted. The City has also added Program E - 10 to evaluate and address the potential constraint regarding the permit requirements for group homes in medium- and higher-density residential zones. The City has objective standards for these homes to add certainty to the development process. As a part of Program B - 6, the City’s objective standards will be reviewed and modified as necessary to ensure they are purely objective in nature.

Single-Room Occupancy Units
Single-room occupancy (SRO) residences are small, one-room units occupied by a single individual, and may either have a shared or private kitchen and bathroom facilities. SROs are rented on a monthly basis, typically without a rental deposit, and can provide an entry point into the housing market for extremely low-income individuals, formerly unhoused, and disabled persons. SRO units are not specifically defined or included in the City’s Zoning Ordinance; however, there is precedence for their allowance within the City.

The City of Gilroy has one SRO development, which opened in 2016. The 25-unit SRO project, the Gilroy Studios (26 units including a manager’s unit), was added to the Sobrato Transitional Apartments, aimed at serving the unhoused population in Gilroy. This project shows that there are no demonstrated constraints on the development of SROs in the City.

Residential Development Ordinance
The Residential Development Ordinance (RDO) was first established in 1979 to monitor the amount of residential growth in the City by limiting the number of dwelling units that could be built in a 10-year period. The RDO is a potential constraint on development; however, it has been made null by provisions of SB 330 and SB 8, both effective through 2030. The RDO limitations are not currently utilized by the City and will not be included in the City’s new zoning

9.2 p. 554 of 1163
Constraints on Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 194
ordinance, and thus do not pose a constraint to development. Program B - 1 requires the removal of the RDO as a part of the comprehensive zoning update.

Affordable Housing Policy
The City does not have an inclusionary policy in effect for the whole City. Although the City currently has an inclusionary housing requirement for developments in its Neighborhood District areas, the policy is limited to property with a Neighborhood District land use designation. The Neighborhood District Policy requires developments to construct a minimum of 15 percent of its units at affordable prices. Incentives for constructing affordable housing in the Neighborhood Districts include density bonuses, reduction in City standards (including zero-lot line developments, clustered housing on smaller lots, and smaller unit sizes), and reduction in road widths. All affordable units must be developed on-site and there is no option for an in-lieu fee. The lack of an in-lieu fee is a constraint to development and does not comply with Government Code Section 65850(g). Program A - 5 is included to revise the Neighborhood District Policy to ensure it is fully compliant with state law.

Similarly, though the Residential Development Ordinance (RDO) growth limits are no longer in effect due to state law, the RDO Exemption Policy was an effective tool for incentivizing affordable restrictions in a development. Portions of the RDO Exemption Policy were set up similarly to an inclusionary housing ordinance, by including resale controls and rental price controls for a minimum of 55 or 30 years, respectively, and specifying a minimum percentage of units for different affordability categories, as follows:
• At least 40% of units affordable to households below 60% of the AMI • At least 15% of units affordable to households between 60% and 80% of the AMI • At least 15% of units affordable to households between 80% and 100% of the AMI • No more than 30% of the units affordable to households between 100% and 120% of the AMI
Both the Neighborhood District Policy and the RDO affordability standards can be used as a benchmark for an affordable housing policy adopted by the City (Program A - 11). The City also understands that inclusionary housing often raises the cost of development by mandating a price subsidy. An inclusionary housing policy is a potential constraint on development.

Urban Growth Boundary and Urban Service Area
Per the City’s General Plan, “The Urban Growth Boundary (UGB) applies to land within the Planning Boundary/Sphere-of-Influence that is intended for urbanization at some point in the future. The UGB indicates the extent and direction of the City's future urban expansion and capital improvements planning. Lands outside the UGB are to be preserved for rural and agricultural uses.”
In 2016, voters passed Measure H, resulting in the UGB. The intent of the UGB is to protect agriculture and open space in the surrounding areas outside of the UGB. Urban development is not allowed outside of the UGB; only uses allowed in the open space designation per the

9.2 p. 555 of 1163
Constraints on Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 195
General Plan are allowed. Until December 31, 2040, lands outside the UGB can only be redesignated by a vote of the people, except for the following exceptions in which the City Council determines that doing so is necessary to comply with state law regarding the provision of housing for all segments of the community and makes each of the following findings based on substantial evidence, per the General Plan:
• That the land proposed to be brought within the UGB and/or redesignated is immediately adjacent to (i) the existing UGB; and (ii) available water and sewer connections; and
• That the proposed development will consist primarily of low- and very low-income housing pursuant to the Housing Element;
• That there is no existing vacant or undeveloped residentially designated land within the UGB to accommodate the proposed development and it is not feasible to accommodate the proposed development by redesignating lands within the UGB for low- and very low-income housing; and
• That the proposed development is necessary to comply with state law requirements for the provision of low- and very low-income housing and the area of land within the proposed development will not exceed the minimum area necessary to comply with state law.

An analysis by the City attorney at the time of the vote estimated that this would yield a reduction of 2,929 potential units compared to the City’s previous General Plan and 4,344 units to the draft General Plan update at the time.35
The City also has an Urban Service Area (USA). The USA is the land to which the City is committed to providing basic infrastructure and services for urban development. The USA is generally coterminous with the UGB. The City accepts applications for USA modifications in the month of July only. The USA is reviewed and amended by the Local Agency Formation (LAFCO) if desired by the City. At the time of the drafting of this document, the City is currently waiting for LAFCO’s decision on an USA amendment application for property north of Gilroy. The City also received an applicant request to amend the USA boundary south of Gilroy. These applications are a good indication of developer interest in Gilroy. The USA acts as a potential constraint to development within City boundaries, which has more permissive development standards than the unincorporated County. Despite this potential constraint, the City has capacity for new housing within the USA and UGB, and has increased residential densities in the Gilroy 2040 General Plan to accommodate any capacity lost under Measure H.

Furthermore, the UGB does not restrict the number or timing of permits within the USA or UGB.
35City Attorney’s Impartial Analysis of Measure H. https://sccvote.sccgov.org/sites/g/files/exjcpb1106/files/E110%20- %20Measure%20H.pdf

9.2 p. 556 of 1163
Constraints on Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 196
Development Review and Permitting Procedures
The efficiency and timing of a jurisdiction’s processes for review and approval of residential development has a significant impact on the amount and pace of housing construction. The procedures for development review and permitting in the City of Gilroy are described below.

Permit Processing
The requirements of the permit processing procedure have the potential to act as a constraint to the development of housing. The time and uncertainty of the review and revision cycle can contribute significantly to the overall cost of the project, ability to obtain and maintain funding, and the cost of each dwelling unit. Certainty and consistency in permit processing procedures and reasonable processing times are important to ensure that the developmental review and approval process does not act as a constraint to development by adding excessive costs or discouraging housing development.

In 2020, the City awarded a contract to Tyler Technologies for the purchase and implementation of a Land Management System. The Land Management System helps to manage land development applications, special event permits, code enforcement cases, and fire prevention/pre-treatment/hazardous materials management. The City began configuring the system in 2021 and intends to “go live” with the public by the end of 2023. This Land Management System will modernize the City's application processes by allowing online application submittals and coordinated digital plan review. The system will automate many steps in the existing permitting process and help mitigate potential constraints caused by a lengthy permitting process. Applicants will be able to check the status of their permit online and staff will have greater control over the workflow.

Development Community Stakeholder Outreach
The City evaluates its permitting and processing procedures biannually. It consults builders and other parties engaged in housing development activities to identify concerns and potential constraints in the permit processing procedure. The City will continue to hold meetings to maintain a dialogue with the development community. Topics discussed at previous roundtable meetings have included bicycle parking, objective design standards, and a potential update to the City's Downtown Specific Plan. Meetings were held virtually in 2020 and 2021, and will be held in person or virtually in the future, to accommodate a wide variety of participants.

Zoning Ordinance Streamlining
In 2021, the City began a comprehensive update of the City's Zoning Ordinance to ensure that it is compliant with the 2040 General Plan. Updates will include changes to help streamline the permit process, including but not limited to creating an administrative use permit process, as currently all use permits require a public hearing before the Planning Commission. City staff is also recommending a more transparent and streamlined process for reviewing and approving applications involving a historic resource (e.g., residential additions). Staff will also be recommending streamlined processing for planned development projects that do not require

9.2 p. 557 of 1163
Constraints on Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 197
a zoning amendment or General Plan amendment. Program B - 5 includes the above changes to streamline the permitting process.

Planning Permit Processing Procedure
The typical planning permit process follows the steps below.

1. Optional Pre-Application Submittal Meeting

2. Application Submittal

3. Input from Other Departments

4. Status Letter to Applicant

5. Plan Revision, as needed (if yes, return to Step 2)

6. Planning Staff Analysis

7. Project Decision, including conditions of approval if applicable The project decision may be appealed, which would result in project review by either the Planning Commission or City Council, depending on the permit.

Administrative versus Discretionary Planning Permits
As discussed previously, most single-family residential projects can be approved ministerially.

Single-family hillside homes and multifamily residential projects that comply with objective development and design standards are approved through an administrative planning staff review process, without the need for public hearings, unless another entitlement tied to the project would require a public hearing.

However, if an applicant wants to change the zoning or land use designation of a particular property, the project will require review and approval by the Planning Commission and City Council, respectively, at separate public hearings. Similarly, if an applicant wants to request flexible development standards through the Planned Development process, the application currently requires public hearings before the Commission and Council. Under Program B-5, the Zoning Ordinance update will include a recommendation by staff to streamline the Planned Development approval process, so that projects that do not require a zoning amendment or General Plan amendment can be approved by the Planning Commission rather than requiring review and approval by both the Planning Commission and City Council. This streamlined process would reduce the review time by approximately two months.

Permit Processing Time
The processing time needed to obtain development permits and required approvals can act as a constraint to development and contribute to the high cost of housing. Permit processing times are partially dependent on the number of staff available to review projects. When staffing levels drop due to attrition (e.g., voluntary termination) or cutbacks (e.g., layoffs), permit processing times increase. In 2017, the City hired Management Partners to complete an organizational review of the Community Development Department, including

9.2 p. 558 of 1163
Constraints on Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 198
recommended staffing levels. Many of the report’s recommendations, such as over-thecounter plan checks, were implemented to reduce permit processing times. The report also recommends that the City reevaluate staffing levels on a regular basis to determine when additional staff resources are needed to meet service demand.

The permit processing times for various permits are shown in Table 65. The level of project review depends on the type of project. Most single-family projects require only a zoning clearance from the Planning Department as part of the ministerial building permit process.

Single-family residential hillside projects can be approved by planning staff through an administrative architecture and site review permit. Similarly, most multifamily (no subdivision map), commercial, industrial, and professional office projects can be approved administratively. These staff-level discretionary planning projects typically take three to six months (depending on application completeness) to obtain planning entitlements, while applications for building permits take another three to four months. Projects that require a tentative subdivision map require Planning Commission review and City Council approval. The subdivision review and approval process typically takes approximately one year to complete, depending on the required California Environmental Quality Act (CEQA) documentation. Once final maps are recorded, building permit applications may be filed, which typically takes another three to four months for approval.

Table 65: Permit Processing Time (2022)
Permit Type Length of
Approval Approval Body
Building Permit 3-4 months* Issued by Building and Safety Division Conditional Use Permit 3-4 months Planning Commission
Variance 3-4 months Planning Commission
Zone Change / Zoning
Amendment
6-12 months City Council
General Plan Amendment 6-12 months City Council
Architecture and Site Review 3-6 months Community Development Director (or designee)
Planned Unit Development 6-9 months City Council
Tentative Tract Map 6-9 months City Council
Negative Declaration 6-9 months Same as project approval body Environmental Impact Report 12 months Same as project approval body Final Subdivision Map 2-4 months City Council
Parcel Map 1-2 months City Council
Source: City of Gilroy, 2022
*Pursuant to AB 2234, must determine whether a post-entitlement phase permit application is complete within 15 business days of submittal. Furthermore, the City must approve a post-entitlement phase permit application or return a full set of written

9.2 p. 559 of 1163
Constraints on Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 199
comments to the applicant: (1) within 30 business days of the application being deemed complete if the housing development project has 25 or fewer units; or (2) within 60 business days if the project has more than 25 units, unless otherwise exempted by law.

The Santa Clara County Planning Collaborative collected data through a survey to provide a regional comparison of permit processing times for jurisdictions across the County. Table 66 displays the permit processing time in months for various types of residential permits. Gilroy has similar or slightly quicker processing times, compared to other County jurisdictions for most permits. For example, the City has a shorter processing time on discretionary permits that go to City Council (5–6 months) than all jurisdictions except two.

Table 66: Permit Processing Time, Months, Regional Comparison (2021-2022) Jurisdiction ADU
Process
Ministerial
By-Right
Discretionary
By-Right
Discretionary
(Hearing
Officer if
Applicable)
Discretionary
(Planning
Commission)
Discretionary
(City Council)
Gilroy 1 - 2 1 - 2 2 - 4* N/A 4 - 5 5 - 6
Campbell 1 1 3 N/A 5 8
Cupertino 1 - 3 1 - 6 2 - 4 2 - 4 3 - 6 6 - 12
Los Altos Hills 1 - 2 0.5 - 2 2 - 3 3 - 4 4 - 6 5 - 8
Los Gatos N/A 1 - 2 1 - 2 2 - 4 4 - 6 6 - 12
Milpitas 1 - 3 1 - 3 2 - 4 3 - 4 4 - 6 6 - 12
Monte Sereno 0.75 0.75 1 1 - 2 1 - 2 1 - 2
Morgan Hill 1 - 2 1 - 2 2 - 3** 2 - 3 4 - 6 4 - 6
Mountain View 3 - 5 4 - 6 2 - 3 6 – 18** N/A 12 - 24
San Jose 2 1 - 3 7 7 7 - 11 5 - 12
Santa Clara 0 - 1 0 - 1 0 - 3 4 - 9 6 - 9 6 - 12
Saratoga 1 1 - 2 2 - 3 N/A 4 - 6 6 - 12
Sunnyvale 1 - 3 1 - 3 3 - 6 6 - 9 9 - 18 9 - 18
Unincorporated
County 4 - 6 6 - 8 9 - 12 12 - 15 15 - 18 15 - 18
Source: Cities Association of Santa Clara County, Planning Collaborative. 2022. *Gilroy does not have "discretionary by-right" permits This timeline represents "Discretionary (Staff)”. This timeline also depends on level of CEQA review.
**Entitlements only
Under Program B - 5 the City will consider streamlining the Planned Development approval process, so that projects that do not require a zoning amendment or General Plan amendment can be approved by the Planning Commission rather than requiring review and approval by both the Planning Commission and City Council. This should reduce the permit processing time by approximately two months.

9.2 p. 560 of 1163
Constraints on Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 200
Objective Design Standards Policy
In October 2021, the City of Gilroy adopted the Mixed-use Residential and Multi-Family Residential Objective Design Standards Policy. The objective design standards were created to ensure the City’s compliance with the Housing Accountability Act. The objective design standards apply to residential projects that are multifamily or mixed-use. Consistent with state law, the standards are purely objective in nature. The objective design standards are also intended to increase consistency in decision making, minimize applicant delays, better utilize limited staff resources, and promote good design principles that help ensure that Gilroy is an attractive place to live and visit.

Program A - 10 will incentivize the production of middle-income housing by allowing ministerial approval of triplexes and quadplexes, on corner lots in the R1 and R2 zones, that meet objective design standards.

Planning, Building, and Development Impact Fees
Housing developments are typically subject to three types of fees: planning permit fees, building permit fees, and development impact fees. The fees are charged by the City and other agencies to cover administrative processing costs associated with development and help ensure the provision of adequate services.

Fees vary based on the type of application necessary for project approvals. The processing fees are typically recouped through the rent or sales price, so excessive fees may ultimately affect the affordability of housing. It is best practice to periodically conduct user fee studies to ensure the City is recouping the cost of providing services in areas for which fees apply. In May 2022, the City completed a Comprehensive User Fee Study to update the City’s user fees schedule, which had been last updated and adopted in 2014. City staff advertised the proposed fee increases to the City’s list of development professionals, including local builders and contractors. Following community meetings and public hearings with the City Council, a new fee schedule was adopted, effective August 1, 2022. There was no public opposition to the proposed fees, which may be an indication that the fees remain reasonable. The most current fee schedule is available on the City’s website. Planning related fees for the City of Gilroy are shown in Table 67.

Table 67: Planning Related Fees (August 2022)
Applications Fee
Annexation $19,632 + actual attorney fees
Architectural Site Review – Residential
New Construction
$8,294/first lot + $592/additional flat land tract plan + $1,203/additional hillside lot
New Hillside Lot - SFD $4,532
Additions $2,648

9.2 p. 561 of 1163
Constraints on Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 201
Applications Fee
Development Agreement $19,081 minimum deposit (hourly rate invoiced against initial deposit, plus $10,000 deposit for attorney fee)
Environmental
Categorical Exemption $536.00
Initial Study/ND/MND, non-complex project
(Staff Review)
$12,113.17 (minimum)
Environmental Impact Report (staff review) $23,739.79 (minimum) EIR/MND/Initial Study (Consultant Contract)
Actual contract cost plus 15% of contract cost + 15% staff review + 10% contingency
General Plan Map Amendment $15,604/first 10 acres + $150/each additional 10 acres, plus attorney fees and publishing costs
Planned Unit Development $16,203
Tentative Parcel Map $10,253 (up to 4 lots), plus publishing Tentative Tract Map $19,036/(5-12 lots) + $302/additional flat land lot + $877/additional hillside lot, plus publishing costs
Urban Service Area Extension $29,188/first 10 acres + $423/each additional 10 acres + publishing1 + LAFCO fees
Variance $5,470, plus attorney fees and publishing costs Zoning Map Amendment $11,884/first 10 acres + $150/each additional 10 acres, plus attorney fees and publishing costs
Source: City of Gilroy. Effective August 1, 2022. (https://www.cityofgilroy.org/DocumentCenter/View/12973/2022-- Comprehensive-User-Fee-Schedule-Effective-August-1-2022)

1. For those projects involving multiple public hearing applications, the publication costs will be reduced to a single charge when it is determined, and reasonably possible, that the public-hearing applications can be processed together.

The City of Gilroy Public Works Department provides a fee schedule for development impact fees. Impact fees are updated each fiscal year. The 2022 impact fee schedule, which runs from July 1, 2022, to June 30, 2023, was updated to reflect the fees adopted as part of the 2022 Comprehensive User Fee Study discussed above. Development impact fees add to the cost of residential development; however, they can be a cost-effective mechanism for financing the new infrastructure (e.g., water, sewer, roads) required to support new development. The fees allow for the consolidation of infrastructure projects when it is more cost-effective to do so and, by law, must be linked to the actual impact of the specific project.

The City of Gilroy imposes a number of development impact fees, including for public facilities, sewer development, storm development, traffic, and water development. Typically, fees per unit for high-density residential are lower than fees per unit for low-density residential.

Development fees for the City of Gilroy are shown in Table 68.

In 2022, the development impact fee was $15.82 per square foot for ADUs that are greater than 750 square feet. Thus, the maximum impact fee for a 1,000-square-foot ADU would be $15,820. In 2022, ADU costs range from approximately $50,000 (conversion of habitable, already-finished space) to $120,000 (new construction). In this case, the impact fee represents 13 percent ($120,000) to 31 percent ($50,000) of the total cost of development. Comparatively,

9.2 p. 562 of 1163
Constraints on Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 202
Gilroy’s impact fee is 34 percent less than the City of Morgan Hill, which charges $21,209 for the same size (1,000 square foot) detached ADU. 36
The impact fees for ADUs in Gilroy are calculated proportionately in relation to the ADU square footage and the square footage of the primary dwelling unit; however the fees may still create a constraint on ADU production. The City will review ADU impact fees as a potential constraint for affordable housing through Program A - 8.

Table 68: Development Impact Fees (2022)
Fee Type Fee
Public Facilities Impact Fees
Residential – Low Density $22,617/unit
Residential – High Density $19,028/unit
Sewer Development Impact Fees
Residential – Low Density $13,262/unit
Residential – High Density $7,176/unit
Storm Development Impact Fees
Residential – Low Density $598/acre
Residential – High Density $940/acre
Traffic Impact Fees
Residential – Low Density $13,012/unit
Residential – High Density $10,548/unit
Water Development Impact Fees
Residential – Low Density $4,556/unit
Residential – High Density $1,843/unit
ADUs ADU impact fees are not assessed for the first 750 square feet. Any floor area above 750 square feet will be assessed an impact fee of $15.82/square foot
Source: City of Gilroy. Fees to Build Effective July 1, 2022.

In late 2021/early 2022, the Santa Clara County Planning Collaborative collected data through a countywide survey to provide a regional comparison of fees for different types of development. Total fees per unit for single-family, small multifamily, and large multifamily collected at that time are shown in Table 69. Generally, Gilroy’s fees are comparable to the region. For single-family fees, Gilroy was the sixth least expensive of the thirteen jurisdictions with listed fees. For small multifamily units, Gilroy was seventh of the twelve listed fees, and for large multifamily Gilroy was eighth of twelve listed fees. 36 https://www.morganhill.ca.gov/DocumentCenter/View/42497/Detached-ADU-checklist-for-Morgan-Hill---FINAL-with-ImpactFees?bidId=

9.2 p. 563 of 1163
Constraints on Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 203
Table 70 displays a regional comparison of fees as a percentage of total development costs. At the time of comparison, Gilroy's single-family fees (1.5 percent of total development) rank sixth least expensive out of fourteen jurisdictions listed. For small multifamily fees, Gilroy ranks seventh out of twelve jurisdictions listed (5.3 percent), and for large multifamily fees, Gilroy is eighth of the twelve jurisdictions listed (5.6 percent).

Table 69: Total Fees per Unit, Regional Comparison (2021-2022) Jurisdiction Single-Family Small Multifamily Large Multifamily Gilroy $69,219 $40,195 $39,135
Campbell $72,556 $20,599 $18,541
Cupertino $136,596 $77,770 $73,959
Los Altos Hills $146,631 N/A N/A
Los Gatos $32,458 $5,764 $3,269
Milpitas $77,198 $74,326 $59,740
Monte Sereno $33,445 $4,815 $4,156
Morgan Hill $55,903 $41,374 $36,396
Mountain View $90,423 $69,497 $82,591
San Jose $9,919 $23,410 $23,410
Santa Clara $72,034 $7,299 $3,048
Saratoga $64,272 $17,063 $15,391
Sunnyvale $133,389 $126,673 $98,292
Source: Santa Clara County Planning Collaborative. 2022.

Table 70: Fees as Percentage of Total Development Costs, Regional Comparison (2021-2022) Jurisdiction Single-Family Small Multifamily Large Multifamily Gilroy 1.5% 5.3% 5.6%
Campbell 2.6% 2.7% 2.6%
Cupertino 2.9% 10.3% 10.5%
Los Altos Hills 3.1% N/A N/A
Los Gatos 1.2% 0.8% 0.5%
Milpitas 2.8% 9.8% 8.5%
Monte Sereno 0.7% 0.6% 0.6%
Morgan Hill 2.0% 5.5% 5.2%
Mountain View 3.3% 9.2% 11.8%
San Jose 0.4% 3.1% 3.3%
Santa Clara 2.6% 1.0% 0.4%
Saratoga 1.4% 2.3% 2.2%
Sunnyvale 4.8% 16.8% 14.0%
Unincorporated County 0.9% N/A N/A

9.2 p. 564 of 1163
Constraints on Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 204
Source: Santa Clara County Planning Collaborative. 2022.

On average, Gilroy’s fees are comparable to surrounding jurisdictions in Santa Clara County.

Fees may represent a barrier to the construction of housing as they increase the minimum cost of development for a dwelling unit and may be passed onto the purchaser or renter.

However, the City’s fees are not excessive and do not constitute unreasonable constraints on the production of housing, as the City has seen robust housing production during the 5th RHNA Cycle.

School Fees
In addition to the costs above, the Gilroy Unified School District charges development fees.

The entirety of Gilroy is served by the Gilroy Unified School District. As of 2018, the residential development fees for the school district were $3.79 per square foot.37 The City does not have control over these fees, but the fees have not constrained the development of housing in recent years.

Transparency of Development Standards
The City of Gilroy provides its development standards on the City website. The Gilroy City Code, General Plan, permit and development fees, affordability requirements, and zoning maps can all be accessed on the City’s website. This includes the most recent Comprehensive User Fee Study. City staff are available to assist applicants or interested parties that do not have internet access. The City is in compliance with requirements set forth in AB 1483.

Under Program B - 4 (Public Fees, Standards, and Plans Online) and pursuant to Assembly Bill (AB) 1483, the City will compile all development standards, plans, fees, and nexus studies in an easily accessible online location (also see Program B - 8).

SB 35 Approval Procedure
SB 35 (2017) requires a Streamlined Ministerial Approval process for developments in jurisdictions that have not made sufficient progress towards their Regional Housing Needs Allocation. Program B - 3 establishes and implements expedited permit processing for qualifying affordable housing projects, pursuant to SB 35 and SB 330.

As of August 2022, the City of Gilroy has not received an SB 35 application. If the City were to receive an SB 35 application, it would follow state law procedure. The following permitting procedure that the City will follow is from the Streamlined Ministerial Approval process guidelines outlined by HCD.

After receiving a notice of intent from the applicant intending to submit an application for a Streamlined Ministerial Approval process, the following steps must occur:
37 Gilroy Unified School District. Developer Fee Justification Study. 2018. https://resources.finalsite.net/images/v1529100379/gusdk12caus/qszb2awtcdnj2lpzxcc8/DeveloperFeeJustificationStudy.pdf.

9.2 p. 565 of 1163
Constraints on Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 205

1. The City will complete the tribal consultation process outlined in Government Code Section 65913.4(b) prior to accepting an application for a Streamlined Ministerial Approval process.

2. Once the tribal consultation process is complete, the City will begin processing the submitted application for a Streamlined Ministerial Approval process.

3. The City will perform a determination of consistency with regard to objective zoning, subdivision, and design review standards.

4. The City will perform a determination of consistency with density requirements.

5. The City will complete the design review within the following timeline, following acceptance of the application in item #2 above:
• Within 60 calendar days of submittal of the application to the City if the development contains 150 or fewer housing units.
• Within 90 calendar days of submittal of the application to the City if the development contains more than 150 housing units.

6. The City will determine whether the application for Streamlined Ministerial Approval complies with all applicable requirements, and will approve or deny the application, within the following timeline:
• Within 90 calendar days of submittal of the application to the City if the development contains 150 or fewer housing units.
• Within 180 calendar days of submittal of the application to the City if the development contains more than 150 housing units.

Under Program B - 3 (SB 35 Permit Processing and SB 330 Compliance), the City will establish and implement expedited permit processing for qualifying affordable housing projects, pursuant to SB 35 and SB 330 and create checklists and instructions for reviewing and approving SB 35 and SB330 projects. The City will also amend the Zoning Ordinance to require that any demolished residential units located on a Sites Inventory property be replaced pursuant to Government Code Section 65915(c)(3) and Government Code Section 65583.2(g).

The City will also add information regarding the expedited permit process on the City’s website.

Housing for Persons with Disabilities
The US Census Bureau defines persons with disabilities as those with a long-lasting physical, mental, or emotional condition. Certain conditions affect a person’s housing choices, whether it creates a need for accessibility, living spaces for caretakers, transit access, or other.

Under Program E - 10 (Development and Rehabilitation of Housing for Persons with Disabilities), the city will evaluate and revise as necessary the permit requirements for residential care homes (i.e., group homes) in medium- and higher-density residential zones.

9.2 p. 566 of 1163
Constraints on Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 206
Reasonable Accommodation Procedures
The City of Gilroy has a Reasonable Accommodation Procedure adopted in 2014 outlined in Section 30.50.23 of the Zoning Ordinance. A request for reasonable accommodation may be made by any person with a disability, their representative, or any entity when the application of a zoning law or other land use regulation, policy, or practice acts as a barrier to fair housing opportunities.

Requests for reasonable accommodation shall be reviewed by the Community Development Director or their designee if no other approval is sought. Requests for reasonable accommodation submitted for concurrent review with another discretionary land use application shall be reviewed by the authority responsible for reviewing the discretionary land use application, in conjunction with that application. The written decision to approve or deny a request for reasonable accommodation shall be based on consideration of the following factors:
• Whether the housing will be used by a disabled individual. • Whether the request for reasonable accommodation is necessary to make specific housing available to an individual with a disability.
• Potential impact on surrounding uses.
• Physical attributes of the property and structures.
• Alternative accommodations which may provide an equivalent level of benefit. • Whether the requested accommodation would impose an undue financial or administrative burden on the City.
• Whether the requested accommodation would require a fundamental alteration of a City program.

The reviewer must make a written determination within 45 days of receipt of a complete application and either approve, approve with modifications, or deny a request for reasonable accommodation.

The City provides Community Development Block Grant (CDBG) funding to Rebuilding Together Silicon Valley to help provide accessibility improvements to very low-income households.

The City supports equal access to housing for persons with disabilities and will evaluate its reasonable accommodation standards and procedures as a potential constraint to accommodating persons with disabilities (Program E - 10).

Definition of Family
The Gilroy City Code defines family as “one (1) or more persons, occupying premises and living together as a single housekeeping unit, as distinguished from a group occupying a hotel, club, fraternity, or sorority.” This definition is consistent with state law and does not pose a constraint on the development of housing for persons with disabilities.

9.2 p. 567 of 1163
Constraints on Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 207
Building Code
The City of Gilroy has adopted the 2022 California Building Code, adopted from the 2021 International Building Code, with local amendments. When development plans are submitted for plan check, they are reviewed by the Building and Safety Division for compliance with the California Building Code. The local amendments were adopted with recommendation by the City of Gilroy chief building official. Modifications and changes are reasonable and necessary due to local climactic, geological, or topographical conditions or are otherwise permitted by state law. Most notably, the City has incorporated electric vehicle (EV) charging requirements for new construction, roofing requirements in Wildland-Urban Interface Fire Areas, and grading requirements for erosion control. While these requirements may add to the cost of construction of residential units, they are necessary to help mitigate the risk of damage by wildfire and contribute to sustainability goals.

Local amendments to the building code can be found in Gilroy City Code Chapter 6, Article II, Section 6.7. Amendments are minor changes, and no modifications pose constraints to development.

Under Program B - 9 (Building Department webpage), the City will update the Building Department webpage to include information required pursuant to AB 2234, including but not limited to specific information required for an application to be considered complete; example of a complete, approved application; and example of a complete set of post-entitlement phase permits for accessory dwelling units, duplexes, multifamily projects, mixed-use projects, and townhomes. This should help reduce applicant time and cost and increase certainty in the building permit process.

Code Enforcement
The City’s Code Enforcement staff responds to potential violations of the Gilroy City Code.

There are two code enforcement officers. Code enforcement is reactive and officers respond to complaints reported by residents. Common violations include abandoned or dangerous buildings, blighted property and maintenance concerns, unsafe living conditions, construction without land use/zoning permits, and illegal tree removal. The City provides CDBG funding to Rebuilding Together Silicon Valley to operate and expand the Home Repair and Accessibility Modification program in Gilroy.

On- and Off-Site Improvement Requirements
The City requires on- and off-site improvements for new developments, which are intended to meet health and safety requirements of the community. Residential developers are responsible for constructing road, water, sewer, and storm drainage improvements on new housing sites. The City’s General Guidelines for development were last updated in August 2014. They include local street rights-of-way and curb-to-curb widths, sanitary sewer and storm drainage lines, street lighting, erosion control, landscaping, and easements.

Notably, all streets must be designed in accordance with accepted engineering principles and conform to the design standards, the standard details, and the complete streets resolution

9.2 p. 568 of 1163
Constraints on Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 208
approved by City Council. All exceptions to the General Guidelines must be approved by the City Engineer prior to the approval of a tentative map. These requirements are similar to those of other jurisdictions and are not considered an unreasonable constraint on development.

Although requirements for on- and off- site improvements do add to the overall cost of the development, they are necessary to ensure provision of vital infrastructure services to residents. Based on the recent entitled and pending housing types (see Table 79), the City’s site improvement requirements do not create an undue constraint on development.

The following example highlights the requirements for a 29-unit single-family redevelopment project, approved in 2020, which was previously an office park. ▪ Street Trees: The applicant shall plant street trees along the project frontage to match the City of Gilroy’s Street Tree Plan in effect at the time of construction. The street tree plans shall be per City Standard Drawings and will include City Standard tree grates. ▪ Tree Grates: The applicant shall install City Standard Tree Grates as specified in the approved plans. Tree grates shall be 4’x6’, model OT-T24 by Urban Accessories, and shall be black power coated. The tree grates shall be shown on the improvement plans to be located at the back of curb to the approval of the City Engineer and shall be installed with the street trees prior to the first occupancy. ▪ Street Markings: The applicant shall install necessary street markings of a material and design approved by the City Engineer and replace any that are damaged during construction. These include but are not limited to all pavement markings, painted curbs, and handicap markings. All permanent pavement markings shall be thermoplastic and comply with Caltrans Standards. Color and location of painted curbs shall be shown on the plans and are subject to approval by the City Engineer. Any existing painted curb or pavement markings no longer required shall be removed by grinding if thermoplastic, or sand blasting if in paint. ▪ Sidewalk: The applicant shall replace to existing City standards all sidewalk surrounding the project site. The actual amount of sidewalk to be replaced shall be determined by the Public Works Construction Inspector in the field prior to construction. Sidewalk replacement shall be constructed per the City Standard Drawings.
▪ Curb Ramp(s): The applicant shall construct 4 curb ramps in accordance with the latest Caltrans State Standard Drawing at the Princevalle & W 6th St intersection. The actual ramp "Case" shall be identified on the plans and shall be to the approval of the City Engineer.
▪ Curb and Gutter: At the time of the A&S application was filed, a minimum of 450-ft linear feet of curb and gutter will need to be replaced. This figure is provided only to determine minimum bonding requirements for the encroachment permit. The actual amount of curb and gutter to be replaced shall be determined by the Public Works Construction Inspector in the field prior to construction. New curb and gutter shall be constructed per the City Standard Drawing STR-12.

9.2 p. 569 of 1163
Constraints on Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 209
▪ Driveway Approaches: The applicant shall install driveway approaches as shown on the approved plans. The new residential driveway approaches shall be constructed per the City Standard Drawing.
▪ Driveway Removal: The applicant is to remove the existing driveway approaches located along the project frontage as shown on the approved A&S application plans, and replace them with sidewalk, curb, and gutter per the City Standard Drawing. ▪ Sewer Lateral: The applicant shall install as a minimum a four (4) inch City Standard sewer lateral connection from the property line to the sewer main located in the street right-of-way for each proposed lot. The installation shall be done in accordance with the City Standard Drawing SWR-6 including a 6" property line clean-out. ▪ Sewer Clean-Out: The applicant shall install a sewer lateral clean-out at the property line for each proposed lot in accordance with the City Standard Drawing SWR-6. ▪ Sanitary Sewer Manholes: The applicant shall install standard sanitary sewer manholes, per approved plans and in accordance with the City Standard Drawing. ▪ Storm Water Catch Basins: The applicant shall install standard storm water catch basins, in accordance with the City Standard Drawing.
▪ Street Lights: The applicant shall provide and install standard aluminum electrolier street lights per City Standard Drawing EL-1 to EL-5. The applicant is responsible for all PG&E service fees and hook-up charges. Any new service point connection required to power the new lights shall be shown on the construction drawings along with the conduit, pull boxes and other items necessary to install the street lights. An Isometric lighting level needs to be provided by the designer/contractor. A separate light study may be required by the City Engineer. The new street light shall have 32’ mounting height per Standard Drawing EL-3, with mounting arm length per Standard Drawing EL4, the Fixture shall be Leotek GC1 or GC2 series in an approved configuration per detail EL-2 or approved equal. The arm shall be installed at the location as shown on the approved plans.
▪ Fire Hydrants: The applicant shall install new fire hydrants along the project frontage.

Spacing shall meet City and Fire Marshall requirements.

Based on the recent proposals submitted and entitled citywide for a range of housing types, the City’s site improvement requirements do not create an undue constraint on development.

Nongovernmental Constraints
Requests to Develop Below the Anticipated Density
In some regions, market factors such as the demand for single-family housing or larger highend condominiums can lead to properties being developed below the maximum allowable density. Requests to develop housing at densities below those anticipated in the Housing Element act as a potential constraint to housing development. However, the City does not

9.2 p. 570 of 1163
Constraints on Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 210
generally receive any requests to develop below densities anticipated. For example, one of the low-income sites identified in the 2015-2023 Housing Element (LI-4) developed above the anticipated density identified in the 2015-2023 RHNA sites inventory. The site was projected for 78 low-income units and was constructed with 120 low-income units for a surplus of 42 units.

The 11 entitlement projects noted in Table 76 had densities between 13.4 and 40.3 du/ac with an average yield percentage of approximately 111 percent. Out of this total, 8 entitlement projects analyzed developed above the anticipated density (72 percent). Entitled projects largely exceed the density assumptions made in the 5th RHNA cycle. For example, in the Downtown Specific Plan Area (excluding the Cannery District), the R4 zone, and the Neighborhood District, the average base densities of actual projects were all higher than assumed.

Projects developed at a lower density than previously assumed were primarily located in the R3 zone. Sites in this district are typically smaller and under separate ownership, and therefore more constrained. In addition, projects in the R3 zone are typically infill or small additions to existing structures, which would characteristically yield a lower density.

Consistent with the 2040 General Plan, the City will amend the Zoning Ordinance to increase the maximum density in the R3 zone and remove the maximum density in the R4 zone. This will help ensure adequate baseline capacity to meet RHNA targets and achieve Housing Element compliance (B - 2).

Land Costs
Land costs have a demonstrable influence on the cost and availability of affordable housing.

Land prices are determined by numerous factors, most important of which are land availability and permitted development densities. As land becomes less available, the price of land increases. The scarcity of adequate housing opportunities in northern Santa Clara County have influenced upward pressure on land and housing costs in Gilroy.

The price of land varies depending on a number of factors, including size, location, the number of units allowed on the property, and access to utilities. Vacant land sales (in early 2022) are shown by cost and acreage in Table 71. The price ranges from $1.80 to $9.69 per square foot, with an average price of $6.75 per square foot (or $293,843 per acre). The City has little control over land costs, which can pose a constraint to development.

9.2 p. 571 of 1163
Constraints on Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 211
Table 71: 2022 Vacant Lot Sales in Gilroy
Acreage Land Cost Cost per sq. ft. Date Sold

7.34 $3 million $9.38 2/28/2022

1.26 $335,000 $6.10 2/18/2022

13.11 $1.03 million $1.80 2/15/2022

7.67 $900,000 $2.69 2/11/2022

1.14 $400,000 $8.06 2/1/2022

2.38 $985,000 $9.50 1/5/2022

1.09 $460,000 $9.69 1/4/2022
Source: Zillow.com, 2022
Construction Costs
Construction costs include the cost of materials and labor. Materials costs include the cost of building materials (wood, cement, asphalt, roofing, pipe, glass, and other interior materials), which vary depending on the type of housing being constructed and amenities provided. In general, construction costs can be lowered by increasing the number of units in a development, until the scale of the project requires a different construction type that has a lower cost per square foot.

One indicator of construction costs is Building Valuation Data, compiled by the International Code Council (ICC). The unit costs compiled by the ICC include structural, electrical, plumbing, and mechanical work, in addition to interior finish and normal site preparation. The data are national and do not account for regional differences, nor include the price of the land upon which the building is built. The Building Valuation Data, dated August 2021, reports the national average for development costs per square foot for apartments and single-family homes as follows:
• Residential Multifamily: $136.73 to $203.34 per square foot • Residential One- and Two-Family Dwelling: $148.33 to $189.34 per square foot • Residential Care/Assisted Living Facilities: $172.87 to $240.35 per square foot California building costs tend to be higher than national levels. A 2020 study by the Berkeley Terner Center noted that construction costs in the state are highest in the Bay Area and reached more than $380 per square foot in 2018.38
38 Terner Center for Housing Innovation. The Hard Costs of Construction: Recent Trends in Labor and Materials Costs for Apartment Buildings in California. March 2020. https://ternercenter.berkeley.edu/wpcontent/uploads/2020/08/Hard_Construction_Costs_March_2020.pdf

9.2 p. 572 of 1163
Constraints on Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 212
Financing Availability
Interest rates affect homeownership opportunities throughout the City. In August 2022, Freddie Mac’s primary mortgage market survey listed interest rates on home loans at 5.55 percent on a 30-year fixed-loan rate. While low interest rates are expected to prolong the availability of financing, low housing inventory can create competition among potential homebuyers, especially for first-time homebuyers. The sales price of housing is typically adjusted for changes in mortgage rates. The Housing Trust of Silicon Valley administers the Santa Clara County Empower Homebuyers First Time Homebuyer Loans and HELP for Homebuyers programs.

Table 72 displays the number of loan applications received in 2020 for the purpose of purchasing a home in the San Jose-Sunnyvale-Santa Clara metropolitan statistical area, which includes the City of Gilroy. Specifically, the table provides the number of total applicants, the number of loans originated, the number of applications that were approved but not accepted by the applicant, and the number of applications denied across various types of loans.

Table 72: Disposition of Home Loans, 2020
Loan Type
Total
Applicants Originated
Approved
Not
Accepted
Denied Withdrawn /
Other
Conventional
Purchase 24,691 15,660 644 1,942 6,445
Government Backed
Purchase 1,879 986 71 138 684
Home Improvement 5,206 2,998 165 961 1,082
Refinance 41,117 21,078 1,208 5,930 12,901
Total 72,893 40,722 2,088 8,971 21,112
Source: lendingpatternslite.com, 2020
Federal and State Programs
There is limited funding available for housing assistance programs from the state and federal governments. For the 2021-2022 and 2022-2023 fiscal years, the City of Gilroy allocated approximately $440,000 each year in CDBG funds from the US Department of Housing and Urban Development. The CDBG program aims to support activities that benefit low-income households, aid in the prevention of slums or blight, or meet an urgent community need, through grants for eligible activities.

For the 2022-2023 and 2023-2024 fiscal years, the City also allocated $237,000 (each year) in Permanent Local Housing Allocation Fund funds for services related to homelessness, fair housing, and special needs, such as persons with disabilities.

9.2 p. 573 of 1163
Constraints on Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 213
Additional information on these funds is included in the Housing Element Accomplishments chapter.

Environmental and Infrastructure Constraints
Environmental hazards affecting housing units include geologic and seismic conditions, soil conditions, flood risk, vegetation and wildlife habitat, toxic and hazardous waste, fire hazards, noise levels, and preservation of agricultural lands. In Gilroy, seismic hazards provide the greatest threat to the built environment. Infrastructure constraints include the availability and cost of water and sewer services. The following hazards may impact future development of residential units in the City and can pose a potential constraint to housing development.

Environmental Constraints
Seismic Hazards
The topography of Santa Clara County consists of three principal geologic features: the Santa Clara Valley, the Santa Cruz Mountains, and the Diablo Range. The area is dominated by a complex system of faults associated with motion between the Pacific and North American plates. The most significant fault is the San Andreas Fault. The area is seismically active and includes other major, active strike-slip faults, including the Calaveras Fault, as well as active folding and thrust faulting. The Sargent Fault, northeast of the City of Gilroy, has significant potential to cause seismic shaking.

Soils
The soils in the Gilroy area consist of gravel, silt, and clay that are often poorly drained with flooding and deposition occurring along the major streams. Because these soils exhibit sitespecific properties, site-specific studies should be completed at the project design stage to characterize the suitability and behavior of soil for specific development applications.

Flooding
The City of Gilroy area lies within two major watersheds: the Uvas Creek watershed and the Llagas Creek watershed. The City of Gilroy Flood Plain Management Ordinance was updated in 2016 to adopt regulations designed to promote public health, safety, and general welfare.

The standards require all new developments in the 100-year floodplain, regardless of project size, to develop a base flood elevation in areas without a determined base flood elevation.

Vegetation and Wildlife Habitat
Vegetation and wildlife habitat within the Gilroy area include both developed and natural areas. Developed areas include urban and agricultural land. Natural communities include annual grassland, coastal oak woodland, and valley foothill riparian habitat.

The 2040 General Plan includes policies aimed at protecting sensitive communities from urban development, in-stream capital projects, and in-stream operations and maintenance. These sensitive communities include wetlands and waterways (including associated freshwater

9.2 p. 574 of 1163
Constraints on Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 214
marsh vegetation and riparian corridor habitats), serpentine rock formations that support native species, and native oak woodlands.

Toxic and Hazardous Wastes
Hazardous waste management in Gilroy includes three areas: control of production, control of disposal, and control of transportation of hazardous waste. A limited number of hazardous materials are produced in the City. Among those produced by point sources are waste oil, antifreeze, solvents, x-ray solutions, and materials associated with graphic design. Hazardous wastes associated with non-point sources include waste oil, antifreeze, and other pollutants associated with motorized vehicles. The City of Gilroy’s Hazardous Materials Specialists and Pretreatment Inspectors and the County Public Health Department regularly inspect activities that store and/or use hazardous materials. Regular inspections and monitoring help ensure compliance with local, state, and federal regulations and help reduce the risks associated with the use and handling of hazardous materials and waste.

Fire Hazards
The City of Gilroy receives fire protection from the Gilroy Fire Department. The areas outside the City are under the jurisdiction of the South Santa Clara County Fire Protection District. The two jurisdictions have a mutual aid agreement that allows reciprocal aid to be provided on an as-needed basis during major emergencies. High Fire Hazard (or “Mutual Threat Zones”) areas are designated by the district. These include much of the hillsides on the western boundary of the City. The City of Gilroy Fire Department has in place a hazard (weed) abatement program.

The City’s Hillside Development Guidelines contain policies relating to fire hazards.

Noise
One of the primary noise sources in the Gilroy area is traffic on local roadways, primarily the result of tire noise on the road surface and the Union Pacific Railway line. Other typical noise sources, as in all suburban areas, include construction, barking dogs, children playing, industry, and recreational activities. Overflying aircraft are also occasionally audible in the Gilroy area.

These sources are not significant compared to the noise produced by the dominant transportation sources.

The City is responsible for evaluating noise impacts as part of the review and approval process for new discretionary project proposals. Project approval may include conditions to mitigate noise levels for project occupants and nearby neighbors. There is no noise impact fee. The cost of construction, as well as maintenance of noise mitigation measures, is borne by the developer. The City of Gilroy aims to buffer residential areas from sources of noise pollution through appropriate zoning wherever possible (e.g., locating commercial uses between residential uses and light industrial uses).

Agricultural Lands
To protect and preserve agricultural land, the City of Gilroy adopted an Agricultural Mitigation Policy. The policy was adopted in 2004 and revised in 2016. CEQA requires all feasible

9.2 p. 575 of 1163
Constraints on Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 215
mitigation for significant unavoidable impacts. Upon certification of the City’s General Plan EIR, the City Council established the Agricultural Mitigation Policy to implement the mitigation measures identified in the 2020 General Plan EIR and 2040 General Plan EIR for loss of agricultural lands. Therefore, significant agricultural impacts as determined under CEQA would be subject to the City’s Agricultural Mitigation Policy. The policy establishes the criteria for determining when mitigation would be required and what lands are acceptable for preservation. The policy requires mitigation for the conversion of agricultural lands to urban uses at a 1:1 replacement ratio. Mitigation may be accomplished with one of two options and the options shall include all costs to cover program administration, monitoring and management of established easements as outlined in the policy.

The policy established a preferred area for the preservation of agricultural lands. This area is located within the City’s Sphere of Influence and outside the General Plan 20-year boundary, east of Highway 101 and south of Masten Avenue. At the time the map was created in 2004, this area contained the greatest concentration of “Prime” and “Statewide Important” farmland remaining in south Santa Clara County. The policy requires new developments to establish a minimum of 150 feet for an agricultural buffer adjacent to permanent agricultural and open space areas. This applies only to a few areas in the City and would aim to reduce potential conflicts between agricultural and non-agricultural uses.

The Agricultural Mitigation Policy poses a potential constraint to development, but also allows for certain exemptions from the 1:1 mitigation ratio as follows:
• Up to 100 feet in width of a permanent agricultural buffer area; • Public facilities established in the City’s General Plan or Parks Master Plan; and • Lands dedicated for public rights-of-way that service the overall community, not just the specific development.

Infrastructure Constraints
Water
The Llagas Basin Aquifer serves as Gilroy’s potable water source for most residential, municipal, industrial, and agricultural land uses. It is estimated that the municipal demand will increase to 53,000 acre-feet per year by 2040.

The City depends solely on local groundwater from wells for its water supply. Currently, there are 15 active wells that serve three water pressure zones. The City’s water supply system relies on well pumping from dispersed sources to supply system pressures in areas of lower elevation during peak demand conditions. Gilroy will continue to meet its future demands through its 2020 Urban Water Management Plan.

Sewer
The City sewer collection system consists of approximately 162 miles of 3-inch through 48-inch diameter sewers. The system consists of trunk sewers that convey the collected wastewater

9.2 p. 576 of 1163
Constraints on Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 216
flows to the Wastewater Treatment Plant. The plant, operated by the South County Regional Wastewater Authority, treats the collected wastewater from the City.

During dry weather conditions, the maximum day and peak wastewater hour flows from the City are 2.8 million gallons per day (mgd) and 5.4 mgd, respectively. During wet weather conditions, the maximum day and peak wastewater hour flows from the City are 6.6 mgd and 20 mgd, respectively.

According to the City’s Sanitary Sewer Master Plan, the existing system was well planned to meet the needs of existing customers. In anticipation of future growth, the City has planned and constructed sewer facilities in conjunction with new street construction. Some project improvements in the master plan will mitigate flows caused by infiltration and inflows that occur during significant storm events.

Energy Conservation Energy Conservation State law (Government Code §65583(a)(7)) requires a Housing Element to provide an analysis of opportunities for energy conservation in residential development. Not only do such energy conservation measures reduce consumption of non-renewable or limited resources, but they can also substantially lower housing maintenance costs.

The Bay Area Regional Energy Network (BayREN) is a coalition of the Bay Area’s nine counties that partners to promote resource efficiency at the regional level, focusing on energy, water and greenhouse gas emissions reductions. BayREN offers rebates, funding, and technical assistance to help residents, property owners, business owners, and local governments improve the resource efficiency and carbon footprint of their buildings. They include additional programs and incentives for lower-income households.

Pacific Gas and Electric (PG&E) provides electrical and gas service for the City. As of January 1, 2020, the State of California began requiring solar on newly constructed low-rise residential buildings (single-family homes, duplexes, and townhouses of 3 stories or less, including ADUs) through the 2019 California Building Standards Energy Code (Title 24, Part 6). The City of Gilroy adopted and implemented the code. PG&E also provides several programs, incentives, and rebates for qualified renters and homeowners to save energy and money. The City provides links to these PG&E programs as well as listing energy-saving measures for residents on the City’s website for energy conservation.

In November 2022, the City adopted the 2022 California Building Code with local amendments.

On January 1, 2023, the codes became effective citywide. Among the codes, Gilroy adopted the 2022 California Green Building Standards Code with reach code amendments that further reduce greenhouse gas emissions. The reach code amendments were based on the model code amendment initiated by Silicon Valley Clean Energy and incorporated adjustments resulting from outreach and stakeholder input from the local community. The reach code amendments provide a higher percentage of charging infrastructure in new construction through a combination of Level 2 electric vehicle supply equipment (EVSE) and Low Power Level 2 Electric Vehicle (EV) Charging Receptacle with varying readiness. The reach code

9.2 p. 577 of 1163
Constraints on Housing ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 217
amendments help reduce greenhouse gas emissions, save on future retrofit costs, and stimulate the use of electric vehicles in the Gilroy community.

In addition, in the reach code amendments, the inclusion of the long-term bicycle parking standards for multifamily buildings and long-term bicycle parking for hotels and motels will include more bicycle parking availability and promote the use of bicycles as an affordable sustainable method of transportation. The California Green Building Standards Code, with reach code amendments, help increase access to renewable energy and reduce fossil fuel consumption, greenhouse gas emissions, and our communities’ carbon footprint.

The City of Gilroy participated in the Silicon Valley Clean Energy reach code grant offering, which provided $10,000 for presenting reach codes to the City Council for consideration.

Silicon Valley Clean Energy also offers incentives and rebates to residents and businesses to help advance clean, electric buildings and transportation.

In summer 2022, the City of Gilroy started a pilot program with Solar Automated Permit Processing Plus (SolarAPP+) and completed the public launch in early 2023. This online platform offers a portal that simplifies and accelerates rooftop solar photovoltaic (PV) permitting processes, allowing residential solar photovoltaic systems to be installed quicker, which helps decrease our community’s nitrogen and carbon emissions footprint and provides clean energy. SolarAPP+ permits PV contractors to upload qualifying solar photovoltaic system specifications. It reviews the submission for code compliance and verifies code-compliant systems. Furthermore, SolarAPP+ increases access to renewable energy, helps reduces fossil fuel consumption, and helps reduce our communities’ carbon footprint, particularly carbon dioxide (CO2), and improves air quality.

These programs, along with smart growth strategies which the City of Gilroy is promoting and implementing as part of the Housing Element, will further local and statewide energy conservation goals.

9.2 p. 578 of 1163
218

CITY OF GILROY

HOUSING ELEMENT
6TH CYCLE

HOUSING SITES AND RESOURCES

9.2 p. 579 of 1163
Sites and Resources ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 219
Housing Sites and Resources
Land Inventory
This section of the Housing Element addresses resources available for the development, rehabilitation, and preservation of housing in Gilroy. It provides an overview of available land resources and residential sites for future housing development and evaluates how these resources can work toward satisfying future housing need. The financial and administrative resources available to support affordable housing are also discussed.

Housing Allocation
As discussed in the Needs Chapter, California General Plan law requires that a community plan for an adequate number of sites to allow for and facilitate production of its share of the regional housing need. Each jurisdiction must identify “adequate sites” to determine whether that jurisdiction has sufficient land to accommodate its share of regional housing needs for each income level. As defined under California Government Code Section 655839(c)(1), adequate sites are those with appropriate zoning and development standards, and with services and facilities to encourage and provide for the development of a variety of housing for all income levels. As shown in Table 73, Gilroy’s RHNA for the 2023-2031 (6th Cycle) planning period is 1,773 units. Broken down by income level, the allocation is 669 very low-, 385 low-, 200 moderate-, and 519 above-moderate units.

Table 73: 2023–2031 RHNA
Very Low Income Low Income Moderate
Income
Above Moderate
Income Total
RHNA 669 385 200 519 1,773
Source: Regional Housing Needs Allocation, ABAG, 2023-2031. *Note: Pursuant to AB 2634, local jurisdictions are also required to project the needs of extremely low-income households (0– 30% of AMI). The projected extremely low-income need can be assumed as 50 percent of the total need for the very low-income households.

As shown in Table 74, the pipeline projects and projected ADUs have already met and exceeded the low- and above moderate RHNA for Gilroy by 11% and 48%, respectively.

9.2 p. 580 of 1163
Sites and Resources ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 220
Table 74: Pipeline Projects and ADUs Progress Towards RHNA Very Low
Income
Low
Income
Moderate
Income
Above
Moderate
Income
Total
A RHNA 669 385 200 519 1,773
B Pipeline Projects 76 387 3 756 1,222
C ADUs 42 42 42 14 140
D
Surplus / (Deficit)
of RHNA
(551) 44 (155) 251 -
E
Percent Surplus Met by
ADUs and Pipeline
Projects
- 11% - 48% -
Target Sites Capacity – 15% No Net Loss Buffer
Changes to state law require jurisdictions to continually maintain adequate capacity in their site inventories. In the event that a site is developed below the anticipated density or at a different income level than projected in the Housing Element, the City must still have adequate sites available to accommodate the remaining balance of the RHNA. Alternatively, the City may identify new sites or rezone sites to continue to accommodate the remaining need. A buffer is not required for RHNA income categories that have been met by pipeline projects or projected ADUs. For this reason, the City is including a buffer of 15 percent above the unmet RHNA in each income category. Table 75 identifies the total target capacity based on the RHNA plus 15 percent of any unmet RHNA. As shown, the pipeline projects (Row B) and projected ADUs (Row C) are subtracted from the RHNA (Row A) to determine the unmet RHNA (Row D). The unmet RHNA of 551 very low- and 155 moderate-income units is multiplied by 15 percent (Row E).

Note that because the RHNA has been met for the low- and above moderate-income categories, there is no unmet RHNA and no target buffer for these income levels. Row F sums the RHNA (Row A) and the 15 percent of the unmet RHNA (Row E) to show the total target sites capacity.

9.2 p. 581 of 1163
Sites and Resources ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 221
Table 75: Target Sites Capacity (15% No Net Loss Buffer of Unmet RHNA) Very Low
Income
Low
Income
Moderate
Income
Above
Moderate
Income
Total
A RHNA 669 385 200 519 1,773
B Pipeline Projects 76 387 3 756 1,222
C ADUs 42 42 42 14 140
D
Unmet RHNA
(A-B-C)
551 - 155 - 706
E
Target Buffer (15% of Unmet RHNA)
(D*0.15)
83 -
23 -
106
F
Unmet RHNA + Target Buffer
(D+E)
634
-
178
-
812
Realistic Capacity
State law requires that a jurisdiction project realistic estimates for housing capacity on its RHNA sites. The realistic capacity of sites may be calculated using recent project history, a minimum density, or other methods. As a majority of growth is expected to take the form of multifamily housing, recently constructed multifamily projects were reviewed to understand and establish historical trends for multifamily housing development in the City. The realistic capacity calculation also takes into account recent inquiries and permits for uses in zones that allow mixed-use or stand-alone commercial uses.

The Downtown Specific Plan allows 100 percent commercial in all six of its zones. Three Downtown Specific Plan districts allow 100 percent residential uses, and mixed-use residential is encouraged in all zones. Mixed use could also include mixed commercial (e.g., retail and office). Residential uses are unconditionally permitted on the second story and above in all Downtown Specific Plan zones. Any time these uses are proposed for the ground level or first floor (sidewalk level), a conditional use permit is required. This has been taken into account through both site selection and a reduction from maximum yield.

Approximately 29.9 percent of the very low-income opportunity site units and approximately

44.9 percent of the moderate-income opportunity site units are located in the City’s Downtown Expansion District (20.4% and 44.9%) and First Street Corridor District (9.5% and 0%). To increase the likelihood that sufficient RHNA units are built in these two districts, the City added Program E - 12 (Downtown Expansion District and Mixed-Use Corridor Flexibility). This Program will allow 100 percent residential projects in the Downtown Expansion District and flexibility for non-residential units in the First Street Mixed Use Corridor, should projects meet certain criteria or provide housing for special needs groups (e.g., extremely low-income).

9.2 p. 582 of 1163
Sites and Resources ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 222
Local Data
To understand development trends in the City, recent inquiries and permit applications were reviewed. In discussions with City staff, including one planner who has worked for the City of Gilroy for over 30 years, staff noted that inquiries coming into the City are primarily for 100 percent residential or mixed-use. Although 100 percent commercial use is allowed, City staff has not seen a demand for new 100 percent commercial projects. The exception to this is new commercial uses occupying existing commercial buildings that don’t require significant upgrades. When mixed use is required, staff stated that developers typically propose a minimal amount of commercial square footage, citing concerns over the viability of commercial uses outside the downtown core. In cases where the likelihood of commercial vacancies is high, staff is generally supportive of amending the zoning to allow 100 percent residential uses.

Inquiries and submittals have included residential uses on upper stories, applications for adaptive reuse of existing historic buildings (i.e., tenant improvements), new commercial uses (e.g., new restaurant) in existing buildings, and new construction and redevelopment (e.g., adding new square footage). For example, the City is currently processing a preliminary application to add two new stories of residential uses to an existing two-story building located at 7541 Monterey Road in the City’s Downtown Historic District.

Development inquiries and proposals illustrate the trend of maximizing residential and minimizing commercial uses in mixed-use zones. Additionally, as noted above Program E - 12 would allow stand-alone residential projects in the Downtown Expansion District and flexibility for nonresidential uses in the First Street Mixed-Use Corridor, should the projects meet certain criteria to provide housing for special needs groups.

Multifamily developments in the City have had success in meeting the densities allowed by the zoning ordinance. Recent projects in multifamily zones, their land uses, zones, and densities are shown in Table 76. Eight of the eleven recent projects have achieved a yield over 100 percent of the maximum density. The average of these yields is 125 percent, suggesting that most developments are able to meet the maximum density, or in the case of zones with no maximum density, a density of at least 30 dwelling units (du) per acre. For projects in zones that allow densities of up to or greater than 30 du/acre, the average density of recent projects is 33.1 du/acre. Three of these recent projects utilized density bonuses: the JEMCOR apartments, Hecker Pass apartments, and the First and Kern apartments.

The Cannery Apartments project yields a noticeably lower percentage of the maximum density than the other projects on the list. This is due to an environmental constraint and easement.

Miller Slough runs through the northern part of the parcel and there was also a homeless encampment within the upper Miller Slough drainage channel which separates the Forest Park single-family development from the Cannery development. Accordingly, there is an “Easement, Joint Use and Maintenance Agreement” encumbering this development. Disregarding the Miller Slough on the northern portion of the parcel, the yield is closer to 70%.

9.2 p. 583 of 1163
Sites and Resources ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 223
Table 76: Example Multifamily Project Densities
Project Land Use Zoning
Project
Density
Number
of Units
Max
Density
Yield
Percentage
The Cannery
Apartments
Cannery District
DTSP CD 21.1 104 40 53%
Cantera
Commons
Mixed-Use Apts
Downtown
Expansion
District DTSP
DED 34.5 10 N/A* 115%
Alexander
Station Apts
Downtown
Expansion
District DTSP
DED 38.7 263 N/A* 129%
Monterey/Gilroy
Gateway Apts
Gateway
District DTSP GD 40.3 75 30 134%
Kern Ave Apts Low Density R3 13.7 27 16 86%
Royal Way
Townhomes
(proposed)
Medium
Density R3 13.4 45 16 83%
Hecker Pass Apts Medium
Density R3 26.2 100 16 164%
Gurries Duets Medium
Density R3 17.4 4 16 109%
Gurries
Townhomes
Medium
Density R3 21.1 4 16 132%
JEMCOR Apts High Density R4 30.8 120 30 103%
Harvest Park
Apts
Neighborhood
District ND 35.2 81 30** 117%
Source: City of Gilroy.
* The DED district in the Downtown Specific Plan has no maximum density. As such, a maximum density of 30 was used to ensure suitability for low-income development per HCD guidelines. ** The ND designation has a variety of densities within the designation, and there is no one maximum density for the zone.

Table 77 shows the assumed yields for higher density zones in the City. The yields were determined based on recent multifamily trends and development standards assessed in the constraints section. Though recent projects suggest that most projects in Gilroy are achieving the maximum, or close to the maximum, density on sites, conservative yields were assumed for the purposes of RHNA projection. The simple average yield is 101 percent, and the weighted average based on the number of units is 109 percent. All of the assumed yields in Table 77 are significantly below the observed yields and averages. For example, recent multifamily projects in the DED and DHD zones have been developed at densities of 34.5, 38.7, and 40.3 du/acre. Although the DED and DHD districts do not have maximum densities, the

9.2 p. 584 of 1163
Sites and Resources ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 224
yield was conservatively assumed at 100 percent of 30 du/acre. The five R3 sites averaged 92 percent yield versus the assumed yield of 70 percent.

Table 77: Assumed Yields
Zone Maximum Density Yield Estimated Yield
Density
R3 20 du/acre 70% 14 du/acre
R4 30 du/acre 80% 24 du/acre
CD 40 du/acre 70% 28 du/acre
DED 30 du/acre* 100% 30 du/acre
DHD 30 du/acre* 100% 30 du/acre
GD 30 du/acre 80% 24 du/acre
Mixed-Use Corridor 30 du/acre 70% 21 du/acre
* The DED and DHD districts have no maximum density.

Assumed Affordability
Density
The California Government Code states that if a local government has adopted density standards consistent with the population-based criteria set by the state, then HCD must accept sites with those density standards as appropriate for accommodating the jurisdiction’s share of lower-income units. For Gilroy, this density is 30 du/acre. The selected RHNA sites within the R4 zone, mixed-use corridor on First Street, and CD, DED, DHD, and GD districts in the Downtown Specific Plan meet the requirements of Government Code Section 65583.2(c)(3)(B).

Table 78 shows the income levels, densities, and their implementing zones in Gilroy.

Moderate-income housing can be accommodated through medium- and higher-density zones, with maximum densities ranging from 15 to 30+ du/ac. These densities support a variety of multifamily housing typologies, including townhomes and garden-style apartments, which may be affordable to moderate-income households. Above moderate-income housing needs may be met through lower-density, single-family typologies, typically in the 0 to 15 du/ac range.

9.2 p. 585 of 1163
Sites and Resources ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 225
Table 78: Densities, Affordability, and Implementing Zones Income Density Range (du/acre) Gilroy Implementing Zone Above
Moderate 0-15 RH, LDR, RR, ND
Moderate 15-30 MDR, ND, TD, DHD, DED, TD, CD, GD, R3, R4 Low 30+ HDR, MU, ND, DHD, DED, CD, GD, R4
Very Low 30+ HDR, MU, ND, DHD, DED, CD, GD, R4
Size
Pursuant to state law, RHNA sites accommodating lower-income units must have areas between 0.5 and 10 acres, regardless of allowed density. The identified RHNA sites for lowerincome units meet these criteria. Sites that may otherwise meet the 30 du/ac default density but are smaller than 0.5 acres are presumed to be affordable to moderate-income households.

The exception to this is one 0.49-acre vacant parcel in the mixed-use corridor. The site is part of a cluster of three vacant sites in the First Street mixed-use corridor (APNs: 790 39 019, 790 39 029, and 70 39 030). It is anticipated that this site could be developed together with the two other sites, which have acreages of 0.55 and 0.97. Even if the site is developed on its own, the

0.49-acre site is functionally the same as a 0.5-acre site for the purpose of its development.

Environmental and Infrastructure Constraints
The Opportunity site inventory analysis takes into consideration any environmental constraints such as habitat, flood, noise hazards, and steep slopes, among others. Any environmental constraints that would lower the potential yield (e.g., steep slopes) have already been accounted for in the site/unit capacity analysis. In general, the deductions in yield from the maximum will cover and accommodate any reductions in site capacity due to environmental constraints.

Local Data
The 2005 Downtown Specific Plan IS/MND analyzed 416 parcels and approximately 160 acres, and identified one contaminated site at 7301-7363 Monterey Road. A Phase I Environmental Site Assessment was completed in 2016, and cleanup was deemed not necessary. The following are two examples of recent projects that completed an environmental analysis. ▪ The ROEM development was submitted with a Phase I Environmental Site Assessment in August 2022. The study did not identify evidence of Recognized Environmental Conditions or Controlled Recognized Environmental Conditions in connection with the property; however, the report recommended subsurface investigation due to the historical use of the property as an auto dismantling storage yard from approximately

9.2 p. 586 of 1163
Sites and Resources ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 226
1963 to 2014. The applicant did not reduce the capacity of the project due to these contaminants and has not asked for any concessions related to the contaminants. ▪ An initial study / Mitigated Negative Declaration (MND) was prepared for the Monterey Gateway projects and identified no significant adverse effects on the environment.

There are no RHNA sites with known contamination, and no sites were identified as having contamination in either the 2040 Gilroy General Plan EIR or the Downtown Specific Plan MND.

Flooding
Portions of Gilroy fall into flood hazard zones as defined by the Federal Emergency Management Agency (FEMA). The City has been a participating community in the National Flood Insurance Program since August 1, 1980. Figure 45 displays the special flood hazard areas in Gilroy. The northern part of the City falls into flood zone “X”, which has a 0.2 percent annual chance of flooding; these areas are not subject to special standards. The large majority of the City has some amount of flood risk.

The southeast portion of the City is within the “AH” flood zones, which indicate areas that are subject to inundation by 1 percent annual chance of shallow flooding. Seven sites located along Monterey Street are within this zone, including three proposed for low-income development.

The City’s standards for development in the identified flood areas were adopted in 2016.39 The City allows for residential development within its floodplains, provided mitigating strategies and design choices are made to ensure safety and limit flood damage. In ”A“ flood zones, the construction must be elevated to or above the base flood elevation and the lowest floor must be elevated at least one foot above the base flood elevation. While the requirements for floodplain development may act as minor constraints to housing production, they are not expected to reduce development yields or preclude new housing production in general. Most of the recent and pipeline projects that are not a part of the Hecker Pass or Glen Loma Specific Plans are located in a flood zone. This includes the Cannery apartments, First and Kern apartments, Harvest Park apartments, and JEMCOR apartments.

The City does not have any RHNA sites within floodways, which is a water channel that directly conveys stormwater and experiences rapid velocities during wet weather events. 39 City of Gilroy Floodplain Ordinance. https://ca-gilroy.civicplus.com/DocumentCenter/View/6324/Gilroy-Flood-OrdinanceUpdate?bidId=

9.2 p. 587 of 1163
Sites and Resources ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 227
Figure 45: Gilroy Special Flood Hazard Areas
Source: Federal Emergency Management Agency.

Fire
Although the City of Gilroy does not have any areas identified by the state as very high fire severity zones, the City has identified properties for potential fire risk through its own Wildland Urban Interface (WUI) area map, as shown in Figure 46. According to FEMA, the adoption and effective implementation of up-to-date building codes is the most effective community mitigation measure. Furthermore, the City’s development standards recommend that people living in the WUI areas prepare for wildfires by maintaining adequate defensible space around their property, hardening their home by using building materials and installation techniques that increase resistance to heat, flames, and embers, and having a pre-evacuation plan prepared in the event of a wildfire and subsequent evacuation orders. The majority of the Gilroy Designated WUI is zoned for open space, Residential Hillside (RH, areas with 10%–30% slopes), R1, and the Hecker Pass Special Use District. None of the RHNA sites are within the WUI areas.

9.2 p. 588 of 1163
Sites and Resources ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 228
Figure 46: Gilroy Wildland Urban Interface Areas
Source: City of Gilroy.

Infrastructure
The City has enough capacity to accommodate the entire RHNA site inventory within the Urban Service Area, where the City is committed to providing basic infrastructure services for urban development. Full urban-level infrastructure services, including water and sewer, are available throughout the City and to the sites in the RHNA inventory. Program E - 1 states that the City will work with public service providers to ensure there is the prioritization of services to housing developments serving lower-income households.

9.2 p. 589 of 1163
Sites and Resources ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 229
Entitled and Pending Pipeline Projects
Per the HCD Sites Inventory Guidebook, the City may credit sites that have been proposed, approved, or given a certificate of occupancy since the beginning of the RHNA projected period.40 Table 79 includes pipeline projects (proposed, entitled, permits issued) that had not received certificates of occupancy as of June 30, 2022. The City has approved or received multiple applications for housing developments in the City. Pipeline project unit counts were based on City approved entitlements, building permits issued, and submitted applications. The City has reviewed the pipeline projects and there are no known barriers to development, phasing, or other relevant factors that would prohibit the pipeline projects from being completed. Any phasing or buildout horizons are considered in unit counts.

All of the lower income units identified in Table 79 are (or will be) deed restricted for a period of 55 years.
• The First and Kern and Hecker Pass apartments are both density bonus projects that are deed restricted for 55 years. The First and Kern and Hecker Pass apartments affordable units were under construction in April 2023 with final occupancy anticipated in spring 2023. • The Glen Loma Apartment Project is subject to the 15 percent affordable unit requirement under the Neighborhood District Policy and has a 55-year regulatory agreement. Final occupancy of the Glen Loma affordable units is also anticipated in spring 2023. • The 94-unit affordable project at 6630-6680 Monterey Street was under review by the Planning Department in April 2023. The environmental review and planning entitlements are anticipated to be complete by the end of 2024. Assuming a two-year construction timeline, this project would potentially be occupied in 2026.

City staff anticipates that the City’s allocation of above-moderate income units will be completed and exceeded during the 2023-2031 planning period.

All pipeline project units are anticipated to be completed in the planning period. The City will monitor the actual units constructed and income/affordability when the pipeline projects are developed as a part of Program A - 1. If the pipeline projects are not developed or are developed with fewer RHNA units than anticipated, the City will identify additional RHNA sites needed to make up the loss. Sites will be identified from the No Net Loss Inventory List created through Program A - 1.
40 HCD Sites Inventory Guidebook https://www.hcd.ca.gov/community-development/housingelement/docs/sites_inventory_memo_final06102020.pdf

9.2 p. 590 of 1163
Sites and Resources ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 230
Table 79: Pipeline Projects Counted in 6th Cycle (Proposed, Entitled, Permits Issued) PIPELINE PROJECTS Status Very
Low Low Moderate Above Moderate Total
JEMCOR First & Kern
Apts.
975 First Street
Building Permits
Issued on 4-21-2021 36 83 1 - 120
JEMCOR Village at Santa
Teresa Apartments
1520 Hecker Pass
Building Permits
Issued 04-12-2022 20 79 1 - 100
Glen Loma BMR
Apartments
1301-1345 Luchessa
Ave
Building Permits
Issued 06-11-2020 - 152 - - 152
Glen Loma, Royal Way,
and Gurries
Townhomes
Various stages of
review/issuance - - - 326 326
7888 Monterey MixedUse ProjectBuilding Permit
Applied 09-22-21 - - - 10 10
108 Chickadee Lane
Mixed-Use Project
Submitted to Planning
05-24-22 - - - 12 12
6630-6680 Monterey
Street Affordable
Housing Project
Submitted to Planning
12-07-22 20 73 1 - 94
Single Family Homes,
Subdivisions
Various stages of
review/issuance - - - 408 408
Total 76 387 3 756 1,222
Source: City of Gilroy.

Accessory Dwelling Units (ADUs)
The City of Gilroy has seen the number of ADU permits increase over recent years. A section of the City website is dedicated to ADU information, including FAQs, links to helpful resources, required documents, and the template to deed-restrict ADUs and junior ADUs. Table 80 displays ADU development trends in Gilroy. Based on the average number of building permits for ADUs in the last four years (15.75), the City is conservatively projecting 140 ADUs over the 2023–2031 6th cycle. The City is not relying heavily on projected ADUs to meet its RHNA (less than 7 percent of the RHNA plus the buffer).

The City is including Programs A - 6 (ADU Tracking and Monitoring), A - 7 (ADU Pre-Designed Plans), A - 8 (Financial Incentives for Affordable ADUs), Program A - 15 (ADU Ordinance Updates), and G - 3 (ADU Education) to incentivize and specifically facilitate ADU construction

9.2 p. 591 of 1163
Sites and Resources ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 231
for lower-income households per California Government Code Section 65583(c)(7).

Furthermore, Program A - 6 (ADU Tracking and Monitoring) requires an update to the ADU strategy if annual production and affordability rates fall below the estimates.

Table 80: ADUs Toward the RHNA
Year # of ADUs
2018 7
2019 16
2020 13
2021 27
Average 15.75
Source: City of Gilroy.

Assumed Affordability
The levels of affordability assumed for the 140 ADUs projected during the 6th Cycle period is based off the ABAG affordability survey data.41 The study allocated 30 percent of ADUs in each of the very low-, low-, and moderate-income categories, and the remaining 10 percent in the above moderate-income category. Table 81 displays the assumed affordability and projected number of ADUs in each income category.

Table 81: ADU Affordability Assumptions
Percent Income Category # of ADUs
30% Very Low 42
30% Low 42
30% Moderate 42
10% Above Moderate 14
140 ADUs (total)
Source: ABAG ADU Technical Assistance Memo, City of Gilroy.

Ability to Meet the RHNA
As shown in Table 82, the City has identified sufficient capacity to meet Gilroy’s RHNA, in addition to a 15 percent buffer, without rezoning. California Government Code Section 65583.2(c) states that cities must have a program to facilitate by-right approval for projects that include at least 20 percent of the units for lower-income housing on rezoned low-income 41 ABAG ADU Technical Assistance Memo. https://abag.ca.gov/sites/default/files/documents/2022-03/ADUs-Projections-Memofinal.pdf

9.2 p. 592 of 1163
Sites and Resources ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 232
sites. The City of Gilroy is not rezoning any sites to meet the RHNA. Thus, this provision is not applicable to the RHNA sites inventory for Gilroy.

Table 82: RHNA Capacity and Buffer
Category
Very
Low Low Moderate
Above
Moderate Total
A RHNA Assessment 669 385 200 519 1,773
B Pipeline Projects (Table 79) 76 387 3 756 1,222
C ADUs (Table 80) 42 42 42 14 140
D Unmet RHNA (A - B - C) 551 - 155 - 720
E Vacant Opportunity Sites (Table 84) 324 - 116 - 440
F Non-Vacant Opportunity Sites (Table 85) 329 - 62 - 391 G Opportunity Site Capacity (E + F) 653 - 178 - 831
H Total Capacity (B + C + G) 771 429 223 770 2,193
J Surplus of RHNA (H - A) 102 44 23 251 420
K % Buffer Above Unmet RHNA ((G – D) / D) 19% - 15% - - Lower Income Capacity
Government Code Section 65583.2(g)(2) states that housing elements relying on non-vacant sites for greater than 50 percent of its lower-income households need to demonstrate that the existing use does not constitute an impediment to additional residential development. Fifty percent of the 1,054 lower-income RHNA is 527 units. The requirements of Government Code Section 65583.2(g)(2) do not apply to Gilroy, since only 31.2 percent of the proposed lowerincome RHNA sites (including the buffer) are met through non-vacant sites (329/1,054 = 31.2%).

The remaining lower-income (low and very low) RHNA units are met through pipeline projects, ADUs, and vacant sites, as illustrated elsewhere in this chapter.

Table 83: Lower Income RHNA Capacity
Category
Lower Income Capacity
(VLI + LI)
% of Lower Income RHNA
(1,054 Units)
Pipeline Projects (Table 79) 463 (76 + 387) 43.9%
ADUs (Table 80) 84 (42 + 42) 8.0%
Vacant Opportunity Sites
(Table 84)
324 (324 + 0) 30.7%
Non-Vacant Opportunity
Sites (Table 85)
329 (329 + 0) 31.2%

9.2 p. 593 of 1163
Sites and Resources ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 233
Category
Lower Income Capacity
(VLI + LI)
% of Lower Income RHNA
(1,054 Units)
Total Lower Income Sites 1,200 (771 + 429) 113.9%
There are enough pipeline projects to fully meet the above moderate and the low-income RHNA categories, as shown in Table 74. There is also sufficient capacity with pipeline projects, ADUs, and opportunity sites to meet the City’s RHNA for all income categories with a 15 percent buffer for the unmet RHNA, as shown in Table 82.

Zoning for Moderate and Above Moderate Households
Pursuant to Government Code Section 65583.2(c)(4), at least 25 percent of the remaining moderate and above moderate RHNA sites are zoned for at least four units of housing (e.g., fourplex or greater). As shown in Table 82, above moderate sites are met entirely through pipeline projects and ADU projections (756 and 14 units, respectively). The 770 units exceed the above moderate RHNA allocation (519) by 251 units. There is no remaining above moderate RHNA that needs to be identified.

There is a remaining need of 155 moderate units after pipeline projects and projected ADUs.

The Opportunity Sites Inventory identifies 178 moderate-income RHNA opportunity site units.

Of these, 167 are on sites that allow for at least four units of development. Only 11 moderate units are identified on sites that allow for less than four units of housing. Thus, the City is compliant with Government Code Section 65583.2(c)(4). The allocation of moderate units on a site-by-site basis is shown in Appendix B.

Market Demand
The following inquiries for residential development act as indicators for potential development throughout the City:
• Inquiries from two different parties to redevelop property located at 7744 and 7740 Eigleberry Street with residential uses
• Inquiry on upzoning the vacant parcel at 820 Sunrise Drive to higher density residential • 7050 Monterey Road (and the two non-vacant parcels on either side of it) • 1355 First Street
• 1440 Ponderosa - large vacant site on west side
• 8955 Monterey Road
• APN 841-13-022 - vacant Pacific Railroad / future High Speed Rail site • APN 790 36 012 - car lot, Church/Howson northeast corner, west of Church, east of Monterey
• APN 790-35-001 and 790-36-02 – two vacant parcels, west of Church, east of Howson / Monterey

9.2 p. 594 of 1163
Sites and Resources ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 234
Opportunity Site Details
The Opportunity Site selection process examined zoned capacity, existing uses, and recent development trends to determine which parcels to include to meet the remaining RHNA after considering pipeline projects and ADUs. Both vacant and non-vacant sites are included in the Opportunity Sites Inventory. The opportunity site selection process took site characteristics, surrounding uses, and development constraints into consideration when evaluating each site’s development potential. To meet the RHNA for lower-income households, the Opportunity Sites Inventory relies on sites with densities that allow for at least 30 du/acre. To meet the RHNA for moderate-income households, the inventory relies on sites zoned for up to 20 du/acre in the medium density General Plan land use category. In addition, smaller sites (< 0.5 acres), zoned for up to and greater than 30 du/acre, may be suitable for moderate-income households. For a detailed analysis of the sites as they relate to affirmatively furthering fair housing, see the Affirmatively Furthering Fair Housing chapter.

Vacant Sites
A portion of the RHNA will be met on vacant land that is zoned for residential use. Per HCD’s Housing Element Sites Inventory Guidebook, a vacant site is one “without any houses, offices, buildings, or other significant improvements […] or structures on a property that are permanent and add significantly to the value of the property.”42 Table 84 displays the capacity of residentially zoned vacant sites included in the Opportunity Sites Inventory. A total of 440 lower- and moderate-income units can be accommodated with currently vacant residentially zoned land. This includes 324 very low units and 116 moderate-income units.

Table 84: Residential Vacant Sites Capacity
Zone Capacity
First Street Mixed-Use Corridor 30
Downtown Specific Plan 171
Neighborhood District 31
R3 6
R4 202
Total 440
Non-Vacant Sites
As shown in Table 82 and Table 83, only 329 (31.2%) of the 1,054 lower-income RHNA units will be met by non-vacant RHNA opportunity sites. When considering both lower-income (329 units) and moderate income (62 units), 391 units are accommodated through non-vacant 42 HCD Housing Element Sites Inventory Guidebook. https://www.hcd.ca.gov/community-development/housingelement/docs/sites_inventory_memo_final06102020.pdf

9.2 p. 595 of 1163
Sites and Resources ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 235
opportunity sites. Table 85 summarizes the capacity of non-vacant sites included to meet the RHNA broken down by their existing General Plan use. As shown in Table 85, the 391 nonvacant site units are located in the First Street mixed-use corridor (32 units), the R4 zone (109 units), Downtown Specific Plan areas (229 units), and the Public Facility zone (21 units).

Table 85: Non-Vacant Site Capacity
Existing GP Use Capacity
First Street Mixed-Use Corridor 32
Downtown Specific Plan 229
R4 109
PF 21
Total 391
Source: City of Gilroy.

Non-Vacant Site Details
Local Data
The City has seen recent interest in redevelopment of non-vacant sites for affordable and market-rate housing. This includes a project proposed in 2022 for a 94-unit, 100 percent lowerincome project on three parcels in the Gateway District in the Downtown Specific Plan area.

Current uses on these parcels include a two-story office building, multiple single-story commercial structures, and their paved parking areas. Another project proposed on a nonvacant site includes the development of an affordable housing project on land owned by Santa Clara County that currently consists of four large structures. The City of Gilroy and the Santa Clara County Office of Supportive Housing entered into a Memorandum of Understanding in October 2022 regarding the development of 57 units for households earning less than 80 percent of AMI. This project is not included in RHNA projections since a formal proposal has not yet been received. The City has also received interest in developing market-rate housing from a developer for a parcel that includes a car dealership in Downtown.

These projects demonstrate the viability and interest in redeveloping non-vacant sites in downtown Gilroy, including for both affordable and market-rate housing. These sites have similar zoning and characteristics to the proposed RHNA sites and therefore demonstrate the strong likelihood of meeting the projected construction of units within the next 8 years.

The following section provides further detail on each of the non-vacant sites identified in the inventory. The non-vacant sites were selected based on their existing uses, capacity for residential redevelopment, and their high potential for short-term redevelopment. Landimprovement ratios were also calculated and considered in site selection. The comparison of assessed values for land and improvements (land-improvement ratios) is a reliable indicator of whether and to what extent sites are utilized. Typically, a newly improved site will have a

9.2 p. 596 of 1163
Sites and Resources ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 236
ratio of well under 0.2, or where the improvements are valued at five times the value of the land.

R4 Northern Cluster
The parcels at 8985, 8955, and 8915
Monterey Road are all R4 zoned sites
adjacent to one another, which provides an
opportunity for consolidation. There are no
existing residential uses on the sites. Their
combined acreage is 3.59 acres. The
combined realistic capacity for these sites
is 86 lower-income units. The northern and
central buildings were built prior to 1956.

There is no maximum FAR and no
maximum density in the R4 zone.
8985 Monterey Road (R4 High Density)
The 0.80-acre site at 8985 Monterey Road is currently occupied by a preschool and day care center. More than half of the lot is a parking lot and is underutilized relative to its potential under the current zoning. It is located in the center of an existing residential community, making this site optimal for further residential development. The site is near several restaurants and gyms, as well as a large park and a grocery store, which provide necessary resources for residents. The land-improvement ratio for this site is 1.05. The realistic capacity for this site is 19 units. The site could be developed to retain the existing use in either existing or new buildings as part of new residential development. 8955 Monterey Road (R4 High Density)
The 2.05-acre site at 8955 Monterey Road is currently occupied by a church, a closed commercial building that was formerly the office of a general contractor, and several storage containers.

9.2 p. 597 of 1163
Sites and Resources ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 237
Commercial structures on the lot are single story, while the church is partially two stories.

Approximately half the site is used for parking or vehicle access. It is located in the center of an existing residential community, making this site optimal for further residential development. There is potential for partial redevelopment of the site, on the western portion of the site, which could maintain some of the existing uses during redevelopment. The site is near several restaurants and gyms, as well as a large park and a grocery store, which provide necessary resources for residents. The assessor data did not provide a value for improvements on this parcel so the land-improvement ratio could not be calculated. The realistic capacity for this site is 49 units. It may be possible to achieve this capacity while maintaining some of the existing uses, specifically the church.
8915 Monterey Road (R4 High Density)
The 0.74-acre site at 8915 Monterey Road is currently occupied by a used car sales lot. It is located in the center of an existing residential community, making this site optimal for further residential development. The site is near several restaurants and gyms, as well as a large park and a grocery store, which provide necessary resources for residents. It is nearly all surface parking, with no expensive or modern permanent structures that would preclude redevelopment. The land-improvement ratio for this site is 19.01. The realistic capacity for this site is 18 units.

9.2 p. 598 of 1163
Sites and Resources ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 238
R4 Northern Cluster Description
APNs 790-14-025 790-14-075 790-14-091
Size (Ac) 2.05 0.74 0.80
Zoning R4
General Plan Designation High Density Residential
Current Use Commercial Commercial Preschool
Land Improvement Ratio N/A 19.01 1.05
Within 1 mile of:

Daycare Yes - Little Blue Star Daycare, 826 Mantelli Dr Grocery Yes - Lopez Produce Market, 8655 Monterey Hwy
School Yes - Vine Academy, 8455 Wren Ave
Income Category Lower
Total Units 49 18 19
Monterey Cluster 1 (Downtown Expansion District)
The parcels at 7191, 7161, 7121 Monterey
Street and Monterey Street (west side),
north of W Ninth Street are all adjacent to
one another, which provides an
opportunity for a larger moderate-income
residential community. The sites are near
several restaurants, a grocery store, and a
train station, which provide necessary
resources for residents. Their combined
acreage is 1.32 acres. The combined
realistic capacity for these sites is 40 units.

Mixed-use projects have a maximum FAR of

2.5 and a minimum residential density of 20 du/ac. There is no maximum density. Under Program E - 12 (Downtown Expansion District Flexibility), the City would allow 100 percent residential uses on this site should the project meet certain criteria or provide housing for special needs groups (e.g., extremely low-income).
7191 Monterey Street (Downtown Expansion District)
The 0.34-acre site at 7191 Monterey Street is currently partially occupied by a vacant singlestory office space. More than half of the lot is a parking lot or for vehicle access and is underutilized land. It is adjacent to an existing residential community, making this site optimal for further residential development and potential lot consolidation. The land-improvement ratio for the site is 0.64. The realistic capacity for this site is 10 moderate-income units. Under

9.2 p. 599 of 1163
Sites and Resources ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 239
Program E - 12 (Downtown Expansion District Flexibility), the City would allow 100 percent residential uses on this site should the project meet certain criteria or provide housing for special needs groups (e.g., extremely low-income).
7161 Monterey Street (Downtown Expansion District)
The 0.32-acre site at 7161 Monterey Street is currently partially occupied by a small plumbing and auto sales office that was built in 1930 (non-historic). More than half of the lot is parking for the used cars being sold by the dealer. It is adjacent to an existing residential community, making this site optimal for further residential development and lot consolidation. The landimprovement ratio for this site is 1.90. The realistic capacity for this site is 10 moderate-income units. Under Program E - 12 (Downtown Expansion District Flexibility), the City would allow 100 percent residential uses on this site should the project meet certain criteria or provide housing for special needs groups (e.g., extremely low-income).

Monterey Street(west side), north of W Ninth Street(Downtown Expansion District) The 0.30-acre site at Monterey Street is currently entirely used as a parking lot or for the used cars being sold by the auto dealer on the adjoining parcel. Redevelopment of this site would benefit the community as its single level use as a parking lot renders the land underutilized and below its zoning potential. It is adjacent to an existing residential community, making this site optimal for further residential development and lot consolidation. The assessor data did not provide a value for improvements on this parcel so the land-improvement ratio could not be calculated. The realistic capacity for this site is 9 moderate-income units. Under Program E - 12 (Downtown Expansion District Flexibility), the City would allow 100 percent residential

9.2 p. 600 of 1163
Sites and Resources ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 240
uses on this site should the project meet certain criteria or provide housing for special needs groups (e.g., extremely low-income).
7121 Monterey Street (Downtown Expansion District)
The 0.36-acre site at 7121 Monterey Street is currently half occupied by a seafood restaurant with some outdoor dining spaces. More than half of the lot is a parking lot or for vehicle access and is underutilized land. It is adjacent to an existing residential community, making this site optimal for further residential development and lot consolidation. The land-improvement ratio is 1.24. The realistic capacity for this site is 11 moderate-income units. Under Program E - 12 (Downtown Expansion District Flexibility), the City would allow 100 percent residential uses on this site should the project meet certain criteria or provide housing for special needs groups (e.g., extremely low-income).

9.2 p. 601 of 1163
Sites and Resources ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 241
Monterey Cluster 1 Description
APNs 799-10-033 799-10-034 799-10-048 799-10-049
Size (Ac) 0.34 0.32 0.30 0.36
Zoning DED – Downtown Expansion District
General Plan Designation Downtown Specific Plan
Current Use Commercial Commercial Parking Lot Commercial Land Improvement Ratio 0.64 1.90 N/A 1.24
Within 1 mile of:

Daycare Yes - Hunny Bunny Daycare, 7361 Eigleberry St
Grocery Yes - Gilroy Valley Market, 7237 Monterey Hwy #6921 School Yes - Glen View Elementary School, West 8th St
Income Category Moderate
Total Units 10 10 9 11
Monterey Cluster 2 (Gateway/Downtown Expansion District) The parcels at 6790 and 6620 Monterey
Road are both in Gateway District zoned
sites adjacent to one another in the
Downtown Specific Plan area. 6920
Monterey Road in the Downtown
Expansion District and is also included in
this group of sites. These sites provide an
opportunity for a larger residential
community and a potential for lot
consolidation. The sites are near several
restaurants, a bulk grocery store, and a
high school, which provide necessary
resources for residents. These sites all
have high land-improvement ratios
indicating strong potential for redevelopment. These sites are adjacent to a proposed project located at 6730, 6630, and 6680 Monterey Street, which are denoted with a crosshatch in the aerial above. Their combined acreage is 2.61 acres and the combined realistic capacity is 73 units. This cluster of sites spans two districts. Mixed-use projects in the Downtown Expansion District have a maximum FAR of 2.5 and a minimum residential density of 20 du/ac (there is no maximum density). Mixed-use projects in the Gateway District have a maximum FAR of

0.75, while stand-alone residential projects have a maximum 30 du/ac density. Under Program E - 12 (Downtown Expansion District Flexibility), the City would allow 100 percent residential

9.2 p. 602 of 1163
Sites and Resources ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 242
uses on this site should the project meet certain criteria or provide housing for special needs groups (e.g., extremely low-income).
6920 Monterey Road (Downtown Expansion District)
The 1.69-acre site at 6920 Monterey Road is currently about two-thirds underutilized vacant lot, with the only building being a permanently closed furniture store. It is adjacent to an existing residential community, making this site optimal for further residential development.

The site has a land-improvement ratio of 0.81. The realistic capacity for this site is 51 lowerincome units. Under Program E - 12 (Downtown Expansion District Flexibility), the City would allow 100 percent residential uses on this site should the project meet certain criteria or provide housing for special needs groups (e.g., extremely low-income). 6790 Monterey Road (Gateway District)
The 0.39-acre site at 6790 Monterey Road currently has an electric company building occupying about 25 percent of the parcel, while the large majority of the site is an underutilized surface parking lot. It is adjacent to an existing residential community, making this site optimal for further residential development. The site has a land-improvement ratio of 2.37. The realistic capacity for this site is 9 moderate-income units. It is possible these units could be built without displacing the existing use.

9.2 p. 603 of 1163
Sites and Resources ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 243
6620 Monterey Road (Gateway District)
The 0.53-acre site at 6620 Monterey Road is currently almost all parking lot and vehicle access, with a small commercial construction building. It is adjacent to an existing residential community, making this site optimal for further residential development. The site has a landimprovement ratio of 3.33. The realistic capacity for this site is 13 lower-income units.

Monterey Cluster 2 Description
APNs 841 14 006 841 14 081 841 14 083
Size (Ac) 0.39 0.53 1.69
Zoning
GD – Gateway District GD – Gateway District DED – Downtown Expansion District
General Plan
Designation Downtown Specific Plan
Current Use Commercial Industrial Parking
Land Improvement
Ratio 2.37 3.33 0.81
Within 1 mile of:

Daycare Yes - Clever Kidz Home Daycare, 295 London Dr
Grocery Yes - Smart & Final Extra!, 250 E 10th St
School Yes - Glen View Elementary School, West 8th St
Income Category Moderate Very Low Very Low
Total Units 9 13 51

9.2 p. 604 of 1163
Sites and Resources ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 244
Monterey Cluster 3 (Gateway District)
The parcels at 6320, 6470, and 6380 Monterey Road are all adjacent to one another in the Downtown Specific Plan area, which
provides an opportunity for a larger
residential community and lot
consolidation. The sites are near a
park, a school, and a grocery outlet,
which provide necessary resources
for residents. Their combined
acreage is 2.06 acres and the
combined realistic capacity is 48
units. Mixed use projects in the
Gateway District have a maximum
FAR of 0.75, while stand-alone
residential projects have a maximum
30 du/ac density.
6320 Monterey Road (Gateway District)
The 0.55-acre site at 6320 Monterey Road is currently occupied by a single-family home and a permanently closed hardware store. Half of the parcel is an underutilized empty lot, making this site optimal for further residential development. The land-improvement ratio for the site is 0.87. The realistic capacity for this site is 12 lower-income units. 6380 and 6470 Monterey Road (Gateway District)
The 0.77- and 0.74-acre sites at 6380 and 6470 Monterey Road are currently an unoccupied former lumber yard and associated buildings. The majority of the parcels are vacant and underutilized. They are adjacent to an existing residential community, making these sites optimal for further residential development. The land-improvement ratio for these sites is 1.25 and 22.52, respectively. The realistic capacity for each site is 18 lower-income units.

9.2 p. 605 of 1163
Sites and Resources ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 245
Monterey Cluster 3 Description
APNs 841 14 015 841 14 036 841 14 037
Size (Ac) 0.55 0.74 0.77
Zoning GD – Gateway District
General Plan
Designation Downtown Specific Plan
Current Use Single - Family
Residential Industrial Industrial
Land Improvement
Ratio 0.87 22.52 1.25
Within 1 mile of:

Daycare Yes - Clever Kidz Home Daycare, 295 London Dr
Grocery Yes- Smart & Final Extra!, 250 E 10th St
School Yes - Gilroy High School, 750 W 10th St
Income Category Very Low
Total Units 12 18 18

9.2 p. 606 of 1163
Sites and Resources ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 246
Monterey Cluster 4 (Downtown Expansion District)
The parcels at 7780, 7760, and 7700 Monterey Road are all adjacent to one another in the Downtown Specific Plan
area, which provides an opportunity for a larger residential community and lot consolidation. The sites are near
multiple schools and a grocery store, which provide
necessary resources for residents. Their combined
acreage is 1.75 acres. The combined realistic capacity for these sites is 52 units. Mixed use projects in the Downtown Expansion District have a maximum FAR of 2.5 and a
minimum residential density of 20 du/ac (there is no
maximum density). Under Program E - 12 (Downtown
Expansion District Flexibility), the City would allow 100 percent residential uses on this site should the project meet certain criteria or provide housing for special needs groups (e.g., extremely low-income).
7780 Monterey Road (Downtown Expansion District)
The 0.44-acre site at 7780 Monterey Road is currently occupied by a single-story office space and a small shed. About 25 percent of the parcel is an underutilized surface lot. Businesses that occupy the site seem to have limited hours, which may eliminate the need for an office space. There is also the possibility for a mixed-use development without displacement of existing businesses. The assessor data did not provide a value for improvements on this parcel so the land-improvement ratio could not be calculated. The realistic capacity for this site is 13 moderate-income units. Under Program E - 12 (Downtown Expansion District Flexibility), the City would allow 100 percent residential uses on this site should the project meet certain criteria or provide housing for special needs groups (e.g., extremely low-income). 7760 Monterey Road (Downtown Expansion District)
The 0.7-acre site at 7760 Monterey Road is currently occupied by a single-story strip mall that includes a restaurant and a window tinting business. About 75 percent of the parcel is an underutilized surface lot with vehicle access both in front of and behind existing businesses.

Development without displacement of existing businesses is possible. The land-improvement

9.2 p. 607 of 1163
Sites and Resources ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 247
ratio for the site is 1.35. The realistic capacity for this site is 21 lower-income units. Under Program E - 12 (Downtown Expansion District Flexibility), the City would allow 100 percent residential uses on this site should the project meet certain criteria or provide housing for special needs groups (e.g., extremely low-income).
7700 Monterey Road (Downtown Expansion District)
The 0.61-acre site at 7700 Monterey Road is currently occupied by a single-story small office park. Over half the site is underutilized lot and vehicle access. The land-improvement ratio for the site is 0.75. The realistic capacity for this site is 18 lower-income units. Under Program E - 12 (Downtown Expansion District Flexibility), the City would allow 100 percent residential uses on this site should the project meet certain criteria or provide housing for special needs groups (e.g., extremely low-income).

9.2 p. 608 of 1163
Sites and Resources ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 248
Monterey Cluster 4 Description
APNs 841 04 018 841 04 019 841 04 020
Size (Ac) 0.61 0.70 0.44
Zoning DED – Downtown Expansion District
General Plan
Designation Downtown Specific Plan
Current Use Office Commercial Office
Land Improvement
Ratio 0.75 1.35 N/A
Within 1 mile of:

Daycare Yes - Forget Me Not Day Care, 7661 Rosanna St
Grocery Yes- El Charrito Market, 7638 Monterey Hwy
School Yes - Gilroy Prep School, 277 IOOF Ave
Income Category Very Low Moderate
Total Units 18 21 13
Monterey Street south of Ninth Street (Downtown Expansion District) The 0.5-acre site is adjacent to a parking lot
and railway and is surrounded by residential,
industrial, and commercial land uses. This
parcel is currently a storage yard for trucks
and is a large, paved parking area. Existing
uses are not expected to preclude
development of this site. The site has a landimprovement ratio of 0 as there are no structures on-site. The realistic capacity for
this site is 16 lower-income units. The zoning
allows a density range of up to 30 du/net acre
in the Downtown Expansion District within the
Downtown Specific Plan Area. Under Program
E - 12 (Downtown Expansion District Flexibility), the City would allow 100 percent residential uses on this site should the project meet certain criteria or provide housing for special needs groups (e.g., extremely low-income).

9.2 p. 609 of 1163
Sites and Resources ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 249
Monterey St., south of Ninth
St (Downtown Expansion
District)
Description
APNs 841 14 001
Size (Ac) 0.5
Zoning DED – Downtown Expansion District
General Plan Designation Downtown Specific Plan
Current Use Storage
Land Improvement Ratio 0
Within 1 mile of:

Daycare Yes – Hunny Bunny Daycare, 7361 Eigleberry St.

Grocery Yes – Grocery Outlet, Smart & Final; E. 10th St.

School Yes – Glen View Elementary School, 600 W 8th St
Income Category Very Low
Total Units 16

9.2 p. 610 of 1163
Sites and Resources ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 250
Other Zoning Districts and Designations
880 Sunrise Drive (PF)
The 1.98-acre site at 880 Sunrise Drive is
currently two-thirds occupied by a City of
Gilroy fire station. The remainder of the
site is vacant. The PF zone permits all
facilities owned or leased, operated, or
used by the City or other governmental
agencies on the site. It is located in the
center of an existing residential
community in a higher resource area of
the City, making this site optimal for
further residential development. The site
is near several schools and a daycare
center, which provide necessary resources for residents. The assessor data did not provide a value for improvements on this parcel so the land-improvement ratio could not be calculated.

The realistic capacity for this site is 21 lower-income units on the vacant land and parking lot portions of the site, while retaining the existing fire station.

9.2 p. 611 of 1163
Sites and Resources ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 251
880 Sunrise Drive Description
APNs 783 20 050
Size (Ac) 1.98
Zoning PF – Park/Public Facilities District
General Plan Designation Low Density Residential
Current Use Fire Station
Land Improvement Ratio N/A
Within 1 mile of:

Daycare Yes - Kool Kids Day Care, 1030 Cheyenne Dr
Grocery No - Safeway, 905 First St (2.2 miles)
School Yes - Christopher High School, 850 Day Rd
Income Category Very Low
Total Units 21
1335 First Street (First Street Mixed-Use Corridor)
The 0.55-acre site is adjacent to two
vacant parcels also listed on the sites
inventory, with strong potential for
redevelopment of all three parcels.

This lot is currently occupied by a twostory commercial building which includes a dental care office and a
permanently closed pregnancy
resource center. The building was built
between 1968 and 1980. The site has a
land-improvement ratio of 0.50. Existing uses are not expected to preclude development of this site. The realistic capacity for this site is 12 lower-income units. The General Plan allows a density range of 20-30 du/net acre in the Mixed-Use land use designation. There are no floor area standards for the residential portion of mixed-use projects. Under Program E - 12 (First Street Corridor Mixed-Use District Flexibility), the City would allow flexibility for the nonresidential uses on this site should the project meet certain criteria or provide housing for special needs groups (e.g., extremely low-income).

9.2 p. 612 of 1163
Sites and Resources ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 252
1335 First Street Description
APNs 790 39 029
Size (Ac) 0.55
Zoning C3 – Shopping Center Commercial District
General Plan Designation Mixed Use
Current Use Office
Land Improvement Ratio 0.5
Within 1 mile of:

Daycare Yes - Sunnyside Daycare, 7962 Westwood Dr A305
Grocery Yes - Safeway, 905 First St
School Yes - Rod Kelley Elementary School, 8755 Kern Ave Income Category Very Low
Total Units 12
1395 First Street(First Street Mixed-Use Corridor)
The 0.97-acre site is adjacent to two vacant
parcels and one other non-vacant parcel also
listed on the sites inventory, with strong
potential for redevelopment of all four
parcels. This lot is currently occupied by a
one-story building, which contains a martial
arts studio, and a large surface parking lot.

The building was built between 1987 and
1998. Existing uses are not expected to
preclude development of this site. The site
has a land-improvement ratio of 0.45. The

9.2 p. 613 of 1163
Sites and Resources ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 253
realistic capacity for this site is 20 lower-income units. The General Plan allows a density range of 20-30 du/net acre in the Mixed-Use land use designation. There are no floor area standards for the residential portion of mixed-use projects. Under Program E - 12 (First Street Corridor Mixed-Use District Flexibility), the City would allow flexibility for the non-residential uses on this site should the project meet certain criteria or provide housing for special needs groups (e.g., extremely low-income).
1395 First Street Description
APNs 790 39 020
Size (Ac) 0.97
Zoning C3 – Shopping Center Commercial District
General Plan Designation Mixed Use
Current Use Office
Land Improvement Ratio 0.45
Within 1 mile of:

Daycare Yes - Sunnyside Daycare, 7962 Westwood Dr A305
Grocery Yes - Safeway, 905 First St
School Yes - Rod Kelley Elementary School, 8755 Kern Ave Income Category Very Low
Total Units 20

9.2 p. 614 of 1163
Sites and Resources ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 254
8897 Monterey Road (R4)
The 0.95-acre site is adjacent to a vacant parcel and is surrounded by residential and commercial land uses. This parcel is
currently occupied by four single-story
buildings that comprise a Budget Motel
and a large paved and unpaved parking
area. The primary buildings were built in
1952 and the last building was
constructed between 1968 and 1980.

Existing uses are not expected to
preclude development of this site. The
site has a land-improvement ratio of

2.09. The realistic capacity for this site is
23 lower-income units. The zoning
allows a density range of up to 30 du/net
acre in the R4 High Density Residential
zone.

9.2 p. 615 of 1163
Sites and Resources ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 255
8897 Monterey Road Description
APNs 790 15 041
Size (Ac) 0.95
Zoning R4 – High Density Residential
General Plan Designation General Services Commercial
Current Use Commercial
Land Improvement Ratio 2.09
Within 1 mile of:

Daycare Yes - Tiny Tots Preschool & Daycare, 8985 Monterey Hwy Grocery Yes - Lopez Produce Market, 8655 Monterey Hwy
School Yes - Rod Kelley Elementary School, 8755 Kern Ave Income Category Very Low
Total Units 23

9.2 p. 616 of 1163
Sites and Resources ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 256
Financial Resources
The Housing Element serves, in part, to identify what actions can be taken to support the production of housing. Through collaboration with City staff, service providers, and the community, the City’s Housing Element identifies financial resources that support housing production.

Countywide Programs
2016 Measure A – Affordable Housing Bond
In November 2016, Santa Clara County voters approved Measure A, the $950 million affordable housing bond. The housing bond provides the County with an unprecedented opportunity to partner with cities, residents, and the affordable and supportive housing community to significantly address the housing needs of the community’s poorest and most vulnerable residents. It provides affordable housing for vulnerable populations, including veterans, seniors, the disabled, low- and moderate-income individuals or families, foster youth, victims of abuse, homeless persons, and individuals suffering from mental health or substance abuse illnesses. The bond proceeds would contribute to the creation and/or preservation of approximately 4,800 affordable housing units in Santa Clara County.

The housing bond will enhance the County’s ability to achieve its housing priorities which include:
• Increasing the scope and breadth of supportive housing for special needs populations, including homeless and chronically homeless persons;
• Increasing the supply of housing that is affordable to extremely low-income households; and
• Improving coordination and collaboration among the County, the cities, other governmental agencies, and the affordable housing community.

About $7.5 million in Measure A funds was used to develop the Monterey Gateway Senior Apartments, a 75-unit affordable housing complex for low-income seniors that was constructed in Gilroy in 2020.

MHSA Housing Program
The California Department of Mental Health, the California Housing Finance Agency, and the County Mental Health Directors Association announced a new housing program in 2016 under which $400 million in Mental Health Services Act (MHSA) funds were made available to finance the capital costs associated with development, acquisition, construction, and/or rehabilitation of permanent supportive housing for individuals with mental illness and their families, especially including unhoused individuals. The new MHSA Housing Program, and funds for capitalized operating subsidies, are included in the $400 million that has been designated for the program.

9.2 p. 617 of 1163
Sites and Resources ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 257
This program will serve persons with serious mental illness who are currently unhoused or at risk of homelessness and who meet the MHSA Housing Program target population description. Santa Clara County’s allocated amount is $19,249,300, of which $6,416,400 can be used for capitalized operating subsidies. MHSA funding pays only for housing units designated to qualified consumers.

The Sobrato Transitional Apartments is an MHSA housing project in Gilroy. The Sobrato Transitional Apartments, developed and constructed by South County Housing Corporation, provides 35 single-occupancy studio units in Gilroy for unhoused individuals with incomes below 30 percent of the area median income (AMI). The South County Housing Corporation will set aside 17 units for individuals that are currently unhoused or at risk of becoming homeless due to mental illness.

U.S. Department of Housing and Urban Development (HUD) Grants HOME
The HOME Program is federally funded by HUD to provide decent affordable housing to lowerincome households. The HOME Program is administered on behalf of the Santa Clara County Urban County cities, which includes Gilroy.

Community Development Block Grant
The City of Gilroy is an entitlement jurisdiction participating in HUD’s Community Development Block Grant (CDBG) Program. A requirement of receiving CDBG funds is the City having a fiveyear Consolidated Plan, which identifies local community development needs and sets forth a strategy to address these needs over a five-year period. The City’s current 5-Year Consolidated Plan spans July 1, 2020 – June 30, 2025.

Developing an Annual Action Plan (AAP) for each of the fiscal years within the Consolidated Plan is also required. AAPs program the use of federal funding for their respective fiscal year by outlining which specific projects or programs will receive funding from the annual allocation. Funding available for housing assistance programs from the state and federal governments is extremely limited. The AAP, which gives a complete breakdown of public service descriptions and use of funds, is available on the City’s website.

For the 2021-2022 and 2022-2023 fiscal years, the City of Gilroy allocated approximately $440,000 (each year) in CDBG funds from HUD. The CDBG program aims to support activities that benefit low-income households, aid in the prevention of slums or blight, or meet an urgent community need, through grants for eligible activities. A breakdown of CDBG-funded agencies are listed below:

9.2 p. 618 of 1163
Sites and Resources ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 258
Table 86: CDBG Funded Agencies
Activity Name 2020/2021
Entitlement
2021/2022
Entitlement
2022/2023
Entitlement
Program Administration $97,250 $87,874 $87,635
Gilroy Youth Center $38,452 $38,452 $38,452
Rebuilding Home Repair Program $144,364 $140,000 $140,000 Gilroy Compassion Center $16,318 - -
Live Oak Adult Day Care $11,549 $8,560 $10,000
Meals on Wheels - $8,643 -
Community Outreach PREP - $10,250 -
Boys & Girls Club - Core Enrichment - - $8,500
C.A.R.A.S - Ryse Up Program - - $8,500
Cherry Blossom Rehab - $81,475 -
Monterey Gateway Improvements - $70,592 -
Code Enforcement $7,700 - -
Sidewalk / Curb Ramp CIP Project $156,155 - $145,090
Source: City of Gilroy, 2022
CDBG CARES ACT-Coronavirus (CDBG-CV) Funds
CDBG-CV funds were specifically made available for programming that would address the impacts resulting from the COVID-19 pandemic, and include the following programs:

Table 87: CARES Act CDBG-CV Funds
Activity Name Entitlement
St. Joseph’s Rental Assistance $150,000
Small Business Assistance $125,486
Small Business Assistance $100,000
St. Joseph's Rental Assistance $137,309
YMCA Healthy Food Delivery $100,359
Source: City of Gilroy, 2022.

Rental Assistance/Subsistence Program
The St. Joseph’s Rental Assistance program utilizes CARES Act funding for Gilroy residents needing rental assistance. Rent relief is provided to persons and households directly affected by the COVID-19 pandemic.

9.2 p. 619 of 1163
Sites and Resources ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 259
Small Business Relief Grant Program
The Small Business Assistance Program, originally developed in 2020, includes $435,000 in professional support for local businesses with processing applications for federal and state loans/grants. This program aligns with the purpose of the CARES Act to provide small grants ($5,000 to $10,000) to help local businesses cope with the COVID-19 related economic downturn by providing funds needed for working capital that will result in low-income jobs being retained and/or created.

Housing Trust Fund
The City had historically allocated funding for services related to housing and homelessness through its Housing Trust Fund (HTF). The City Council replaced the HTF with the Permanent Local Housing Allocation (PLHA) Fund, making more funds available for public service programs addressing basic needs and homelessness prevention. The HTF will continue to be used to partially cover staff and consulting service costs to monitor affordable rental and ownership agreements, until the money is depleted.

Permanent Local Housing Allocation Fund
The PLHA Fund spans a five-year period and will make available $1.4 million. The City is contracting with Santa Clara County’s Office of Supportive Housing to administer the programs under the PLHA Consortium Agreement. The following agencies were approved by the City Council for FY 22-23 and FY 23-24:

9.2 p. 620 of 1163
Sites and Resources ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 260
Table 88: Permanent Local Housing Allocation Funds for FYs 2022-2024 Agency Funded Services Funding
Amount
St. Joseph’s Family Center
Emergency rental assistance, utility assistance, and
other supportive programs that help diminish the
risk of becoming homeless
$110,000
St. Joseph’s Family Center
Training and employment readiness to prepare
individuals that are homeless or at risk of
homelessness for stability and greater selfsufficiency $70,000
Project Sentinel Fair housing services and investigates complaints to address housing discrimination for Gilroy residents $40,000 Project Sentinel
Landlord-tenant counseling and dispute resolution
program to help resolve housing conflict and protect
Gilroy residents from displacement
$40,000
The Health Trust
Meals to low income and homebound seniors at risk
of food insecurity, allowing them to remain in their
homes
$54,000
South County
Compassion Center
Services to unhoused Gilroy residents to meet their
basic needs and to connect them with services that
can help them attain permanent housing
$80,000
Community Agency for
Resources Advocacy and
Services
Rental and deposit assistance to prevent
homelessness for Gilroy families and individuals $40,000 Silicon Valley
Independent Living
Center
Counseling for Gilroy residents with disabilities,
emergency rental assistance, and housing search
services to obtain safe, affordable, and accessible
long-term housing
$40,000
Source: City of Gilroy, 2023.

Housing Choice Voucher Program
The Housing Choice Voucher (HCV) program is a rental assistance program that helps very lowincome families to live in market-rate housing units rather than public housing. Households are provided with vouchers that are paid to private market-rate landlords, who are then reimbursed by HUD. In addition to the regular voucher program, Santa Clara County Housing Authority (SCCHA) administers special housing programs. These programs include the Veterans Affairs Supportive Housing (VASH) Program, Mainstream Program, and Emergency Housing Vouchers (EHV).
• The VASH Program is for homeless veterans with severe psychiatric or substance abuse disorders. The Veterans Affairs Palo Alto and SCCHA have partnered to provide rental

9.2 p. 621 of 1163
Sites and Resources ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 261
vouchers and supportive services to eligible veterans. The veteran must demonstrate to the VA Medical Center that they are homeless (has been living outdoors, in a shelter, in an automobile, etc.) before being evaluated for this program. • The Mainstream Program is designed to provide assisted housing to persons with disabilities to enable them to rent suitable and accessible housing in the private rental market. Mainstream applicants are offered a voucher as allocations become available.

Applicants must be participating in programs of rehabilitation and/or support services within the community that are directly related to their disability. • The EHV program is available through the American Rescue Plan Act. Through EHV, HUD provided SCCHA with 664 housing vouchers to assist individuals and families who are homeless, at risk of homelessness, were recently homeless or have a high risk of housing instability; or who are fleeing or attempting to flee domestic violence, dating violence, sexual assault, stalking, or human trafficking.

Project-Based Voucher Program
The Project-Based Voucher Program provides rental assistance to households living in specific housing sites. Because the rental assistance is tied to a particular unit, a family cannot retain the assistance if they move (voluntarily or through eviction). The Housing Authority administers different waiting lists by bedroom size for each project-based housing site. These housing sites are either multifamily or senior housing developments.

Statewide Resources
There are a variety of statewide programs and resources available. The City receives regular notification regarding state and federal funding and grant opportunities. Additionally, the City pursues grants on a programmatic and project basis for active programs and projects in Gilroy.

Senate Bill 2 (SB 2) Grant. In 2020, the City was awarded $160,000 in SB 2 grant funding to create and adopt objective design standards for mixed-use and multifamily residential projects in Gilroy. The City also used the funding to create and adopt objective design standards for SB 9 projects. The project was eligible for funding under the SB 2 Policy Priority Area Objective Design and Development Standards. The goal of the project was to create objective design standards that would increase consistent decision making; minimize applicant delays; better utilize staff resources; and promote/require good design principles in Gilroy to help ensure that housing development projects conform to the City’s minimum design expectations.

Local Early Action Planning (LEAP) Grant. In 2020, the City was awarded $150,000 in LEAP grant funding. A portion (or potentially all) of the funding will be used to help supplement costs associated with preparation of the 2023-2031 Housing Element.

Regional Early Action Planning (REAP) Grant. In 2021, the City was awarded $32,603 in REAP grant funding to further supplement costs associated with preparation of the 2023-2031 Housing Element.

9.2 p. 622 of 1163
Sites and Resources ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 262
The No Place Like Home Program
The No Place Like Home Program provides loans to eligible counties to acquire, design, construct, rehabilitate, and/or preserve permanent supportive housing for persons who are experiencing homelessness or chronic homelessness, or who are at risk of chronic homelessness, and who need mental health services. Projects funded through this program must be apartment complexes of five or more units.

Administrative Resources
The City of Gilroy’s Community Development Department consists of the Housing and Community Development (HCD) Division, the Planning Division, and the Building and Safety Division which includes code enforcement. The Community Development Department helps implement several of the programs outlined in this Housing Element with the help of the City’s HCD Technician. The Community Development Director manages the City’s Housing and Community Development program and administers the CDBG funds, the City's PLHA Fund, and the former HTF. The Planning Division reviews land-use entitlement applications and is responsible for the implementation of the General Plan, Zoning Ordinance, and adopted specific plans. The Building and Safety Division processes and issues building permits, conducts plan reviews, conducts building inspections, and resolves land-use related violations through Code Enforcement.

9.2 p. 623 of 1163
263

CITY OF GILROY

HOUSING ELEMENT
6TH CYCLE

HOUSING GOALS, POLICIES, AND PROGRAMS

9.2 p. 624 of 1163
Goals, Policies, and Programs ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 264
Housing Goals, Policies, and Programs
The section of the Housing Element outlines the City of Gilroy’s goals, policies, and implementation programs for the preservation, conservation, improvement, and production of housing for the 2023 – 2031 planning period. The goals, policies, programs, and quantified objectives are designed to help ensure housing opportunities for all existing and future residents of the community.

Housing Production
Goal 1

HOUSING PRODUCTION
Provide adequate residential sites to accommodate projected housing needs and encourage the production of a variety of housing types Policy 1.1: The City shall encourage the provision of a variety of housing options for Gilroy residents.

Policy 1.2: The City shall strive to ensure adequate land is available at a range of densities to meet Gilroy’s existing and projected housing needs.

Policy 1.3: The City shall encourage the provision of new affordable housing.

Policy 1.4: The City shall encourage partnerships between non-profit and for-profit housing developers to encourage affordable housing production.

Policy 1.5: The City shall continue to implement the Downtown Specific Plan and encourage and coordinate activities with Downtown stakeholders.

Policy 1.6: The City shall support the development of workforce housing to enable the workforce to live in the community.

Removal of Governmental Constraints
Goal 2

REMOVAL OF GOVERNMENT CONSTRAINTS
Remove or reduce governmental constraints to the development, improvement, and maintenance of housing where feasible and legally permissible.

9.2 p. 625 of 1163
Goals, Policies, and Programs ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 265
Policy 2.1: The City Shall periodically review City regulations, ordinances, permitting processes, and residential fees to ensure that they do not unreasonably constrain housing development and are consistent with State law.

Policy 2.2: The City shall continue to provide individuals with disabilities reasonable accommodation through flexibility in the application of land use or zoning when necessary to eliminate barriers to housing opportunities.

Policy 2.3: The City shall consider the development of single-room occupancy units, studio apartments, micro-units, and other similar unit types that are affordable to extremely lowincome residents in higher-density areas of the City.

Housing Preservation and Rehabilitation
Goal 3

HOUSING PRESERVATION AND REHABILITATION
Maintain and conserve the existing housing stock in a sound, safe, and sanitary condition.

Policy 3.1: The City shall strive to preserve the affordability of existing below market rate housing units.

Policy 3.2: The City shall promote the maintenance and rehabilitation of structures in poor condition and take action to prevent poorly maintained properties from further deterioration.

Policy 3.3: The City shall encourage the retention and rehabilitation of older homes in and near the historic City Center and ensure that rehabilitation activities are sensitive to the historic character of the building and/or site.

Housing Assistance to Meet the Needs of All Income Levels Goal 4

HOUSING ASSISTANCE TO MEET THE NEEDS OF ALL INCOME LEVELS Encourage and support the provision of a variety of affordable housing types.

Policy 4.1: The City shall continue to participate in programs that assist lower- and moderateincome households to secure affordable housing, such as the County’s Mortgage Credit Certificate program, Housing Choice Voucher programs, and Silicon Valley’s assistance programs.

Policy 4.2: The City shall support homeownership opportunities for low- and moderateincome households.

Policy 4.3: The City shall provide incentives for affordable housing, including but not limited to the density bonus ordinance and expedited project review.

9.2 p. 626 of 1163
Goals, Policies, and Programs ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 266
Special Housing Needs
Goal 5

SPECIAL HOUSING NEEDS
The City shall increase access to decent and suitable housing for Gilroy residents with special housing needs.

Policy 5.1: The City shall encourage housing opportunities for special needs groups, including:
seniors; persons with disabilities, including developmental disabilities; the unhoused; large households; single female-headed households; and farmworkers.

Policy 5.2: The City shall encourage the development, rehabilitation, and preservation of affordable and market-rate housing for seniors, particularly in neighborhoods that are accessible to public transit, commercial services, and health and community facilities.

Policy 5.3: The City shall support efforts to provide emergency shelter, transitional housing, and permanent supportive housing for unhoused persons and those at risk of homelessness.

Policy 5.4: The City shall support the development of permanent and seasonal farmworker housing in appropriate areas of the City.

Policy 5.5: The City shall encourage affordable housing developments to include units that can accommodate large households of five or more.

Policy 5.6: The City shall encourage the development and maintenance of housing accessible topeople with disabilities, including developmental disabilities.

Affirmatively Furthering Fair Housing
Goal 6

FAIR HOUSING
Ensure equal housing opportunities for all Gilroy residents regardless of race, color, religion, sex, sexual orientation, marital status, national origin, ancestry, familial status, disability, or source of income.

Policy 6.1: The City shall promote fair housing standards and comply with State laws.

Policy 6.2: The City shall refer discrimination complaints to Project Sentinel or other organizations that address housing discrimination.

Policy 6.3: The City shall prioritize economic investment and opportunity in the Downtown Specific Plan area, especially the Racially/Ethnically Concentrated Areas of Poverty (R/ECAP) and the Equity and Engagement District (EED), which is the focus of the City’s Environmental Justice goals, policies, and programs.

9.2 p. 627 of 1163
Goals, Policies, and Programs ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 267
Education and Outreach
Goal 7

EDUCATION AND OUTREACH
Increase awareness of and participation in housing programs.

Policy 7.1: The City shall consolidate and disseminate housing related resources to provide better access to information on available housing programs and affordable housing units.

Policy 7.2: The City shall encourage the production of secondary units in single family districts through outreach and educational materials.

Policy 7.3: The City shall provide information on resources available to assist residents facing foreclosure.

Policy 7.4: The City shall encourage involvement of all Gilroy neighborhoods in the public decision-making process.

Quantified Objectives
Government Code Section 65583 (b) requires that quantified objectives be developed with regard to new construction, rehabilitation, conservation, and preservation activities that will occur during the eight-year Housing Element cycle. The quantified objectives set a target goal for Gilroy to achieve based on needs, resources, and constraints. State law recognizes that the total housing needs identified by a community may exceed available resources and the community’s ability to satisfy this need. Table 89 summarizes Gilroy’s quantified objectives for the 6th Cycle.

Table 89: Total Quantified Objectives, 2023 – 2031
Target
Extremely
Low
Income
Very
Low
Income
Low
Income
Moderate
Income
Above
Moderate
Income Total
New Construction 334 335 385 200 519 1,773
Conservation 30 30 30 30 - 120
Rehabilitation 80 - 80
Preservation 55 - - 55
Total 2,028

9.2 p. 628 of 1163
Goals, Policies, and Programs ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 268
Programs
The programs in this section of the Housing Element describe specific actions the City will carry out over the eight-year Housing Element cycle to satisfy the community’s housing needs and meet the requirements of State law. The programs are organized by the following seven major housing goals:
• Housing Production
• Removal of Governmental Constraints
• Housing Preservation and Improvement
• Housing Assistance
• Special Housing Needs
• Affirmatively Furthering Fair Housing
• Education and Outreach

9.2 p. 629 of 1163
Goals, Policies, and Programs ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 269
A. Housing Production
Number Title Action Responsible
Party
Funding
Source Timeline
A - 1 No Net Loss
Inventory and
Monitoring
To ensure that the City monitors its compliance with SB 166 (No Net Loss), the City will develop a procedure to and will track:
• Unit count and income/affordability assumed on
parcels included in the sites inventory.
• Actual units constructed and income/affordability
when parcels are developed.
• Net change in capacity and summary of remaining
capacity in meeting remaining RHNA.

To ensure the City has adequate sites to accommodate any net loss of Regional Housing Needs Allocation (RHNA)
capacity due to development of RHNA sites or accessory
dwelling units (ADUs) below projections, the City shall create a No Net Loss Inventory of replacement sites within 18
months of Housing Element certification. The backup
replacement sites in the No Net Loss Inventory will be
separate and distinct from the identified RHNA sites
inventory included in Appendix B. The No Net Loss
Inventory replacement sites are all appropriate for lowerincome development based on the criteria used for RHNA site selection. The City has begun development of this list and initial estimates include capacity for approximately 600 units, if needed.

Quantified Objective: No net loss of capacity below the RHNA requirement during the planning period.

CDD General
Fund
Adopt procedure
and create No
Net Loss
Inventory by end
of Q4 2024.

Review RHNA site
status twice
yearly and
update No Net
Loss Inventory as
necessary to
maintain
adequate RHNA
sites.

9.2 p. 630 of 1163
Goals, Policies, and Programs ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 270
Number Title Action Responsible
Party
Funding
Source Timeline
A - 2 Surplus
Lands/Affordable
Housing on CityOwned Sites
Implement the Surplus Lands Act and report any Cityowned surplus land in the Annual Progress Report. Provide affordable housing developers the first priority for
designated surplus lands as applicable per Government
Code Section 54227.

Assess City-owned properties for their potential
redevelopment or development for residential uses that
include housing for extremely low-income households and those with special needs such as seniors and persons with disabilities. Consider adding City owned parcels to the No Net Loss Inventory, as needed. Proactively advertise surplus land opportunities to affordable housing providers, the Santa Clara Office of Supportive Housing, and developers of special needs housing (e.g., extremely low income, disabled, farmworker housing).

Quantified Objective: The City will contact affordable
housing developers regarding any surplus lands, with the goal of developing at least 21 lower-income units during the planning period.

CDD General
Fund
Report surplus
lands in
conjunction with
the Annual
Progress Report.

Advertise surplus
land
opportunities to
affordable
housing
developers, as
they become
available. Review
all City owned
sites by the end
of Q4 2025 to
determine which
additional sites
could be declared
as surplus.

A - 3 By-Right
Approval of
Projects with 20
Percent
Affordable Units
on “Reused”
RHNA Sites
Pursuant to the statutory requirements of Government
Code Sections 65583.2(h) and (i), amend the Zoning
Ordinance to require by-right approval of any “reuse” 4th and 5th Cycle sites being used to meet the 6th Cycle RHNA, if 20 percent of the units in the development are affordable to lower-income households.

CDD General
Fund
By end of Q4
2023.

9.2 p. 631 of 1163
Goals, Policies, and Programs ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 271
Number Title Action Responsible
Party
Funding
Source Timeline
A - 4 Publicize
Residential Sites
Inventory
The City shall make the residential sites inventory available to developers by publicizing it on the City website and providing copies of the inventory to developers.

The City shall update the list of sites annually, or as projects are approved on the sites.

Quantified Objective: Maintain accurate and publicly
available residential sites inventory throughout the planning period.

CDD General
Fund
Post on website
by end of Q4
2023; update
annually.

A - 5 Revise
Neighborhood
District Policy
The City will revise the Neighborhood District Policy so it does not rely on the Residential Development Ordinance
(RDO). Revisions to the policy include:
• Studying and adopting an inclusionary housing
policy and in-lieu fee for Neighborhood District
areas.
• Updating the Neighborhood District target
densities, consistent with the Gilroy 2040 General
Plan.
• Adopting standards related to the distribution of
units across the levels of affordability (e.g., 30% of
the 15% affordable units shall be designated for
low income).
• Adopting standards related to the term of
affordability (e.g., rental units shall be restricted as affordable for a minimum of 55 years).

CDD General
Fund
By end of Q4
2024.

9.2 p. 632 of 1163
Goals, Policies, and Programs ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 272
Number Title Action Responsible
Party
Funding
Source Timeline
A - 6 ADU Tracking
and Monitoring
Continuously track the number of building permits issued for ADUs. The City will also review geographic distributions of ADUs biennially. If the average ADU production is less than 25 units in years 2023, 2024, and 2025, the City will update the ADU strategy by the end of 2026. In this case, the City will hold a focus group event with local stakeholders in spring or fall 2026. The purpose of the collaborative meeting will be to identify appropriate ADU programs to help increase production. If necessary, the City will identify additional RHNA sites in No Net Loss Inventory, as
discussed in Program A - 1.

Quantified Objective: Increase the number of new ADUs
permitted in the City from an average of approximately

15.75 (2018-2021) to an average of approximately 25.

CDD General
Fund
Track ADU
permits as they
are submitted.

Review ADU
strategies
annually as part
of the Annual
Progress Report
process. Hold a
focus group
event with local
stakeholders in
spring or fall
2026 if average
ADU production
is less than 25 in
years 2023, 2024,
and 2025.

Identify
additional
programs or sites
within six months
of shortfall.

9.2 p. 633 of 1163
Goals, Policies, and Programs ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 273
Number Title Action Responsible
Party
Funding
Source Timeline
A - 7 ADU PreDesigned PlansThe City will develop an ADU program that includes pre designed “model” plans for ADUs that meet zoning and
building, and fire codes. The program may be modeled after successful programs implemented in other cities.

To inform this effort, the City will work with the Santa Clara County Planning Collaborative and join the ADU Advisory Committee. The Collaborative and Advisory Committee are working on creating a subregional program of pre designed ADU plans and a variety of ADU tools and resources that can be available to all residents and cities in Santa Clara County to encourage ADU production.

Quantified Objective: Increase the number of new ADUs
permitted in the City from an average of approximately 17.5 (2018–2021) to an average of approximately 25.

CDD General
Fund
By end of Q4
2024.

A - 8 Financial
Incentives for
Affordable ADUs
Upon securing funding, the City will develop a financial assistance program for homeowners who build ADUs with
an affordability restriction or commitment to offering
housing choice vouchers.

If ADU production is lower than anticipated, the City will evaluate ADU impact fees as a potential constraint for
affordable housing and update them as necessary to ensure the fees are consistent with regional trends and do not unreasonably constrain ADU development. This effort will complement Program A-6 (ADU Tracking and Monitoring)
The City will review successful programs from other cities or the Housing Trust of Silicon Valley and contact Community Development Financial Institutions for potential
partnerships.

CDD In-lieu
fees,
other
applicable
affordable
housing
funding
After program
funding is
secured and
sufficient for the
intended
purpose.

Evaluate the
effect of impact
fees on ADU
development by
Q4 end of 2026 if
ADU production
is lower than
anticipated in
year 2025

9.2 p. 634 of 1163
Goals, Policies, and Programs ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 274
Number Title Action Responsible
Party
Funding
Source Timeline
A - 9 Monitor Permit
Requirements,
Processing
Procedures, and
Land Use
Controls
Implement the Land Management System for Tyler
Technologies with a "go-live" date in 2023 and hold an
outreach meeting to educate users on how to use the new permitting system. To assess the effectiveness of the new Land Management System, the City will survey users six
months after its launch.

The City will also create metrics that track the time to process permits. These metrics can be compared year-toyear to determine if the City’s processes and procedures are efficient or need refinement.

As a part of the City’s outreach and engagement with
developers, the City shall consult builders and other parties engaged in housing development activities to identify
potential constraints in the City’s permit requirements, processes, procedures, and land use controls and analyze potential streamlining where feasible. Outreach methods will include or be equivalent to the City’s annual developer roundtable meeting.

Quantified Objective: Increase the percentage of permits that are processed online. Decrease the time it takes to process permits.

CDD General
Fund
Survey six
months after “golive” date.

Annual outreach
to builders and
developers, such
as through the
City’s annual
developer’s
roundtable
meetings.

9.2 p. 635 of 1163
Goals, Policies, and Programs ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 275
Number Title Action Responsible
Party
Funding
Source Timeline
A - 10 Facilitate Missing
Middle / Middle
Income Housing
Amend the City Code to allow triplexes, and fourplexes to be approved ministerially on corner lots with a minimum 6,000 sf lot size in the R1 and R2 zones (approximately 1,106 lots) so long as the project complies with objective design standards.

This Program provides more flexibility than SB 9, by allowing triplexes or fourplexes, in lieu of a duplex with an ADU and a junior ADU. This program will also encourage the
development of missing middle housing throughout the
City, including high-resource areas primarily comprising detached single-family residences.

Update the City’s SB 9 policy and website to reflect the changes allowed under this program. Create an
informational and promotional pamphlet regarding
opportunities to develop triplexes and fourplexes on corner lots in R1 and R2 zones. Provide the pamphlet online, at City Hall, and at informational booths where housing resources are provided (see Program G - 5).

Quantified Objective: Increased production and reduced
permitting time and cost for triplexes and fourplexes.

Facilitate construction of 50 missing middle (duplex, triplex, quadplex) housing units over the 6
th Cycle planning period.

CDD General
Fund
By end of Q4
2024.

9.2 p. 636 of 1163
Goals, Policies, and Programs ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 276
Number Title Action Responsible
Party
Funding
Source Timeline
A - 11 Inclusionary
Housing Policy
Conduct an inclusionary housing feasibility study to identify appropriate inclusionary requirements that will not
constrain housing production. Review the City’s existing Neighborhood District Policy and former RDO Exemption
Policy as a benchmark for developing the inclusionary
requirements (e.g., resale controls, minimum term [years of affordability], minimum percentage of units that must be restricted as affordable, minimum percentage within each affordability category).

Develop an affordable housing policy to establish
inclusionary housing requirements so that specified new developments reserve a percentage of the total units for lower- and moderate-income households or pay an in-lieu of housing fee for projects below the threshold for
inclusionary housing, such as smaller projects that cannot feasibly construct affordable housing. The inclusionary housing ordinance will include a requirement that the
developer market the below market-rate units and
accessible/adaptable units.

Quantified Objective: Increased production of affordable housing within the City, including housing choice and
mobility for lower-income households. Prioritize use of inlieu fees to develop affordable housing options in higher resource areas of the City.

CDD General
Fund
By end of Q4
2024.

9.2 p. 637 of 1163
Goals, Policies, and Programs ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 277
Number Title Action Responsible
Party
Funding
Source Timeline
A - 12 Incentives
Beyond Density
Bonus State Law
Study and consider adopting an affordable housing
incentives policy above and beyond the minimum
requirements of density bonus state law. Specifically
consider additional incentives for households with special housing needs such as large households, extremely lowincome households, farmworkers, and households with members with intellectual or developmental disabilities. In lieu of adopting a separate incentives / density bonus policy, the City could structure the Inclusionary Policy (A - 11) like a density bonus program with incentives that are tiered by level of affordability provided.

Quantified Objective: Increased housing choice and
mobility for special needs households.

CDD General
Fund
By end of Q4
2025.

A - 13 Coordination
with California
High Speed Rail
Authority
Continue to coordinate with the California High Speed Rail Authority so that the Station Area Plan includes the
development of a mix of affordable and market-rate
housing and commuter parking on the parcels associated
with the High Speed Rail Station.

Quantified Objective: Develop a specific commitment to
housing development; set objective targets for the
development of affordable and market-rate housing on the High Speed Rail site.

CDD,
California
High Speed
Rail
Authority
General
Fund
Immediately and
throughout the
planning period
until the Station
Area Plan is
complete.

9.2 p. 638 of 1163
Goals, Policies, and Programs ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 278
Number Title Action Responsible
Party
Funding
Source Timeline
A - 14 Coordination
with Santa Clara
County Office of
Supportive
Housing
The City will continue its partnership with Santa Clara County Office of Supportive Housing regarding
development of affordable housing at the property at 8th and Alexander. This includes the offer of impact fee waivers through a memorandum of understanding approved by the
Gilroy City Council and the County Board of Supervisors in September 2022. Next steps include community
engagement and working on the City’s priorities for the site (e.g., targeted income / special needs groups).

Quantified Objective: Development of affordable housing on the 8th and Alexander property by the end of 2028.

CDD, Santa
Clara County
Office of
Supportive
Housing
General
Fund
Continual
partnership
throughout the
planning period.

Anticipated
project
completion by
end of Q4 2028.

A - 15 ADU Ordinance
Updates
The City worked in collaboration with the California
Department of Housing and Community Development
(HCD) on its current ADU ordinance. The City will continue to work with HCD to make necessary changes and ensure
compliance with state law. prior to the end of 2023.

To incentivize ADU production, the City will increase the allowable floor area from 1,000 square feet to 1,200 square feet. The City will also replace the ADU deed restriction requirement with an owner affidavit form that does not
require recordation at the County. This change will
accelerate and streamline the process for approving ADUs in the City. The City will use the affidavits to track the number of ADUs to ensure they are being built at the
assumptions in the Housing Sites and Resources section.

Quantified Objective: Increase the number of new ADUs
permitted in the City from an average of approximately 17.5 (2018–2021) to an average of approximately 25 over the 6 th
Cycle planning period.

CDD General
Fund
By end of Q4
2023.

9.2 p. 639 of 1163
Goals, Policies, and Programs ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 279
Number Title Action Responsible
Party
Funding
Source Timeline
A - 16 Senate Bill (SB) 9
Processing
In conjunction with Program A-10 (Facilitate Missing Middle / Middle Income Housing), the City will update its SB 9
webpage to highlight the streamlined process for approving SB 9 applications. The City will also create and post step-bystep, user friendly instructions for processing SB 9 units and lot splits in Gilroy.

The Planning Department will hold informational meetings with the building division and engineering/land
development division to review the streamlined process to ensure the City complies with state law.

Quantified Objective: Process ten (10) SB 9 applications in the 6
th Cycle planning period.

CDD General
Fund
By end of Q4
2024.

9.2 p. 640 of 1163
Goals, Policies, and Programs ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 280
B. Removal of Government Constraints
Number Title Action Responsible
Party
Funding
Source Timeline
B - 1 Residential
Development
Ordinance
(RDO)
Removal
Repeal the RDO.

The growth control measures of the City's RDO have been made null and void by SB 330 (2019). The RDO will be repealed as a part of the City's comprehensive zoning update. Portions of the policy related to affordability requirements may be used as a benchmark for the City’s proposed Inclusionary Policy.

CDD General
Fund
Concurrent
with the
comprehensive
Zoning
Ordinance
update, end of
Q4 2023.

B - 2 Zoning and
General Plan
Densities
Amend the Zoning Ordinance to ensure that the Gilroy 2040 General Plan maximum densities are achievable in the
implementing zones (Housing Accountability Act/AB 3194).

Changes include:
• Increasing the maximum density in the R3 (medium
density) zone from 16 to 20 dwelling units per acre;
• Removing the maximum density in the R4 (high density) zone;
• Creating a zoning district for the mixed-use First Street corridor with a density range of 20–30 dwelling units per net acre; and
• Creating Neighborhood District High and Neighborhood
District Low zoning designations with density allowances that are consistent with the 2040 General Plan.

CDD General
Fund
Concurrent
with the
comprehensive
Zoning
Ordinance
update, end of
Q4 2023.

B - 3 Senate Bill
(SB) 35
Permit
Processing
and SB 330
Compliance
Establish and implement expedited permit processing for qualifying affordable housing projects, pursuant to SB 35 and SB 330. Create checklists and instructions for reviewing and approving SB 35 and SB330 projects.

Add information regarding the expedited permit process on the City’s website.

CDD General
Fund
By end of Q4
2024.

9.2 p. 641 of 1163
Goals, Policies, and Programs ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 281
Number Title Action Responsible
Party
Funding
Source Timeline
B - 4 Public Fees,
Standards,
and Plans
Online
Pursuant to Assembly Bill (AB) 1483, the City will compile all development standards, plans, fees, and nexus studies in an easily accessible online location (also see Program B-8). The City will continue to provide a high-quality, parcel-specific zoning map and General Plan map online.

CDD General
Fund
By end of Q4
2023.

B - 5 Permit
Streamlining
As a part of the 2023 comprehensive Zoning Ordinance update, the City is pursuing changes to streamline the permitting process, including but not limited to:
• Creating a ministerial use permit process; and
• Creating a more transparent and streamlined process for reviewing and approving applications involving a historic resource (e.g., residential addition).
• Streamlining the Planned Development approval process, so that projects that do not require a zoning amendment or General Plan amendment can be approved by the
Planning Commission rather than requiring review and
approval by both the Planning Commission and City
Council.

Additionally, the City will ensure it adheres to newly passed legislation surrounding permit streamlining, such as AB 2234.

Quantified Objective: Decreased permit processing time.

CDD General
Fund
Concurrent
with the
comprehensive
Zoning
Ordinance
update, end of
Q4 2023.

B - 6 Objective
Standards
Review and revise development standards, design guidelines, and findings to ensure they are objective and facilitate development of properties at their maximum densities.

CDD General
Fund
By end of Q4
2026.

9.2 p. 642 of 1163
Goals, Policies, and Programs ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 282
Number Title Action Responsible
Party
Funding
Source Timeline
B - 7 Zoning
Ordinance
Update
As a part of the 2023 comprehensive Zoning Ordinance update to ensure compliance with the 2040 General Plan and streamline various application processes (Program B – 5), the City will evaluate development standards for all zones including the Downtown Specific Plan zones, for potential governmental constraints. The City will also revise the definition of “townhouse” to be consistent with state law. The City will also amend the Zoning Ordinance to require that any demolished residential units on the Sites Inventory be replaced pursuant to Government Code Section 65583.2(g).

CDD General
Fund
By end of Q4
2023.

9.2 p. 643 of 1163
Goals, Policies, and Programs ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 283
Number Title Action Responsible
Party
Funding
Source Timeline
B - 8 Entitlement
Roadmap
Webpage
To provide clear and simple information about the City’s permitting process, the City will create an Entitlement Roadmap webpage that clearly spells out the City’s permitting process for residential development. Specifically, the webpage will include application forms, a flow chart outlining the development process, FAQs, and live links to other necessary pages and resources.

The webpage will advertise the City’s ministerial process for most single-family homes and administrative approval process for many other types of residential development that meet objective development standards.

Also see Program B-4.

CDD General
Fund
By end of Q4
2024.

B - 9 Building
Department
Webpage
To reduce applicant time and cost and increase certainty, the City will update the Building Department webpage to include
information required pursuant to AB 2234, including but not limited to specific information required for an application to be considered complete; example of a complete, approved application; and example of a complete set of post-entitlement phase permits for accessory dwelling units, duplexes, multifamily projects, mixed-use projects, and townhomes.

Quantified Objective: Updated website by end of Q4 2023.

CDD General
Fund
By end of Q4,
2023.

9.2 p. 644 of 1163
Goals, Policies, and Programs ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 284
Number Title Action Responsible
Party
Funding
Source Timeline
B - 10 Zoning Code
Annual
Updates
California’s legislature continues to pass new laws each year to encourage housing production and address the state’s severe housing shortage. Under this program, the Community
Development Department will establish a process to update City policies, codes and ordinances to comply with new State laws affecting housing and land use.

Quantified Objective: Following passage of new state legislation, Community Development Department staff will develop a list of laws that require updates to the City’s policies, codes and ordinances.

CDD General
Fund
The City will
update City
policies, codes
and
ordinances
annually, or as
needed to
comply with
new state laws.

B - 11 General Plan
Consistency
For the City’s General Plan to serve its purpose effectively, it must be reviewed, maintained, modified as necessary, and implemented in a systematic and consistent manner. Gilroy implements the General Plan through the City’s ordinances and regulations, policy decisions, and actions and is responsible for tracking, reporting and evaluating its progress in implementing the General Plan.

General Plan consistency will be reviewed as part of the Annual Progress Report, pursuant to Government Code Section 65400. As amendments are made to the General Plan, the City will also review the Housing Element for ongoing consistency.

CDD General
Fund
Consistency
between the
General Plan
and Housing
Element will be
reviewed as
part of the
annual
progress
report prior to
April 1st of each
year.

9.2 p. 645 of 1163
Goals, Policies, and Programs ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 285
C. Housing Preservation and Rehabilitation
Number Title Action Responsible
Party
Funding
Source Timeline
C - 1 Monitoring of
Units At Risk of
Converting to
Market Rate
Continue to provide regular monitoring of deed-restricted units that have the potential of converting to market rate.

The City currently contracts with HouseKeys to serve as the Below Market Rate (BMR) Program Administrator of the
City’s below market-rate homeownership and rental
property program. The BMR Program Administrator will
continue to monitor and evaluate the City's current multifamily affordable housing stock to determine if any developments are at risk of conversion.

Together with the BMR Program Administrator, the City will implement strategies to preserve projects identified as being at risk of converting to market-rate housing.

Strategies include:
• Monitoring affordable housing term expiration
status annually.
• Notifying property owners annually about
compliance with the extended noticing
requirement (three year, one-year, and six-month
Notice of Intent) under state law.
• Including preservation as an eligible use in Notices
of Funding Availability.
• If below market-rate units appear to be at risk of
conversion, work with qualified operators, the
California Department of Housing and Community
Development (HCD), and the property owners to
preserve the housing for lower-income
households.
• Biennial contact with property owners of
affordable units.

CDD and
Program
Administrator
(e.g.,
HouseKeys)
General
Fund
Annually review
affordable
housing term
expirations.

Noticing as
needed with
expiration of
covenants.

9.2 p. 646 of 1163
Goals, Policies, and Programs ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 286
Number Title Action Responsible
Party
Funding
Source Timeline
• Identification of funding opportunities to purchase
and preserve affordable units.
• Noticing of tenants and technical assistance with
applications for funds.

Quantified Objective: Preservation of below market-rate units.

C - 2 Housing
Rehabilitation
To enhance the quality of existing neighborhoods, the
City shall continue to utilize Community Development
Block Grant (CDBG) funds, as available, to assist in the improvement of substandard housing. For example, the
City has provided CDBG grants to the Rebuilding Together Silicon Valley Home Repair, Rehabilitation and
Accessibility Modification program, which provides a wide range of home repair, accessibility, mobility and limited rehabilitation improvements for low-income homeowners
in Gilroy.

The City will facilitate Tax Equity and Fiscal Responsibility Act (TEFRA) hearings throughout the planning period to
allow for the development and rehabilitation of
affordable housing units throughout the City.

Quantified Objective: Provide assistance to 100
households. Target 25% in the Racially and Ethnically
Concentrated Area of Poverty (R/ECAP) and DTSP area.

CDD General
Fund
Annually
evaluate
progress and
review contract.

Following each
contract
renewal, hold
informational
meetings to alert
the community
about the
availability of
programs such
as Rebuilding
Together
rehabilitation
loans.

9.2 p. 647 of 1163
Goals, Policies, and Programs ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 287
Number Title Action Responsible
Party
Funding
Source Timeline
C - 3 Code
Enforcement
Program
Within current staffing limits and AFFH standards, the City shall contact owners of units identified as substandard, offering inspection services and providing information on the Rebuilding Together Program (or similar) and
landlord/tenant information and mediation services.

Quantified Objective: Provide information regarding the Rebuilding Together (or similar) and landlord/tenant
information and mediation services to 240 households.

CDD General
Fund
Ongoing
throughout the
planning period.

C - 4 Resale Control
on OwnerOccupied
Below MarketRate Units
The BMR Program Administrator shall continue to
implement resale controls on owner-occupied BMR units
to ensure that affordable units provided through public assistance or public action are retained per the terms
specified in the affordable housing agreement (e.g., 30 years) as affordable housing stock.

Quantified Objective: Maintain all affordable units
throughout the planning period or as specified in the
affordable housing agreement.

CDD and BMR
Program
Administrator
(e.g.,
HouseKeys)
General
Fund
Annual
assessment of
units at risk of
conversion.

C - 5 Resale Control
on Rental
Below MarketRate Units
The BMR Program Administrator shall continue to
implement resale controls on renter-occupied BMR units
to ensure that affordable units provided through public assistance or public action are retained per the terms
specified in the affordable housing agreement (e.g., 30 years) as affordable housing stock.

Quantified Objective: Maintain all affordable units
throughout the planning period or as specified in the
affordable housing agreement.

CDD and BMR
Program
Administrator
(e.g.,
HouseKeys)
General
Fund
Annual
assessment of
units at risk of
conversion.

9.2 p. 648 of 1163
Goals, Policies, and Programs ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 288
Number Title Action Responsible
Party
Funding
Source Timeline
C - 6 Identification
and
Preservation of
At-Risk Units
The City will complete its ongoing effort to create an
inventory of BMR units.

In the event that the City identifies units with restrictive covenants that expire during the 6
th Cycle, the City will
ensure that owners of the properties are contacted,
encouraged to extend or renew the rent or sales price
restrictions. The City will also ensure appropriate advanced notice of conversion to tenants is provided.

CDD General
Fund
By end of Q4
2024.

9.2 p. 649 of 1163
Goals, Policies, and Programs ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 289
D. Housing Assistance
Number Title Action Responsible
Party
Funding
Source Timeline
D - 1 Permanent
Local Housing
Allocation Fund
The City shall continue to utilize the Permanent Local
Housing Allocation (PLHA) Fund for all eligible activities, including new construction, acquisition, rehabilitation, home buyer assistance, homeless assistance, public
services related to housing, and preservation of affordable housing.

The City contracts with Santa Clara County Office of
Supportive Housing to administer the PLHA Fund, which
provided $237,000 in funding each year during the FY 22-23 and FY 23-24 funding periods for homelessness prevention services, fair housing, and basic needs (e.g., meals on wheels).

The City shall continue to inform nonprofit organizations of funding availability through the City’s website and
informational packets at City Hall.

Quantified Objectives: Through various eligible funding programs, assist 80 households annually.

CDD Permanent
Local
Housing
Allocation
Fund
The PLHA funds
span a 5-year
basis. Conduct
outreach and
allocate funding
every two years.

9.2 p. 650 of 1163
Goals, Policies, and Programs ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 290
Number Title Action Responsible
Party
Funding
Source Timeline
D - 2 Funding Sources
to Assist
Homeownership
The City shall pursue potential sources of additional
funding for homeownership assistance and inform the
public of existing resources, including the availability of State HCD, CalHFA funds, HOME, Metropolitan
Transportation Commission (MTC), the Association of Bay Area Governments (ABAG), and Santa Clara County funds.

The City shall improve public outreach activities through conducting workshops and outreach events and the
compilation of resources for down payment assistance and other means of acquiring a home.

Quantified Objectives: The City will conduct public
outreach to inform the community of existing resources, assistance programs, and funding opportunities, and
annually pursue funding for down payment assistance and increase awareness as new funding is available.

CDD General
Fund
Conduct public
outreach on
existing housing
resources and
pursue funding
and conduct
research
annually.

D – 3 Housing Choice
Voucher
Referrals
The City shall provide information to City residents on the Santa Clara County Housing Authority Housing Choice
Voucher (HCV) program. This information shall also be
available on the City website.

The City shall notify interested residents and provide
technical assistance to residents who need help applying to the Housing Choice Voucher program.

The City shall refer residents that experience discrimination based on source of income (including vouchers) to Project Sentinel.

Quantified Objective: Assist or refer 40 individuals
annually.

CDD General
Fund
Immediately
upon opening
of HCV waitlist.

Technical
assistance to
residents as
needed. Annual
education and
outreach to
landlords.

9.2 p. 651 of 1163
Goals, Policies, and Programs ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 291
Number Title Action Responsible
Party
Funding
Source Timeline
D - 4 Pursue Funding
for Affordable
Housing
The City shall pursue funding from state, federal, and
regional sources and support applications for funding to help increase the supply of affordable housing. Funding programs may include but are not limited to:
• One Bay Area Grants awarded by ABAG;
• HCD Local Housing Trust Fund Program;
• US Department of Housing and Urban
Development (HUD) Section 811 funding for
supportive housing for extremely low-income
residents;
• The state Infill Infrastructure Grant program,
sponsored by HCD; and
• The State Multifamily Housing Program, sponsored
by HCD.

Additionally, the City will consider the use of PLHA funds for eligible activities, including the predevelopment,
development, acquisition, rehabilitation, and preservation of affordable housing.

The City will meet with affordable housing developers to identify development opportunities, provide support for funding applications, consider incentives and concessions beyond SDBL, and provide priority processing.

CDD General
Fund
Pursue funding
sources
annually.

9.2 p. 652 of 1163
Goals, Policies, and Programs ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 292
Number Title Action Responsible
Party
Funding
Source Timeline
D - 5 Community
Development
Block Grant
Program
The City shall continue to utilize the CDBG Program for all eligible activities, including acquisition, rehabilitation, home buyer assistance, economic development, homelessness
assistance, public services, and public improvements. The City shall continue to inform nonprofit organizations of funding availability through the City’s website and email distribution lists. The City will advertise funded programs that provide public assistance on its website and through informational brochures at City Hall.

The City expects to receive an estimated $400,000 in CDBG funds from HUD each year. The primary objectives of the CDBG Program include activities that benefit low-income households, aid in the prevention of slums or blight, or meet an urgent community need.

CDD General
Fund
Administer
funds annually.

9.2 p. 653 of 1163
Goals, Policies, and Programs ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 293
E. Special Housing Needs
Number Title Action Responsible
Party
Funding
Source Timeline
E - 1 Priority Water
and Sewer
Service for
Affordable
Housing
Developments
Pursuant to Government Code 65589.7, the City will review and update, as necessary, the Water and Sewer Service
Priority Policy, and work with public service providers to ensure prioritization of services to housing developments serving lower-income households. This policy is currently in place.

The Housing Element will be provided to water and sewer service providers upon adoption.

CDD General
Fund
By end of Q4
2026.

E - 2 Zoning to
Encourage
and Facilitate
Single-Room
Occupancy
Units
As a part of the comprehensive Zoning Ordinance update, the City shall revise the Zoning Ordinance to establish explicit definitions for and regulatory standards addressing singleroom occupancy units.

CDD General
Fund
Concurrent with
the
comprehensive
Zoning
Ordinance
update, end of
Q4 2023.

E - 3 Emergency
Shelter
Standards
Amend the Zoning Ordinance to modify the requirements for emergency shelters in compliance with Assembly Bill (AB) 2339, AB 139, and Government Code Section 65583(a)(4).

The City will modify its Zoning Ordinance to ensure that emergency shelters are allowed by right in the City’s R4 zone and First Street mixed-use corridor. Pursuant to AB 2339, emergency shelters and other interim interventions, including but not limited to a navigation center, bridge housing, and respite or recuperative care, will not require a conditional use permit or any other discretionary permit in zones designated for emergency shelters. The Zoning Ordinance will be revised to set parking requirements based on staff levels only and remove subjective development and operational standards.

CDD General
Fund
At the time of
Housing
Element
adoption.

9.2 p. 654 of 1163
Goals, Policies, and Programs ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 294
Number Title Action Responsible
Party
Funding
Source Timeline
E - 4 Low Barrier
Navigation
Centers
Pursuant to Senate Bill (SB) 48 and AB 2339, amend the
Zoning Ordinance to allow low-barrier navigation centers, meeting specific objective requirements, by-right in areas zoned for nonresidential uses, including mixed-use zones and multifamily zones.

CDD General
Fund
By end of Q4
2023.

E - 5 Incentivize
Micro-Units
Ensure that provisions for efficiency units are consistent with AB 352 (2017), concurrent with the comprehensive Zoning Ordinance update by the end of Q4 2023.

Revise the Zoning Ordinance to establish development
standards for micro-units, create incentives for micro-unit production, and remove barriers to micro-unit development, by the end of 2025.

CDD General
Fund
By end of Q4
2023 and 2025.

E - 6 Reduced
Parking
Requirements
for Senior
Housing
The City shall conduct a study to determine if reduced parking standards for senior housing are appropriate in Gilroy. Based on the findings of the study, the City may revise the Zoning Ordinance, as necessary, to reduce parking standards for senior housing.

The passing of AB 2097 will reduce constraints to senior housing development as it prohibits any minimum parking requirement on any residential, commercial, or other
development project located within 0.5 miles of public transit.

CDD General
Fund
By end of Q4
2026.

9.2 p. 655 of 1163
Goals, Policies, and Programs ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 295
Number Title Action Responsible
Party
Funding
Source Timeline
E - 7 Development
and
Conservation
of Housing for
Farmworkers
In 2022, the City partnered with the Santa Clara County Office of Supportive Housing, to facilitate lower-income housing on a County owned property by waiving development impact
fees for the project.

The City shall continue to partner with the Santa Clara County Office of Supportive Housing and various nonprofit
organizations to explore and implement ways of providing affordable farmworker housing, including identification of state and federal funding opportunities.

At least once a year, the City will forward information about surplus City-owned land and other development
opportunities to the Santa Clara County Office of Supportive Housing, affordable housing developers, and service
providers who may be interested in developing more
farmworker housing in Gilroy. The City will also provide this information at the annual developer roundtable and to
individuals on the housing developer list, created through Program G - 1
Quantified Objective: Preserve and maintain the 3
farmworker housing developments (56 units) located in
Gilroy.

CDD General
Fund
Ongoing
throughout the
planning
period.

E - 8 Consistency
with the
Employee
Housing Act
As a part of the 2023 comprehensive Zoning Ordinance
update, the City shall update the Zoning Ordinance to be consistent with the Employee Housing Act (Health and Safety Code Section 17021). This act generally requires by-right approval of employee housing for agricultural employees (i.e., farmworker housing) as follows: Less than six persons, byright in all zones allowing single-family residential uses; No more than 12 units or 36 beds, by-right in all zones allowing agricultural uses.

CDD General
Fund
Concurrent with
the
comprehensive
Zoning
Ordinance
update, end of
Q4 2023.

9.2 p. 656 of 1163
Goals, Policies, and Programs ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 296
Number Title Action Responsible
Party
Funding
Source Timeline
E - 9 Priority for
Gilroy
The City will develop a system to prioritize occupancy of affordable for-sale and for-rent units in Gilroy for incomeeligible Gilroy residents and/or individuals working in the City of Gilroy, who originate in the City of Gilroy. The City will determine how to weigh specific factors and develop a
process for priority tenure, while affirmatively furthering fair housing.

CDD General
Fund
By end of Q4
2024.

E - 10 Development
and
Rehabilitation
of Housing for
Persons with
Disabilities
As part of the 2023 comprehensive Zoning Code update, the City will evaluate reasonable accommodation standards and procedures and the permit requirements for residential care homes (i.e., group homes) in medium- and higher-density residential zones. The City will revise, as necessary,
regulations that act as potential constraints to
accommodating persons with disabilities.

CDD General
Fund
By end of Q4
2023.

9.2 p. 657 of 1163
Goals, Policies, and Programs ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 297
Number Title Action Responsible
Party
Funding
Source Timeline
E - 11 Housing for
Extremely
Low Income
and Special
Needs
Households
The City will facilitate and support affordable housing by meeting with potential affordable housing developers and homeless service providers to identify development
opportunities, provide site information, assist in the
entitlement processes, and consider on a case-by-case basis other incentives, including but not limited to fee deferrals and modification of standards.

As included in Program G - 1, the City will conduct proactive outreach to specifically include developers of housing for special needs and low-income households in the annual
developer roundtable.

Additionally, the City will pursue funding sources, such as use of PLHA funds, to assist special needs households, such as extremely low-income households, farmworkers, large
families, seniors, and persons with disabilities, including developmental disabilities. The City will consider using PLHA funding for eligible activities, including the predevelopment, development, acquisition, rehabilitation and preservation of affordable housing.

Quantified Objective: Outreach to affordable housing
developers at least bi-annually (4 times over the planning period) when PLHA funds become available.

CDD General
Fund,
PLHA
funding
As applications
are received.

Annual
developer
roundtable.

Pursue funding
sources as they
are made
available.

9.2 p. 658 of 1163
Goals, Policies, and Programs ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 298
Number Title Action Responsible
Party
Funding
Source Timeline
E - 12 Downtown
Expansion
District and
First Street
Mixed-Use
Corridor
Flexibility
The City will develop a process to allow 100% residential projects in the Downtown Expansion District. The City will also create a process that allows flexibility in the type of nonresidential uses allowed in the new First Street Mixed-Use Corridor such as supporting amenities, facilities or services, subject to certain criteria. In exchange for this flexibility, the City may require that a certain percentage of units are dedicated to extremely low-income households, farmworkers, persons with disabilities, or other identified groups. The intent of this program is to facilitate and encourage housing for extremely low income and special needs households.

Quantified Objective: Adopted zoning amendments.

Facilitation of 100 units using the adopted process in the planning period.

CDD General
Fund
Amendments
by end of Q4
2025
E - 13 Permanent
Supportive
Housing
As part of the 2023 Comprehensive Zoning Code update, the City will amend the code to allow supportive housing uses byright in zones where multi-family and mixed-uses are permitted, consistent with Government Code Section 65651 CDD General
Fund
By end of Q4
2023.

9.2 p. 659 of 1163
Goals, Policies, and Programs ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 299
F. Affirmatively Furthering Fair Housing
Number Title Action Responsible
Party
Funding
Source Timeline
F - 1 Source of Income
Protection
Coordinate with Project Sentinel to conduct a
meeting/workshop to inform residents of sources of
income protection and state rent control laws such as
AB 1482.

Continue to coordinate outreach efforts to inform
landlords and tenants of recent changes to state law
that prevent source of income discrimination,
including allowance of housing choice vouchers
(HCVs) to establish a renter’s financial eligibility.

Quantified Objective: Outreach to 50 landlords or
tenants annually.

CDD General
Fund
Informational
outreach by end of Q4
2024. Annual
education and
outreach to landlords
and tenants.

F - 2 Fair Housing
Counseling
The City shall continue to provide funds to and
contract with a non-profit agency to provide fair
housing assistance including landlord/tenant
counseling. The City shall disseminate information
about fair housing assistance through pamphlets in
City-owned buildings and other public locations (e.g.,
City Hall, Library, post office, other community
facilities) and by posting information on the City
website. Pamphlets will be made available in English
and Spanish.

Quantified Objective: Work with Fair Housing
Provider to track number of households assisted in
Gilroy annually. Provide information to 30 households
annually.

CDD General
Fund
Annual or biennial
award of funds.

Provision of
pamphlets by end of
Q4 2024.

9.2 p. 660 of 1163
Goals, Policies, and Programs ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 300
F - 3 Place-Based
Improvements in
Downtown Gilroy
Develop programs and strategies to create placebased improvements through investments in the public right of way. Specific actions include:
• As part of the $3.9 million Clean California
Grant, the City will renovate and beautify a
portion of Gourmet Alley and Railroad Street
within the downtown area with: pedestrian
and bicycle-friendly markings along each
block; improvements to the stormwater
drainage system; additional landscaping and
lighting; new benches; cleanup days for the
alleys; and an anti-littering campaign.
• As a part of downtown revitalization, the City
will construct a new downtown parking lot
that will also serve as a community resource
for a Farmers Market and community events
in the downtown.
• As a part of the CIP, to support economic
development in the downtown, complete
Automall Parkway Pavement Rehabilitation
including reconstruction of 20 curb ramps,
addition of Class II bike lanes, and repair and
replacement of deteriorated curb and gutter
(estimated $2.4 million)
• As a part of the CIP, to support pedestrian
infrastructure in the DTSP area, install and
upgrade ADA curb ramps in Downtown
Gilroy. In March 2023 the City Council
awarded a contract to conduct ADA curb
ramp improvements at nine locations in and
around Downtown Gilroy.
• The Downtown Façade Improvement and
Blight Removal Program, which includes
CDD, Public
Works
General
Fund
Streetscape and
infrastructure
improvements will be
completed pursuant to
the City’s CIP schedule.

The Clean California
Grant project must be
completed by June 30,
2024.

Construction of the
parking lot with
community event
space will be complete
by the end of May
2023.

9.2 p. 661 of 1163
Goals, Policies, and Programs ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 301
Number Title Action Responsible
Party
Funding
Source Timeline
providing a 50%/50% matching grant of up to
$5,000 to property owners and tenants
within a portion of Downtown to assist with
exterior improvements to the façade, or
face, of the building. These improvements
may include new paint, building surface
treatment, awnings, windows, doors, and
other improvements that can help improve
the exterior of a building. The maximum
grant award amount may be increased to
$10,000 if the project includes blight removal
activities, approved by the City.
• The Downtown Building and Planning Permit
Fee Reduction Policy. This includes a 50%
rebate of up to $5,000 for all City-related
building and planning fees. This is available
to any downtown business or property
owner that pulls a permit for buildings along
Monterey Road between First and Tenth
Streets

9.2 p. 662 of 1163
Goals, Policies, and Programs ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 302
Number Title Action Responsible
Party
Funding
Source Timeline
F - 4 Housing Mobility
and Choice in
Higher
Opportunity Areas
Improve housing mobility and choice, especially in
higher opportunity areas of the City through the follow actions:
• Allow triplexes and quadplexes that meet
objective design standards to be approved
ministerially on corner lots in the R1 and R2 zones
(Program A-10).
• Adopt an inclusionary housing policy (Program A11)
• Adopt a incentives beyond density bonus state
law policy to include incentives for special needs
households (Program A-12)
CDD General
Fund
By end of Q4 2025.

F - 5 Displacement
Prevention Policy
Adopt a displacement prevention policy. Organize a
focus group of organizations with experience in
displacement prevention policies (e.g., SV@Home)
and complete an analysis of best practices in
jurisdictions that are similar to Gilroy. Measures that are being considered for inclusion in the policy are
“tenant option to purchase agreements” for
redevelopment projects meeting specified thresholds,
a just cause eviction ordinance, and relocation
agreements.

Through Program B-7, the City will amend the Zoning
Ordinance to require that any demolished residential
units on the Sites Inventory be replaced pursuant to
Government Code Section 65583.2(g).

CDD General
Fund
Hold focus group and
complete analysis by
end of Q4 2025. Adopt
policy by end of Q4
2026.

9.2 p. 663 of 1163
Goals, Policies, and Programs ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 303
G. Education and Outreach
Number Title Action Responsible
Party
Funding
Source Timeline
G - 1 Collaboration
with
Development
Community
The City shall continue to cultivate new and existing
relationships, throughout the planning period, with
for-profit and non-profit development companies
working in the area of affordable housing,
facilitating collaborative approaches to affordable
housing development.

Invite affordable housing developers and
developers of housing for special needs households
to the annual developer roundtable meeting.

The City will create a list of housing developers,
including developers of affordable and special
needs housing. The list will be used for the annual
developer roundtable (or equivalent), and to
advertise development opportunities, funding
opportunities, and other educational and
engagement efforts in the City.

Quantified Objective: Host an annual developer
roundtable (or equivalent) meeting. Participation of
at least four developers of affordable and special
needs housing in the annual meeting.

CDD General
Fund
Annual developer
roundtable meeting.

Creation of developer
interest list by end of Q4
2024.

9.2 p. 664 of 1163
Goals, Policies, and Programs ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 304
Number Title Action Responsible
Party
Funding
Source Timeline
G - 2 Community
Outreach and
Inclusion in
the Decision
Making
Process
To implement Goal EJ 1 from the City's 2040 General
Plan Environmental Justice Element, the City will
encourage involvement of all Gilroy neighborhoods
in the public decision-making process through the
use of various methods of delivery, such as print
media, mailers, web-based information, accessible
meetings, pop-up events, and other methods that
consider economic and cultural considerations
unique to the City of Gilroy.

Provide all pamphlets and communications in
English and Spanish
Geographic Targeting: R/ECAP and Downtown
Specific Plan area
CDD General
Fund
Ongoing throughout
General Plan
implementation.

9.2 p. 665 of 1163
Goals, Policies, and Programs ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 305
Number Title Action Responsible
Party
Funding
Source Timeline
G - 3 ADU
Education
Develop and implement a comprehensive
marketing program to advertise the benefits of
ADUs and the process for constructing ADUs.

The City will provide educational pamphlets on the
City website and at City Hall with detailed
information on the ADU process as well as basic
responsibilities and legal requirements of being a
landlord. The pamphlets will be provided in both
English and Spanish.

The City will consolidate its two ADU webpages into
a single page that has all relevant information for
ADUs.

The City will focus outreach and education in the
higher opportunity areas of the City to expand
housing mobility and choice. Upon biennial review
of geographic ADU distribution, the City will review
and adjust promotion and outreach strategies to
ensure ADUs are being marketed in high resource
areas that are seeing less ADU construction.

Quantified Objective: Increase the number of new
ADUs permitted in the City from an average of
approximately 17.5 (2018-2021) to an average of
approximately 25.

CDD General
Plan
Develop marketing plan by
end of Q2 2024; implement
marketing program by end
of Q4 2025. Biennial review
of ADU geographic
distribution. ADU webpage
consolidation by the end of
Q4 2024.

9.2 p. 666 of 1163
Goals, Policies, and Programs ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 306
Number Title Action Responsible
Party
Funding
Source Timeline
G - 4 Increased
Outreach in
Downtown
Areas
To implement Policies EJ 1.3 and EJ 1.5 from the
City's 2040 General Plan Environmental Justice
Element, the City will consult with local community
leaders in the Downtown Specific Plan Area to
ensure community priorities are being addressed.

The City will consider the viewpoints and concerns
of all neighborhoods within Gilroy when drafting the
High Speed Rail Station Area Plan and when
updating the Downtown Specific Plan.

Geographic Target: R/ECAP and Downtown Specific
Plan area
CDD General
Fund
Upon receiving funding and
availability of adequate
staffing resources to
complete these area plans.

9.2 p. 667 of 1163
Goals, Policies, and Programs ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 307
G - 5 Housing
Outreach and
Information
The City shall provide information about housing
assistance, fair housing, housing resources, and
housing programs through a wide variety of
outreach methods such as:
• Conducting workshops and webinars by
partnering with community-based organizations
to inform residents of housing resources,
assistance programs, and funding opportunities,
on a monthly basis on average.
• Disseminating information about fair housing in
City-owned buildings and other public locations
(e.g., City Hall, Library, post office, other
community facilities) and by posting information
on the City website. Pamphlets will be made
available in English and Spanish.
• Advertising housing assistance information on
the City website, through the compilation of
resources for rental assistance, down payment
assistance, and other means of retaining
existing housing or acquiring a new home.
• Coordinating with the City’s Fair Housing Service
Provider to provide resources and information
at a housing resources event in the DTSP area.

Geographic Targeting: Annual housing event in the
DTSP area.

Quantified Objective: Provision of housing
resources and information through at least three
different mediums. All information made available
in English and Spanish. Annual housing event in the
DTSP. Outreach with 150 households annually.

CDD General
Fund
Update the City website
with housing information
as new resources become
available.

Annual housing event in
the DTSP area.

Conduct community
outreach workshops on
housing resources on a
monthly basis on average.

9.2 p. 668 of 1163
Goals, Policies, and Programs ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 308
Number Title Action Responsible
Party
Funding
Source Timeline
G - 6 Unhoused
Population
Education and
Outreach
The City will develop a program to educate the
public on the unhoused population and
homelessness as well as advertise resources that
available for the unhoused population. Specifically,
the program will include:
• Creation of a dedicated webpage with
information on unhoused resources and efforts.
• Development of printed collateral for
distribution at City Hall and by code
enforcement officers in the field.
• Gathering information on resources that exist in
the City and County for the unhoused
population and promote the information at City
Hall and on the City’s website. This information
will also be provided through the various
outreach methods in Program G - 5.
• Revamping the unhoused service providers
network which consists of monthly meetings
with direct unhoused service providers in the
City. The network serves to increase
collaboration and partnership among service
providers and the City, to connect the unhoused
with services. The monthly meetings serve to
coordinate with service providers regarding the
needs of the unhoused community, inform and
coordinate with events, and collaborate on
outreach efforts.

Quantified Objective: Minimum of 3 medium of
outreach. Scheduled service provider meetings
throughout the planning period.

CDD General
Fund
By end of Q4 2025; monthly
(or as scheduled) meetings
of the unhoused service
providers network.

9.2 p. 669 of 1163
Goals, Policies, and Programs ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 309
Number Title Action Responsible
Party
Funding
Source Timeline
G - 7 Bilingual
Engagement
Given the City’s large Hispanic population, the City
will increase Spanish language engagement within
city services and through translation of outreach
materials and interpretation of housing
opportunities. Translation of outreach materials is
included in both programs G - 3 and G - 5.

In August 2022 the City expanded its collective
bargaining bilingual pay system to increase the
number of bilingual staff available to assist the
Spanish-speaking community. The City will advertise
its collective bargaining unit bilingual pay benefits to attract new staff that can converse with the City’s
Spanish speaking population.

CDD General
Fund
Immediately upon
adoption of the Housing
Element.

G - 8 Help Center
Webpage
In partnership with local nonprofit organizations,
the City will develop a Housing Help Center
webpage to provide a centralized resource for
tenants and landlords to receive information on
local laws, assistance to apply for rent relief, and
legal aid. This webpage will consolidate existing
information on the City’s website with additional
information provided by local service providers to
best serve the needs of the Gilroy community.

Quantified Objective: The City will advertise the
Housing Help Center to at least 100 residents each
year through the City’s community outreach efforts.

CDD General
Fund
By end of Q4 2024

9.2 p. 670 of 1163
APPENDIX A ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 310
APPENDIX A: SITES INVENTORY MAP

9.2 p. 671 of 1163
APPENDIX A ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 311

9.2 p. 672 of 1163
APPENDIX B ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 312
APPENDIX B: SITES INVENTORY LIST
Table 90: Opportunity Sites
APN Address43 Zip
Code
Size
(Acres)
Existing
Zone
Existing
General
Plan
Max.

Density
Existing
Units
Very
Low
Income
Capacity
Low
Income
Capacity
Moderate
Income
Capacity44
Above
Moderate
Income
Capacity
Total
Capacity
Existing Use Infrastructure Publicly
Owned
4th
Cycle
5th
Cycle
Type
783 20 050 880 Sunrise
Dr 95020 1.98 PF Low Density 15 0 21 0 0 0 21 74 Pub,Buildings,Public Yes Yes No No Opportunity
Site
790 14 025
8955
Monterey
Rd
95020 2.05 R4 High Density 30 0 49 0 0 0 49 58 Com,Retail Not In Shopping Center Yes No Yes Yes
Opportunity
Site
790 14 075
8915
Monterey
Rd
95020 0.74 R4 High Density 30 0 18 0 0 0 18 58 Com,Retail Not In Shopping Center Yes No Yes Yes
Opportunity
Site
790 14 091
8985
Monterey
Rd
95020 0.80 R4 High Density 30 0 19 0 0 0 19 62 Ins,Childcare,Preschl,Adult Daycare Yes No Yes Yes
Opportunity
Site
790 15 036
8877
Monterey
Rd
95020 1.21 R4
General
Services
Commercial
30 0 29 0 0 0 29 69 Vacant,Urban Yes No Yes Yes
Opportunity
Site
790 15 041
8897
Monterey
Rd
95020 0.95 R4
General
Services
Commercial
30 0 23 0 0 0 23 58 Com,Retail Not In Shopping
Center Yes No Yes Yes
Opportunity
Site
790 32 052 620
Broadway 95020 0.06 R3 Medium Density 20 0 0 0 1 0 1 69 Vacant,Urban Yes No No No Opportunity
Site
790 32 053 622
Broadway 95020 0.06 R3 Medium Density 20 0 0 0 1 0 1 69 Vacant,Urban Yes No No No Opportunity
Site
790 32 054 626
Broadway St 95020 0.06 R3 Medium Density 20 0 0 0 1 0 1 69 Vacant,Urban Yes No No No Opportunity
Site
790 32 055 624
Broadway St 95020 0.06 R3 Medium Density 20 0 0 0 1 0 1 69 Vacant,Urban Yes No No No Opportunity
Site
790 39 019 1375 First St 95020 0.97 C3 Mixed Use
Corridor High 30 0 20 0 0 0 20 69 Vacant,Urban Yes No Yes No Opportunity
Site
790 39 020 1395 First
Street 95020 0.97 C3 Mixed Use Corridor High 30 0 20 0 0 0 20 59 Pro,Offices,Banks And Clinics Yes No No No Opportunity
Site
790 39 029 1335 First St 95020 0.55 C3 Mixed Use
Corridor High 30 0 12 0 0 0 12 59 Pro,Offices,Banks And Clinics Yes No No No Opportunity
Site
790 39 030 1355 First St 95020 0.49 C3 Mixed Use
Corridor High 30 0 10 0 0 0 10 69 Vacant,Urban Yes No No No Opportunity
Site
43 The APN is the most accurate representation of the location of these sites. Addresses are the addresses connected to each APN from the Assessor’s portal. 44 The sites inventory does not include sites for the Above Moderate income category as the RHNA has already been exceeded by pending projects.

9.2 p. 673 of 1163
APPENDIX B ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 313
APN Address43 Zip
Code
Size
(Acres)
Existing
Zone
Existing
General
Plan
Max.

Density
Existing
Units
Very
Low
Income
Capacity
Low
Income
Capacity
Moderate
Income
Capacity44
Above
Moderate
Income
Capacity
Total
Capacity
Existing Use Infrastructure Publicly
Owned
4th
Cycle
5th
Cycle
Type
799 03 054
7733
Monterey
Rd
95020 0.10 DED
Downtown
Specific Plan
Area
30 0 0 0 3 0 3 69 Vacant,Urban Yes No No No
Opportunity
Site
799 03 055
7711
Monterey
Rd
95020 0.20 DED
Downtown
Specific Plan
Area
30 0 0 0 6 0 6 04 Res,5 Or More Family Units Yes No No No Opportunity
Site
799 04 008
7601
Monterey
Rd
95020 0.51 DHD
Downtown
Specific Plan
Area
30 0 15 0 0 0 15 69 Vacant,Urban Yes No No No
Opportunity
Site
799 04 016 7660
Eigleberry St 95020 0.18 DED
Downtown
Specific Plan
Area
30 0 0 0 5 0 5 69 Vacant,Urban Yes No No No
Opportunity
Site
799 10 033 7191
Monterey St 95020 0.34 DED
Downtown
Specific Plan
Area
30 0 0 0 10 0 10 58 Com,Retail Not In Shopping
Center Yes No No No
Opportunity
Site
799 10 034 7161
Monterey St 95020 0.32 DED
Downtown
Specific Plan
Area
30 0 0 0 10 0 10 58 Com,Retail Not In Shopping
Center Yes No No No
Opportunity
Site
799 10 042
Eigleberry
Street (east
side), north
of W Ninth
St
95020 0.16 TD
Downtown
Specific Plan
Area
20 0 0 0 2 0 2 69 Vacant,Urban Yes No No No
Opportunity
Site
799 10 048
Monterey St.
(west side),
north of W
Ninth St
95020 0.30 DED
Downtown
Specific Plan
Area
30 0 0 0 9 0 9 69 Vacant,Urban Yes No No No
Opportunity
Site
799 10 049 7121
Monterey St 95020 0.36 DED
Downtown
Specific Plan
Area
30 0 0 0 11 0 11 58 Com,Retail Not In Shopping
Center Yes No No No
Opportunity
Site
799 34 036 80 W Tenth
St 95020 0.89 DED
Downtown
Specific Plan
Area
30 0 27 0 0 0 27 69 Vacant,Urban Yes No No No
Opportunity
Site
808 01 024
Located at
intersection
of Santa
Teresa Blvd
and Third St
95020 7.22 R4 High Density 30 0 142 0 31 0 173 69 Vacant,Urban Yes No No Yes Opportunity
Site
808 21 009
10 W
Luchessa
Ave
95020 0.57 ND Neighborhood
District 30 0 12 0 0 0 12 69 Vacant,Urban Yes No No No
Opportunity
Site
808 49 078
Monterey
Rd (west
side), south
95020c 0.92 ND Neighborhood
District 30 0 19 0 0 0 19 91 Agr,Orchard Yes No No No
Opportunity
Site

9.2 p. 674 of 1163
APPENDIX B ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 314
APN Address43 Zip
Code
Size
(Acres)
Existing
Zone
Existing
General
Plan
Max.

Density
Existing
Units
Very
Low
Income
Capacity
Low
Income
Capacity
Moderate
Income
Capacity44
Above
Moderate
Income
Capacity
Total
Capacity
Existing Use Infrastructure Publicly
Owned
4th
Cycle
5th
Cycle
Type
of Luchessa
Ave
841 01 064
Swanston
Lane (east
side), south
of Leavesley
Rd
95020 0.17 R3 Medium
Density 20 0 0 0 2 0 2 69 Vacant,Urban Yes No No No
Opportunity
Site
841 02 058
7840
Monterey
Rd
95020 0.43 DED
Downtown
Specific Plan
Area
30 0 0 0 13 0 13 69 Vacant,Urban Yes No No No
Opportunity
Site
841 04 018
7700
Monterey
Rd
95020 0.61 DED
Downtown
Specific Plan
Area
30 0 18 0 0 0 18 58 Com,Retail Not In Shopping
Center Yes No No No
Opportunity
Site
841 04 019
7760
Monterey
Rd
95020 0.70 DED
Downtown
Specific Plan
Area
30 0 21 0 0 0 21 58 Com,Retail Not In Shopping
Center Yes No No No
Opportunity
Site
841 04 020
7780
Monterey
Rd
95020 0.44 DED
Downtown
Specific Plan
Area
30 0 0 0 13 0 13 86 Vacant,Public Uses Yes Yes No No
Opportunity
Site
841 13 022
Alexander St
(west side),
south of Old
Gilroy
95020 3.62 CD
Downtown
Specific Plan
Area
40 0 50 0 50 0 100 43 Tra,Transportation,Railroad Yes No No No Opportunity
Site
841 14 001
Monterey
St., south of
Ninth St
95020 0.55 DED
Downtown
Specific Plan
Area
30 0 16 0 0 0 16 69 Vacant,Urban Yes No No No
Opportunity
Site
841 14 006
6790
Monterey
Rd
95020 0.39 GD
Downtown
Specific Plan
Area
30 0 0 0 9 0 9
58 Com,Retail Not In Shopping
Center Yes No No No
Opportunity
Site
841 14 015
6320
Monterey
Rd
95020 0.55 GD
Downtown
Specific Plan
Area
30 1 12 0 0 0 12 01 Res,Single Family Residence Yes No No No Opportunity
Site
841 14 036
6470
Monterey
Rd
95020 0.74 GD
Downtown
Specific Plan
Area
30 0 18 0 0 0 18 29 Mfg,Petroleum Products Yes No No No Opportunity
Site
841 14 037
6380
Monterey
Rd
95020 0.77 GD
Downtown
Specific Plan
Area
30 0 18 0 0 0 18 10 Ind,Lumber & Other Bldg
Materials Yes No No No
Opportunity
Site
841 14 081
6620
Monterey
Rd
95020 0.53 GD
Downtown
Specific Plan
Area
30 0 13 0 0 0 13 16 Ind,Non-Mfg,Combo Mfg &
Non-Mfg Yes No No No
Opportunity
Site
841 14 083
6920
Monterey
Rd
95020 1.69 DED
Downtown
Specific Plan
Area
30 0 51 0 0 0 51 11 Ind,Warehousing,Public Yes No No No Opportunity
Site

9.2 p. 675 of 1163
APPENDIX B ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 315

9.2 p. 676 of 1163
APPENDIX B ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 316
Table 91: Pipeline Project Sites
APN Address Zip
Code
Size
(Acres
)
Existin
g
Zone
Existing
General Plan
Max.

Densit
y
Existin
g Units
Consoli
dation45
Very
Low
Income
Capacit
y
Low
Income
Capacit
y
Moderate
Income
Capacity
Above
Moderate
Income
Capacity
Total
Capacit
y
Existin
g Use
Infrastructur
e
Publicl
y
Owned
4th
Cycle
5th
Cycle
Type
783 03 073 8340 Wintergreen
Court 95020 0.56 RH Hillside Residential 0.5 -
- - - 1 1 - Yes No No No
Pipeline
Project
783 03 074 8350 Winter
Green Court 95020 0.63 RH Hillside Residential 0.5 -
- - - 1 1 - Yes No No No
Pipeline
Project
783 03 081 8341 Winter
Green Court 95020 0.61 RH Hillside Residential 0.5 -
- - - 1 1 - Yes No No No
Pipeline
Project
783 04 023 Hecker Pass And
Autumn Way 95020 22.4
Hecker
Pass
Special
District
Hecker Pass
Special District -

-
- - - 72 72 - Yes No No No
Pipeline
Project
783 52 032 8745 Wild Iris
Drive 95020 0.29 RH Hillside Residential 0.5 -
- - - 1 1 - Yes No No No
Pipeline
Project
783 52 050 1975 Saffron
Court 95020 0.91 RH Hillside Residential 0.5 -
- - - 1 1 - Yes No No No
Pipeline
Project
783 64 022 2331 Hoya Lane 95020 0.41 RH Hillside
Residential 0.5 -
- - - 1 1 - Yes No No No
Pipeline
Project
783 65 022 2354 Banyan Ct 95020 0.90 RH Hillside
Residential 0.5 -
- - - 1 1 - Yes No No No
Pipeline
Project
783 72 012 1870 Carob Court 95020 0.91 RH Hillside
Residential 0.5 -
- - - 1 1 - Yes No No No
Pipeline
Project
783 72 017 1820 Carob Court 95020 0.64 RH Hillside
Residential 0.5 -
- - - 1 1 - Yes No No No
Pipeline
Project
783 72 020 9145 Tea Tree Wy 95020 0.51 RH Hillside
Residential 0.5 -
- - - 1 1 - Yes No No No
Pipeline
Project
783 72 033 8971 Tea Tree
Way 95020 0.57 RH Hillside Residential 0.5 -
- - - 1 1 - Yes No No No
Pipeline
Project
783 72 036 8955 Mimosa Ct. 95020 1.39 RH Hillside
Residential 0.5 -
- - - 1 1 - Yes No No No
Pipeline
Project
783 72 055 2282 Gunnera Ct 95020 0.82 RH Hillside
Residential 0.5 -
- - - 1 1 - Yes No No No
Pipeline
Project
783 72 027 9025 Mimosa
Court 95020 0.54 RH Hillside Residential 0.5 -
- - - 1 1 - Yes No No No
Pipeline
Project
783 72 038 9005 Mimosa
Court 95020 0.72 RH Hillside Residential 0.5 -
- - - 1 1 - Yes No No No
Pipeline
Project
783 72 035 8950 Mimosa
Court 95020 1.11 RH Hillside Residential 0.5 -
- - - 1 1 - Yes No No No
Pipeline
Project
45 Projects consisting of multiple Consolidated parcels are noted here, with all parcels from the same project being listed with the same corresponding letter. The total units assigned to these consolidated projects are only listed in the first APN for that project.

9.2 p. 677 of 1163
APPENDIX B ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 317
APN Address Zip
Code
Size
(Acres
)
Existin
g
Zone
Existing
General Plan
Max.

Densit
y
Existin
g Units
Consoli
dation45
Very
Low
Income
Capacit
y
Low
Income
Capacit
y
Moderate
Income
Capacity
Above
Moderate
Income
Capacity
Total
Capacit
y
Existin
g Use
Infrastructur
e
Publicl
y
Owned
4th
Cycle
5th
Cycle
Type
783 52 032 8745 Wild Iris
Drive 95020 0.29 RH Hillside Residential 0.5 -
- - - 1 1 - Yes No No No
Pipeline
Project
790 07 007 95 Farrell Avenue 95020 0.90 C1 Low Density
Residential -

-
- - - 4 4 - Yes No No No
Pipeline
Project
790 17 002 9130 Kern Avenue 95020 2.54 R3 Neighborhood
District 20 -
C - - - 29 29 - Yes No No No
Pipeline
Project
790 17 003 9160 Kern Avenue 95020 1.00 R3 Neighborhood
District 20 -
C * * * * - * Yes No No No
Pipeline
Project
790 21 041 975 First Street 95020 3.82 C3 High Density
Residential - - 36 89 1 - 120 - Yes No Yes Yes
Pipeline
Project
790 35 053 307 Gurries Drive 95020 0.23 R3 Medium Density Residential 20 - D - - - 1 1 - Yes No No No
Pipeline
Project
790 35 054 308 Gurries Drive 95020 0.04 R3 Medium Density Residential 20 - D - - - 1 1 - Yes No No No
Pipeline
Project
790 66 057 108 Chickadee
Lane 95020 0.84 C1 Neighborhood District - - - - - 12 12 - Yes No No No Pipeline
Project
799 01 058 7851 Eigleberry
Street 95020 0.18 R2 Downtown Specific Plan Area 10 1 - - - - - - Yes No No No Pipeline
Project
799 06 049 7533 Monterey
Road 95020 0.12 HD Downtown Specific Plan Area - - - - - 3 3 - Yes No No No Pipeline
Project
799 26 033 700 W 6th Street 95020 1.51 PO Low Density
Residential - - A - - - 19 19 - Yes No No No
Pipeline
Project
799 26 037 701 W 6th Street 95020 0.67 R1 Low Density
Residential 1

-
A * * * * - * Yes No No No
Pipeline
Project
799 26 049 702 W 6th Street 95020 0.74 R1 Low Density
Residential 1

-
A * * * * - * Yes No No No
Pipeline
Project
799 26 050 703 W 6th Street 95020 0.10 R1 Low Density
Residential 1

-
A * * * * - * Yes No No No
Pipeline
Project
799 26 051 704 W 6th Street 95020 0.58 R1 Low Density
Residential 1

-
A * * * * - * Yes No No No
Pipeline
Project
799 26 052 705 W 6th Street 95020 0.08 R1 Low Density
Residential 1

-
A * * * * - * Yes No No No
Pipeline
Project
799 35 053 305 Gurries 95020 2.28 R-3
Medium Density
Residential -

-
- - - 2 2 - Yes No No No
Pipeline
Project
799 44 093
Intersection of
Filbro Dr and
Royal Way,
adjacent to 6695
Filbro Dr
95020 0.23 R3 Medium Density
Residential 20 -
B - - - 45 45 - Yes No No No
Pipeline
Project

9.2 p. 678 of 1163
APPENDIX B ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 318
APN Address Zip
Code
Size
(Acres
)
Existin
g
Zone
Existing
General Plan
Max.

Densit
y
Existin
g Units
Consoli
dation45
Very
Low
Income
Capacit
y
Low
Income
Capacit
y
Moderate
Income
Capacity
Above
Moderate
Income
Capacity
Total
Capacit
y
Existin
g Use
Infrastructur
e
Publicl
y
Owned
4th
Cycle
5th
Cycle
Type
799 44 094
Intersection of
Filbro Dr and
Royal Way
95020 0.28 R3 Medium Density
Residential 20 -
B * * * * - * Yes No No No
Pipeline
Project
799 44 095 Royal Way, South
of 6690 Filbro Dr 95020 0.19 R3 Medium Density Residential 20 - B * * * * - * Yes No No No
Pipeline
Project
799 44 096 Royal Way, South
of 6685 Filbro Dr 95020 0.18 R3 Medium Density Residential 20 - B * * * * - * Yes No No No
Pipeline
Project
799 44 097
Intersection of
Royal Way and
Imperial Dr
95020 0.19 R3 Medium Density
Residential 20 -
B * * * * - * Yes No No No
Pipeline
Project
799 44 098
Intersection of
Royal Way and
Imperial Dr,
adjacent to 6670
Imperial Dr
95020 0.21 R3 Medium Density
Residential 20 -
B * * * * - * Yes No No No
Pipeline
Project
799 44 101 Royal Way, West
of 711 Antonio Ct 95020 0.00 R3 Low Density Residential 20 - B * * * * - * Yes No No No
Pipeline
Project
799 44 109 Royal Way, West
of 711 Antonio Ct 95020 1.92 R3 Medium Density Residential 20 - B * * * * - * Yes No No No
Pipeline
Project
799 44 110 321 W Luchessa
Ave 95020 0.24 R3 Low Density Residential 20 -
B * * * * - * Yes No No No
Pipeline
Project
808 01 021 1410 First St 95020 7.60 R3 High Density
Residential 20 -
G - - - 202 202 - Yes No No No
Pipeline
Project
808 01 022 7890 Santa Teresa
Blvd 95020 1.67 R3 High Density Residential 20 -
G * * * * - * Yes No No No
Pipeline
Project
808 01 023 1490 First St 95020 1.57 R4 High Density
Residential 30 -
G * * * * - * Yes No No No
Pipeline
Project
808 19 023
NW of the
intersection of
Miller Ave and W.

Luchessa Ave
95020 7.60 OS Glen Loma Ranch -

-
- 152 - - 152 - Yes No No No
Pipeline
Project
808 57 007 1265 Hernandez
Wy 95020 0.07
Glen
Loma
Ranch
Special
District
Glen Loma Ranch -

-
J - - - 1 1 - Yes No No No
Pipeline
Project
808 57 008 1255 Hernandez
Wy 95020 0.07
Glen
Loma
Ranch
Special
District
Glen Loma Ranch -

-
J - - - 1 1 - Yes No No No
Pipeline
Project
808 57 021 1290 Hernandez
Wy 95020 0.07 Glen
Loma
Glen Loma Ranch -

-
J - - - 1 1 - Yes No No No
Pipeline
Project

9.2 p. 679 of 1163
APPENDIX B ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 319
APN Address Zip
Code
Size
(Acres
)
Existin
g
Zone
Existing
General Plan
Max.

Densit
y
Existin
g Units
Consoli
dation45
Very
Low
Income
Capacit
y
Low
Income
Capacit
y
Moderate
Income
Capacity
Above
Moderate
Income
Capacity
Total
Capacit
y
Existin
g Use
Infrastructur
e
Publicl
y
Owned
4th
Cycle
5th
Cycle
Type
Ranch
Special
District
808 57 022 1300 Hernandez
Wy 95020 0.09
Glen
Loma
Ranch
Special
District
Glen Loma Ranch -

-
J - - - 1 1 - Yes No No No
Pipeline
Project
808 57 025 1285 Qualteri Wy 95020 0.08
Glen
Loma
Ranch
Special
District
Glen Loma Ranch -

-
J - - - 1 1 - Yes No No No
Pipeline
Project
808 57 026 1275 Qualteri Wy 95020 0.07
Glen
Loma
Ranch
Special
District
Glen Loma Ranch -

-
J - - - 1 1 - Yes No No No
Pipeline
Project
808 57 030 1235 Qualteri Wy 95020 0.07
Glen
Loma
Ranch
Special
District
Glen Loma Ranch -

-
J - - - 1 1 - Yes No No No
Pipeline
Project
808 57 031 1225 Qualteri Wy 95020 0.07
Glen
Loma
Ranch
Special
District
Glen Loma Ranch -

-
J - - - 1 1 - Yes No No No
Pipeline
Project
808 57 039 1270 Qualteri Wy 95020 0.09
Glen
Loma
Ranch
Special
District
Glen Loma Ranch -

-
J - - - 1 1 - Yes No No No
Pipeline
Project
808 57 040 1290 Qualteri Wy 95020 0.08
Glen
Loma
Ranch
Special
District
Glen Loma Ranch -

-
J - - - 1 1 - Yes No No No
Pipeline
Project
808 57 041 1300 Qualteri Wy 95020 0.08
Glen
Loma
Ranch
Special
District
Glen Loma Ranch -

-
J - - - 1 1 - Yes No No No
Pipeline
Project
808 57 042 1310 Qualteri Wy 95020 0.07
Glen
Loma
Ranch
Glen Loma Ranch -

-
J - - - 1 1 - Yes No No No
Pipeline
Project

9.2 p. 680 of 1163
APPENDIX B ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 320
APN Address Zip
Code
Size
(Acres
)
Existin
g
Zone
Existing
General Plan
Max.

Densit
y
Existin
g Units
Consoli
dation45
Very
Low
Income
Capacit
y
Low
Income
Capacit
y
Moderate
Income
Capacity
Above
Moderate
Income
Capacity
Total
Capacit
y
Existin
g Use
Infrastructur
e
Publicl
y
Owned
4th
Cycle
5th
Cycle
Type
Special
District
808 57 043 1320 Qualteri Wy 95020 0.08
Glen
Loma
Ranch
Special
District
Glen Loma Ranch -

-
8J - - - 1 1 - Yes No No No
Pipeline
Project
808 57 044 1330 Qualteri Wy 95020 0.07
Glen
Loma
Ranch
Special
District
Glen Loma Ranch -

-
J - - - 1 1 - Yes No No No
Pipeline
Project
808 57 045 1340 Qualteri Wy 95020 0.09
Glen
Loma
Ranch
Special
District
Glen Loma Ranch -

-
J - - - 1 1 - Yes No No No
Pipeline
Project
808 57 046 6435 Juristac Wy 95020 0.07
Glen
Loma
Ranch
Special
District
Glen Loma Ranch -

-
J - - - 1 1 - Yes No No No
Pipeline
Project
808 57 049 6465 Juristac Wy 95020 0.07
Glen
Loma
Ranch
Special
District
Glen Loma Ranch -

-
J - - - 1 1 - Yes No No No
Pipeline
Project
808 57 050 6480 Godani St 95020 0.10
Glen
Loma
Ranch
Special
District
Glen Loma Ranch -

-
J - - - 1 1 - Yes No No No
Pipeline
Project
808 57 053 6450 Godani St 95020 0.10
Glen
Loma
Ranch
Special
District
Glen Loma Ranch -

-
J - - - 1 1 - Yes No No No
Pipeline
Project
808 57 054 6440 Godani St 95020 0.10
Glen
Loma
Ranch
Special
District
Glen Loma Ranch -

-
J - - - 1 1 - Yes No No No
Pipeline
Project
808 57 055 6430 Godani St 95020 0.10
Glen
Loma
Ranch
Glen Loma Ranch -

-
J - - - 1 1 - Yes No No No
Pipeline
Project

9.2 p. 681 of 1163
APPENDIX B ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 321
APN Address Zip
Code
Size
(Acres
)
Existin
g
Zone
Existing
General Plan
Max.

Densit
y
Existin
g Units
Consoli
dation45
Very
Low
Income
Capacit
y
Low
Income
Capacit
y
Moderate
Income
Capacity
Above
Moderate
Income
Capacity
Total
Capacit
y
Existin
g Use
Infrastructur
e
Publicl
y
Owned
4th
Cycle
5th
Cycle
Type
Special
District
808 57 056 6420 Godani St 95020 0.10
Glen
Loma
Ranch
Special
District
Glen Loma Ranch -

-
J - - - 1 1 - Yes No No No
Pipeline
Project
808 57 057 6410 Godani St 95020 0.10
Glen
Loma
Ranch
Special
District
Glen Loma Ranch -

-
J - - - 1 1 - Yes No No No
Pipeline
Project
808 57 070 1305 Michael Bo
Ln 95020 0.10
Glen
Loma
Ranch
Special
District
Glen Loma Ranch -

-
J - - - 1 1 - Yes No No No
Pipeline
Project
808 57 072 1285 Michael Bo
Ln 95020 0.10
Glen
Loma
Ranch
Special
District
Glen Loma Ranch -

-
J - - - 1 1 - Yes No No No
Pipeline
Project
808 57 078 1225 Michael Bo
Ln 95020 0.10
Glen
Loma
Ranch
Special
District
Glen Loma Ranch -

-
J - - - 1 1 - Yes No No No
Pipeline
Project
808 57 084 1240 Mirassou Ln 95020 0.11
Glen
Loma
Ranch
Special
District
Glen Loma Ranch -

-
J - - - 1 1 - Yes No No No
Pipeline
Project
808 57 089 1290 Mirassou Ln 95020 0.12
Glen
Loma
Ranch
Special
District
Glen Loma Ranch -

-
J - - - 1 1 - Yes No No No
Pipeline
Project
808 57 093 1330 Mirassou Ln 95020 0.15
Glen
Loma
Ranch
Special
District
Glen Loma Ranch -

-
J - - - 1 1 - Yes No No No
Pipeline
Project
808 57 098 6390 Carsey Wy 95020 0.10
Glen
Loma
Ranch
Glen Loma Ranch -

-
J - - - 1 1 - Yes No No No
Pipeline
Project

9.2 p. 682 of 1163
APPENDIX B ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 322
APN Address Zip
Code
Size
(Acres
)
Existin
g
Zone
Existing
General Plan
Max.

Densit
y
Existin
g Units
Consoli
dation45
Very
Low
Income
Capacit
y
Low
Income
Capacit
y
Moderate
Income
Capacity
Above
Moderate
Income
Capacity
Total
Capacit
y
Existin
g Use
Infrastructur
e
Publicl
y
Owned
4th
Cycle
5th
Cycle
Type
Special
District
808 57 099 6380 Carsey Wy 95020 0.12
Glen
Loma
Ranch
Special
District
Glen Loma Ranch -

-
J - - - 1 1 - Yes No No No
Pipeline
Project
808 57 100 6370 Carsey Wy 95020 0.12
Glen
Loma
Ranch
Special
District
Glen Loma Ranch -

-
J - - - 1 1 - Yes No No No
Pipeline
Project
808 57 106 1235 Mirassou Ln 95020 0.10
Glen
Loma
Ranch
Special
District
Glen Loma Ranch -

-
J - - - 1 1 - Yes No No No
Pipeline
Project
808 57 112 1240 Bouret Ct 95020 0.14
Glen
Loma
Ranch
Special
District
Glen Loma Ranch -

-
J - - - 1 1 - Yes No No No
Pipeline
Project
808 18 031
North Of Santa
Teresa, East Of
Syrah Dr, And
West Of Miller
Ave.
95020 31.11
Glen
Loma
Ranch
Special
District
Glen Loma Ranch
Special District -

-
F - - - 172 172 - Yes No No No
Pipeline
Project
808 60 071 6811 Vintner 95020 0.16
Glen
Loma
Ranch
Special
District
Glen Loma Ranch
Special District -

-
F * * * * - * Yes No No No
Pipeline
Project
808 60 072 6821 Vintner 95020 0.14
Glen
Loma
Ranch
Special
District
Glen Loma Ranch
Special District -

-
F * * * * - * Yes No No No
Pipeline
Project
808 60 073 6831 Vintner 95020 0.13
Glen
Loma
Ranch
Special
District
Glen Loma Ranch
Special District -

-
F * * * * - * Yes No No No
Pipeline
Project
808 60 074 6841 Vintner 95020 0.11
Glen
Loma
Ranch
Glen Loma Ranch
Special District -

-
F * * * * - * Yes No No No
Pipeline
Project

9.2 p. 683 of 1163
APPENDIX B ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 323
APN Address Zip
Code
Size
(Acres
)
Existin
g
Zone
Existing
General Plan
Max.

Densit
y
Existin
g Units
Consoli
dation45
Very
Low
Income
Capacit
y
Low
Income
Capacit
y
Moderate
Income
Capacity
Above
Moderate
Income
Capacity
Total
Capacit
y
Existin
g Use
Infrastructur
e
Publicl
y
Owned
4th
Cycle
5th
Cycle
Type
Special
District
808 60 075 6851 Vintner 95020 0.11
Glen
Loma
Ranch
Special
District
Glen Loma Ranch
Special District -

-
F * * * * - * Yes No No No
Pipeline
Project
808 60 076 6861 Vintner 95020 0.12
Glen
Loma
Ranch
Special
District
Glen Loma Ranch
Special District -

-
F * * * * - * Yes No No No
Pipeline
Project
808 60 077 6871 Vintner 95020 0.15
Glen
Loma
Ranch
Special
District
Glen Loma Ranch
Special District -

-
F * * * * - * Yes No No No
Pipeline
Project
808 60 078 6881 Vintner 95020 0.13
Glen
Loma
Ranch
Special
District
Glen Loma Ranch
Special District -

-
F * * * * - * Yes No No No
Pipeline
Project
808 60 079 6891 Vintner 95020 0.13
Glen
Loma
Ranch
Special
District
Glen Loma Ranch
Special District -

-
F * * * * - * Yes No No No
Pipeline
Project
808 60 080 6901 Vintner 95020 0.11
Glen
Loma
Ranch
Special
District
Glen Loma Ranch
Special District -

-
F * * * * - * Yes No No No
Pipeline
Project
808 60 081 6911 Vintner 95020 0.12
Glen
Loma
Ranch
Special
District
Glen Loma Ranch
Special District -

-
F * * * * - * Yes No No No
Pipeline
Project
808 61 001 7001 Vintner 95020 0.11
Glen
Loma
Ranch
Special
District
Glen Loma Ranch
Special District -

-
F * * * * - * Yes No No No
Pipeline
Project
808 61 002 7011 Vintner 95020 0.11
Glen
Loma
Ranch
Glen Loma Ranch
Special District -

-
F * * * * - * Yes No No No
Pipeline
Project

9.2 p. 684 of 1163
APPENDIX B ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 324
APN Address Zip
Code
Size
(Acres
)
Existin
g
Zone
Existing
General Plan
Max.

Densit
y
Existin
g Units
Consoli
dation45
Very
Low
Income
Capacit
y
Low
Income
Capacit
y
Moderate
Income
Capacity
Above
Moderate
Income
Capacity
Total
Capacit
y
Existin
g Use
Infrastructur
e
Publicl
y
Owned
4th
Cycle
5th
Cycle
Type
Special
District
808 61 003 7021 Vintner 95020 0.16
Glen
Loma
Ranch
Special
District
Glen Loma Ranch
Special District -

-
F * * * * - * Yes No No No
Pipeline
Project
808 61 004 7031 Vintner 95020 0.13
Glen
Loma
Ranch
Special
District
Glen Loma Ranch
Special District -

-
F * * * * - * Yes No No No
Pipeline
Project
808 61 005 7041 Vintner 95020 0.12
Glen
Loma
Ranch
Special
District
Glen Loma Ranch
Special District -

-
F * * * * - * Yes No No No
Pipeline
Project
808 61 006 7051 Vintner 95020 0.12
Glen
Loma
Ranch
Special
District
Glen Loma Ranch
Special District -

-
F * * * * - * Yes No No No
Pipeline
Project
808 61 007 7061 Vintner 95020 0.13
Glen
Loma
Ranch
Special
District
Glen Loma Ranch
Special District -

-
F * * * * - * Yes No No No
Pipeline
Project
808 61 008 7071 Vintner 95020 0.13
Glen
Loma
Ranch
Special
District
Glen Loma Ranch
Special District -

-
F * * * * - * Yes No No No
Pipeline
Project
808 61 009 7081 Vintner 95020 0.13
Glen
Loma
Ranch
Special
District
Glen Loma Ranch
Special District -

-
F * * * * - * Yes No No No
Pipeline
Project
808 61 010 7091 Vintner 95020 0.13
Glen
Loma
Ranch
Special
District
Glen Loma Ranch
Special District -

-
F * * * * - * Yes No No No
Pipeline
Project
808 61 011 7101 Vintner 95020 0.13
Glen
Loma
Ranch
Glen Loma Ranch
Special District -

-
F * * * * - * Yes No No No
Pipeline
Project

9.2 p. 685 of 1163
APPENDIX B ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 325
APN Address Zip
Code
Size
(Acres
)
Existin
g
Zone
Existing
General Plan
Max.

Densit
y
Existin
g Units
Consoli
dation45
Very
Low
Income
Capacit
y
Low
Income
Capacit
y
Moderate
Income
Capacity
Above
Moderate
Income
Capacity
Total
Capacit
y
Existin
g Use
Infrastructur
e
Publicl
y
Owned
4th
Cycle
5th
Cycle
Type
Special
District
808 61 012 7111 Vintner 95020 0.12
Glen
Loma
Ranch
Special
District
Glen Loma Ranch
Special District -

-
F * * * * - * Yes No No No
Pipeline
Project
808 61 013 7121 Vintner 95020 0.12
Glen
Loma
Ranch
Special
District
Glen Loma Ranch
Special District -

-
F * * * * - * Yes No No No
Pipeline
Project
808 61 014 7131 Vintner 95020 0.12
Glen
Loma
Ranch
Special
District
Glen Loma Ranch
Special District -

-
F * * * * - * Yes No No No
Pipeline
Project
808 61 015 7141 Vintner 95020 0.11
Glen
Loma
Ranch
Special
District
Glen Loma Ranch
Special District -

-
F * * * * - * Yes No No No
Pipeline
Project
808 61 016 7100 Vintner 95020 0.16
Glen
Loma
Ranch
Special
District
Glen Loma Ranch
Special District -

-
F * * * * - * Yes No No No
Pipeline
Project
808 61 017 7090 Vintner 95020 0.14
Glen
Loma
Ranch
Special
District
Glen Loma Ranch
Special District -

-
F * * * * - * Yes No No No
Pipeline
Project
808 61 018 7080 Vintner 95020 0.13
Glen
Loma
Ranch
Special
District
Glen Loma Ranch
Special District -

-
F * * * * - * Yes No No No
Pipeline
Project
808 61 019 7070 Vintner 95020 0.14
Glen
Loma
Ranch
Special
District
Glen Loma Ranch
Special District -

-
F * * * * - * Yes No No No
Pipeline
Project
808 61 020 7060 Vintner 95020 0.15
Glen
Loma
Ranch
Glen Loma Ranch
Special District -

-
F * * * * - * Yes No No No
Pipeline
Project

9.2 p. 686 of 1163
APPENDIX B ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 326
APN Address Zip
Code
Size
(Acres
)
Existin
g
Zone
Existing
General Plan
Max.

Densit
y
Existin
g Units
Consoli
dation45
Very
Low
Income
Capacit
y
Low
Income
Capacit
y
Moderate
Income
Capacity
Above
Moderate
Income
Capacity
Total
Capacit
y
Existin
g Use
Infrastructur
e
Publicl
y
Owned
4th
Cycle
5th
Cycle
Type
Special
District
808 61 021 7050 Vintner 95020 0.17
Glen
Loma
Ranch
Special
District
Glen Loma Ranch
Special District -

-
F * * * * - * Yes No No No
Pipeline
Project
808 61 022 7040 Vintner 95020 0.13
Glen
Loma
Ranch
Special
District
Glen Loma Ranch
Special District -

-
F * * * * - * Yes No No No
Pipeline
Project
808 61 023 7030 Vintner 95020 0.13
Glen
Loma
Ranch
Special
District
Glen Loma Ranch
Special District -

-
F * * * * - * Yes No No No
Pipeline
Project
808 60 069 1470 Vinador Pl 95020 0.14
Glen
Loma
Ranch
Special
District
Glen Loma Ranch
Special District -

-
F * * * * - * Yes No No No
Pipeline
Project
808 60 037 1495 Winzer Pl 95020 0.10
Glen
Loma
Ranch
Special
District
Glen Loma Ranch
Special District -

-
F * * * * - * Yes No No No
Pipeline
Project
808 60 038 1485 Winzer Pl 95020 0.10
Glen
Loma
Ranch
Special
District
Glen Loma Ranch
Special District -

-
F * * * * - * Yes No No No
Pipeline
Project
808 60 036 1505 Winzer Pl 95020 0.11
Glen
Loma
Ranch
Special
District
Glen Loma Ranch
Special District -

-
F * * * * - * Yes No No No
Pipeline
Project
808 60 039 1475 Winzer Pl 95020 0.11
Glen
Loma
Ranch
Special
District
Glen Loma Ranch
Special District -

-
F * * * * - * Yes No No No
Pipeline
Project
808 60 054 1450 Winzer Pl 95020 0.11
Glen
Loma
Ranch
Glen Loma Ranch
Special District -

-
F * * * * - * Yes No No No
Pipeline
Project

9.2 p. 687 of 1163
APPENDIX B ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 327
APN Address Zip
Code
Size
(Acres
)
Existin
g
Zone
Existing
General Plan
Max.

Densit
y
Existin
g Units
Consoli
dation45
Very
Low
Income
Capacit
y
Low
Income
Capacit
y
Moderate
Income
Capacity
Above
Moderate
Income
Capacity
Total
Capacit
y
Existin
g Use
Infrastructur
e
Publicl
y
Owned
4th
Cycle
5th
Cycle
Type
Special
District
808 60 055 1460 Winzer Pl 95020 0.11
Glen
Loma
Ranch
Special
District
Glen Loma Ranch
Special District -

-
F * * * * - * Yes No No No
Pipeline
Project
808 60 056 1470 Winzer Pl 95020 0.11
Glen
Loma
Ranch
Special
District
Glen Loma Ranch
Special District -

-
F * * * * - * Yes No No No
Pipeline
Project
808 60 057 1480 Winzer Pl 95020 0.12
Glen
Loma
Ranch
Special
District
Glen Loma Ranch
Special District -

-
F * * * * - * Yes No No No
Pipeline
Project
808 60 015 1575 Hurka Wy 95020 0.16
Glen
Loma
Ranch
Special
District
Glen Loma Ranch
Special District -

-
F * * * * - * Yes No No No
Pipeline
Project
808 60 003 1490 Hurka Wy 95020 0.13
Glen
Loma
Ranch
Special
District
Glen Loma Ranch
Special District -

-
F * * * * - * Yes No No No
Pipeline
Project
808 60 004 1500 Hurka Wy 95020 0.15
Glen
Loma
Ranch
Special
District
Glen Loma Ranch
Special District -

-
F * * * * - * Yes No No No
Pipeline
Project
808 60 019 1535 Hurka Wy 95020 0.14
Glen
Loma
Ranch
Special
District
Glen Loma Ranch
Special District -

-
F * * * * - * Yes No No No
Pipeline
Project
808 60 020 1525 Hurka Wy 95020 0.13
Glen
Loma
Ranch
Special
District
Glen Loma Ranch
Special District -

-
F * * * * - * Yes No No No
Pipeline
Project
808 60 021 1515 Hurka Wy 95020 0.13
Glen
Loma
Ranch
Glen Loma Ranch
Special District -

-
F * * * * - * Yes No No No
Pipeline
Project

9.2 p. 688 of 1163
APPENDIX B ▐
City of Gilroy Housing Element ▐ 6
th Cycle Housing Plan 328
APN Address Zip
Code
Size
(Acres
)
Existin
g
Zone
Existing
General Plan
Max.

Densit
y
Existin
g Units
Consoli
dation45
Very
Low
Income
Capacit
y
Low
Income
Capacit
y
Moderate
Income
Capacity
Above
Moderate
Income
Capacity
Total
Capacit
y
Existin
g Use
Infrastructur
e
Publicl
y
Owned
4th
Cycle
5th
Cycle
Type
Special
District
808 60 022 1505 Hurka Wy 95020 0.14
Glen
Loma
Ranch
Special
District
Glen Loma Ranch
Special District -

-
F * * * * - * Yes No No No
Pipeline
Project
808 60 027 1540 Sawana Wy 95020 0.18
Glen
Loma
Ranch
Special
District
Glen Loma Ranch
Special District -

-
F * * * * - * Yes No No No
Pipeline
Project
808 60 024 1510 Sawana Wy 95020 0.14
Glen
Loma
Ranch
Special
District
Glen Loma Ranch
Special District -