Gustine City Council
January 21, 2025

Merced County Association of Governments
Merced County Multi-Jurisdictional Housing Element (2024-2032) D2-10
Comment Theme Comment Response
Land Use Element. In addition, maximum height
standards in the R-3 zone, 30 feet, potentially limits the development of affordable housing. The Housing
Element includes several programs to address
development standards as a constraint to housing
development. Housing Program 6 directs the City to
allow minor modifications to height for affordable
housing projects and Housing Program 8 directs the City to adopt a Density Bonus Ordinance that offers density
increases for affordable housing development. Housing
Programs 2, 6, and 8 direct the City to revise the Zoning Code and General Plan to maintain consistency and to
establish a minimum of one multi-family or mixed-use
zone/land use designation that has a maximum density
that can accommodate affordable housing, at least 20
units per acre, consistent with State guidelines. This will be accomplished through updating the allowed density
of the medium-high density residential land use
designation in the General Plan Land Use Element and
revising the Zoning Code to ensure a minimum of one
multi-family or mixed-use zone has a density that allows up to 20 units per acre, consistent with State guidelines.

The City analyzed minimum density, minimum lot size,
and parking requirements established within the Zoning
Code in Chapter D4, Housing Constraints, Section D4.3.2 Residential Development Standards. A discussion of the
findings of the analysis is discussed below.

The City does not have mandatory distribution of
income levels for housing development. This is further
discussed below.

Constraints State legislature and regulation
stipulates that no requirement be
placed on the distribution of income
levels among units within a housing
development.

Neither the Zoning Code nor the Housing Element
include mandatory distribution of income levels for
housing development. The distribution of income levels
within the Site Inventory is intended to demonstrate
that the City has adequate zoning to accommodate the
distribution of housing units by income level required by the City's RHNA. However, the allocation of units by
income levels presented in the Site Inventory is not
required in the event a housing opportunity site is
developed in the future.

An affordable housing project that utilizes Density
Bonus provisions or other incentives or concessions
offered via State law or City code is required to record a deed restriction that sets forth requirements for the
provision of affordable units to run with the land for the time period agreed upon by the developer and the City,
or as required per State law or City code. Market-rate
housing units are not required to adhere to income
restrictions and the Housing Element does not impose
such a requirement on market-rate housing.

Constraints The proposed zoning of Site 1 in the
Site Inventory creates multiple
constraints to development housing
on the site, including minimum lot size
and front setbacks requirements.

The City analyzed development standards established
by the City's Zoning Code in Chapter D4, Housing
Constraints Analysis, Section D4.3.2 Residential
Development Standards. Based on this analysis, the
City's zoning and development standards are

City of Gustine
Public Participation
2024-2032 Housing Element D2-11
Comment Theme Comment Response
While the Zoning Code allows for small
lot housing in the R-3 zone, the
current minimum lot size of 7,500
square feet with an allowance for
subdividing into smaller parcels is
ambiguous. The proposed
development standards in Table D4-5
make small lot housing infeasible.

Recommended development
standards for the R-3 zone should
include a minimum lot size of 2,000
square feet and a front setback of 5
feet. Planned development standards
are also restrictive and should be
addressed.
appropriate to accommodate the development of a
range of housing types. To further incentivize the
development of housing, and in particular affordable
housing, the City will rezone four sites to establish a minimum density of 20 units per acre and a maximum
density of 25 units per acre to provide additional
opportunities for multi-family housing development, as
outlined in Housing Program 2. Multi-family zones
accommodate a variety of housing types, including
duplexes, triplexes, quadplexes, townhomes, and multifamily housing with more than two units through a ministerial approval process (Zoning Clearance).

The City's Zoning Code allows small lot housing in the R2, R-3, and PD zones. Small lot housing projects in the R2, R-3, and PD zones are currently allowed to subdivide larger parcels (that meet the minimum lot size) into
smaller lots, provided that the project complies with the allowed density of the zone the project is located.

Constraints Requiring two parking spaces per unit
is an acceptable standard, but garages
and driveways should be explicitly
allowed to fulfill off-street parking
requirements.

The City analyzed its parking requirements in Chapter
D4, Housing Constraints Analysis, Section D4.3.2.1
Parking. Table D4-6 shows residential parking
requirements established by the Zoning Code.

Residential parking space requirements are based on
unit type and number of bedrooms. Some residential
uses, including single-family dwellings and mobile
homes, require covered parking spaces. The Zoning
Code specifies that garages and carports meet the
requirement for covered parking and that while the
Zoning Code does not specifically state that residential driveways would meet off-street parking requirements
there are no restrictions that would preclude this. This language has been added to Chapter D4, Housing
Constraints Analysis, Section D4.3.2.1 Parking.

Constraints Minimum densities should not be so
restrictive that a property owner is
required to develop a substandard
project that does not fit the character
or needs of the community.

The City's General Plan Land Use Element and Zoning
Code currently establishes a minimum density of 10
units per acre in the R-3 zone and the Housing Element
proposes to rezone four sites to establish a minimum
density of 20 units per acre on those sites. These
minimum density standards are intended to encourage
the development of higher density and affordable
housing. Allowing low-density residential uses in high
density zones can be a constraint to housing
development since multi-family housing with more than
two units is only permitted conditionally in the R-2 zone and in the R-3 zone. Site 1 in the Site Inventory is zoned R-3 and no changes to the site's zoning is proposed in
the Housing Element. The allowed density of the R-3
zone (10 to 20 units per acre) accommodates a variety
of housing types, including small-lot single-family
homes, duplexes, triplexes, quadplexes, townhomes,
and multi-family housing.

Merced County Association of Governments
Merced County Multi-Jurisdictional Housing Element (2024-2032) D2-12
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City of Gustine
Housing Needs Assessment
2024-2032 Housing Element D3-1
D3 Housing Needs Assessment
This section provides an individual assessment of housing needs for the city of Gustine. It summarizes demographic, employment, and housing characteristics. The main source of the information is the pre-approved data package for jurisdictions approved by the California Department of Housing and Community Development (HCD). This data is primarily sourced from the U.S. Census, the U.S. Department of Housing and Urban Development’s (HUD) Comprehensive Housing Affordability Strategy (CHAS), and American Community Survey (ACS) 2017-2021 five-year estimates. Tables and figures also include comparable data for Merced County and California where it is found most useful.

D3.1 Population Characteristics
Population characteristics, such as growth rate, age, and income levels, affect the type and amount of housing needed in a community. Residents’ age and income, employment trends, and other factors influence the type of housing needed and the community’s ability to afford housing. The following section analyzes the City of Gustine’s population characteristics and trends.

D3.2 Population Growth
Table D3-1 analyzes population change from 2000 to 2021. Gustine grew by 17.5 percent from 2000 to 2010, and 8.5 percent from 2010 to 2021. This is consistent with Merced County percentages, but overall higher than California’s rate of growth.

Table D3-1 Population Change (2000 - 2021)
Jurisdiction 2000 2010 2021
Percent
Change
Percent
Change
2000-2010 2010-2021
Gustine 4,698 5,520 5,990 17.5% 8.5%
Merced County 210,554 255,793 279,150 21.5% 9.1%
California 33,971,648 37,253,956 39,455,353 9.7% 5.9%
Source: U.S. Census Bureau, Census 2000, 2010; Social Explorer tables for Census 2021.

D3.3 Age Characteristics
Table D3-2 shows population by age group and each group’s percentage of the total population. The age groups include preschool (under five years), school-age students (five to seventeen years), college-age students (18 to 24 years), young adults (25 to 44), middle-aged adults (45 to 64), and seniors (65 and over). In Gustine, the largest age group is the young adult category, representing

27.2 percent of the total population, similar to Merced County (27.0 percent) and California (28.6 percent). The second largest group in Gustine is middle-aged adults at 27.1 percent. The smallest population by age are preschoolers at 2.4 percent, which is lower than Merced County (7.5 percent) and California (6.0 percent). Gustine also has a higher proportion of residents 45 years and older

Merced County Association of Governments
Merced County Multi-Jurisdictional Housing Element (2024-2032) D3-2
(42.7 percent) compared to Merced County (32.3 percent) and California (39.4 percent). The proportion of the City’s population that is under five years old (2.4 percent) is much smaller than Merced County (7.5 percent) and California averages (6.0 percent).

Table D3-2 Population by Age Group (2021)
Jurisdiction
Under 5
years
(Preschool)
5 to 17
years
(School-age
Students)
18 to 24
years
(College-age
Students)
25 to 44
(Young
Adults)
45 to 64
(Middle-aged
Adults)
65 years and
over
(Seniors)
Total
Population
Gustine 145 1,003 653 1,630 1,623 936 5,990
Percent 2.4% 16.7% 10.9% 27.2% 27.1% 15.6%
Merced
County 20,969 61,609 31,111 75,342 59,131 30,988 279,150 Percent 7.5% 22.1% 11.1% 27.0% 21.2% 11.1%
California 2,350,335 6,642,097 3,665,851 11,282,671 9,844,520 5,669,879 39,455,353 Percent 6.0% 16.8% 9.3% 28.6% 25.0% 14.4%
Source: U.S. Census Bureau, ACS 17-21 (5-year Estimates), Table B01001.

D3.4 Race and Ethnicity
Table D3-3 shows race and ethnicity data for residents in Gustine, Merced County, and California. In terms of race, most of the population of Gustine identifies as white at 55.9 percent, which is considerably higher than countywide (46.2 percent) or across the state (52.1 percent). The second largest population group is Some Other Race representing 33 percent of the total population in Gustine. This is similar to Merced County (33.7 percent) and higher than California (15.3 percent). In terms of ethnicity, most of the population of Gustine identifies as Hispanic or Latino (57.1 percent) which is slightly lower than Merced County (61.2 percent) but higher than California (39.5).

Table D3-3 Population by Race
Jurisdiction
White
Alone
Black or
African
American
Alone
American
Indian and
Alaska
Native
Alone
Asian
Alone
Native
Hawaiian
and
Other
Pacific
Islander
Alone
Some
Other Race
Alone1
Two or
More
Races2
Hispanic or
Latino, Any
Race Total
Gustine 3,347 - 71 161 - 1,974 437 3,423 5,990
Percent 55.9% 0.0% 1.2% 2.7% 0.0% 33.0% 7.3% 57.1%
Merced
County 128,897 8,057 3,267 20,945 797 93,978 23,209 170,730 279,150 Percent 46.2% 2.9% 1.2% 7.5% 0.3% 33.7% 8.3% 61.2%
California 20,553,732 2,233,258 360,607 5,887,396 148,278 6,036,865 4,235,217 15,593,787 39,455,353 Percent 52.1% 5.7% 0.9% 14.9% 0.4% 15.3% 10.7% 39.5%
(1) Note: “Some other race alone” includes all other responses not included in the "white alone", "Black or African American alone", "American Indian and Alaska Native alone”, “Asian alone” and “Native Hawaiian and Other Pacific Islander alone” race categories (2) Note: “Two or more races” includes responses from all individuals who identify themselves as two or more of the aforementioned race groups. If an individual responded with both “two or more races” and “some other race,” their response was only included under “two or more races.”
Source: U.S. Census Bureau, ACS17-21 (5-year Estimates), Table B02001; U.S. Census Bureau, ACS17-21 (5-year Estimates), Table B03001.

City of Gustine
Housing Needs Assessment
2024-2032 Housing Element D3-3
D3.5 Economic Characteristics
Employment
Understanding employment and occupation patterns can provide insight into present housing needs. Table D3-4 shows employment by industry. Educational Services, Health Care, and Social Assistance is the most common industry in Gustine, representing 19.2 percent of all industries. This is also the most common industry in Merced County (22 percent) and California (21.4 percent). The second largest industry in Gustine is Manufacturing with 11.6 percent.

Table D3-4 Employment by Industry (2021)
Industry Gustine Percent
Merced
County Percent California Percent
Educational Services, And Health
Care and Social Assistance
419 19.2% 23,797 22% 3,990,094 21.4%
Manufacturing 254 11.6% 11,778 10.9% 1,676,715 9%
Agriculture, Forestry, Fishing and
Hunting, And Mining
235 10.8% 12,326 11.4% 394,881 2.1%
Transportation And Warehousing,
And Utilities
222 10.2% 7,626 7.1% 1,071,181 5.7%
Arts, Entertainment, And Recreation,
And Accommodation and Food
Services
194 8.9% 7,682 7.1% 1,835,141 9.8%
Retail Trade 171 7.8% 11,804 10.9% 1,919,513 10.3%
Public Administration 160 7.3% 5,058 4.7% 864,476 4.6%
Professional, Scientific, And
Management, And Administrative,
And Waste Management Services
158 7.2% 7,146 6.6% 2,612,859 14%
Finance And Insurance, And Real
Estate, And Rental and Leasing
135 6.2% 3,075 2.8% 1,107,961 5.9%
Construction 81 3.7% 8,623 8% 1,235,586 6.6%
Other Services, Except Public
Administration
76 3.5% 4,275 4% 927,253 5%
Wholesale Trade 67 3.1% 4,036 3.7% 501,378 2.7%
Information 10 0.5% 968 0.9% 539,683 2.9%
Source: U.S. Census Bureau, ACS 17-21 (5-year Estimates), Table C24050.

According to the California Bureau of Labor Statistics, as of September 2024 the unemployment rate in Gustine as of September 2024 is 12.1 percent, which is slightly lower than the long-term average of 12.95 percent observed over the previous two years. Since 2020, Bureau of Labor Statistics data Data indicates that unemployment rates have decreased significantly in Gustine and California since 2020. Gustine’s unemployment rate is higher than the Merced County as a whole average (9.1 percent) but is muchand higher than the statewide average (5.3 percent).

Table D3-5 shows the major employers in Merced County, together with the number of employees per employer, and type of industry. The majority of large employers are located in the City Merced, which is the county’s largest city and the County seat. None of the County’s largest employers are located in Gustine. The City’s largest employers, by City staff estimates, are Saputo (dairy

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Merced County Association of Governments
Merced County Multi-Jurisdictional Housing Element (2024-2032) D3-4
manufacturing), Hillview Packing Company (fruit manufacturing/packing), and Gustine Unified School District. No significant changes in employment trends or new large-scale employers are expected to occur during the planning period.

Table D3-5 Major Employers in Merced County (2024)
Employer Name Number of Employees Location Industry
Costco Wholesale 100-249 Merced Wholesale Clubs
County-Merced-Behavioral Hlth 100-249 Merced Clinics
Dignity Health-Mercy Med Ctr 1,000-4,999 Merced Hospitals Foodmaxx 100-249 Merced Grocers-Retail
Foster Farms 1,000-4,999 Livingston Poultry Processing Plants (mfrs) Golden Valley Health Ctr 500-999 Merced Pharmacies
Golden Valley Health Ctr 100-249 Merced Clinics
Hilmar Cheese Co Inc 500-999 Hilmar Cheese Processors (mfrs) J Marchini & Son Inc 500-999 Le Grand Farming Service
Liberty Packing Co 250-499 Los Banos Packing & Crating Service Live Oak Farms 250-499 Le Grand Fruits & Vegetables-Growers & Shippers Livingston Union School District 250-499 Livingston School Districts Malibu Boats Inc 250-499 Merced Boats-Manufacturers
Memorial Hospital Los Banos 100-249 Los Banos Hospitals Mental Health Svc For Merced 250-49 Merced Mental Health Services Merced County Human Svc 500-999 Merced Government Offices-County Quad/Graphics Inc 500-999 Merced Printers (mfrs)
Scholle 100-249 Merced Packaging Materials-Manufacturers Sensient Natural Ingredients 250-499 Livingston Dehydrating Service (mfrs) University of CA Merced 500-999 Merced Schools-Universities & Colleges Academic Walmart 250-499 Merced Department Stores
Walmart Supercenter 250-499 Atwater Department Stores
Weaver Union School District 100-249 Merced School Districts Western Marketing & Sales 500-999 Atwater Farms
Yosemite Wholesale Warehouse 100-249 Merced Warehouses
Source: California Employment Development Department, Major Employers in Merced County. Accessed November 2024:
https://labormarketinfo.edd.ca.gov/majorer/countymajorer.asp?CountyCode=000047 Table D3-6 shows the employment estimates, average hourly wage, and average annual wage for employment industries in the Merced Metropolitan Statistical Area (MSA) as of May 2023. The occupations offering the lowest wages are food preparation and serving related, healthcare support, farming, fishing, and forestry. Occupations offering the highest wages include Mmanagement, Llegal, and Hhealthcare Ppractitioners.

The largest percentage of employed civilians in Gustine are in health care, manufacturing, and agriculture. While healthcare practitioners’ average higher annual salaries ($107,806) than Merced County’s Area Median Income (AMI), which was $69,106 in 2021, Hhealthcare Ssupport salaries ($36,900) average approximately 53 percent of the AMI. Additionally, average salaries for

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City of Gustine
Housing Needs Assessment
2024-2032 Housing Element D3-5
production ($45,760) and farming, fishing, and forestry ($37,398) fall short of the AMI as well.

Compared to the annual income limits shown on Table D3-6 , it can be assumed that the majority ofmost healthcare practitioners fall in the Aabove Mmoderate-income category, while Cconstruction and Ssales employesworkers fall into the Llow-income category, and Hhealthcare Ssupport employeesworkers fall into the Vvery Llow-income category.

Table D3-6 Occupational Employment and Wages by Major Occupational Group, Merced Metropolitan Area (2023)
Major Occupational Group Mean Hourly Wage Mean Annual Wage Total, all occupations $27.45 $57,096
Management $58.77 $113,073
Business and financial operations $37.87 $78,770
Computer and mathematical $43.64 $90,771
Architecture and engineering $43.00 $89,440
Life, physical, and social science $36.22 $75,338
Community and social service $28.81 $59,925
Legal $54.16 $112,653
Educational instruction and library $36.71 $76,357
Arts, design, entertainment, sports, and media $28.59 $59,467 Healthcare practitioners and technical $51.83 $107,806
Healthcare support $17.74 $36,900
Protective service $29.50 $61,360
Food preparation and serving related $17.87 $37,170
Building and grounds cleaning and maintenance $20.78 $43,222 Personal care and service $19.05 $39,624
Sales and related $21.76 $45,261
Office and administrative support $23.71 $49,317
Farming, fishing, and forestry $17.98 $37,398
Construction and extraction $30.48 $63,398
Installation, maintenance, and repair $30.43 $63,294
Production $22.00 $45,760
Transportation and material moving $22.02 $45,802
Source: U.S. Bureau of Labor Statistics. Occupational Employment and Wages in Merced (May 2023) https://www.bls.gov/regions/west/news-release/occupationalemploymentandwages_merced.htm Income Definitions and Income Limits
The state and Federal governments classify household income into several categories based upon the relationship to the county area median income (AMI), adjusted for household size. The U.S.

Department of Housing and Urban Development (HUD) estimate of AMI is used to set income limits for eligibility in federal housing programs. The income categories include:
 Acutely low-income households, which earn up to 15 percent AMI;  Extremely low-income households, which earn up to 30 percent AMI;

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Merced County Association of Governments
Merced County Multi-Jurisdictional Housing Element (2024-2032) D3-6
 Very low-income households, which earn between 31 and 50 percent AMI;  Low-income households, which earn between 51 and 80 percent AMI; and  Median-income households, which earn 100 percent AMI.

For all income categories, income limits are defined for various household sizes based on a fourperson household as a reference point. Income limits for larger or smaller households are calculated by HUD (See Table D3-7). According to HUD, the AMI for a four-person household in Merced County was $80,300 in 2022.

Table D3-7 HUD Income Limits by Person per Household
Household Size: 1 2 3 4 5 6 7 8
Acutely Low $8,450 $9,650 $10,850 $12,050 $13,000 $14,000 $14,950 $15,900 Extremely Low $16,350 $18,700 $23,030 $27,750 $32,470 $37,190 $41,910 $46,630 Very Low $27,300 $31,200 $35,100 $38,950 $42,100 $45,200 $48,300 $51,450 Low Income $43,650 $49,850 $56,100 $62,300 $67,300 $72,300 $77,300 $82,250 Median Income $56,200 $64,250 $72,250 $80,300 $847,300 $931,500 $99,550 $106,000 Moderate Income $67,450 $77,100 $89,700 $96,350 $104,050 $111,750 $119,450 $127,200 Source: U.S. Department of Housing and Urban Development (HUD), Income Limits, 2022.

The California Department of Housing and Community Development (HCD) uses the income categories shown in Table D3-8 to determine eligibility for state housing programs. HCD’s methodology for calculating AMI is slightly different from HUD’s methodology, and therefore the AMI and income limits vary.

Table D3-8 State of California Income Categories
Income Category Percent of County Area Median Income (AMI) Extremely Low 0-30% AMI
Very Low 31%-50% AMI
Low 51%-80% AMI
Moderate 81%-120% AMI
Above Moderate 120% AMI or greater
Source: California, CA Health & Safety Code § 50093.

Figure D3-1 shows the median household income in Gustine reported in the 2017-2021 ACS. This median income is for all households, regardless of household size. The median household income in Gustine was $51,376 in 2021, which was lower than Merced County ($58,861) and significantly lower than California ($84,097).

City of Gustine
Housing Needs Assessment
2024-2032 Housing Element D3-7
Figure D3-1 Median Household Income
Source: U.S. Census Bureau, ACS17-21 (5-year Estimates), Table B19013.

Table D3-9 compares the median household income by race/ethnicity in 2021. In Gustine, Some Other Race households had the highest median income of $75,689, followed by Two or More Races households with $55,268. This differs from both Merced County and the state statistics, where Asian households have the highest median income. This data is not available for Gustine.

Table D3-9 Median Household Income by Race/Ethnicity (dollars) Jurisdiction
White,
alone
Black or
African
American,
alone
American
Indian
and
Alaskan
Native,
alone
Asian,
alone
Native
Hawaiian
and Other
Pacific
Islander,
alone
Some
Other
Race,
alone
Two or
More
Races,
alone
Hispanic
or Latino,
Any Race
Gustine 42,177 - - - - 75,689 55,268 56,801
Merced
County
60,918 45,573 50,214 71,829 125,500 55,083 56,355 54,635 California 88,616 58,958 66,904 108,477 87,066 63,975 79,777 67,327 Source: U.S. Census Bureau, ACS 17-21 (5-year Estimates), Table B19013.

Overpayment and Housing Cost Burdens
Table D3-10 lists the number of households overpaying for housing by tenure. Generally, renters are more affected by overpayment than owners, though Gustine has similar levels of overpayment across the two categories. HUD defines cost-burdened families as those “who pay more than 30 percent of their income for housing” and “may have difficulty affording necessities such as food, clothing, transportation, and medical care.” A severe rent burden is defined as paying more than 50 percent of one’s income on rent. As shown in Table D3-10, 22.3 percent of total households are overpaying renter-occupied households in Gustine, which is lower than Merced County and California percentages. Owner-occupied overpaying households account for 19.5 percent of total households, which is a higher rate than Merced County and California. $51,376
$58,861
$84,097
$-
$10,000
$20,000
$30,000
$40,000
$50,000
$60,000
$70,000
$80,000
$90,000
Gustine Merced County California
Median Household Income

Merced County Association of Governments
Merced County Multi-Jurisdictional Housing Element (2024-2032) D3-8
Table D3-10 Cost Burdened Households by Tenure
Jurisdiction Owner-Occupied Overpaying Renter-Occupied Overpaying Total Overpaying Gustine 423 483 906
Percent 19.5% 22.3% 41.8%
Merced County 9,611 17,470 27,081
Percent 11.8% 21.4% 33.2%
California 1,904,162 3,030,934 4,935,096
Percent 14.4% 22.9% 37.3%
Source: U.S. Census Bureau, ACS 06-10, 11-15, 17-21 (Five-year Estimates), Table B25091 and B25070.

CHAS data provided by HUD provides information on cost burden based on the HUD Area Median Family Income (HAMFI). This data is shown in Table D3-11 below. While the totals do not align exactly with 2021 ACS data presented above, the CHAS data identifies the level at which cost burdened households are overpaying for housing. As shown, 27.3 percent of cost-burdened households are paying between 30 percent and 50 percent of their income on housing costs.

Further, 9.5 percent of households are spending more than 50 percent of their income on housing.

Based on CHAS data, Gustine has higher rates of moderate cost burden than Merced County and California, but a lower rate of severe cost burden than Merced County and California.

Table D3-11 Overpayment by Tenure
Jurisdiction Moderate Cost Burden >30% to <=50% Severe Cost Burden >50% Total Households Gustine 560 195 2,055
Percent 27.3% 9.5% 100.0%
Merced County 14,710 12,285 80,010
Percent 18.4% 15.4% 100.0%
California 2,632,205 2,427,660 13,044,265
Percent 20.2% 18.6% 100.0%
Source: U.S. Department of Housing and Urban Development, CHAS 2015-19 (5-Year Estimates), Table 7.

D3.6 Household Characteristics
Table D3-12 provides information on household types. Of the 2,169 households in Gustine, 863 are married-couple households with or without children, and 166 are cohabitating couple households with or without children. Approximately half the total households in Merced County and California are married-couple households, though Gustine has a lower percentage of these households at about 40 percent.

City of Gustine
Housing Needs Assessment
2024-2032 Housing Element D3-9
Table D3-12 Households by Type
Jurisdiction
Married-Couple Household Cohabitating Couple Household
Total
Total Children No Children Total Children No Children Households Gustine 863 313 550 166 21 145 2,169
Percent 39.8% 14.4% 25.4% 7.7% 1.0% 6.7%
Merced County 39,912 18,171 21,741 6,862 3,910 2,952 139,044 Percent 48.9% 22.3% 26.6% 8.4% 4.8% 3.6%
California 6,539,445 2,780,272 3,759,173 938,780 338,874 599,906 13,217,586 Percent 49.5% 21.0% 28.4% 7.1% 2.6% 4.5%
Source: U.S. Census Bureau, ACS 17-21 (Five-year Estimates), Table B11012.

D3.7 Large Households
Table D3-13 provides information on large households by tenure. As shown, 9.9 percent of households in Gustine consist of five or more people, which is lower than California and Merced County. In Gustine, owner-occupied five-person households (3.2 percent of total households) and owner-occupied six-person households (3.1 percent) make up the largest percentages of large households. The city has no owner-occupied six-person households or renter-occupied seven-ormore-person households, lower than Merced County and California numbers.

Table D3-13 Large Households by Tenure
Jurisdiction
Total Large
Households
Owner-Occupied
Large Households
Renter-Occupied
Large Households
5-Person 6-Person
7-or-More
Person 5-Person 6-Person
7-or-More
Person
Gustine 513215 69 68 0 19863 17815 0
Percent 17.39.9% 2.33.2% 2.33.1% 0.0% 6.72.9% 6.00.7% 0.0% Merced
County
17,710 4,737 1,952 1,649 5,380 2,184 1,808
Percent 21.7% 5.8% 2.4% 2.0% 6.6% 2.7% 2.2%
California 1,830,468 580,759 246,420 200,281 456,013 199,263 147,732 Percent 13.9% 4.4% 1.9% 1.5% 3.5% 1.5% 1.1%
Source: U.S. Census Bureau, ACS 17-21 (5-year Estimates), Table B25009.

D3.8 Overcrowding
Table D3-14 provides information on overcrowding by tenure in Gustine. The U.S. Census defines an overcrowded unit as one occupied by 1.01 persons or more per room (excluding bathrooms and kitchens). Units with more than 1.5 person per room are considered severely overcrowded. There is a total of 60 overcrowded households in the City, of which 50 percent are owner-occupied households, and 50 percent are renter occupied.

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Merced County Association of Governments
Merced County Multi-Jurisdictional Housing Element (2024-2032) D3-10
Table D3-14 Overcrowding Severity by Tenure
Jurisdiction
Owner-Occupied Renter-Occupied
Total

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

1.0 to 1.5
Occupants
per Room
More than 1.5
Occupants per
Room
Gustine 1,057 30 - 1,112 30 -
Percent 48.7% 1.4% 0.0% 51.3% 1.4% 0.0%
Merced County 42,146 1,766 551 39,472 3,090 1,362
Percent 51.6% 2.2% 0.7% 48.4% 3.8% 1.7%
California 7,335,247 229,637 82,236 5,882,339 453,625 321,169 Percent 55.5% 1.7% 0.6% 44.5% 3.4% 2.4%
Source: U.S. Census Bureau, ACS 06-10, 11-15, 17-21 (5-year Estimates), Table B25014.

D3.9 Special Needs Groups
Within the general population, there are several groups of people who have special housing needs.

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

Seniors
Table D3-15 identifies senior households in Gustine, Merced County, and California. The percentage row identifies the percent of the specified age range out of all owner-occupied or renter-occupied households. There are far more owner-occupied senior households in Gustine (367 total), than renter-occupied senior households (241 total), which is similar to Merced County and California. As shown, seniors between the ages of 65 and 74 make up the largest percentages of owner and renter-occupied households (20.4 percent and 14.9 percent of total households, respectively), consistent with Merced County and California.

Table D3-15 Senior Households by Tenure
Jurisdiction
Owner-Occupied Renter-Occupied
65 to 74 75 to 84 85 and over 65 to 74 75 to 84 85 and over Gustine 216 151 - 166 21 54
Percent 20.4% 14.3% 0.0% 14.9% 1.9% 4.9%
Merced County 7,176 4,232 1,559 3,318 1,216 495
Percent 39.9% 23.5% 8.7% 18.4% 6.8% 2.8%
California 1,386,828 679,546 288,915 501,465 229,153 132,237 Percent 43.1% 21.1% 9.0% 15.6% 7.1% 4.1%
Source: U.S. Census Bureau, ACS 17-21 (5-year Estimates), Table B25007.

Table D3-16 shows the housing cost burdens by elderly family type and tenure in Gustine based on CHAS data (note that the CHAS data defines senior or elderly as age 62 and over, as opposed to the American Community Survey, which reports seniors as age 65 and older). Based on data in this table, of all elderly persons in lower-income categories (less than or equal to 80 percent HAMFI),

City of Gustine
Housing Needs Assessment
2024-2032 Housing Element D3-11

38.1 percent of all senior-owner households and 57.5 percent of all senior-renter households in Gustine had a housing cost burden of 30 percent or greater.

Table D3-16 Overpayment by Tenure among Senior Households Owners Renters
Total
Elderly
Family
Elderly NonFamily Elderly
Family
Elderly NonFamily
Household Income <= 30% HAMFI Extremely Low-Income
TOTAL HOUSEHOLDS <= 30% HAMFI - 20 - 75 95
Number w/ Cost Burden <= 30% - 20 - - 20
Number w/ Cost Burden > 30% to <= 50% - - - - -
Number w/ Cost Burden > 50% - - - 75 75
Percent with Cost Burden >30% HAMFI 0.0% 0.0% 0.0% 100.0% 79.0% Household Income > 30% to <= 50% HAMFI Very Low-Income
TOTAL HOUSEHOLDS > 30% to <= 50% HAMFI - 40 - 25 65
Number w/ Cost Burden <= 30% - 25 - - 25
Number w/ Cost Burden > 30% to <= 50% - 15 - 25 40
Number w/ Cost Burden > 50% - - - - -
Percent with Cost Burden >30% HAMFI 0.0% 38.0% 0.0% 100.0% 62.0% Household Income > 50% to <= 80% HAMFI Low-Income
TOTAL HOUSEHOLDS > 50% to <= 80% HAMFI 210 20 15 25 270 Number w/ Cost Burden <= 30% 25 20 - 25 70
Number w/ Cost Burden > 30% to <= 50% 185 - - - 185
Number w/ Cost Burden > 50% - - 15 - 15
Percent with Cost Burden >30% HAMFI 88.0% 0.0% 100.0% 0.0% 74.0% Household Income > 80% to <= 100% HAMFI
TOTAL HOUSEHOLDS > 80% to <= 100% HAMFI 70 - - - 70
Household Income > 100% HAMFI
TOTAL HOUSEHOLDS > 100% HAMFI 145 20 40 20 225
Total Income <80% HAMFI and Cost Burden > 30% 200 115 315 Percent Income <80% HAMFI and Cost Burden > 30% 38.1% 57.5% 57.5% GRAND TOTAL HOUSEHOLDS 425 100 55 145 725
Elderly family constitutes 2 persons with either or both age 62 and over.

HAMFI = HUD Area Median Family Income
Source: HUD Consolidated Planning / Comprehensive Housing Affordability Strategy (CHAS) database, 2015-2019 estimates, Table 7, accessed 2023. https://www.huduser.gov/portal/datasets/cp.html Table D3-17 summarizes cost burden data for units occupied by senior households. As shown,

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

Further, 33.1 percent are cost burdened by greater than 30 percent and less than or equal to 50 percent, while 12.4 percent are cost burdened by more than 50 percent. There is a higher percentage of senior households cost burdened by over 30 percent in Gustine than in Merced County.

Merced County Association of Governments
Merced County Multi-Jurisdictional Housing Element (2024-2032) D3-12
Table D3-17 Cost Burdened Senior Households
Jurisdiction
Cost Burden
<= 30%
Cost Burden
>30% to <=50%
Cost Burden
>50%
Total Senior
Households
Gustine 395 240 90 725
Percent 54.5% 33.1% 12.4% 100.0%
Merced County 12,080 3,220 2,880 18,180
Percent 66.4% 17.7% 15.8% 100.0%
California 1,963,195 620,335 736,510 3,320,040
Percent 59.1% 18.7% 22.2% 100.0%
Source: U.S. Department of Housing and Urban Development, CHAS 2015-19 (5-Year Estimates), Table 7.

Resources for Senior-Headed Households
The Merced County Housing Authority manages six senior housing complexes, one of which is located in Gustine. As shown in Table D3-18, the Gustine Garden Apartments includes 33 senior rental units available to low-income households. As shown in Table D3-16, there are a total of 200 senior renter households (55 elderly family, 145 elderly non-family), of which 115 are lower income.

Based on this data, there is a gap between lower-income senior renter households and available units of approximately 80 units.

Table D3-18 Inventory of Senior Housing
Housing Development Address City Affordable Units Total Units Gustine Garden Apartments 394 Wallis Avenue Gustine 33 341 Note: All locally assisted or restricted developments may not be included in this list. 1 Affordable housing developments often have one market rate unit included. This is often made available to an on-site manager or other facility employee.

Source: California Housing Partnership, 2023.

Persons with Disabilities (including Developmental Disabilities) Table D3-19 identifies the number of residents with one or more disabilities. In Gustine, 10.3 percent of the total population has one type of disability, while 14.5 percent report two or more disabilities. The total population with a disability is significantly higher in Gustine than Merced County and California averages. Among those with a disability, 41.5 percent have one disability, while 58.5 percent have two or more types of disability.

Table D3-19 Population by Number of Disabilities
Jurisdiction Total
With One Type
of Disability
With two or More
types of Disability No Disability
Gustine 5,990 615 868 4,507
Percent 10.3% 14.5% 75.2%
Merced County 276,304 18,099 17,266 240,939
Percent 6.6% 6.3% 87.2%
California 38,946,377 2,108,406 2,037,095 34,800,876
Percent 5.4% 5.2% 89.4%
Source: U.S. Census Bureau, ACS17-21 (5-year Estimates), Table C18108.

City of Gustine
Housing Needs Assessment
2024-2032 Housing Element D3-13
Table D3-20 summarizes the population with a disability by age. In Gustine, residents aged 18 to 64 years make up the largest population of disabled individuals at 14.2 percent of the total population.

The rate for this group is drastically higher than Merced County (6.6 percent) and California (5.1 percent). The under-18 age group accounts for the smallest percent of those with a disability at 2.6 percent, but this rate is still higher than both Merced County and California.

Table D3-20 Disability by Age for the Total Population
Jurisdiction Total Under 18 Years 18 to 64 Years 65 Years and Older Gustine 5,990 156 849 478
Percent 2.6% 14.2% 8.0%
Merced County 276,304 3,666 18,311 13,388
Percent 1.3% 6.6% 4.9%
California 38,946,377 315,849 1,964,845 1,864,807
Percent 0.8% 5.1% 4.8%
Source: U.S. Census Bureau, ACS 17-21 (5-year Estimates), Table C18108.

Table D3-21 identifies residents with a developmental disability by age. In Gustine, most residents with a developmental disability are under 18 years old, which is consistent with both Merced County and California.

Table D3-21 Developmental Disability by Age
Jurisdiction Under 18 Years 18 Years and Older Total Population with a Disability Gustine 48 28 76
Merced County 1,507 1,287 2,794
California 192,384 185,353 377,737
Source: California Department of Developmental Services, DDS Quarterly Consumer Report, December 2021.

Table D3-22 includes data summarizing the housing status of residents with developmental disabilities. AThe majority of Gustine residents with a developmental disability in Gustine live in the home of a parent, family member, or guardian (75 individuals). Less than 11 residents live in an independent/ supported living facility and no residents live in community care facilities, intermediate care facilities, or foster/family homes. This data highlights reliance on family-based housing and reflects broader challenges faced by individuals with developmental disabilities, such as limited affordable and accessible housing options and the need for supportive services to enable independent living. Housing Program 6 addresses these needs by amending the Zoning Code to allow Residential Care Facilities with seven or more residents in all zones that permit residential uses to reduce constraints in providing essential housing and services to individuals with disabilities.

Further, Housing Program 8 helps address this need through expanding affordable housing options through the facilitation of regulatory concessions and incentives such as expedited and streamlined project application review for housing for persons with disabilities or developmental disabilities.

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Merced County Association of Governments
Merced County Multi-Jurisdictional Housing Element (2024-2032) D3-14
Table D3-22 Developmental Disability by Residence
Residence Type City of Gustine Merced County California Home of Parent/Family/Guardian 75 2,937 309,381
Independent/Supported Living <11 232 27,881
Community Care Facility 0 80 23,728
Intermediate Care Facility 0 60 6,188
Foster/Family Home 0 <11 8,288
Other 0 <11 4,792
Total >75 >3,309 380,258
Source: California Department of Developmental Services, DDS Quarterly Consumer Report, January 2022.

The Supplemental Security Income (SSI) program, administered by the U.S. Social Security Administration, provides income to persons with disabilities. It can be a proxy for shows the number of persons with disabilities who may have housing needs by disability status, asbecause receipt of SSI benefits because of their may indicate low household incomes. As of December 2021, 10,190 SSI recipients in Merced County were receiving benefits because they were blind or disabled1.

Resources Persons with Disabilities
While there are no specific public housing resources that are accessible exclusively to people with disabilities in Gustine, there are 33 total public housing units, all of which are senior housing units and are available to low- and moderate-income households, including those with a disability. Of the 1,483 residents with a disability in Gustine, only 478 are seniors. This results in a significant resource gap of 1,450 units for residents with disabilities. Additionally, while there are no disability resource centers in Gustine, there are several organizations based in Merced that serve the entire county:
 California Children Services (CCS): Provides coverage for specialized medical care and rehabilitation for children with eligible medical conditions (260 East 15th Street, Merced, California, 95341, (209) 381-1114)
 Central Valley Regional Center: Administers developmental screenings for autism, epilepsy, cerebral palsy, and intellectual disabilities and provides care coordination to supportive services (3172 M Street, Merced, California, 95348, (209) 723-4245)  Challenged Family Resource Center: Provides support and advocacy training for families with children with disabilities (827 West 20th Street, Merced, California, 95340, (209) 385-5314)  Deaf and Hard of Hearing Service Center, Inc. (DHHSC): A private, non-profit social service agency that serves individuals who are deaf, hard of hearing, deaf-blind, and late-deafened, their families, friends, and community service providers. (865 W. 18th Street, Merced, California, 95340, (209) 230-9910)
 Exceptional Parents Unlimited: Provides supportive services for families and children with disabilities. (4440 N First Street, Fresno, California, 93726, (559) 229-2000) 1 Source: U.S. Social Security administration. SSI Recipients by State and County, 2021. https://www.ssa.gov/policy/docs/statcomps/ssi_sc/2021/ca.html Note: Although these figures can give a sense of the proportion of the population with different types of disabilities, a much smaller proportion of the population may actually require specially adapted housing to accommodate disabilities.)

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City of Gustine
Housing Needs Assessment
2024-2032 Housing Element D3-15
Housing Program 8 directs the City to amend the Zoning Code to facilitate the development of affordable housing for special needs households, such as households with persons with a disability, including expedited and streamlined project application review for housing for persons with disabilities. Through this program, the City will support affordable and accessible housing options and the need for supportive services to enable independent living will be supported.

Large Households
Table D3-23 provides information on large households by tenure in Gustine, Merced County, and California. See Section D3.7, Large Households, for more information. As shown, there are 137 owner-occupied large households and 78 renter-occupied large households. There is a smaller percentage of large households in Gustine (9.9 percent) than Merced County (21.7 percent) and California (13.9 percent).

Table D3-23 Large Households by Tenure
Jurisdiction
Total
Households
Owner-Occupied
Large Households
Renter-Occupied
Large Households
5-Person 6-Person
7-or-More
Person 5-Person 6-Person
7-or-More
Person
Gustine 2,9169 69 68 - 63 15 -
Percent 2.33.2% 2.33.1% 0.0% 6.72.9% 6.00.7% 0.0%
Merced County 81,618 4,737 1,952 1,649 5,380 2,184 1,808 Percent 5.8% 2.4% 2.0% 6.6% 2.7% 2.2%
California 13,217,586 580,759 246,420 200,281 456,013 199,263 147,732 Percent 4.4% 1.9% 1.5% 3.5% 1.5% 1.1%
Source: U.S. Census Bureau, ACS 16-20 (5-year Estimates), Table B25009.

Resources for Large Households
Units with four or more bedrooms are the primary housing resource for large households.

Table D3-24 compares the number of large households to the number of large units. Units with five or more rooms provide housing options for large households and work to lessen overcrowding. As shown, there are 124 units in Gustine with five or more bedrooms but 215 large households, leaving a resource gap of 91 units. However, considering all large units with four or more bedrooms (627) the need for adequate housing for large households in the City would be met, with additional units available.

Table D3-24 Large Households and Units
Jurisdiction Total Households
Large Households
(5 or more persons) Total Units
Large Units
(4 bedrooms)
Large Units
(5 or more bedrooms)
Gustine 2,9169 513215 2,302 503 124
Percent 17.39.9% 23.2% 5.4%
Merced County 81,618 17,710 86,767 17,656 3,175
Percent 21.7% 21.6% 3.7%
California 13,217,586 1,830,468 14,328,539 2,373,268 627,903 Percent 13.8% 18.0% 4.4%
Source: U.S. Census Bureau, ACS 17-21 (5-year Estimates), Tables DP04.

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Merced County Association of Governments
Merced County Multi-Jurisdictional Housing Element (2024-2032) D3-16
Housing Program 8 directs the City to amend the Zoning Code to facilitate the development of affordable housing for special needs households, such as large households.

Female-Headed Households
Table D3-25 identifies single female-headed households with their own children under age 18. The table values do not include female-headed households with unrelated dependents. Gustine has a total of 15 single female-headed households with their own children under 18, representing 0.7 percent of total households. This is lower than Merced County (7.8 percent) and California (4.7 percent).

Table D3-25 Single Female-Headed Households with Own Children Jurisdiction Total Households Single Female-Headed Households* Percent Gustine 2,169 15 0.7%
Merced County 81,618 6,365 7.8%
California 13,217,586 614,747 4.7%
Notes: Single Female-Headed Households with own children under age 18, does not include unrelated dependents.

Source: U.S. Census Bureau, ACS 17-21 (5-year Estimates), Table B11012.

Table D3-26 compares female-headed households by tenure. As shown, there is a larger percentage of renter-occupied female-headed households (61.6 percent) than owner-occupied households (38.4). Both Merced County and California follow a similar trend.

Table D3-26 Female-Headed Family Households by Tenure
Jurisdiction Owner-Occupied Renter-Occupied Total
Gustine 208 334 542
Percent 38.4% 61.6%
Merced County 4,569 10,129 14,698
Percent 31.1% 68.9%
California 713,100 996,675 1,709,775
Percent 41.7% 58.3%
Source: U.S. Census Bureau, ACS17-21 (5-year Estimates), Table B17010.

Resources for Single-Parent and Female-Headed Households Resources for lower-income, female-headed households include existing affordable housing units in the city as well as rental assistance provided through the County’s Housing Choice Voucher (HCV) program. The Housing Authority of the County of Merced currently administers the HCV Program, a federal rent subsidy program under the Department of Housing and Urban Development. The program provides rent subsidy to families in privately owned existing rental units in Merced County.

Below is a list of local agencies dedicated to assisting parents:
 First 5 Merced County is dedicated to improving the lives of Merced County’s young children, including Gustine, and their families through a comprehensive system of education, health services, and other crucial programs. The Strong Families programs enable families to raise their children in a safe, stable, and nurturing home. These programs work with families, educators, health, and social services providers to support parents and guardians.

City of Gustine
Housing Needs Assessment
2024-2032 Housing Element D3-17
 Ace Overcomers Program, committed to helping teens and adults overcome the effects of adverse childhood experiences (ACEs).
 Merced County Office of Education, providing educational services to children and families including childcare subsidies to offset the costs of care.  Sierra Vista Child and Family Services, committed to supporting the community by providing mental health services to children and youth ages from birth to 21 years old.  Maternal, Child, and Adolescent Health (MCAH) Services, providing information and services to mothers and children.

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

Table D3-27 identifies extremely low-income households by tenure in Gustine. Renter-occupied extremely low-income households (160) make up 62 percent of total extremely low-income households. This is lower than Merced County (74 percent) and California (71 percent). Owneroccupied extremely low-income households (100) comprise 38 percent of total extremely lowincome households. This is higher than Merced County (26 percent) and California (29 percent).

There are 260 total extremely low-income households in Gustine, making up approximately 12.7 percent of total households in the City. This is lower than Merced County (14 percent) and California (15 percent).

Table D3-27 Extremely Low-Income Households by Tenure
Jurisdiction
Income <=30% HAMFI
Owner-Occupied Renter-Occupied Total ELI Households Total Households

Gustine
100 160 260 2,055
Percent 4.9% 7.8% 12.7% 100.0%
Merced County 2,940 8,540 11,480 80,010
Percent 3.7% 10.7% 14.3% 100.0%
California 592,010 1,427,405 2,019,415 13,217,586
Percent 4.5% 10.8% 15.3% 100.0%
Source: U.S. Housing and Urban Development, CHAS 2015-19 (5-Year Estimates), Table 7.

Table D3-28 summarizes cost burdens among extremely low-income households. As shown, all extremely low-income renter-occupied households are experiencing a moderate or severe housing

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Merced County Association of Governments
Merced County Multi-Jurisdictional Housing Element (2024-2032) D3-18
cost burden. In addition, 80 of the 100 extremely low-income renter-occupied households (80 percent) are experiencing a moderate or severe housing cost burden. This is similar to Merced County (80 percent) and lower than California (88 percent). In Gustine, 32.7 percent of extremely low-income households are renter-occupied households with a moderate cost burden. This is higher than in Merced County (13.3 percent) and California (10.7 percent). ELI households also generally experience more housing problems compared to other income categories. “Housing problems” typically include overpayment, overcrowding, or substandard housing conditions. Approximately 75 percent of total ELI households experience any housing problem, while approximately 60 percent of lLow-income households and approximately 18 percent of mModerate- and Aabove mModerateincome households experience any housing problem.

Table D3-28 Extremely Low-Income Households Overpaying by Tenure Jurisdiction
Owner-Occupied Renter-Occupied
Total ELI
Households
Cost
Burden
<30%
Moderate
Cost
Burden
30%-50%
Severe
Cost
Burden
>50%
Cost
Burden
<30%
Moderate
Cost
Burden
30%-50%
Severe
Cost
Burden
>50%
Gustine 20 - 80 - 85 75 260
Percent 7.7% 0.0% 30.8% 0.0% 32.7% 28.8% 100.0%
Merced County 615 595 1,730 1,075 1,530 5,935 11,480
Percent 5.4% 5.2% 15.1% 9.4% 13.3% 51.7% 100.0%
California 117,890 92,945 381,175 172,130 216,880 1,038,395 2,019,415 Percent 5.8% 4.6% 18.9% 8.5% 10.7% 51.4% 100.0%
Source: US Housing and Urban Development, CHAS 2015-19 (5-Year Estimates).

Resources for Extremely Low-Income Households
The Housing Authority of the County of Merced currently administers 2,705 Housing Choice Vouchers.2
Families who are eligible must meet the income guidelines set by the U.S. Department of Housing and Urban Development, must pass criminal background checks, must not owe the Housing Authority dollars for any past client history, and comply with completing forms and presenting verifications and documentation that the Housing Authority requires, including immigration status.

Housing Program 11 directs the City to expand awareness of and connect extremely low-income and low-income residents with housing assistance programs, including the Merced County Housing Authority HCV program.

In addition to the HCV program, the Housing Authority also administers Emergency Housing Vouchers (EHV). In order to be eligible for an EHV, an individual must meet one of the four eligibility criteria: 1. Homeless; 2. At risk of homelessness; 3. Fleeing, or attempting to flee, domestic violence, dating violence, sexual assault, stalking, or human trafficking; 4. Recently homeless and for whom providing rental assistance will prevent the family’s homelessness or having high risk of housing instability.3

2 Housing Authority of Merced County, Housing Choice Voucher, http://www.merced-pha.com/housing-choice-voucher/ (accessed June 2023).
3 Housing Authority of Merced County, Emergency Housing Vouchers, http://www.merced-pha.com/emergency-housing-vouchers-ehvfrequently-asked-questions-faq/ (accessed June 2023).

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City of Gustine
Housing Needs Assessment
2024-2032 Housing Element D3-19
Table D3-29 includes an inventory of publicly assisted affordable housing in Gustine. As shown, there are 33 affordable units in the City. These units serve senior households making less than 80 percent of the area median income and may be available to extremely low-income households.

Based on the identified need (260 extremely low-income households) there is a need for additional units affordable to extremely low-income households in the city.

Table D3-29 Inventory of Public Assisted Complexes, Gustine Name Address City Zip Affordable Units
Gustine Garden Apartments 394 Wallis Avenue Gustine 95322 33 Note: All locally assisted or restricted developments may not be included in this list.

Source: California Housing Partnership, 2023.

Housing Program 11 directs the City to support the Merced County Housing Authority in meeting the housing needs of extremely low-income households and spread awareness of available resources to residents, including publishing an inventory of affordable housing on the City’s website.

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

Farmers and farmworkers are the cornerstone of the larger food sector, which includes the industries that provide farmers with fertilizer and equipment;, farms to produce crops and livestock;, and industries that process, transport, and distribute food to consumers. Farmworker households are often compromised of extended family members or single male workers.

Farmworkers make up the majority of the agricultural labor sector and include individuals whose primary income is earned through either seasonal or permanent agricultural labor.

Farmworkers are traditionally defined as persons whose primary incomes are earned through permanent or seasonal agricultural labor. Migrant farmworkers as a group consist of individuals who travel not only across county lines but also from one major geographic region of California to another to find work. Travel for work prevents them from returning to their primary residence every evening. Many migrant farmworkers are single males, most of whom are married and migrate alone to support their families who live at home baseelsewhere. However, there are many migrant families who have more than one employed member.

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

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Merced County Association of Governments
Merced County Multi-Jurisdictional Housing Element (2024-2032) D3-20
in existing single family rental units in older neighborhoods that offer relatively low-cost housing and its central location in relation to farmland.

According to a study conducted by the University of California, Merced, farmworker households frequently experience high poverty rates, severe overcrowding, and poor housing conditions, with a majority renting and living in substandard environments due to their typically lower incomes and face a disproportionate need for more affordable housing. Undocumented farm workers face an increased lack of housing resources due to their ineligibility for certain government-subsidized programs. These housing issues, combined with the demanding and poorly compensated nature of farmwork, often lead to negative health outcomes and exacerbate respiratory and infectious diseases.4
The U.S. Department of Agriculture provides countywide farmworker population data generated by the Census of Agriculture. The most recent Census of Agriculture data (2017) identified 15,566 farmworkers in Merced County.5
Table D3-30 provides 2021 ACS data for the total population of residents working in the agriculture, forestry, fishing and hunting, and mining industries (including farmworkers) in Gustine and Merced County. Gustine had 235 workers in these categories in 2021, representing 1.9 percent of the total population across Merced County.

Table D3-30 Farmworker Population
Jurisdiction
Population in Agriculture, Forestry, Fishing and Hunting, and Mining Industries (Including Farmworkers)
Gustine 235
Percent 1.9%
Total Merced County 12,326
Source: U.S. Census Bureau, ACS17-21 (5-year Estimates), Table C24050.

The USDA Census of Agriculture reported the presence of 1,397 farms with a total of 15,945 workers in Merced County in 2017 (see Table D3-31). The majority of the farmworkers were seasonal, working fewer than 150 days per year.

Table D3-31 Farmworkers in Merced County by Days Worked (2017) Farm Type Number of Farms Number of Workers
150 Days or More (Year-Round)
Small Farms (less than 10 workers per farm 512 1,535
Large Farms (10 or more workers per farm) 291 7,853
Subtotal 803 9,388
Fewer than 150 Days (Seasonal)
Small Farms (less than 10 workers per farm) 438 1,346
Large Farms (10 or more workers per farm) 156 5,211
4 Farmworker Health in California. UC Merced. August 2022. https://clc.ucmerced.edu/sites/clc.ucmerced.edu/files/page/documents/fwhs_report_2.2.2383.pdf?_gl=1*1rg0e9w*_ga*MTU3Njc2MD MzNS4xNzA4OTk2Nzgx*_ga_TSE2LSBDQZ*MTcwODk5Njc4MC4xLjAuMTcwODk5Njc4MC42MC4wLjA 5 U.S. Department of Agriculture, Census of Agriculture, https://www.nass.usda.gov/AgCensus/ accessed June 2023, accessed June 2023.

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City of Gustine
Housing Needs Assessment
2024-2032 Housing Element D3-21
Farm Type Number of Farms Number of Workers
Subtotal 594 6,557
Total 1,397 15,945
Source: USDA. 2022 Census of Agriculture - County Data. https://www.nass.usda.gov/Publications/AgCensus/2022/Full_Report/Volume_1,_Chapter_2_County_Level/California/st06_2_007_007 .pdf
Resources for Farmworkers
While there are no farm labor housing projects in Gustine, Los Banos has a migrant center approximately 22 miles away. It is operated by the Housing Authority of Merced County and offers 48 temporary housing to migrant farmworkers between April and November. To be eligible for migrant housing, households must earn a minimum of $5,752.50 annually from farm labor employment. As reported in Table D3-30 above, there were more than 235 farmworkers living in Gustine in 2021. Despite the housing opportunities listed above, there is a significant gap in housing resources for farmworkers within the City.

Housing Program 6 directs the City to amend the Zoning Code to permit employee housing for six or fewer employees as a single-family use and employee housing containing up to 36 beds or 12 singlefamily units as an agricultural use in compliance with the Employee Housing Act. In addition, Housing Program 8 directs the City to allow expedited and streamlined project application review for housing for farmworkers. Along with these programs, Program 11 will assist the development of housing to meet the needs of extremely low-, very low-, and low-income households through programs such as housing choice vouchers, public housing, project-based voucher programs, and migrant housing centers through the Housing Authority of Merced County.

Persons Experiencing Homelessness
Figure D3-2 shows households experiencing homelessness by type between 2005 to 2022. The Continuum of Care (CoC) is the organization responsible for coordinating and implementing a system to meet the needs of populations and subpopulations experiencing homelessness within a given geographic area. As shown, 2005 had the highest reported number of households (1,101) by the Merced County CoC, the majority of which were unsheltered. Data for 2020 indicates that 559 households experienced homelessness in Merced County, including 313 of those counted as unsheltered. These numbers increased from 2020 to 2022, at which point over 680 households experienced homelessness in Merced County.

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Merced County Association of Governments
Merced County Multi-Jurisdictional Housing Element (2024-2032) D3-22
Figure D3-2 Homelessness by Type Over Time, Households, Merced County Source: U.S. HUD, CoC Homeless Populations and Subpopulations Reports (2005, 2010, 2015, 2020, 2022).).

Point in time count data is reported for Merced County, including Gustine. Table D3-32 provides the most recent (2023) point-in-time count for individual residents experiencing homelessness in Merced County. As of 2023, there are no individuals reported as experiencing homelessness in Gustine.

Table D3-32 Homelessness by Type (2023)
Jurisdiction Sheltered Unsheltered Total
Merced County 394 390 784
Gustine 0 0 0
Percent 0% 0% 0%
Source: Merced City and County Continuum of Care, Point-in-Time Count (2023).

Figure D3-3 identifies homelessness by type by race in Merced County for the year 2023. Most of the homeless population was reported as sheltered. In terms of race, 69 percent reported as white, 17 percent as Black or African American, one percent as Asian, three percent as American Indian or Alaska Native, less than one percent as Native Hawaiian or Other Pacific Islander, and 10 percent as multiple races.
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City of Gustine
Housing Needs Assessment
2024-2032 Housing Element D3-23
Figure D3-3 Homelessness by Type by Race (2023)
Source: Merced City and County Continuum of Care, Point-in-Time Count (2023).

The 2023 Merced County CoC point in time count data also considers ethnicity, as shown in Table D3-33. Among those counted, 332 of 784 individuals (42.3 percent) identified as Hispanic or Latino.

Table D3-33 Homelessness by Ethnicity (2023)
Ethnicity Sheltered Unsheltered Total
Hispanic or Latino (any race) 186 146 332
Percent 23.7 18.6 42.3
Other 208 244 452
Percent 26.5 31.1 57.7
Source: Merced City and County Continuum of Care, Point-in-Time Count (2023).

Resources for Persons Experiencing Homelessness
Although there are no emergency shelters or transitional housing units for the unhoused in Gustine, there is a permanent supportive housing center in Los Banos operated by Merced County Mental Health. The Pacheco Place-Project Hope Westside is located approximately 22 miles from Gustine and offers an eight-unit apartment complex for those who are chronically homeless and have a qualifying mental illness.

The lack of resources for the unhoused in Gustine indicates a need for supportive and accessible housing for those experiencing homelessness.

Housing Program 1 directs the City to collaborate with other jurisdictions in the region to address housing and supportive services unhoused individuals. In addition, Housing Program 6 directs the

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Merced County Association of Governments
Merced County Multi-Jurisdictional Housing Element (2024-2032) D3-24
City to amend the Zoning Code to allow transitional and supportive housing, emergency shelters byright, in compliance with state law.

D3.10 Housing Stock Characteristics
A community’s housing stock is defined as the collection of all housing units located within the jurisdiction. The characteristics of the housing stock, including growth, type, age, condition, tenure, vacancy rates, housing costs, and affordability are important in determining the housing needs for the community. The following sections detail the housing stock characteristics of Gustine to identify how well the current housing stock meets the needs of current and future residents.

Housing Growth
Table D3-34 summarizes the growth in the housing stock in Gustine by providing the total number of units constructed each decade from 1980 and 2020. The largest growth rate occurred between 1980 and 1990 with a 25 percent change during this ten-year period. Growth then slowed down between 1990 and 2000 before rising again between 2000 to 2010 to 18.4 percent. Between 2010 and 2020, however, the number of housing units in the City only increased by 9.6 percent.

Table D3-34 Total Housing Units Over Time (1980 to 2020) Jurisdiction 1980 1990 2000 2010 2020
Gustine 1,266 1,583 1,763 2,087 2,287
Percent Change 25.0% 11.4% 18.4% 9.6%
Source: U.S. Census Bureau, Census 1980 (STF1:T65), 1990 (STF1:H1), 2000 (SF1:H1); ACS 16-20 (5-year Estimates), Table B25001.

Housing Type and Tenure
Table D3-35 identifies the total housing units by type in Gustine, Merced County, and California. In Gustine, single detached homes make up most of the housing stock, with 76.9 percent of total units.

This is more than Merced County with 73.8 percent and California with 57.6 percent. The second most common housing type is housing with three to four units, providing 8.6 percent of the total units in the City. This is higher than Merced County (4.8 percent) and California (5.4 percent). The third most common housing type in Gustine is mobile homes (3.9 percent), of which there is a higher rate in Merced County (6.7 percent) but a similar rate in California (3.6 percent).

City of Gustine
Housing Needs Assessment
2024-2032 Housing Element D3-25 Table D3-35 Total Housing Units by Type Jurisdiction Total 1,
Detached
1,
Attached 2 3 or 4 5 to 9 10 to 19 20 to 49
50 or
more
Mobile
Home
Boat, RV,
Van, etc.

Gustine 2,302 1,771 73 54 199 66 20 21 9 89 0
Percent 76.9% 3.2% 2.3% 8.6% 2.9% 0.9% 0.9% 0.4% 3.9% 0.0% Merced County 86,767 64,045 1,908 2,785 4,172 3,876 1,634 801 1,649 5,775 122 Percent 73.8% 2.2% 3.2% 4.8% 4.5% 1.9% 0.9% 1.9% 6.7% 0.1% California 14,328,539 8,248,814 1,031,608 340,666 777,600 842,158 721,058 713,636 1,121,470 514,764 16,765 Percent 57.6% 7.2% 2.4% 5.4% 5.9% 5.0% 5.0% 7.8% 3.6% 0.1% Source: U.S. Census Bureau, ACS17-21 (5-year Estimates), Table B25024.

Merced County Association of Governments
Merced County Multi-Jurisdictional Housing Element (2024-2032) D3-26
Table D3-36 indicates housing units by tenure. In Gustine, 48.7 percent of units are owner occupied compared to 51.3 percent renter occupied. In contrast, Merced County and California have higher percentages of owner-occupied units than renter-occupied housing units.

Table D3-36 Housing Units by Tenure
Jurisdiction Total Owner-Occupied Renter-Occupied
Gustine 2,169 1,057 1,112
Percent 48.7% 51.3%
Merced County 81,618 42,146 39,472
Percent 51.6% 48.4%
California 13,217,586 7,335,247 5,882,339
Percent 55.5% 44.5%
Source: U.S. Census Bureau, ACS17-21 (5-year Estimates), Table B25042.

Vacancy Rate
Table D3-37 provides data on vacancy status by type for the total vacant units. All of Gustine’s vacant units (133) were categorized as “other vacant” type units in 2021. Gustine’s proportion of total vacant units (5.8 percent) is similar to Merced County (5.8 percent) but is lower than the California average (7.8 percent).

City of Gustine
Housing Needs Assessment
2024-2032 Housing Element D3-27 Table D3-37 Vacancy Status by Type for Total Vacant Unit Jurisdiction Total Vacant
Units For Rent
Rented, Not
Occupied For Sale Only
Sold, Not
Occupied
For Seasonal,
Recreational, or
Occasional Use
For Migrant
Workers Other Vacant
Gustine 133 0 0 0 0 0 0 133 Percent 5.8% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 100.0% Merced County 5,149 1,298 112 377 553 556 202 2,051
Percent 5.9% 25.2% 2.2% 7.3% 10.7% 10.8% 3.9% 39.8% California 1,110,953 240,840 53,537 73,319 54,970 370,908 2,992 314,387 Percent 7.8% 21.7% 4.8% 6.6% 5.0% 33.4% 0.3% 28.3% Source: U.S. Census Bureau, ACS17-21 (5-year Estimates), Table B25004.

Merced County Association of Governments
Merced County Multi-Jurisdictional Housing Element (2024-2032) D3-28
Housing Unit Size
Table D3-38 provides housing unit size data for Gustine, Merced County, and California. In Gustine, three-bedroom units (39.4 percent) are the most common housing type, followed by four-bedroom units (23.2 percent) and two-bedroom (21.2 percent). This is similar to countywide and statewide data, though Merced County has a larger stock of three-bedroom units than the state or Gustine.

Table D3-38 Housing Unit Size
Jurisdiction Total Studio 1 Bedroom 2 Bedroom 3 Bedroom 4 Bedroom 5 of More
Bedroom
Gustine 2,169 135 94 459 854 503 124
Percent 6.2% 4.3% 21.2% 39.4% 23.2% 5.7%
Merced County 81,618 1,883 4,320 16,306 38,451 17,656 3,002 Percent 2.3% 5.3% 20.0% 47.1% 21.6% 3.7%
California 13,217,586 564,387 1,691,491 3,539,857 4,451,995 2,373,268 596,588 Percent 4.3% 12.8% 26.8% 33.7% 18.0% 4.5%
Source: U.S. Census Bureau, ACS17-21 (5-year Estimates), Table B25042.

Age and Condition of Housing Stock
Table D3-39 provides data on the total occupied housing units by year built. The city experienced the most growth between 2000 to 2009. During this period, 480 units were constructed, representing 22.1 percent of the housing stock at the time. Merced County saw similar growth, with 16,856 units being constructed between 2000 to 2009. In contrast, the largest percentage of units were constructed in the 1970s, with 17.4 percent. Notably, in Gustine, only 95 units have been constructed since 2010. Of the total 2,169 occupied housing units, 1,111 are more than 40 years old.

This accounts for half (51.2 percent) of the total occupied housing units today.

City of Gustine
Housing Needs Assessment
2024-2032 Housing Element D3-29 Table D3-39 Total Occupied Housing Units by Year Built Jurisdiction Total
2020 or
later
2010 to
2019
2000 to
2009
1990 to
1999
1980 to
1989
1970 to
1979
1960 to
1969
1950 to
1959
1940 to
1949
1939 or
earlier
Gustine 2,169 0 95 480 320 163 450 324 75 93 169 Percent 0.0% 4.4% 22.1% 14.8% 7.5% 20.7% 14.9% 3.5% 4.3% 7.8% Merced County 81,618 44 3,229 16,856 11,846 11,034 14,718 7,585 7,356 5,007 3,943 Percent 0.1% 4.0% 20.7% 14.5% 13.5% 18.0% 9.3% 9.0% 6.1% 4.8% California 13,217,586 15,877 634,508 1,451,946 1,438,264 1,980,874 2,295,943 1,728,569 1,755,123 753,750 1,162,732 Percent 0.1% 4.8% 11.0% 10.9% 15.0% 17.4% 13.1% 13.3% 5.7% 8.8% Source: U.S. Census Bureau, ACS 17-21 (5-year Estimates), Table B25036.

Merced County Association of Governments
Merced County Multi-Jurisdictional Housing Element (2024-2032) D3-30
Table D3-40 provides information on substandard housing units. In Gustine, there are no units lacking kitchen facilities or lacking plumbing facilities. By contrast, 0.4 percent of units in Merced County and California lack plumbing facilities, and 0.4 percent in Merced County and 1.1 percent in California lack kitchen facilities. Although 1,111 units are 40 years or older, they have not been identified as needing replacement or rehabilitation; however, Housing Program 10 will be implemented to ensure that the Code Enforcement Division tracks areas where rehabilitation needs are heightened.

The City’s Code Enforcement Division estimates that noapproximately four units require major rehabilitation and that there are no units beyond repair.

Table D3-40 Substandard Housing Units
Jurisdiction Total Lacking Plumbing Facilities Lacking Kitchen Facilities Gustine 2,826169 0 0
Percent 0% 0%
Merced County 81,618 298 357
Percent 0.4% 0.4%
California 13,217,586 53,643 149,252
Percent 0.4% 1.1%
Source: U.S. Census Bureau, ACS17-21 (5-year Estimates), Table B25049.

Housing Costs
Median Home Sale Prices
Table D3-41 provides information on the median housing value in Gustine from 1980 to 2020. As shown, prices rose steeply from 1980 to 1990, experiencing a large increase of 89 percent in value.

Increases in value slowed in the next decade to a growth rate of 16 percent, before increasing to

64.9 percent between 2000 and 2010 and 47.1 percent between 2010 and 2020. A similar trend was seen across other jurisdictions in Merced County, where the smallest increase in values generally occurred between 1990 and 2000 and the largest value increase occurred between 2000 and 2010.

According to Zillow, the average house prices were $302,759 in 2020 and $416,131 in 2024.

Table D3-41 Median Housing Value Over Time (1980 to 20210) Jurisdiction 1980 1990 2000 2010 2020
Gustine $50,800 $96,000 $111,400 $183,700 $273,500
Percent Change 89.0% 16.0% 64.9% 32.8%
Merced $57,700 $90,300 $103,200 $223,500 $251,500
Percent Change 56.5% 14.3% 116.6% 11.1%
Atwater $56,000 $89,400 $99,900 $214,600 $251,100
Percent Change 59.6% 11.7% 114.8% 14.5%
Dos Palos $44,300 $66,900 $88,500 $179,800 $232,700
Percent Change 51.0% 32.3% 103.2% 22.7%
Livingston $43,400 $71,900 $92,300 $244,900 $231,100
Percent Change 65.7% 28.4% 165.3% -6.0%
Los Banos $49,000 $110,100 $138,200 $248,900 $315,500
Percent Change 124.7% 25.5% 80.1% 21.1%

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Housing Needs Assessment
2024-2032 Housing Element D3-31
Jurisdiction 1980 1990 2000 2010 2020
Unincorporated County $53,100 $90,100 $110,900 $241,000 $268,800 Percent Change 69.7% 23.1% 117.3% 10.3%
Note: Data are not inflation-adjusted to 2022 dollars.

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

Table D3-42 provides information on the median housing value in Gustine since 2017. As shown, housing values in Gustine have steadily risen over this time period, with the greatest increase in value occurring between 2017 and 2018 (23.7 percent) and the smallest change in value occurred between 2018 and 2019. Other jurisdictions have experienced a similar trend, where the largest increase in median housing value occurred between 2017 and 2018, followed by a modest increase between 2018 and 2019.

Table D3-42 Median Housing Value from 2017 to 2021
Jurisdiction 2017 2018 2019 2020 2021
Gustine $157,600 $195,000 $222,700 $273,500 $322,300
Percent Change - 23.70% 14.20% 22.80% 17.80%
Merced $185,700 $212,100 $237,500 $251,500 $268,600
Percent Change - 14.20% 12.00% 5.90% 6.80%
Atwater $179,400 $207,800 $229,400 $251,100 $265,200
Percent Change - 15.80% 10.40% 9.50% 5.60%
Dos Palos $134,000 $183,500 $194,500 $232,700 $252,800
Percent Change - 36.90% 6.00% 19.60% 8.60%
Livingston $187,500 $222,400 $229,900 $231,100 $242,400 Percent Change - 18.60% 3.40% 0.50% 4.90%
Los Banos $226,700 $265,500 $293,400 $315,500 $340,800
Percent Change - 17.10% 10.50% 7.50% 8.00%
Merced County $196,200 $229,500 $252,700 $268,800 $288,400 Percent Change - 17.00% 10.10% 6.40% 7.30%
Note: Data are not inflation-adjusted to 2022 dollars.

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

D3.11D3.1 Distribution of Owner-Occupied Units
Table D3-39 compares data on the number of all owner-occupied housing units by race in Gustine, Merced County, and California. In Gustine, most owner-occupied units are occupied by residents that identify as white (74.2 percent). This percentage is greater than in Merced County (59.4 percent) and higher than in California (41.6 percent).

Considering ethnicity, 39.6 percent of all owner-occupied units are occupied by Hispanic or Latino residents of any race. This percentage is lower than in Merced County (43.5 percent) but higher than in California (24.1 percent). Given that 57.1 percent of the entire population of Merced identifies as Hispanic or Latino of any race, this group is underrepresented in the housing market.

Merced County Association of Governments
Merced County Multi-Jurisdictional Housing Element (2024-2032) D3-32
Table D3-39 Owner Occupied Units by Race
Jurisdiction White Black
American
Indian
and
Alaska
Native Asian
Native
Hawaiian
and Other
Pacific
Islander
Some
Other
Race
Two or
More
Races
Hispanic or
Latino of any
Race
Gustine 784 - 0 0 0 154 119 408
Percent 74.2% 0.0% 0.0% 0.0% 0.0% 14.6% 11.3% 39.6%%
Merced
County 25,012 1,182 436 2,801 43 9,588 3,084 18,848
Percent 59.4% 2.8% 1% 6.7% 0.1% 22.8% 7.3% 43.5%
California 4,660,216 287,300 53,643 1,150,895 18,216 633,875 531,102 1,807,053 Percent 62.1% 3.8% 0.7% 15.3% 0.2% 8.4% 7.1% 24.1%
Source: U.S. Census Bureau, ACS 17-21 (5-year Estimates), Table B25003.

D3.12 Housing Rent Pricess
According to the 2017-2021 ACS, the median contract rent in Gustine was $930 per month (Figure D3-4), which was slightly higher than the median rent for Merced County ($923) and significantly lower than California ($1,547).

Figure D3-4 Median Contract Rent
Source: U.S. Census Bureau, ACS 17-21 (5-year Estimates), Table B25058.

Table D3-43 below provides data on median gross rent from 1980 to 2020. Median gross rent has grown increased from $210 per month in 1980 to $1,039 in 2020. Between 1980 and 1990 rents in the City increased grew by 96.7 percent. From 1990 to 2000, rents increased grew at a slower rate of 23.5 percent, before increasing by 54.3 between 2000 and 2010 and by 32.0 percent between 2010 and 2020.
$930 $923
$1,547
$-
$200
$400
$600
$800
$1,000
$1,200
$1,400
$1,600
$1,800
Gustine Merced County California
Median Contract Rent

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City of Gustine
Housing Needs Assessment
2024-2032 Housing Element D3-33
Table D3-43 Median Gross Rent Over Time, Gustine
1980 1990 2000 2010 2020
Gustine $210 $413 $510 $787 $1,039
Percent Change 96.7% 23.5% 54.3% 32.0%
Source: Source: U.S. Census Bureau, Census 1980(ORG STF3), 1990(STF3), 2000(SF3); ACS 06-10, 16-20 (5-year Estimates), Table B25064 Table D3-44 provides an overview of median rent for rental housing by number of bedrooms based on 2021 ACS data. The median rent data shows the estimated rent in Gustine is $1,074 for a onebedroom, $1,006 for a two-bedroom, and $1,590 for a three-bedroom. There is no median rent data for studios or four-bedroom units for Gustine. Rents in Gustine are more than those in Merced County and less than statewide.

Table D3-44 Median Rent by Number of Bedrooms
Jurisdiction Studio 1 Bedroom 2 Bedroom 3 Bedroom 4 Bedroom Gustine - $1,074 $1,006 $1,590 -
Merced County $708 $795 $989 $1,234 $1,548
California $1,293 $1,450 $1,737 $1,948 $2,326
Source: U.S. Census Bureau, ACS17-21 (5-year Estimates), Table B25031.

D3.11 Distribution of Owner-Occupied Units
Table D3-45 compares data on the number of all owner-occupied housing units by race in Gustine, Merced County, and California. In Gustine, most owner-occupied units are occupied by residents that identify as white (74.2 percent). This percentage is greater than in Merced County (59.4 percent) and higher than in California (41.6 percent).

Considering ethnicity, 39.6 percent of all owner-occupied units are occupied by Hispanic or Latino residents of any race. This percentage is lower than in Merced County (43.5 percent) but higher than in California (24.1 percent). Given that 57.1 percent of the entire population of Merced identifies as Hispanic or Latino of any race, this group is underrepresented in the housing market.

Table D3-45 Owner Occupied Units by Race
Jurisdiction White Black
American
Indian
and
Alaska
Native Asian
Native
Hawaiian
and Other
Pacific
Islander
Some
Other
Race
Two or
More
Races
Hispanic or
Latino of any
Race
Gustine 784 - 0 0 0 154 119 408
Percent 74.2% 0.0% 0.0% 0.0% 0.0% 14.6% 11.3% 39.6%%
Merced
County 25,012 1,182 436 2,801 43 9,588 3,084 18,848
Percent 59.4% 2.8% 1% 6.7% 0.1% 22.8% 7.3% 43.5%
California 4,660,216 287,300 53,643 1,150,895 18,216 633,875 531,102 1,807,053 Percent 62.1% 3.8% 0.7% 15.3% 0.2% 8.4% 7.1% 24.1%
Source: U.S. Census Bureau, ACS 17-21 (5-year Estimates), Table B25003.

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Merced County Multi-Jurisdictional Housing Element (2024-2032) D3-34
D3.13D3.12 Housing Affordability
Housing affordability levels are calculated using the median household income. Affordable monthly housing costs are calculated by taking 30 percent of a household’s annual income and dividing it by 12 months. The rental utility allowance is a fixed number provided for each household size by the Merced County Housing Authority. Taxes, insurance, and homeowners’ association fees are calculated as 20 percent of the monthly affordable cost. Affordable monthly rent is calculated by subtracting affordable monthly housing costs and the rental utility allowance. Affordable home prices assume a 30-year fixed mortgage with a seven percent interest rate and 10 percent down payment. Taxes, insurance, and homeowners’ association fees only apply to homeowners.

Table D3-46 shows the maximum amount that a household can pay for housing each month without incurring a cost burden (overpayment) for Gustine. A summary of each income category’s ability to pay for housing is provided below the table.

Table D3-46 Housing Affordability Matrix – Gustine (2021) Annual
Income
Limits
Affordable
Monthly
Housing Costs
Rental Utility
Allowance
(2020)
Taxes, Insurance,
Homeowners
Association Fees
Affordable
Rent
Affordable
Home Price
Extremely Low Income (0-30% AMI)
1-Person (Studio) $10,950 $274 $192 $16 $82 $36,575
2-Person (1 BR) $12,500 $313 $233 $16 $80 $41,752
3-Person (2 BR) $14,050 $351 $236 $23 $115 $46,929
4-Person (3 BR) $15,600 $390 $257 $27 $133 $52,107
5-Person (4 BR) $16,850 $421 $279 $28 $142 $56,282
Very Low Income (30-50% AMI)
1-Person $18,250 $456 $192 $53 $264 $60,958
2-Person $20,850 $521 $233 $58 $288 $69,643
3-Person $23,450 $586 $236 $70 $350 $78,327
4-Person $26,050 $651 $257 $79 $394 $87,011
5-Person $28,100 $703 $279 $85 $424 $93,859
Low Income (50-80% AMI)
1-Person $29,150 $729 $192 $107 $537 $97,366
2-Person $33,350 $834 $233 $120 $601 $111,395
3-Person $37,500 $938 $236 $140 $702 $125,256
4-Person $41,650 $1,041 $257 $157 $784 $139,118
5-Person $45,000 $1,125 $279 $169 $846 $150,308
Median Income (80-100% AMI)
1-Person $36,450 $911 $192 $144 $719 $121,749
2-Person $41,650 $1,041 $233 $162 $808 $139,118
3-Person $46,850 $1,171 $236 $187 $935 $156,487
4-Person $52,100 $1,303 $257 $209 $1,046 $174,023
5-Person $56,250 $1,406 $279 $225 $1,127 $187,884

City of Gustine
Housing Needs Assessment
2024-2032 Housing Element D3-35
Annual
Income
Limits
Affordable
Monthly
Housing Costs
Rental Utility
Allowance
(2020)
Taxes, Insurance,
Homeowners
Association Fees
Affordable
Rent
Affordable
Home Price
Moderate Income (100-120% AMI)
1-Person $43,750 $1,094 $192 $180 $902 $170,488
2-Person $50,000 $1,250 $233 $203 $1,017 $194,843
3-Person $56,250 $1,406 $236 $234 $1,170 $219,199
4-Person $62,500 $1,563 $257 $261 $1,306 $243,554
5-Person $67,500 $1,688 $279 $282 $1,409 $263,038
Source: U.S. Census Bureau, ACS17-21 (5-year Estimates), Table B19113.

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

Extremely low-income households have an annual income of $10,950 or below for a one-person household and $16,850 or below for a five-person household. Extremely low-income households cannot afford market-rate rental or ownership housing in Gustine.

Very- Low-income Households
Very low-income households earn between 31 and 50 percent of the county median income – up to $18,250 for a one-person household and up to $28,100 for a five-person household in 2022. A very low-income household can generally afford homes offered at prices between $60,958 and $93,895, adjusting for household size. After deductions for utilities, a very low-income household can afford to pay approximately $264 to $424 in monthly rent, depending on household size. Given the cost of housing in Gustine, very low-income households could not afford to purchase a home or rent an adequately sized unit.

Low-income Households
Low-income households earn between 51 and 80 percent of the county median income – up to $29,150 for a one-person household and up to $45,000 for a five-person household in 2022. A lowincome household can generally afford homes offered at prices between $97,366 and $150,308, adjusting for household size. After deductions for utilities, a low-income household can afford to pay approximately $537 to $846 in monthly rent, depending on household size. Finding appropriately sized market-rate rental housing can be challenging to households in this income group.

Median-Income Households
Median-income households earn between 80 and 100 percent of the county’s median income – up to $36,450 for a one-person household and up to $56,250 for a five-person household in 2022. The affordable home price for a median-income household ranges from $121,749 to $187,884. After deductions for utilities, a one-person median-income household could afford to pay up to $719 in rent per month and a five-person low-income household could afford to pay as much as $1,127.

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

Merced County Association of Governments
Merced County Multi-Jurisdictional Housing Element (2024-2032) D3-36
Moderate-Income Households
Moderate-income households earn between 100 and 120 percent of the county’s median income – up to $43,750 for a one-person household and up to $67,500 for a five-person household in 2022.

The maximum affordable home price for a moderate-income household is $170,488 for a oneperson household and $263,038 for a five-person family. Moderate-income households in Gustine could afford to purchase the median priced home; however, finding an affordable adequately sized home could present a challenge for households earning incomes at the lower end of the middle/upper category. The maximum affordable rent payment for moderate-income households is between $902 and $1,409 per month. Appropriately sized market-rate rental housing is generally affordable to households in this income group.

Workforce Housing
Federal guidelines define workforce housing as housing that is affordable to households earning incomes within the range of 60 to 120 percent of the median income (in Gustine, that range is $31,260 to $62,520 for a household of four). A broader definition of workforce housing is housing that is affordable to people who work in Merced County. A four-person household with an annual income of $52,100 could afford monthly rent of $1,046 for a three-bedroom housing unit and a home purchase price of $174,023 without being burdened by housing costs. As noted in Table D3-44, the average monthly rental price for a three-bedroom unit is $1,590, significantly higher than what is affordable to this income group.

Cost Burden
Table D3-47 and Table D3-48 identify cost-burdened households by tenure over time in Gustine.

There has been a decrease in the number of owner-occupied cost-burdened households from 329 households in 2010 to 213 in 2020. In contrast, cost-burdened renter-occupied households saw a significant increase from 212 units in 2010 to 420 units in 2020.

Table D3-47 Cost Burdened Owner-Occupied Households Over Time Jurisdiction 1980 1990 2000 2010 2020
Gustine 56 123 188 329 213
Percent 119.6% 52.9% 75% -35.3%
Note: Data are not inflation-adjusted to current 2023 dollars.

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

Table D3-48 Cost Burdened Renter-Occupied Households Over Time Jurisdiction 1980 1990 2000 2010 2020
Gustine 74 166 201 212 420
Percent 124.3% 21.1% 5.5% 98.1%
Note: Data are not inflation-adjusted to current 2022 dollars.

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

CHAS data provided by HUD provides information on cost burden by income category based on the HUD Area Median Family Income (HAMFI). This data is included in Table D3-49 below. While the totals do not align exactly with 2020 ACS data presented above, the CHAS data gives insight into which income categories are currently experiencing costs burdens in the city. As shown, lowerPage 166 of 593 City of Gustine
Housing Needs Assessment
2024-2032 Housing Element D3-37
income households experience a high rate of cost burden greater than 30 percent, including 240 of 260 extremely low-income households, 135 of 210 very low-income households, and 305 of 460 low-income households.

Table D3-49 Cost Burden by Income and Tenure
Row Labels
Owner
occupied
Renter
occupied
Grand
Total
Household income is <= to 30% of HAMFI (extremely low income) 100 160 260 Housing cost burden is <= to 30% 20 - 20
Housing cost burden > 30% but <= to 50% - 85 85
Housing cost burden is > 50% 80 75 155
Income is greater than 30% but <= to 50% of HAMFI (very low income) 90 120 210 Housing cost burden is <= to 30% 75 - 75
Housing cost burden is > 30% but <= to 50% 15 95 110
Housing cost burden is > 50% - 25 25
Income is > 50% but <= to 80% of HAMFI (low income) 245 215 460 Housing cost burden is <= to 30% 60 95 155
Housing cost burden is > 30% but <= to 50% 185 105 290
Housing cost burden is > 50% - 15 15
Income is > 80% <= to 100% of HAMFI (median income) 145 120 265 Housing cost burden is <= to 30% 120 100 220
Housing cost burden is > 30% but <= to 50% 25 20 45
Housing cost burden is > 50% - - 0
Income is greater than 100% of HAMFI (moderate income) 670 185 855 Housing cost burden is <= to 30% 640 185 825
Housing cost burden is > 30% but <= to 50% 30 - 30
Housing cost burden is > 50% - - 0
Grand Total 1,250 800 2,050
Source: U.S. Department of Housing and Urban Development, Comprehensive Housing Affordability Strategy (CHAS) dataset, 2015-19 (5-Year Estimates), Table 6, Table 7.

D3.14D3.13 Assisted Housing Units
Assisted housing units are those that are restricted for use by occupants with limited household incomes. These units are assisted under federal, state, and/or local programs, including HUD programs, state and local bond programs, former redevelopment agency (RDA) programs, density bonus, or direct assistance programs.

At-Risk Housing Units
The California Housing Partnership maintains an affordable housing database to monitor changes in affordable housing and to identify units or housing developments that are at risk of converting to market-rate uses. Assisted units in the preservation data base are classified by the following risk categories:

Merced County Association of Governments
Merced County Multi-Jurisdictional Housing Element (2024-2032) D3-38
 Low Risk: affordable housing units that are at-risk of converting to market rate in ten+ years and/or are owned by a large/stable non-profit, mission-driven developer.  Moderate Risk: affordable housing units that are at-risk of converting to market rate in the next five to ten years that do not have a known overlapping subsidy that would extend affordability and are not owned by a large/stable non-profit, mission-driven developer.  High Risk: affordable housing units that are at-risk of converting to market rate in the next one to five years that do not have a known overlapping subsidy that would extend affordability and are not owned by a large/stable non-profit, mission-driven developer.

Table D3-50 shows assisted units in Gustine by estimated affordability end date. As shown, there are 33 assisted units in the City, none of which are at risk of conversion by 2033.

Housing Program 9 directs the City to preserve housing units that are deed restricted as affordable housing for lower-income households by monitoring and maintaining a database on all subsidized units in the city and maintaining annual contact with property owners of affordable housing.

City of Gustine
Housing Needs Assessment
2024-2032 Housing Element D3-39 Table D3-50 Inventory of Public Assisted Complexes – Gustine Name Address City Zip Affordable
Units
Total
Units
Active
Program(s)
Estimated
Affordability End
Year/Date Risk Level
Gustine Garden Apartments 394 Wallis Avenue Gustine 95322 33 34 LIHTC; USDA 2069 Low Note: All locally assisted or restricted developments may not be included in this list. Source: California Housing Partnership, Publicly Assisted Housing Units, 2023.

Merced County Association of Governments
Merced County Multi-Jurisdictional Housing Element (2024-2032) D3-40
Funding Sources for Assisted Housing
HUD Section 8 Program
Under the HUD Section 8 program, which is administered by the Housing Authority of the County of Merced, participating building owners are entitled to receive HUD Fair Market Rents (FMRs) for units with Section 8 contracts. For Section 8 units, HUD makes up the difference between 30 percent of a household’s monthly income and the FMRs.

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

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

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

City of Gustine
Housing Constraints Analysis
2024-2032 Housing Element D4-1
D4 Housing Constraints Analysis
Constraints to the development of adequate housing include market, governmental, infrastructure, and environmental factors. These constraints may result in housing that is not affordable to lowand moderate-income households and may render residential construction economically infeasible for developers. Constraints to housing production significantly impact households with low and moderate incomes and special needs.

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

The following chapter outlines non-governmental, governmental, environmental and infrastructure constraints to housing and was used in the development of specific policies and actions included in Chapter D7, Housing Plan, to remove barriers to housing and to incentivize housing production, specifically targeting housing production at all income levels and housing for persons with special needs.

D4.1 Summary of Local Housing Constraints
 The costs associated with developing housing are increasing, and the availability of financing due to recent trends of rising interest rates make it increasingly difficult for people to buy a home or build new housing. There is a lack of federal, state, and local funding, and the funding that is available is increasingly competitive.
 Several of Gustine’s development regulations, including height, setback, and density requirements are not sufficiently flexible. Height restrictions for multi-family developments, large setback requirements, and low density allowances potentially constrain the development of a variety of housing types.
 The minimum open space requirements for multi-family housing projects with more than five units are considerable. This could potentially constrain the development of multi-family housing in the city.
 The City’s Accessory Dwelling Unit (ADU) Ordinance is not in compliance with state law as it does not allow the development of ADUs in all residential zones.  Gustine’s development review and impact fees are much higher than in other small cities in the region.

D4.2 Non-Governmental Constraints
The availability of housing is affected by a complex set of interrelated market factors including, but not limited to, cost of land, cost of construction, and availability of financing. These factors contribute to determining a new home’s sale price or the rents required to make a project feasible.

Merced County Association of Governments
Merced County Multi-Jurisdictional Housing Element (2024-2032) D4-2
Non-governmental constraints include factors outside of direct governmental control that directly impact housing prices. The cost of construction and the availability of financing contribute to the cost of housing and can hinder the production of housing. The following analysis accounts for these non-governmental constraints.

D4.2.1 Land Costs
The cost of land can impede the production of housing. Land costs are influenced by many variables, including land scarcity and developable density (both of which are indirectly controlled through governmental land use regulations), location, site constraints, and the availability of public utilities.

Costs associated with the acquisition of land include the market price of raw land and the cost of holding land throughout the development process. These costs can account for as much as half of the final sales prices of new homes in very small developments or in areas where land is scarce.

Among the variables affecting the cost of land are its location, its amenities, the availability of public services, and the financing arrangement made between the buyer and seller. According to Stephens & Borrelli Real Estate, as reported in the 2019 Housing Element,the typical single-family lot (6,000 to 8,000 square feet) with improvements sold for $49,000. At the time this analysis was conducted, no land was listed for sale in Gustine.

Table D4-1 provides the average price per acre for land sold between January 2021 and December 2022 in Gustine. The average price per acre for land sales was $448,859. All vacant lots sold between were less than 10 acres in size and in areas zoned single-family residential.

Table D4-1 Sold Land Prices – Gustine
Lot Size Average Price per Acre (Listed)
Less than 10 acres $448,859*
10 or more acres N/A
Average $/acre $448,859
Source: Zillow, Inc., 2024.
*Note: One property was sold multiple times from 2021-2022. For the purposes of this analysis the sale price of $479,524/acre was used in the calculation of the average price per acre.

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

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

Recommended Action
None required.

City of Gustine
Housing Constraints Analysis
2024-2032 Housing Element D4-3
D4.2.2 Construction Costs
Construction costs can be broken down into two primary categories: materials and labor. A major component of the cost of housing is the cost of building materials, including wood and wood-based products, cement, asphalt, roofing materials, and pipe. The availability and demand for such materials affect prices for these goods.

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

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

Table D4-2 shows the estimated cost of constructing a basic 1,500 square foot single-family home to be $300,252.19 in incorporated areas of the county and $243,977.58 in unincorporated areas. This estimate includes construction costs such as materials, labor, and equipment costs, but does not include the price of land, development impact fees, administrative costs, or developer profit.

Table D4-2 Estimated Construction Cost, Gustine
Item Cost
Material $180,151.32
Labor $114,095.83
Equipment $6,005.04
Total $300,252.19
Notes: Based on average costs of lots and units sold in 2022 and 2023. Typical 6,000 sq. ft. residential lot and 1,500 sq. ft. single-family unit; 20 percent administrative costs and developer profit.

Source: Zillow, Inc, 2023; Mintier Harnish., 2023.

Table D4-3 shows the estimated typical development costs in Gustine for a single-family home, assumed to be 1,600 square feet, and a 10-unit multi-family development with 800 square foot units. This includes the price of land, site improvement costs, construction costs, and permit and development impact fees; however, this does not include financing or marketing costs by the developer. As shown in the table below, the typical cost of an individual single-family development is an estimated $333,893, while the development cost of an apartment unit is an estimated $169,390.
1 Central Valley Voice, City of Merced Affordable Housing Project Update, February 22, 2023, https://centralvalleyvoice.com/city-ofmerced-secures-31-million-in-state-funding-for-affordable-housing/ (accessed June 2023).

Merced County Association of Governments
Merced County Multi-Jurisdictional Housing Element (2024-2032) D4-4
Table D4-3 Estimated Construction Cost
Cost Type Single-Family1 Multi-Family2
Site Improvement Cost $8,000 $20,000
Construction Cost $267,790 $1,198,400
Permit and Impact Fees $58,103 $475,500
Total Cost $333,893 $1,693,900
Cost per Unit $333,893 $169,390
(1) Assumed to be a 1,600 sq. ft. single-family home.
(2) Assumed to be a 10-unit multi-family complex of 800 sq. ft. units. (3) Land price based on average price per square foot provided by the City at $300 per square foot There is little that municipalities can do to mitigate the impacts of high construction costs, apart from reducing the number of local amendments to uniform building codes that unnecessarily increase construction costs without significantly adding to health, safety, or construction quality.

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

Recommended Action
None required.

D4.2.3 Availability of Financing
Mortgage interest rates have a large influence over housing affordability. Higher interest rates increase a homebuyer’s monthly payment and decrease the range of housing that a household can afford. Lower interest rates result in a lower cost and lower monthly payments for the homebuyer.

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

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

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

City of Gustine
Housing Constraints Analysis
2024-2032 Housing Element D4-5
for the private sector, for-profit developers, and market-rate housing to meet the housing needs of all community members.

Affordable Housing Financing
A description of available funding sources for affordable development is provided in Chapter D3, Housing Needs Assessment.

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

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

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

Conventional loans are made by the private sector (banks, mortgage companies, etc.) and are not guaranteed or insured by the U.S. government. Conversely, government-backed loans, such as those issued by the Federal Housing Administration, Department of Veterans Affairs, and the Rural Housing Services/Farm Service Agency, are completely or partially insured by the U.S. government. Within the county, 8,028 of the applications received were for conventional loans and 2,732 were for government backed loans. As discussed in Chapter 3, Regional Housing Constraints Analysis, 37.0 percent of the conventional loans originated, and 12.6 percent of the applications were denied. Additionally, 10.7 percent of the government backed loans originated and 3.1 percent of the applications were denied.

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

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

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

Merced County Association of Governments
Merced County Multi-Jurisdictional Housing Element (2024-2032) D4-6
Construction Financing Timing
The timing between project approval and requests for building permits affects project viability.

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

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

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

Recommended Action
The City will implement Housing Program 14 to support homeownership opportunities and homebuying education, particularly for racial and ethnic groups underrepresented in the homebuying market. This includes maintaining existing local programs such as the Homebuyer Assistance Program as well as state and federal programs.

D4.2.4 Requests for Lower Development Densities
In Gustine, requests for development at densities below anticipated densities are not common. The City spoke with one developer interested in developing lower density than permitted. However, the City has no plans to reduce planned densities. The development approval of such projects at densities lower than maximum allowed densities is often driven by market preferences for the inclusion of certain project features, and are not necessarily due to any singular code requirement.

D4.3 Governmental Constraints
Although local governments have little influence on market factors such as interest rates, local policies and regulations can impact where, how much, and what type of residential development is built. Land use controls, site improvement requirements, fees and exactions, and permit processing procedures, among other policies and regulations, may constrain the maintenance, development, and improvement of housing.

D4.3.1 Land Use Controls
Land use controls provided in the Gustine General Plan and Zoning Code influence housing production in several ways. The permitted and conditionally permitted uses in each zone guide new development and provide both developers and the public with an understanding of how vacant land will develop in the future. This includes the density of development that will occur within a particular zone, the compatibility of planned uses in each area, and the range and type of buildings and uses that will be located throughout Gustine.

City of Gustine
Housing Constraints Analysis
2024-2032 Housing Element D4-7
D4.3.1.1 General Plan
The Gustine General Plan provides policies and programs to guide development in the City. The City last updated the General Plan in 2002; however, the Land Use Map was updated in 2012, and the Housing Element was updated in 2019. The City ensures that all goals and policies contained within the Housing Element are consistent with the goals and policies set forth in all other elements of the General Plan. The Gustine General Plan contains the following residential land use designations:
 Residential Estate: 1.0 to 2.0 units per acre
 Low Density Residential: 2.0 to 6.0 units per acre
 Medium Density Residential: 6.0 to 10.0 units per acre  Medium-High Density Residential: 10 to 15.0 units per acre  Planned Development: 1.0 to 6.0 units per acre
 Mobile Home Park Zone: Up to 12.0 units per acre
Conclusion
The General Plan includes six residential land use designations with a density range from 1.0 to 15.0 dwelling units per acre. However, to provide capacity for affordable multi-family housing development, based on the default density standard as define by the California Department of Housing and Community Development (HCD), the City should provide a minimum of one multifamily or mixed-use designation that allows at least 20 dwelling units per acre. The current densities are not sufficient to provide capacity for affordable housing development. In addition, allowed maximum densities are not consistent between the General Plan and Zoning Code. The R-3 zone is not consistent with the corresponding General Plan land use designation of medium-high density residential. The Land Use Element establishes the medium-high density residential land use designation with an allowed density of 10 to 15 dwelling units per acre, while the Zoning Code establishes the R-3 zone with an allowed density of 10 to 20 units per acre.

Recommended Action
Revise the allowed maximum densities established in the General Plan to include at least one land use designation with a density of at least 20 dwelling units per acre and amend the General Plan to ensure consistency between the General Plan Zoning Code. The City will implement Housing Program 7 to revise the General Plan to include a minimum of one multi-family or mixed-use designation that allows at least 20 dwelling units per acre.

D4.3.1.2 Zoning Code
The City regulates the type, location, density, and scale of residential development primarily through the Zoning Code, as well as specific plan development codes. A zone is assigned to every parcel in the city and the Zoning Code identifies compatible uses. In general, the City’s zoning regulations are designed to carry out the policies of the Gustine General Plan by classifying and regulating the uses of land and structures within the City, consistent with the General Plan. The Zoning and Subdivision Code is adopted to protect and to promote the public health, safety, comfort, convenience, prosperity, and general welfare of residents and businesses in the city. More specifically, the purposes of the Zoning and Subdivision Code are to:
 Provide standards and guidelines for the continuing orderly growth and development of the city that will assist in protecting the rural character and community identity of Gustine;

Merced County Association of Governments
Merced County Multi-Jurisdictional Housing Element (2024-2032) D4-8
 Create a comprehensive and stable pattern of land uses upon which to plan transportation, water supply, sewerage, energy, and other public facilities and utilities;  Minimize automobile congestion through pedestrian-oriented development, compact community form, safe and effective traffic circulation, and adequate on- and off-street parking facilities; and
 Ensure compatibility between different types of development and land uses.

The City’s Zoning Code allows residential uses in the following zones:
 Residential Estate (R-E): The R-E zone is intended to provide areas that are appropriate for largelot, single-family residential development along with limited agricultural uses. The maximum allowable density is two dwelling units per acre. The R-E zone is consistent with and implements the Residential Estate Zone land use designation of the General Plan.  Single-Family Residential (R-1): The R-1 zone is intended to provide areas appropriate for neighborhoods of detached single-family homes and related, compatible uses. The maximum allowable density is two to six dwelling units per acre. The R-1 zone is consistent with and implements the Low-Density Residential land use designation of the General Plan.  Medium Density Residential (R-2): The R-2 zone is intended to provide areas appropriate for neighborhoods with a mixture of housing types, including detached single-family homes, zero lot line homes, duplexes, and other related, compatible uses. The maximum allowable density is 10 dwelling units per acre. The R-2 zone is consistent with and implements the Medium Density Residential land use designation of the General Plan.
 Multiple Residential (R-3): The R-3 zone is intended to provide areas appropriate for a variety of housing types, including small-lot single-family housing, and various types of multi-family housing (for example, duplexes, triplexes, and townhouses). The City revised the Zoning Code in 2019 to increase the allowable density in the R-3 zone from 15 to 20 dwelling units per acre. The R-3 zone is not consistent with and implements the Residential - Medium/High Density land use designation of the General Plan, which has an allowed density of 10 to 15 dwelling units per acre.
 Residential Professional (R-4): The R-4 zone is a specialized zone that allows all the residential uses allowed in the R-3 Zone, plus commercial and professional uses. Development standards for residential uses in this zone are the same as standards for the R-3 zone.  Planned Development (P-D): The P-D zone is intended to provide a process for development of greenfield areas within the Ccity limits and the Sphere of Influence that are intended for the development of new neighborhoods. As noted by the General Plan, this use combines residential development densities to allow for a broad range of housing options, while trying to eliminate "cookie-cutter" housing. The P-D zone is also intended to provide for new neighborhoods that are based upon traditional neighborhood development (TND) design features. The P-D zone is consistent with and implements the Planned Development land use designation of the General Plan. The maximum allowable density for this zone is six units per gross acre.

In Gustine, minimum residential lot sizes are required in some zones. Table D4-4 provides the minimum lot size by zone.

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City of Gustine
Housing Constraints Analysis
2024-2032 Housing Element D4-9
Table D4-4 Minimum Lot Size
District Lot Area
R-E 15,000 square feet
R-1 6,000 square feet
R-2 7,500 square feet (1)
R-3 7,500 square feet (1)
R-4 7,500 square feet (1)
PD 7,500 to 15,000
(1) A condominium, townhome, or planned development project may be subdivided with smaller parcels for ownership purposes, with the minimum lot area requirement determined through the subdivision review process, provided that the overall development site complies with the lot area requirements of this Chapter, and the total number of dwellings is in compliance with the maximum density established by underlying General Plan designation.

Source: Gustine Zoning Code
Conclusion
The City’s Zoning Code provides for a range of densities. However, as discussed in Section D4.3.1.1 General Plan, the R-3 zone is not consistent with the corresponding General Plan land use designation of medium-high density residential.

Recommended Action
The City will implement Housing Program 2 to revise the General Plan to include a minimum of one multi-family or mixed-use designation that allows 20 dwelling units per acre, to ensure consistency with the zoning districts established in the City’s Zoning Code.

D4.3.2 Residential Development Standards
Table D4-5 shows the development standards for residential zones. The minimum parcel area for residential zones ranges from 6,000 square feet to 15,000 square feet. Maximum site coverage ranges from 35 percent to 60 percent of the lot area, depending on the zone.

The front setback requirement is 20 feet for all R-1, R-2, and R-3 , and R-4 zones and 30 feet for R-E and P-D zones. The interior side setback requirement is 20 feet for R-E and P-D zones and 5 feet for R-1, R-2, R-3 and R-4 zones. The street side setback is 25 feet for R-E and P-D zones, and 15 feet for R-1, R-2, R-3, and R-4 zones. Rear setback requirement is 20 feet for R-E and P-D zones; 10 feet for the R-1 zone; and 15 feet for R-2, R-3, and R-4 zones.

The maximum allowed height is 30 feet in the R-E, R-1, R-2, and P-D zones and is 35 feet in the R-3 and R-4 zones. Height requirements for ADUs are the same for all residential zones and depend on the type of ADU and the number of stories of the ADU. Maximum density ranges from two2 units per acre in the R-E zone to 20 units per gross acre in the R-3 zone. The maximum height of a building that the City can allow is limited because the City only has a fire truck that can service 35-foot buildings. A 35-foot building can accommodate three stories, and the number of units that can be accommodated in a 35-foot building depends on other development standards as well as the size of the unit.

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Merced County Association of Governments
Merced County Multi-Jurisdictional Housing Element (2024-2032) D4-10
Table D4-5 Residential Development Standards
Zone
Minimum
Parcel
Area
(sq. ft.)
Minimum Setback (in feet)
Maximum
Height
(feet)
Maximum
Height
(Accessory
Dwelling
Unit)
Maximum
Lot
Coverage
(percent of
lot)
Maximum
Density
Front (du/acre)
Street
Side
Interior
Side Rear
R-E 15,000 30 25 20 202 30 Single story:
may not
exceed 16
feet or one
story.

Two-story:
may not
exceed height
of primary
dwelling.
35 2
R-1 6,000 20 15 5 103 30 40 6
R-2 7,500 20 15 5 15 30 50 10
R-3 7,500 20 15 5 15 35 60 20
R-4 7,500 20 15 5 15 35 60 20
P-D 7,500 to
15,0001
30 25 20 202 30 35 6
(1) A condominium, townhome, or planned development project may be subdivided with smaller parcels for ownership purposes, with the minimum lot area requirement determined through the subdivision review process, provided that the overall development site complies with the lot area requirements of this Chapter, and the total number of dwellings is in compliance with the maximum density established by underlying General Plan designation.
(2) 1,000 sq. ft. left uncovered on rear 1/3 of lot.
(3) 800 sq. ft. left uncovered on rear 1/3 of lot.

Source: Gustine Zoning Code, Adopted February 25, 2022
Conclusion
Development standards related to parcel area and site coverage do not constrain residential development. However, limiting maximum height to thirty-five35 feet in multi-family zones is a potential constraint to affordable housing development. The City should provide an opportunity for minor modifications to height restrictions for developments with an affordable component. Setback requirements could be considered a constraint, as setbacks of 20 to 30 feet can significantly limit the developable area of smaller lots. In addition, the maximum density in any zone is 20 units per acre in the R-3 and R-4 zone, which provides limited opportunity for projects with densities that can accommodate lower-income housing projects (which is 20 units per acre based on state guidelines).

Recommended Action
The City will allow flexibility in development standards to ensure sites can develop at maximum densities anticipated in site inventory as part of Program 2: Adequate Sites for RHNA and Monitoring of No Net Loss and Program 6: Zoning Code Amendments. Revise the Zoning Code to allow minor modifications to height restrictions for developments with an affordability component and to revise setback requirements to allow greater flexibility for higher density housing development, particularly on smaller lots. The City will implement Housing Program 6 to make these revisions to the Zoning Code. The City has also identified sites to rezone to allow housing by-right, making it easier to build housing within the city. The City will implement Housing Programs 2 and 7 to rezone sites within the Site Inventory to establish densities appropriate for low-income housing.

D4.3.2.1 Parking
According to the Terner Center for Housing Innovation at UC Berkeley, parking can cost $25,000 to $75,000 per space to construct. However, given the age of data and the increased cost of land and

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City of Gustine
Housing Constraints Analysis
2024-2032 Housing Element D4-11
construction costs discussed above, the costs per parking space are likely much higher.2 Parking provided in underground or structured parking facilities, or if required to be covered or enclosed, can significantly increase the cost of housing and could affect the feasibility of various housing projects in the city. In addition, requirements for parking space locations and maximum distances from dwelling units may also increase the cost of housing and affect the feasibility of housing projects. Requiring less parking not only reduces the project budget but can allow for more space to build additional housing units.

While Gustine does not have any spatial constraints to parking and that would necessitate underground or structured parking facilities, covered or enclosed parking requirements can contribute to increased housing costs that potentially constrain affordable residential development.

Single-family units and mobile homes are required to provide covered parking. Article 9 Glossary of the Zoning Code specifies that garages and carports meet the requirement for covered parking. The Zoning Code does not specify that a driveway for a residential use would meet the requirement for an off-street parking space. However, the Zoning Code does not include any regulations that would preclude a residential driveway from serving as the required off-street parking for a residential use as long as off-street parking is not located within a required setback area.

Gustine’s parking requirements for residential uses are summarized in Table D4-6.

Table D4-6 Residential Parking Requirements
Residential Use Required Parking Spaces
Single family units 2 covered spaces per unit
Multi-family dwelling Studio or 1 bedroom unit 1 per unit 2 or 3 bedroom unit 2 per unit
Guest parking 1 guest space per 4 units
Multi-family dwelling
in a mixed-use project
Studio or 1 bedroom unit 1 per unit
2 or 3 bedroom unit 2 per unit
Guest parking 1 guest space per 4 units
Mobile homes Individual mobile home 1 covered space for each unit Mobile home park 1 covered space for each unit plus 0.5 uncovered guest parking space and 0.25
parking space for each unit for
vehicle storage
Organizational house 1 covered or uncovered space for each bedroom Residential care homes Six or fewer clients 2 covered spaces Seven or more clients 1 space for each 2 residential units, plus 1 space For each 5 units for guests and employees
Rooming and boarding houses 1 covered or uncovered space for each bedroom Second unit, carriage house 1 off street, all-weather surface parking space, plus, the off-street parking required for the
main dwelling
2 Terner Center for Housing Innovation at UC Berkeley, 2016. Available at: http://ternercenter2.berkeley.edu/proforma/

Merced County Association of Governments
Merced County Multi-Jurisdictional Housing Element (2024-2032) D4-12
Residential Use Required Parking Spaces
Senior housing project 1 per each two units, with half the spaces covered, plus 1 guest parking space for each 10 units
Spaces for single-family units are required to be permanently covered.

Multifamily units require one guest parking space per four dwelling units.

Source: Gustine Zoning Code, Adopted February 2022.

Conclusion
Residential parking requirements are not a constraint to housing development.

Recommended Action
None required.

D4.3.2.2 Open Space and Park Requirements
The City’s Zoning Code establishes open space requirements for multi-family projects and mobile home park projects within the Mobile Home Park Combining zone (T). Table D4-7 shows the open space requirements for multi-family projects. For all multi-family development, there is also a minimum private open space requirement of 150 square feet per unit in addition to minimum requirements for common open space. The required minimum common open space ranges from zero to over 2,000 square feet for multi-family projects. In addition, common open space must be easily accessible, continuous, usable, separated from parking lots, landscaped, safe, and secure. The review authority may allow required open space to be in different locations and of different dimensions if it determines that the alternative approach would provide open space of equivalent utility and aesthetic quality. Multifamily developments with 30 or more units are also required to provide a minimum of 1,000 square feet of indoor recreation space.

Mobile home parks within the T zone are required to maintain a recreation or open space of at least 1,000 square feet in area, plus 150 square feet for each mobile home space over ten homes. This open space may be distributed over more than one location, but no one location may be less than 1,000 square feet in size.

In addition, ADUs have some requirements related to open space. Primarily, no ADU project construction may cause the total percentage of open space of the lot to fall below 50 percent. While this requirement may limit the size of the ADU, no application of FAR lot coverage, or open space requirement may require the ADU to be less than 800 square feet.

Table D4-7 Multi-Family Project Open Space Requirements Project Size Minimum Common Open Space Required1
Minimum Private Open
Space Required2
2 units None, other than required setbacks 150 sq. ft. for each unit 3 or 4 units 200 sq. ft.
5 to 10 units 500 sq. ft.
11 to 30 units 1,000 sq. ft.
31 and more units 2,000 sq. ft., plus an additional 65 ft. for each unit over 31 (1) Each common open space area shall have a minimum dimension of 20 feet. (2) Private open space shall be at the same elevation as, and immediately accessible from within the unit. All dimensions of each private open space area shall be a minimum of 10 feet.

Source: Gustine Zoning Code, Adopted February 2022.

City of Gustine
Housing Constraints Analysis
2024-2032 Housing Element D4-13
Conclusion
Open space requirements in Gustine are more stringent than other jurisdictions throughout Merced County, particularly for multi-family housing projects with more than five units. Most other jurisdictions in Merced County do not require any private open space for multi-family developments. A 10-unit multi-family development in Gustine would be required to provide, a minimum 1,500 square foot private open space for each unit and 500 square feet of common open space per unit, totaling 5,000 square feet of common open space for this sample project. This could potentially constrain multi-family housing developments within the city.

Recommended Action
The City will implement Housing Program 6 to revise the Zoning Code to reduce private open space requirements for multi-family developments.

D4.3.2.3 Density Bonus
California law requires local jurisdictions to provide density bonuses (generally ranging from five to 80 percent) and development incentives or concessions for housing developments that include housing units that are affordable to lower- and moderate-income households or senior housing or the donation of land for housing within the local jurisdiction (Government Code Section 65915- 65918). Certain housing development projects may be granted unlimited density if they meet certain conditions, including projects where 100 percent of units are affordable units (including density bonus units) with no more than 20 percent of units for moderate-income households and the project is located within on-half mile of a major transit stop as defined by subdivision (b) of Section 21155 of the Public Resources Code. An unlimited density bonus means there is no cap on the total number of residential units per acre permitted on the site; however, there are other restrictions, such as height limits, that have a practical limiting effect on the number of units that can be built. Development incentives or concessions are reductions or modifications to site development standards or architectural design requirements that result in cost reductions, such as setbacks, parking requirements, and maximum building height.

Chapter 4.32 of the Gustine Zoning Code establishes the City’s affordable housing incentives, which includes its density bonus policy. The City provides a density bonus and other incentives or concessions to applicants for residential projects who agree to provide housing affordable to very low-, low-, or moderate-income households, senior housing, or donation of land for housing, consistent with Government Code Sections 65915-65918. Gustine does not have an inclusionary housing ordinance.

Allowed density bonuses. A project is eligible for a density bonus for a housing development of five or more dwelling units that complies with and satisfies the provisions in Section 4-32-020 of the Zoning Code. A Bonus density of at least a 25 percent increase in the number of dwelling units normally allowed by the applicable General Plan designation and zone is granted.

Types of incentives. Incentives or concessions include any of the following:

1. A modification of development standards pertaining to building height, open space, lot size requirements, street access, off-street parking, landscaping, fencing, a reduction in setback and square footage requirements or off-site improvements. Such reduction or modification requirements must exceed the minimum building standards approved by the California Building Standards Commission in compliance with Health and Safety Code Section 18901 et seq.;

Merced County Association of Governments
Merced County Multi-Jurisdictional Housing Element (2024-2032) D4-14

2. Approval of mixed use zoning in conjunction with the housing project if commercial, office, industrial or other land uses will reduce the cost of the housing development and if such nonresidential uses are compatible with the housing project and the existing or planned development in the area where the housing project will be located;

3. Other regulatory incentives or concessions proposed by the developer or the City which result in identifiable cost reductions; and

4. Direct financial incentives which include, in order of City priority:
a. Financial contributions or mortgage financing from the redevelopment agency’s twenty percent set aside for low and moderate income housing (as available); b. Modification of dedication requirements;
c. Waiver or reduction of fees (not including connection charges); d. Provision of publicly owned land.

Processing of Density Bonus and Incentive Request
Within 30 days of receipt of a complete written proposal, the director shall notify the applicant in writing of: the types of incentives which may be recommended in order to comply with Chapter

17.84 of the Zoning Code; and whether staff may support the granting of a density bonus on the basis of required development standards and findings. The target units must be compatible in floor plan, furnishings, and exterior design to non-designated units. Further, the target units must be reasonably dispersed throughout the development. Each density bonus project shall record an affordable housing agreement and resale and/or rental restrictive covenant, or other equivalent document approved as to form by the City attorney.

Conclusion
The City of Gustine’s density bonus policy does not reflect the most recent changes to State Density Bonus Law. This can be considered a constraint to housing.

Recommended Action
The City will implement Housing Program 6 and 8 to revise the Zoning Code to be consistent with State Density Bonus Law.

D4.3.2.4 On- and/ Off- Site Improvement Standards
The typical improvements required by local jurisdictions for subdivision and development of property include reasonable off-site and on-site improvements for the parcels being created, including those that are necessary for public health and safety and/or a necessary prerequisite for the orderly development of the surrounding area. As stated in HUD’s study of Subdivision Requirements as a Regulatory Barrier, such requirements can reasonably be considered regulatory barriers to affordable housing if Gustine determines that the requirements are greater (and hence, more costly) than those necessary to achieve health and safety requirements in the community. The City provides and operates water, wastewater, and stormwater drainage services. Electricity, gas, communications, and garbage services are provided by outside entities.

If a development borders or is traversed by an existing street, the applicant may be required to do the following sitework as required by the review authority and City public improvement standards:

1. Widen an existing street to the standards of width established by the City.

City of Gustine
Housing Constraints Analysis
2024-2032 Housing Element D4-15

2. Installation or reinstallation of curb, gutter, and sidewalk on the street bordering the development.

3. Installation of street trees and other landscaping within the public right-of-way(s) bordering the development.

4. Installation of drainage facilities to the full extent of the service requirements generated by the development, as required by the City Engineer.

5. Install other improvements determined by the review authority to be reasonably related to the needs for pedestrian and vehicle circulation, and community infrastructure demands created by the project.

Improvement Standards
The City requires curbs, gutters, and sidewalks on all residential streets, including access ramps at corners. According to the City’s Improvement Standards and Specifications, typical right-of-way for local streets varies. Typical residential streets are approximately 52 feet and typical residential collector streets are 70 feet, with 17-foot-wide lanes, six-inch gutters, 4-foot-wide landscaping, and minimum 5-foot-wide sidewalks. Streetlights and fire hydrants are required at regular intervals within the City to ensure an acceptable level of public health and safety.

Public improvement standards and approximate values for new housing developments are listed below.
 Residential street – street width of 34 feet plus 5 feet for sidewalks and 4 feet for landscaping.

Value: range between $6.00 to $10.00 per square foot.
 Residential collector – street width of 40 feet plus 5 feet for sidewalks and 10 feet for landscaping. Value: range between $8.00 to $12.00 per square foot.  Onsite Landscaping and Open Space – front yard setback and lot coverage and one street tree per 30-foot length of right-of-way. Value: range between $4.00 to $6.00 per square foot.  Curb, Gutters, Sidewalk, Utilities – require curb, gutters, sidewalks, and roads where they do not exist, as well as connection to City water and sewer and the installation of fire hydrants and undergrounding of utilities. Value: range between $6.00 to $10.00 per square foot. Value: curb, gutter, and sidewalk $6.00 to $10.00 per square foot; utilities $100.00 to $200.00 per linear foot.

Section 4-68-050 of the City’s Subdivision Code dictates the improvement requirements for new residential developments that include the subdivision of land. When improvements are deemed infeasible, the review authority may grant, on a case-by-case basis, an in-lieu fee for future improvements:; otherwise, all subdivision improvements are required to be constructed and funded by the developer. Such iImprovements include:
 Bicycle paths
 Bridges and major thoroughfares
 Fire hydrants
 Landscaping
 Monuments
 Private facilities – maintenance (HOA)
 Public utilities and utility easements

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Merced County Association of Governments
Merced County Multi-Jurisdictional Housing Element (2024-2032) D4-16
 Railroad crossings
 Sewage disposal
 Street lighting
 Street signs and street names
 Storm drainage
 Water supply
Additionally, Section 4-30-080 of the Gustine Zoning Code provides that an approved project construct improvements for each public street frontage as required by the review authority and City public improvement standards. These can include both on- and off-site improvements such as widening an existing street, installation/reinstallation of curb, gutter, and sidewalk, installation of street trees and other landscaping to the public right-of-way, and/or any other improvements determined to be reasonably related to the needs for pedestrian and vehicular circulation and community infrastructure demands.

The City does not have exact costs of on- or off-site improvement for recent projects. Through execution of Program 8, the City will continue to monitor development fees as a constraint to development.

Conclusion
On/off-site improvement requirements in Gustine are typical of small cities and comparable to surrounding jurisdictions. These improvements may increase housing costs, but they are necessary to achieve health and safety requirements. The City can mitigate the cost of these improvement requirements by assisting affordable housing developers in obtaining state and federal financing for their projects or providing regulatory and financial incentives.

Recommended Action
None Required
D4.3.3 Provision of a Variety of Housing Types
Housing Element law specifies that jurisdictions must identify adequate sites that are zoned to encourage the development of a variety of housing types available to all economic segments of the population. Individuals and households of different ages, types, incomes, and lifestyles have a variety of housing needs and preferences that evolve over time and in response to changing life circumstances. This includes single-family homes, multi-family housing, accessory dwelling units, mobile homes, agricultural employee housing, homeless shelters, and transitional housing, among others. Table D4-8 summarizes the housing types permitted and conditionally permitted in the City of Gustine.

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Housing Constraints Analysis
2024-2032 Housing Element D4-17
Table D4-8 Residential Use Matrix
Residential Use R-E R-1 R-2 R-3/R-4 P-D(4) C-N C-O C-1 C-2 C-H Accessory dwelling unit P P P P(4)
Employee housing, 6 or
fewer clients
P P P P(4)
Emergency Shelter UP UP UP
Home occupation P P P P P(4)
Live/Work Unit P P UP UP
Mobile home – in mobile
home park
P P P P P(4)
Mobile home – outside of
mobile home park

P P P P
Mobile home park UP UP P(4)
Multifamily housing, 2
units
P P P(4)
Multifamily housing, 3 or
4 units
UP P P(4)
Multifamily housing, 5 or
more units
P P(4)
Residential accessory use
or structure
P P P P P(4)
Residential care facility, 6
or fewer clients
P P P P P(4)
Residential care facility, 7
or more clients
UP UP UP UP P(4) UP UP
Residential care facility for
the elderly (RCFE)
UP UP P(4) UP UP
Residential component of
mixed-use project
UP P(4) P P P P
Rooming or boarding
house
UP UP
Single-family dwelling P P P P(4)
Supportive and
transitional housing
P(5) P(5) P(5) P(5) P(4) P(5) P(5) P(5) P(5)
P = permitted use, zoning clearance required; UP = use permit required; S= permit required set by specific use regulations; -- = use not allowed
(4) = use allowed in the PD zone only when authorized through Planned Development Permit approval (5) = use allowed only under conditions set forth in Section 4-44-190 (Transitional and Supportive Housing).

Source: Gustine Zoning Code, Adopted February 2022.

Conclusion
The City allows for a variety of housing types in residential districts.

Recommended Action
None required.

Merced County Association of Governments
Merced County Multi-Jurisdictional Housing Element (2024-2032) D4-18
Manufactured Housing
State law mandates that manufactured homes must be permitted in the same manner and in the same zones where conventional single-family structures are permitted (Government Code Section 65852.3). The Zoning Code defines “single-family dwelling” as a building designed for and/or occupied exclusively by one family, that includes factory-built, modular housing units, constructed in compliance with the Uniform Building Code (UBC), and mobile homes/manufactured housing units that comply with the National Manufactured Housing Construction and Safety Standards Act of 1974, placed on permanent foundations. Therefore, the City’s Zoning Ordinance is in compliance with Government Code Section 6582.3(a) in allowing the installation of manufactured homes on lots zoned for conventional single-family dwellings.

Conclusion
All residential zones permit the construction of manufactured homes, provided that they are placed on permanent foundations.

Recommended Action
None required.

D4.3.3.1 Accessory Dwelling Units
In recent years, several bills have added requirements for local governments related to accessory dwelling unit (ADU) regulation. Updates to state law in 2016 and 2017 included changes pertaining to the allowed size of ADUs, permitting ADUs by-right in at least some areas of a jurisdiction, and reduced parking requirements related to ADUs. More recent bills reduce the maximum allowable time to review and approve ADU applications to 60 days and remove lot size and replacement parking space requirements. AB 68 allows an ADU and a junior ADU (JADU) to be built on a singlefamily lot, if certain conditions are met. The State has also removed owner-occupancy requirements for ADUs, created a tiered permit fee structure for ADUs based on their size and location, and prohibits fees on units of less than 750 square feet. In addition, AB 671 requires the Housing Element to include plans to incentivize and encourage affordable ADU rentals.

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

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

ADUs are permitted by-right in R-E, R-1, and R-2 zones subject to development standards outlined in Section 4.44.140 of the City’s Zoning Code and included below:

A. Height.
a. A single-story attached or detached ADU may not exceed 16 feet in height above grade, measured to the peak of the structure.

City of Gustine
Housing Constraints Analysis
2024-2032 Housing Element D4-19
b. A second story or two-story attached ADU may not exceed the height of the primary dwelling.
c. A detached ADU may not exceed one story.

B. Number of Units.
a. Converted on single-family lot – Only one ADU or JADU on a lot with a proposed or existing single-family dwelling on it, where the ADU or JADU:
i. Is either: within the space of a proposed single-family dwelling; within the existing space of an existing single-family dwelling; or within the existing space of an accessory structure, plus up to 150 additional square feet if the expansion is limited to accommodating ingress and egress.
ii. Has exterior access that is independent of that for the single-family dwelling. iii. Has side and rear setbacks sufficient for fire and safety, as dictated by applicable building and fire codes.
b. Limited detached on single-family lot – One detached, new-construction ADU on a lot with a proposed or existing single-family dwelling (in addition to any JADU that might otherwise be established on the lot), if the detached ADU satisfies the following limitations:
i. The side- and rear-yard setbacks are at least four-feet. ii. The total floor area is 800 square feet or smaller. iii. The peak height above grade is 16 feet or less.
c. Converted on multi-family lot – Multiple ADUs within portions of existing multi-family dwelling structures that are not used as livable space, including, but not limited to, storage rooms, boiler rooms, passageways, attics, basements, or garages, if each converted ADU complies with state building standards for dwellings. At least one converted ADU is allowed within an existing multi-family dwelling, and up to 25 percent of the existing multi-family dwelling units may each have a converted ADU under this paragraph. d. Limited detached on multi-family lot – No more than two detached ADUs on a lot that has an existing multi-family dwelling if each detached ADU satisfies the following limitations:
i. The side- and rear-yard setbacks are at least four-feet. ii. The total floor area is 800 square feet or smaller.

C. Mobile Homes. Mobile homes shall be permitted as an accessory dwelling unit.

D. Manufactured Homes. Manufactured homes shall be allowed as a detached accessory dwelling unit provided the manufactured unit complies to standards and conditions of this chapter.

E. Existing Unit. A single-family or multi-family residential unit shall exist on a parcel before an accessory dwelling unit.

F. Rental term. No ADU or JADU may be rented for a term that is shorter than 30 days.

G. One Family. The accessory dwelling unit shall provide complete living facilities for one or more persons.

H. Maximum Size.
a. The maximum size of a detached or attached ADU subject to this subsection F. is 850 square feet for a studio or one-bedroom unit and 1,000 square feet for a unit with two bedrooms.

No more than two bedrooms are allowed.

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b. An attached ADU that is created on a lot with an existing primary dwelling is further limited to 50 percent of the floor area of the existing primary dwelling. c. Application of other development standards in this subsection F., such as FAR or lot coverage, might further limit the size of the ADU, but no application of FAR, lot coverage, or open-space requirements may require the ADU to be less than 800 square feet.

I. Floor Area Ratio (FAR). No ADU subject to this subsection may cause the total FAR of the lot to exceed 45 percent, but no application of FAR may require the ADU to be less than 800 square feet.

J. Lot Coverage. No ADU subject to this subsection may cause the total lot coverage of the lot to exceed 50 percent, but no application of lot coverage requirements may require the ADU to be less than 800 square feet.

K. Passageway. No passageway is required for an ADU.

L. Parking.
a. Generally. One off-street parking space is required for each ADU. The parking space may be provided in setback areas or as tandem parking.
b. Exceptions. No parking is required in the following situations:
i. The ADU is located within one-half mile walking distance of public transit. ii. The ADU is located within an architecturally and historically significant historic zone. iii. The ADU is part of the proposed or existing primary residence or an accessory structure.
iv. When on-street parking permits are required but not offered to the occupant of the ADU.
v. When there is an established car share vehicle stop located within one block of the ADU.
c. No replacement. When a garage, carport, or covered parking structure is demolished in conjunction with the construction of an ADU or converted to an ADU, those off-street parking spaces are not required to be replaced.

M. Owner Occupancy.
a. All ADUs created before January 1, 2020 are subject to the owner-occupancy requirement that was in place when the ADU was created.
b. An ADU that is created after that date but before January 1, 2025, is not subject to any owner-occupancy requirement.
c. All ADUs that are created on or after January 1, 2025 are subject to an owner-occupancy requirement. A natural person with legal or equitable title to the property must reside on the property as the person's legal domicile and permanent residence. d. All JADUs are subject to an owner-occupancy requirement. A natural person with legal or equitable title to the property must reside on the property, in either the primary dwelling or JADU, as the person's legal domicile and permanent residence. However, the owneroccupancy requirement of this paragraph does not apply if the property is entirely owned by another governmental agency, land trust, or housing organization.

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N. Utilities. If the ADU or JADU will connect to an onsite water-treatment system, the owner must include with the application a percolation test completed within the last five years or, if the percolation test has been recertified, within the last ten years.

O. Fees.
a. Impact fees.
i. No impact fee is required for an ADU that is less than 750 square feet in size. ii. Any impact fee that is required for an ADU that is 750 square feet or larger in size must be charged proportionately in relation to the square footage of the primary dwelling unit. (E.g., the floor area of the primary dwelling, divided by the floor area of the ADU, times the typical fee amount charged for a new dwelling.) "Impact fee" here does not include any connection fee or capacity charge for water or sewer service. b. Utility fees.
i. Converted ADUs and JADUs on a single-family lot are not required to have a new or separate utility connection directly between the ADU or JADU and the utility. Nor is a connection fee or capacity charge required unless the ADO or JADU is constructed with a new single-family home.
ii. All ADUs and JADUs not covered by subsection above require a new, separate utility connection directly between the ADU or JADU and the utility. The connection is subject to a connection fee or capacity charge that is proportionate to the burden created by the ADU or JADU, based on either the floor area or the number of drainage-fixture units (DFU) values, as defined by the Uniform Plumbing Code, upon the water or sewer system. The fee or charge may not exceed the reasonable cost of providing this service.

Conclusion
The City of Gustine’s ADU Ordinance was last updated in 2022 and is not in compliance with State ADU Law.

Recommended Action
The City will implement Housing Program 5 and 6 to facilitate the development of ADUs by revising the Zoning Code to allow ADUs in all residential and mixed-use zones, developing pre-approved ADU plans, and spreading awareness of available ADU development resources.

D4.3.3.2 Multi-Family
Multi-family housing is permitted by right or by use permit across the city in all zones allowing multifamily uses, including the R-2, R-3, R-4, and P-D zones. Multifamily development is not permitted in any other zone.

Conclusion
Multifamily development requirements are not a constraint to residential development.

Recommended Action
None required.

Merced County Association of Governments
Merced County Multi-Jurisdictional Housing Element (2024-2032) D4-22
D4.3.3.3 Group Homes and Residential Care Facilities
State law requires residential care facilities with six or fewer persons to be allowed by-right in all zones that allow residential uses in zones where single-family residential uses are allowed. Group homes with six or fewer residents are permitted by-right in all residential zones, in compliance with state law. The City allows the development of group homes with seven or more residents through a use permit in all residential zones.

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

Conclusion
The use permit requirement for group homes/residential care facilities of seven or more is a constraint to the development of housing for residents with a disability.

Recommended Action
The City will implement Housing Program 6 to permit residential care facilities with seven or more residents in all residential zones with objectivity and approval certainty, and subject only to the requirements of residential uses of similar type and form.

D4.3.3.4 Emergency Shelters
The City defines emergency shelters as “facilit[ies] for the temporary shelter and feeding of indigents or disaster victims, operated by a public or non-profit agency.” The definition of emergency shelter in the Zoning Code does not include interim intervention, (e.g., navigation centers, bridge housing, and respite or recuperative care) as required by AB 2339. Emergency shelters are allowed by-right in the M zone, as well as through a use permit in some of the City’s commercial zones, including Downtown Commercial (C-1), General Commercial (C-2), and Highway Commercial (C-H), and Public/Institutional (P-I) zones. There are no parking requirements and there are no additional development standards for emergency shelters.

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

The M Zone encompasses approximately 21 acres and is generally located along transportation routes, near commercial services, and provides the capacity for at least one emergency shelter.

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Housing Constraints Analysis
2024-2032 Housing Element D4-23
While the M Zone allows manufacturing, it also permits a wide variety of uses, including live/work units, single-family dwellings, child day cares, transit stations, convenience stores, fitness or health facilities, restaurants, cafes, and coffee shops, compatible with the development of emergency shelters. In addition, there are no known environmental constraints or other conditions on land within the M Zone that could render it unsuitable for residential or emergency shelter uses.

The Merced County Point-in-Time Count estimated that 855 people experienced homelessness in Merced County in 2022, including 555 in Merced, 125 in Los Banos, 59 in Atwater, and 116 in the remainder of the county areas. At the time of this Point-in-Time count, no persons experiencing homelessness were present in Gustine. The 2021 point-in-time count identified seven residents experiencing homelessness in Gustine.

As shown on Table D4-9, the M zone has potential capacity for more than 9,940 individuals in emergency shelters, which is significantly greater than the identified housing need (seven individuals counted in 2021). All sites listed below are located in the M zone, and are near the city’s commercial and mixed-use zones, and within walking distance of the City’s main transportation corridor (Highway 33) and downtown commercial streets where grocery stores, city and nonprofit services, and health clinics are located. The site located farthest from the center of the city (APN 063-320-006) is still less than a mile from the same goods, services, transportation corridors.

Table D4-9 Emergency Shelter Capacity Analysis
APN Acreage Realistic Capacity (beds)
020-220-002 1.11 241
020-021-004 0.46 100
020-021-005 0.48 104
020-021-011 0.79 172
020-021-007 2.1 457
020-042-031 0.71 154
063-320-006 40 8,712
Total 45.65 9,940
In 2019, AB 101 was passed requiring that a Low-Barrier Navigation Center development be a use by-right in mixed-use districts and nonresidential districts permitting multi-family uses. A LowBarrier Navigation Center is a low-barrier, temporary, service-enriched shelter that helps homeless individuals and families obtain permanent housing. Low-barrier navigation centers are not listed as permitted uses in any zoning district, and the City will need to amend its Zoning Ordinance to explicitly allow the development of Low-Barrier Navigation Centers, by-right, in residential use and mixed-use districts, as well as nonresidential districts permitting multi-family uses.

Within portions of the MU zone, underlying zoning allows multi-family residential uses. However, these areas do not allow emergency shelters or low-barrier navigation centers.

Conclusion
Currently, emergency shelters are allowed within the M zone which permits single-family homes, among other uses. The M zone has sufficient capacity to meet the identified need for emergency shelters. However,

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The City’s Zoning Code does not have any standards for emergency shelters, and the Zoning Code definition of an emergency shelter does not include a description of, or allow for, interim intervention such as low-barrier navigation centers. Therefore, t The City’s Zoning Ordinance is inconsistent with state law which requires low-barrier navigation centers be allowed by-right in areas zoned for mixed-use and nonresidential zones permitting multifamily uses.

Recommended Action
The City will implement Housing Program 6 to provide development standards (including parking requirements) consistent with state law, and to revise the emergency shelter definition in the Zoning Code to include a description of, and allow for, interim interventions in compliance with state law, and to allow low-barrier navigation centers by-right in areas zoned for mixed-use and nonresidential zones permitting multi-family uses.

D4.3.3.5 Transitional and Supportive Housing
“Transitional housing” is defined as buildings configured as rental housing operating under program requirements that require the termination of assistance and recirculation of the assisted unit to another eligible program recipient at some predetermined future point in time, which shall be no less than six months from the beginning of the assistance. Transitional housing units are residential uses subject only to those requirements and restrictions that apply to other residential uses of the same type in the same zone.
“Supportive housing” is defined as housing with no limit on length of stay that is occupied by the target population and that is linked to on-site or off-site services that assist the supportive housing resident in retaining permanent housing, health services, and employment, as needed. Supportive housing units are residential uses subject only to those requirements and restrictions that apply to other residential uses of the same type in the same zone. AB 2162, which went into effect on January 1, 2019, requires that cities allow supportive housing with up to 50 units by-right in multifamily and mixed-use zones and precludes cities from imposing parking requirements on supportive housing developments located within one-half mile of a public transit stop.

The City defines supportive housing to have the same meaning as stated in Government Code Section 65650(a) and transitional housing is defined to have the same meaning as stated in Government Code Section 65582(j).

Transitional housing and supportive housing are permitted as a residential use and therefore are permitted in all zones allowing residential uses and are not subject to any restrictions (e.g., occupancy limit) not imposed on similar dwellings (e.g., single-family home, apartments) in the same zone in which the transitional housing and supportive housing is located.

Conclusion
The City’s definition of transitional and supportive housing is consistent with state law. The City allows transitional and supportive housing in zones allowing residential uses, in compliance with state law. However, the Zoning Code does not provide any parking requirements for transitional and supportive housing.

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Housing Constraints Analysis
2024-2032 Housing Element D4-25
Recommended Action
The City will implement Housing Program 6 to revise the Zoning Code to establish parking requirements for transitional and supportive housing, in compliance with state law.

D4.3.3.6 Farmworker Housing and Employee Housing
The Employee Housing Act (Health and Safety Code Section 17021.6) requires that any employee housing consisting of no more than 36 beds in group quarters or 12 units or spaces designed for use by a single family or household, shall be deemed an agricultural land use. No conditional use permit, zoning variance, or other zoning clearance shall be required of employee housing that is not required of any other agricultural activity in the same zone. The permitted occupancy in employee housing in a zone allowing agricultural uses shall include agricultural employees who do not work on the property where the employee housing is located. Farmworker/employee housing for 6 or fewer residents is permitted by-right in the R-E, R-1, and R-2 zones, as well as when authorized through Planned Development Permit approval in the P-D zone in accordance with the Employee Housing Act. Single-family dwellings are also only allowed when authorized through Planned Development Permit approval in the P-D zone. Employee housing for 7 or more residents is permitted by right in the Agricultural-Commercial (A-C) zone.

Conclusion
The Zoning Code does not allow farmworker and employee housing in compliance with state law.

Agricultural uses are permitted by-right in the R-E, R-1, P-D(4) zones, however, these zones do not permit employee housing for more than 6 employees. In addition, the I, M, A-C, and P-1 zones permit agricultural uses by-right however only the A-C zone permits employee housing.

Recommended Action
The City will implement Housing Program 6 to amend the Zoning Code to ensure compliance with the Employee Housing Act (Health and Safety Code Section 17021.6).

D4.3.3.7 Single-Room Occupancy Units (SROs)
The City currently has no provisions in the Zoning Code to allow the development of SROs.

Conclusion
Without provisions to address the development of SROs, the Zoning Code potentially constrains the development of these types of units.

Recommended Action
The City will implement Housing Program 6 to revise the Zoning Code to allow the development of SROs in residential zones allowing multi-family uses and/or commercial zones allowing hotel and motel uses.

D4.3.4 Housing for Persons with Disabilities
California Government Code Section 65583 requires local jurisdictions to analyze potential and actual government constraints on the maintenance, improvement, and development of housing for people with disabilities. This is to ensure that persons with either physical or mental disabilities are

Merced County Association of Governments
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provided reasonable accommodation for access to and the enjoyment of all facilities, including housing. Government Code Section 65583(c)(3) also requires housing elements to provide a program to “…address, and where appropriate and legally possible, remove governmental constraints to the maintenance, improvement, and development of housing for persons with disabilities.”
This section analyzes if the zoning policies and permitting procedures in Gustine impose any constraints to persons with disabilities accessing appropriate and adequate housing in the city.

D4.3.4.1 Definition of Family
Local jurisdictions may restrict access to housing for households that do not meet the jurisdiction’s definition for “family.” A restrictive definition of “family” that limits the number of individuals living together may illegally limit the development and siting of group homes for persons with disabilities, but not for housing families that are similarly sized or situated.

The City does not restrict occupancy of unrelated individuals in group homes and does not define family or enforce a definition in its Zoning and Subdivision Code.

Conclusion
The City’s definition of “family” is not restrictive.

Recommended Action
None required.

D4.3.4.2 Reasonable Accommodation Procedures
The federal Fair Housing Act and the California Fair Employment and Housing Act require that cities and counties provide reasonable accommodation where such accommodation may be necessary to afford individuals with disabilities equal housing opportunities. Cities and counties must also consider requests for accommodations related to housing for people with disabilities and provide the accommodation when it is determined to be “reasonable” based on fair housing laws and the case law interpreting the statutes.

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

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

The City’s Zoning Code provides a formal procedure to request reasonable accommodation in order to make specific housing available to an individual with a disability, which can be found in Section

4.2.3 of the City of Gustine Zoning Code. Any person may request a modification or exception to the zoning and other land use regulations, policies, practices and procedures for the siting, development and use of housing or housing-related facilities that would eliminate regulatory barriers and provide

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a person with a disability equal opportunity to housing of their choice. The review authority may grant a variance to the site planning or development standards of the Zoning Code, so long as the variance is necessary to reasonably accommodate the needs of a disabled person in compliance with the Americans with Disabilities Act (ADA). Article 1 of Chapter 2 (Administration and Enforcement) of the Gustine Municipal Code outlines the City’s reasonable accommodation process for individuals to make a request for reasonable accommodation for zoning and other land use regulations, policies, practices, and procedures pursuant to the Fair Housing Act. Any person may request a modification or exception to the zoning and other land use regulations, policies, practices and procedures for the siting, development and use of housing or housing-related facilities that would eliminate regulatory barriers and provide a person with a disability equal opportunity to housing of their choice. The review authority may grant a variance to the site planning or development standards of the Zoning Code, so long as the variance is necessary to reasonably accommodate the needs of a disabled person in compliance with the Americans with Disabilities Act (ADA). The process includes the following steps:
 Application Process.
 Individuals, or their designated representative, shall provide the following information, as summarized below, to supplement their reasonable accommodation request:
− Name and address of applicant
− Name and address of property owner
− Address for which accommodation is requested
− Description of the accommodation
− The basis for the claim that fair housing laws apply
− Reason the request for accommodation is necessary
− Description on how the property will be use but the applicant  Approval Process,
 The Planning Director or designee is the review authority for reasonable accommodation and must make a decision on the matter within 30 days of a complete application. Approval is contingent on the following findings:
− The housing, which is the subject of the request, will be used by an individual disabled as defined under the Acts
− The requested reasonable accommodation is necessary to make specific housing available to an individual with a disability under the Acts. − The requested reasonable accommodation would not impose an undue financial or administrative burden on the city.
− The requested reasonable accommodation would not require a fundamental alteration in the nature of a city program or law, including but not limited to land use and zoning. − There are no reasonable alternatives that would provide an equivalent level of benefit without requiring a modification or exception to the city's applicable rules, standards and practices.The City retains any information identified as confidential in a manner so as to respect the privacy rights of the individual. The City also provides assistance to ensure that the process for requesting reasonable accommodation is accessible. There is no adopted fee in the current fee schedule for a reasonable accommodation request, which would default to a minimum $185/hour in-house planning fee to process the

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request. Since the last planning period, the City has not received any reasonable accommodation requests.
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The following development types shall be submitted to the planning department for review:

1. Name and address of the applicant;

2. Name and address of the property owner(s);

3. Address of the property for which accommodation is requested;

4. The current use of the property for which accommodation is requested;

5. Description of the requested accommodation, and the regulation(s), policy or procedure for which accommodation is sought, which could include site plans, floor plans, and/or details as necessary to define the extent of the accommodation;

6. The basis for the claim that the fair housing laws apply to the individual(s) with a disability and evidence supporting the claim, which may be in the form of a letter from a medical doctor or other licensed healthcare professional, a handicapped license, or other appropriate evidence;

7. Reason that the requested accommodation may be necessary for the individual(s) with the disability to use and enjoy the property; and

8. How the property will be used by the applicant and individual(s) with disabilities.

The City retains any information identified as confidential in a manner so as to respect the privacy rights of the individual. The City also provides assistance to ensure that the process for requesting reasonable accommodation is accessible. There is no adopted fee in the current fee schedule for a reasonable accommodation request, which would default to a minimum $185/hour in-house planning fee to process the request. Since the last planning period, the City has not received any reasonable accommodation requests. In addition, if the applicant needs assistance in making the request for reasonable accommodation, City staff will provide assistance to ensure that the process is accessible.

Conclusion
Gustine enforces State requirements related to reasonable accommodation.

Recommended Action
None required.

D4.3.5 Planning and Development Fees
The development review process is intended to regulate all projects. Through this process, residential yard size and other open space uses are determined, which in turn control population density for conformance with the General Plan. Regulation is necessary to conserve and stabilize property values, provide adequate open space, diminish street congestion; facilitate adequate community utilities such as transportation, water, sewage, schools, parks, and other public facility requirements; and to safeguard public health, safety, and general welfare.

The City collects fees to help cover the costs of processing, inspections, and environmental review.

The City has a two-part fee schedule. The first fee is intended as a Full Cost Recovery Estimate that is collected to offset full-time staff’s costs for processing an application. The second fee is a Cost

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Recovery Deposit that is drawn upon due to time and effort of a Contract Planner, Contract Engineer, Contract Attorney, and other contracted services. The fee deposit is drawn upon as the contracted person expends time and effort on the application. Additional funding from the deposit is collected as needed. Should funding remain after all work on the application is completed, the remaining balance is refunded.

The City charges various fees and assessments to cover the cost of processing permits and providing certain services and utilities. Development impact fees in Gustine are reasonable in comparison to other jurisdictions in the state and region. Table D4-10 describes residential development planning fees for both single-family and multi-family development.

Table D4-10 Residential Development Planning Fees
Fee Title Full Cost Recovery (FCR) Amount Deposit Amount Tentative Subdivision Map Review $5,760 $7,500
Final Subdivision Map Review $4,464 $5,000
Tentative Parcel Map $3,600 $5,000
Final Parcel Map $2,976 $3,500
General Plan Amendment $3,600 $7,500
Master plans/specific
plans/development plans
New: N/A
Amendment: $3,600
New: $10,000
Amendment: $5,000
Zone change $3,600 $7,500
Environmental Impact Report $7,200 $10,000
Negative Declaration $1,440 $5,000
Categorical Exemption $250 N/A
Conditional Use Permit (minor: within
residential zones and open space
zones)
$360 $650
Conditional Use Permit (major: within
commercial zones, industrial zones,
and public)
$1,080 $2,750
Source: City of Gustine, Master Schedule of User and Regulatory Fees. 2024.

Table D4-11 shows development impact and permit fees for single-family and multi-family prototype developments. The single-family prototype is a single-family detached residential dwelling unit with 1,600 square feet of living area. Single-family residential development fees are $58,103 per unit. Estimated multi-family fees are based on a 20,000 square foot multi-family development, with approximately 23 units. Multifamily residential development fees are $47,550 per unit.

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Merced County Multi-Jurisdictional Housing Element (2024-2032) D4-30
Table D4-11 Residential Development Fees
Cost Per Unit
Single-Family Multi-Family
Building Fees (1)
Building Permit $2,566 $706
Plan Check Fee $1,925 $529
Subtotal $4,491 $1,235
Impact Fees (2)
General Government $1,807 $1,682
Police $1,495 $1,391
Fire $2,081 $1,936
Parks $7,455 $6,938
Storm Drain $7,853 $3,656
Transportation $4,830 $2,621
Subtotal $25,521 $18,224
Water $8,299 $8,299
Sewer $19,792 $19,792
Subtotal $28,091 $28,091
Total per Unit Fees $58,103 $47,550
Source:
(1)Master Schedule of User and Regulatory Fees October 2023. (2) Public Facilities Impact Fee Update for the City of Gustine adopted May 2022.

Single-family development fees in Gustine are higher than similarly sized cities in the same county.

Fees for a single-family unit range are approximately $58,103 in Gustine but range from $12,326 to $32,961 in the cities of Atwater, Dos Palos, Livingston, Los Banos, and Merced. Fees for multi-family developments are also higher than neighboring cities. Fees for a multi-family unit are approximately $47,550 per multi-family unit in Gustine but range from $8,997 to $26,423 per unit in other cities.

Table D4-12 shows a comparison of development fees in other Merced County jurisdictions.

Table D4-12 Residential Development Fee Comparison
Jurisdiction
Total Cost Per Unit
Single-Family Multi-Family
Atwater $22,000 $14,000
Dos Palos $12,435 $12,435
Gustine $58,103 $47,550
Livingston $20,804 $5,561
Los Banos $32,961 $26,197
Merced (City) $12,326 $8,997
Merced (County) $30,996 $26,423

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