Agenda packet — Patterson City Council, May 19, 2026 (part 5 of 6)

The High Efficiency Toilet Rebate Program involves replacing high-water-use toilets with low-flush toilets, which are estimated to save approximately 38 gallons of water each day. The rebate amount for a qualifying high-efficiency toilet (1.28 gallons per flush or less) is $100. The following rules apply:
▪ Rebates are available on a first-come, first-served basis, and only City of Patterson utility customers are eligible;
▪ The toilet being replaced must use more than 1.6 gallons per flush. Homes built before 1994 with original toilets may qualify for the program;
▪ Toilets must have been purchased after July 1, 2018; and Packet Pg. 1366
Section 2.0 Housing Constraints Assessment 2-55 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 ▪ If the toilet has already been replaced, you may still qualify for a rebate. The applicant must have the original receipt, and the new toilet must be 1.28 gallons per flush or less and Water Sense approved. A post-verification visit is required.

In addition to the rebate programs, the City offers free water-conserving fixtures. Replacing old plumbing fixtures can save hundreds of gallons a day and reduce water bills. As part of the City’s Water Conservation Program, free low-flow bathroom and kitchen aerators, free showerheads, and free toilet leak detection tablets are available. The following rules apply:
▪ Supplies are limited and are available on a first-come, first-served basis; ▪ A post-verification visit may be required; and
▪ Only City of Patterson utility customers are eligible for this program.

In addition to City resources, local utility providers such as the Turlock Irrigation District and Pacific Gas and Electric offer additional rebate programs that assist lower-income households and support energy conservation goals. Table 2-18 identifies local assistance programs that offer incentives for energy conservation and assist low-income households. In addition to local assistance, several federal programs can help lower-income households pay their utility bills while also supporting the city’s energy conservation goals. Table 2-19 outlines federally funded programs that offer incentives and subsidies to encourage energy conservation and assist low-income households.

The City disseminates information about energy conservation programs through informational flyers available at City offices and public buildings, announcements at City Council meetings, and links on the City’s website. Energy conservation information and assistance programs are also featured in the City's quarterly newsletter.

Table 2-18 Programs and Incentives for Residential Properties in Stanislaus County Program Description
Turlock Irrigation District
Rebate Programs Turlock Irrigation District offers several rebate programs, including those for residential general improvements, appliances, heating and cooling, shade trees, and HVAC tune-ups.

Weatherization Program TID’s Weatherization program offers free weatherization measures and energy-efficient appliances to qualified low-income households. TID determines qualified households through a sliding income scale based on the size of a household. The program includes measures such as attic insulation, weather stripping, caulking, and minor home repairs.

Some customers qualify for replacement of appliances including electric water heaters, air conditioners and evaporative coolers.

TID Cares Program The TID Cares Program provides qualifying residential customers an $11 discount on their residential customer charge, as well as 15 percent off the first 800 kilowatt-hours (kWh) of use. Eligibility is dependent on several criteria listed online.12 12 https://www.tid.org/customer-service/payment-assistance-programs/tid-cares-rate-assistance-program/ Packet Pg. 1367
Section 2.0 Housing Constraints Assessment 2-56 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Program Description
Pacific Gas & Electric
Rebate Programs PG&E offers rebates to homeowners who make improvements that reduce energy use, such as buying an energy-efficient dishwasher, refrigerator, or water heater or sealing and insulating ducts and attics.

California Alternate Rates for
Energy (CARE)
Provides a 20 percent discount on energy rates for qualifying low- and fixed-income households and housing facilities. Qualifications are based on the number of people living in the home and total annual household income.

Family Electric Rate
Assistance (FERA)
Helps eligible customers pay their energy bill. Income-qualified customers get an 18 percent monthly discount on electric rates. Participants must be a household with three or more people.

Relief for Energy Assistance
through Community Help
(REACH)
Provides an energy credit of up to $2,000 based on the past-due balance.

Low-Income Home Energy
Assistance Program
(LIHEAP)
Provides assistance with residential utility bill payment; emergency help with residential energy-related crisis, such as utility shutoff notices, energy-related life-threatening emergencies, and home weatherization.

Medical Baseline Program Assists residential customers who depend on power for certain medical needs. The additional allotment of energy is roughly 500 kilowatt-hours (kWh) of electricity and/or 25 therms of gas per month. This amount depends on the customer’s energy needs. These needs must be verified by a medical practitioner during certification.

Central Valley Opportunity Center
Home Energy Assistance
Program
The Home Energy Assistance Program provides one payment per year to utility companies for low-income individuals. TID customers apply through the Central Valley Opportunity Center. To be eligible, the individual must be a Stanislaus County resident and income must be at or below 130 percent of the poverty level per the Federal Register.

Energy Crisis Intervention
Program
The Energy Crisis Intervention Program provides one payment per year to utility companies for low-income customers that have received a 48-hour Shut Off Notice or if a senior citizen or disabled person have received a 15-day Shut Off Notice. The program also assists customers in obtaining propane and firewood for heating and repair or replacement of heating sources. To be eligible, the individual must be a Stanislaus County resident and income must be at or below 130 percent of the poverty level per the Federal Register, in addition to having received a 48-hour Shut Off Notice or 15-day Shut Off Notice prior to application.

The Salvation Army
Energy Assistance Program The Salvation Army Energy Assistance Program provides financial assistance to qualified customers in TID’s service territory. Qualified customers can receive up to $300 towards their TID bills. Selection and assistance granted is at the discretion of The Salvation Army.

Source: Turlock Irrigation District, 2024; Pacific Gas and Electric, 2024; Central Valley Opportunity Center, 2024.

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Section 2.0 Housing Constraints Assessment 2-57 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Table 2-19 Federally Funded Programs and Incentives for Residential Properties Program Description
Low-Income Weatherization Program's (LIWP)
Multifamily Energy and Efficiency and Renewables
Program
Provides technical assistance and incentives for the
installation of energy efficiency measures and solar
photovoltaic systems in low-income multi-family dwellings serving priority populations.

Low-Income Home Energy Assistance Program
(LIHEAP)
LIHEAP can offer a one-time payment to help pay heating or cooling bills or in an emergency or energy crisis, such as a utility disconnection. Additionally, LIHEAP can also
provide in-home weatherization services for improved
energy efficiency and health and safety.

Low-Income Weatherization Program’s (LIWP)
Farmworker Housing Energy Efficiency and Solar PV
Provides direct installation of energy efficiency measures and solar photovoltaic (PV) systems for eligible farmworker households at no cost.

Low-Income Household Water Assistance Program
(LIHWAP)
LIHWAP offers one-time support to help low-income
households pay past due or current residential water and sewer bills and keep their water on.

Source: California Department of Community Services and Development, 2024 Packet Pg. 1369
Section 2.0 Housing Constraints Assessment 2-58 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 This side intentionally left blank.

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Section 3.0 Housing Action Plan 3-1 EMC Planning Group
City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025

3.0 Housing Action Plan
This chapter describes housing goals, policies, and programs for the City of Patterson. A goal is defined as a general statement of the highest aspirations of the community. A policy is a course of action chosen from among many possible alternatives. It guides decision-making and provides a framework around which the housing programs operate. A program is a specific action that implements the policy and moves the community toward the achievement of its goals. Programs are a part of the City’s action plan and constitute the City’s local housing strategy.

Section 65583(b) of the State Government Code describes the requirements for the City’s housing programs in the following areas:
 Provide adequate sites;
 Assist in the development of adequate housing to meet the needs of extremely low-, very low-, low- and moderate-income households;
 Address governmental constraints;
 Conserve and improve the condition of the existing affordable housing stock;  Promote equal housing opportunities; and
 Preserve units at-risk of converting to market rate.

3.1 Goals, Policies and Programs
The City is responsible for enabling the production of housing by reducing regulatory barriers, providing incentives, and supporting programs that create or preserve housing, especially for vulnerable populations. To enable the construction of quality housing, the City has identified five goals:
 Goal 1: Facilitate Housing Construction;
 Goal 2: Preserve and Improve the Existing Housing Stock;  Goal 3: Exemplify Sustainable Development and Energy Conservation;  Goal 4: Provide New Affordable and Other Special Needs Housing; and  Goal 5: Publicize Housing Needs and Resources.

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Section 3.0 Housing Action Plan 3-2 EMC Planning Group
City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 The policies for the 2023-2031 planning period are carried forward and modified from the 2015- 2023 Housing Element as follows:
 Policy H-1 Ensure Adequate and Diverse Housing Supply: The City shall maintain an adequate supply of residentially zoned land at appropriate densities to accommodate current and future housing needs and ensure a diverse range of housing types.  Policy H-2 Promote Affordable Housing Development: The City shall actively encourage the development of affordable housing for various income groups, prioritizing higher-density projects near transit, shopping, services, schools, and jobs.  Policy H-3 Conserve and Preserve Existing Affordable Housing: The City shall strive to conserve and preserve the existing affordable housing stock, particularly rental units for lowerand moderate-income households.  Policy H-4 Support Housing for Special Needs and Vulnerable Populations: The City shall prioritize housing development for extremely low-income households and special needs groups, including seniors, disabled persons, large families, farmworkers, and the homeless.  Policy H-5 Facilitate Streamlined and Efficient Development Processes: The City shall promote timely, consistent, and predictable development procedures by streamlining the approval process for residential projects.
 Policy H-6 Promote Sustainable and Energy-Efficient Housing: The City shall promote sustainable housing practices by encouraging energy and water-efficient design and construction in new and existing residential developments.
 Policy H-7 Protect and Stabilize Residential Neighborhoods: The City shall protect residential neighborhoods from incompatible land uses and promote neighborhood revitalization.
 Policy H-8 Promote Fair Housing and Equal Opportunity: The City shall ensure equal housing opportunities for all residents, regardless of race, color, religion, sex, sexual orientation, marital status, national origin, ancestry, familial status, disability, or source of income.  Policy H-9 Ensure Consistency with the General Plan: The City shall ensure that the Housing Element is internally consistent with the other elements of the General Plan via zoning amendments or changes to the Municipal Code.

Policies and programs from the 2015-2023 Housing Element have been incorporated herein. As a result of the analysis of effectiveness in Appendix B, they have been updated, modified, or deleted as necessary to reflect accomplished programs, existing and projected needs, constraints, available resources, and changes necessary to comply with new state laws. Monitoring of program accomplishments will be conducted periodically through the Housing Element Annual Progress Report to the City Council and to the Housing and Community Development Department (HCD).

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Section 3.0 Housing Action Plan 3-3 EMC Planning Group
City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Quantified Objectives
Quantified Objectives estimate the number of units likely to be constructed, rehabilitated, or conserved/preserved by income level during the planning period. The Quantified Objectives do not represent a ceiling on development, but rather set a target goal for the jurisdiction to achieve, based on needs, resources, and constraints. These objectives will focus communication between the City and HCD with future Annual Progress Reports (APRs). HCD does not demand that all objectives must be met, rather, it is a goal that enables objective assessments about program effectiveness so that the City may make informed determinations to continue, modify, or delete programs with the next Housing Element update cycle. Table 3-1 summarizes the number of units anticipated to be constructed as a result of the programs and capacity available for housing in Patterson.

Table 3-1 Quantified Objectives
Income Category New Construction Rehabilitation Conservation/Preservation* Extremely Low Income
(<30% AMI) 572 12 127
Very Low Income
(30-50% AMI) 572 12 127
Low Income
(50-80% AMI) 822 24 -
Moderate Income
(80-120% AMI) 593 8 -
Above Moderate Income
(>120% AMI) 1,353 - -
Total 3,912 56 254
SOURCE: City of Patterson, 2024
NOTE: *The California Housing Partnership Preservation Database reported 254 deed-restricted affordable units in Patterson, none of which are anticipated to expire until 2068 at the earliest.

Goal 1: Facilitate Housing Construction
Program 1.1 Provide Adequate Sites for RHNA and Monitoring of No Net Loss For the 2023-2031 Housing Element planning period, the City of Patterson has been assigned a RHNA of 3,716 units, with the following income distribution: 1,046 very low-income, 724 lowincome, 593 moderate-income, and 1,353 above moderate-income units. Due to an unaccommodated need of 196 lower-income units from the 5 th Cycle Housing Element, the City’s
adjusted RHNA is 3,912 units, increasing the very low- and low-income RHNA by 98 units each.

Based on projected ADUs, pipeline projects, and identified housing opportunity sites, the City has adequate capacity to meet its RHNA.

To ensure the City complies with SB 166 (No Net Loss), the City will monitor the consumption of residential, commercial, and mixed-use acreage to ensure an adequate inventory is available to meet Packet Pg. 1373
Section 3.0 Housing Action Plan 3-4 EMC Planning Group
City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 the City’s RHNA obligations. To ensure sufficient residential capacity is maintained to accommodate the RHNA, the City will annually update and submit their Annual Progress Report (APR) to HCD. This will facilitate an ongoing (project-by-project) evaluation procedure pursuant to Government Code Section 65863. Should an approval of development result in a reduction in capacity below the residential capacity needed to accommodate the remaining need for lower- and moderate-income households, the City will identify and if necessary, rezone sufficient sites to accommodate the shortfall and ensure no net loss in capacity to accommodate the RHNA.

Additionally, the City shall develop and maintain a database of all City-owned land, particularly surplus land, for opportunities to rezone, where appropriate, for affordable housing development.

Annually, the City shall conduct outreach to property owners and assist developers in identifying available vacant and underutilized properties in the city that are suitable sites for residential development. The City shall also continue to make this information available to the public and developers through the City’s website.

Monitoring Development of Pipeline Projects
The City’s Site Inventory includes two pipeline projects (Sites 16 and 17) that will accommodate a total of 341 residential units, including 96 moderate-income and 245 above-moderate-income units.

To ensure these units are developed within the planning period, the City will closely monitor the progress of these projects. In December 2027, the City will conduct a mid-cycle evaluation for each pipeline project to assess development progress. If construction has not commenced by January 2028, the City will explore alternative land use strategies, such as rezoning or identifying alternative sites for development.

Timeline:  Upon Housing Element adoption, make the sites inventory available on the City website.  Annually update APRs.
 Develop database to track City-owned lands available for development by June 2026.  Annually conduct outreach to property owners and assist developers in identifying vacant and underutilized properties in the city.
 Monitor development progress of Sites 16 and 17 and conduct mid-cycle evaluation in December 2027.
 Pursue alternative land use strategies, such as rezoning or identifying alternative sites for development by January 2028.

Objectives:  Maintain a sites inventory that is adequate to accommodate the City’s adjusted RHNA of 3,912 units.
 Track City-owned lands available for development.

Performance Metric: Number of sites available for meeting RHNA goals Geographic Targeting: City-wide
Responsible Agencies: Community Development Department
Funding Sources: General Fund
Implementing Policy:  Policy H-1 Ensure Adequate and Diverse Housing Supply Packet Pg. 1374
Section 3.0 Housing Action Plan 3-5 EMC Planning Group
City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Program 1.2 Replacement Housing Requirements
Pursuant to new State Law (AB 1397), non-vacant sites identified in the sites inventory with existing, vacated, or demolished residential uses and occupied by, or subject to an affordability requirement for, lower-income households within the previous five years, must be replaced with units affordable to lower-income households. As a condition of any development on the site, the replacement housing requirements must be consistent with those set forth in the State Density Bonus Law.

Timeline:  Amend Municipal Code by December 2025
 Annually monitor development of non-vacant sites.

Objectives:  Pursuant to State Law, amend the Municipal Code by the end of December 2025 to include the replacement housing requirements on non-vacant sites used to fulfill the City’s lowerincome RHNA.  Monitor development of non-vacant sites identified in Chapter 2 and ensure that any development, as a condition of project approval, replace existing units occupied by or deed-restricted for occupancy by lower-income households are replaced.

Performance Metric: Number of units replaced
Geographic Targeting: City-wide
Responsible Agencies: Community Development Department
Funding Sources: General Fund
Implementing Policy:  Policy H-1 Ensure Adequate and Diverse Housing Supply Program 1.3 Encourage Lot Consolidation to Facilitate Housing Development While the City does not rely on small sites (less than 0.5 acres) to fulfill its lower-income RHNA, the City encourages the consolidation of small parcels to facilitate developments with quality site planning and amenities. To facilitate lot consolidation, the City will:
 Post the Housing Element sites inventory online with information on lot consolidation potential;
 Market lot consolidation opportunities online and provide printed materials at City Hall;  Assist interested property owners and developers in identifying sites with consolidation potential;
 Provide technical assistance to property owners and developers on how lot consolidation could help the site planning and design of a project to achieve the maximum allowable density; and  By December 2028, evaluate lot consolidation trends in facilitating housing development on small sites and develop additional tools and incentives, if necessary.

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Section 3.0 Housing Action Plan 3-6 EMC Planning Group
City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Additionally, the City will offer the following incentives to developers that provide affordable housing:
 Reduced planning fees for projects that include 20 percent deed-restricted affordable units; and  Provide concurrent/expedited review of project applications.

Timeline:  Upon Housing Element adoption, post sites inventory online.  Annually monitor lot consolidation projects.
 By December 2028, evaluate lot consolidation trends.

Objectives:  Promote lot consolidation with the goal of achieving four projects with lot consolidation during the planning period.
 Review and revise lot consolidation tools and incentives by December 2028.

Performance Metric: Number of lot consolidation projects during planning period.

Geographic Targeting: City-wide, specifically in the City’s downtown region.

Responsible Agencies: Community Development Department
Funding Sources: General Fund
Implementing Policy:  Policy H-1 Ensure Adequate and Diverse Housing Supply Program 1.4 Density Bonus
The City’s Density Bonus provisions must be updated to reflect recent changes to State law, such as AB 1763, which made several changes to density bonus requirements for 100 percent affordable projects, AB 2345, which further incentivizes the production of affordable housing, and AB 1227, which includes provisions for students experiencing homelessness.

Timeline:  Amend City’s Density Bonus Ordinance by June 2026.

Objectives:  Amend the City’s Density Bonus Ordinance to be consistent with recent changes to State Density Bonus Law. Ensure City’s Inclusionary Housing Ordinance complies with State Density Bonus Law.
 Achieve 100 lower-income affordable units between 2023-2031 through density bonus and inclusionary hosing.

Performance Metric: Number of lower-income affordable units permitted during planning period through density bonus.

Geographic Targeting: City-wide
Responsible Agencies: Community Development Department
Funding Sources: General Fund
Implementing Policy:  Policy H-1 Ensure Adequate and Diverse Housing Supply Packet Pg. 1376
Section 3.0 Housing Action Plan 3-7 EMC Planning Group
City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Program 1.5 Inclusionary Housing Requirements
In 2013, the City adopted an Inclusionary Housing Ordinance (Municipal Code Chapter 18.86), which has since had limited success in generating affordable housing units, largely due to a lack of dedicated oversight to enforce the ordinance. Without consistent enforcement, developers have often opted to pay the in-lieu fee instead of building affordable units. To encourage the construction of affordable housing amid expected development growth, the City will dedicate staff to manage the housing element, focusing on implementing and enforcing the Inclusionary Housing Ordinance to promote affordable unit construction over in-lieu fee payments.

Additionally, to ensure compliance with recent changes to State Density Bonus Law, the City will review and update its Inclusionary Housing Ordinance, if necessary.

Timeline:  Review and update, if necessary, the City’s Inclusionary Housing Ordinance to comply with State Density Bonus Law by December 2026.

Objectives:  Ensure City’s Inclusionary Housing Ordinance complies with State Density Bonus Law.  Achieve 100 lower-income affordable units between 2023-2031 through density bonus Performance Metric: Number of lower-income affordable units permitted during planning period inclusionary housing.

Geographic Targeting: City-wide
Responsible Agencies: Community Development Department
Funding Sources: General Fund
Implementing Policy:  Policy H-1 Ensure Adequate and Diverse Housing Supply  Policy H-2 Promote Affordable Housing Development
Program 1.6 Facilitating Affordable Housing Development The City currently has limited staffing to oversee housing element implementation. To meet RHNA goals and support residential development, the City will hire 1.0 Full-Time Equivalent (FTE) to the Community Development Department to focus on housing issues and needs. This will include facilitating affordable housing development for lower- and moderate-income households, including Patterson’s workforce, extremely low-income (ELI) individuals, and those with disabilities and developmental disabilities, through the following initiatives:
 Coordinate annually with the Stanislaus Regional Housing Authority to market and provide Housing Choice Vouchers (HCV) to eligible Patterson residents;  Refer ELI residents to wrap-around support services and community organizations (i.e. housing resources, transportation assistance, utility assistance, etc.);  Research the feasibility of establishing an Affordable Housing Matching Program to allow ELI residents to monitor the availability of affordable housing in the city. Assess feasibility by June 2026. If determined feasible, identify City staff or a consultant to develop and implement the program by January 2027;
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Section 3.0 Housing Action Plan 3-8 EMC Planning Group
City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025  Maintain a list on the City’s website of resources available to special needs groups, including ELI residents;
 Collaborate with non-profit organizations and developers to construct affordable units that are suitable for the needs of large households;
 Conduct outreach annually to interested developers; annually assist with identification of appropriate sites for affordable housing;
 Provide information on the city website highlighting local fabricators that build high density residential;
 Annually assist nonprofit developers to pursue affordable housing funds available at local, state, and federal levels to implement the goals and policies of this Housing Element;  Provide expedited planning review and processing for affordable housing projects, and offer pre-application consultation to ensure maximum development potential is achieved;  Reduce planning permit entitlement fees for affordable housing projects with deed-restricted units by 50 percent and defer payment of impact fees until prior to issuance of Certificate of Occupancy;
 Grant development concessions and incentives for housing developments that include units affordable to ELI households; and
 Seek cost-effective methods to reduce housing construction costs.

Timeline:  Hire 1.0 FTE to manage housing element implementation by December 2025.  Annually coordinate with the Housing Authority to encourage ELI residents to apply for HCV.
 Determine if Affordable Housing Matching program is feasible by June 2026. If feasible, implement by January 2027.
 Semi-annually update the City’s website with resources for ELI (and other special needs) residents.
 Ongoing referral of ELI residents to support services and community organizations.  Annually coordinate with non-profit organizations and developers in identifying funding resources and housing opportunity sites on an annual basis.  Annually meet with housing developers to identify opportunities for affordable housing development.
 Implement identified cost-effective methods to reduce housing construction by June 2027.  Annually monitor lower-income housing units permitted during the planning period.

Objectives:  Match at least 5 ELI residents with landlords willing to accept HCV  Refer at least 10 ELI residents to social service organizations  Expedite planning review and processing for affordable housing projects.  Monitor the number of lower-income housing units permitted during the planning period with a goal of achieving 1,770 lower-income units to satisfy the RHNA.

Performance Metric: Number of lower-income units permitted during planning period.

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Section 3.0 Housing Action Plan 3-9 EMC Planning Group
City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Geographic Targeting: City-wide
Responsible Agencies: Community Development Department
Funding Sources: General Fund
Implementing Policy:  Policy H-2 Promote Affordable Housing Development  Policy H-3 Conserve and Preserve Existing Affordable Housing  Policy H-4 Support Housing for Special Needs and Vulnerable Populations  Policy H-5 Facilitate Streamlined and Efficient Development Processes Program 1.7 Establish Procedures for SB 35 and SB 330
Government Code section 65913.4 allows qualifying development projects with a specified proportion of affordable housing units to optionally move more quickly through the local government review process and restricts the ability of local governments to reject these proposals.

The City will create an SB 35 checklist and written procedures for processing SB 35 applications to ensure efficient and complete application processing and will update the documents in conformance with any changes to state law within twelve months of adoption of new laws. Additionally, the City will develop an application for SB 330 in conformance with State law.

Timeline:  Adopt checklist and written procedures by June 2026 and within 12 months of any change to the law that would impact the City.

Objectives:  Expedite review process for affordable residential projects.

Performance Metric:  N/A
Geographic Targeting: City-wide
Responsible Agencies: Community Development Department
Funding Sources: General Fund
Implementing Policy:  Policy H-5 Facilitate Streamlined and Efficient Development Processes Program 1.8 Objective Design Standards
To remove subjectivity from the site plan review and approval process, and to provide clarity and predictability for future development and housing construction, the City will create Objective Design Standards (ODS) for mixed-use and multi-family residential developments. The City will explore funding opportunities for the development of ODS, such as REAP, or LEAP funds.

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Section 3.0 Housing Action Plan 3-10 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Timeline:  Adopt Objective Design Standards for Mixed-Use and Multi-Family Residential by June 2026.

Objectives:  Adopt Objective Design Standards for Mixed-Use and Multi-Family Residential Performance Metric: N/A
Geographic Targeting: City-wide
Responsible Agencies: Community Development Department
Funding Sources: General Fund; REAP; LEAP
Implementing Policy:  Policy H-5 Facilitate Streamlined and Efficient Development Processes Program 1.9 Supporting Transportation Demand Strategies & Reducing Parking Requirements for Multi-Family Residential Development
The City is served by the Stanislaus Regional Transportation Authority (StanRTA) which operates two bus routes, Route 45, that provides service in Patterson and to the cities of Newman and Turlock and Route 40, that provides service to Modesto. In order to facilitate transit use for residents of new multi-family residential developments, the City will encourage the development of transportation demand management strategies that include but are not limited to the following:
 Work with StanRTA to expand transportation access to the western and eastern regions of the city, specifically west of Baldwin Road to facilitate residential development and improve citywide connectivity and east of Ward Avenue;  Collaborate with StanRTA to develop an incentive program for developers to provide bike parking and transit passes to residents of new affordable residential units for a minimum of 10 years;
 Facilitate increased use of public transit by providing information on bus frequency and transit stop locations in common areas for the life of the program; and  Reduction of minimum parking standards by December 2026.

To remove potential constraints to the development of multi-family housing, the City will amend the Municipal Code to reduce parking standards (including guest parking) for multi-family uses in multi-family zones as follows:
 Zero to one bedroom: one onsite parking space;
 Two bedrooms: one and one-half onsite parking spaces; and  Three or more bedrooms: two onsite parking spaces.

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Section 3.0 Housing Action Plan 3-11 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Timeline:  Collaborate and develop transportation demand management strategy by June 2027.  Amend Municipal Code to reduce parking standards by December 2026.

Objectives:  Address constraints and facilitate the development of affordable housing.  50 transit passes per year with new affordable units.

Performance Metric:  Number of affordable units permitted.

Geographic Targeting: City-wide
Responsible Agencies: Community Development Department
Funding Sources: General Fund
Implementing Policy:  Policy H-2 Promote Affordable Housing Development  Policy H-5 Facilitate Streamlined and Efficient Development Processes  Policy H-6 Promote Sustainable and Energy-Efficient Housing Program 1.10 Remove Barriers to Multi-family Residential Development To remove potential zoning constraints related to residential development standards on housing development, particularly for affordable multi-family residential units, the City is committed to amending the Zoning Code for the High Density Residential, Neighborhood Commercial, and Downtown Core Zoning Districts, as detailed in Table 3-2. The proposed changes to development standards do not apply to the Zacharias Baldwin Ranch Master Plan areas.

Parking standards will be revised in accordance with the specifications in Table 3-2. These measures, along with the City's support to StanRTA, are also included in Program 1.9. Further, the City will remove the conditional use permit (CUP) requirement for multi-family residential units in the Downtown Core (DC) Zoning District.

The site inventory in Chapter 4 of this Housing Element relies on increased densities in the High Density Residential (HR) and Downtown Core Zoning Districts to meet RHNA goals. To support this, the City is committed to raising residential densities in the High Density Residential Zoning District from the current range of 12.1 to 20.0 dwelling units per acre to 20.1 to 35.0 dwelling units per acre, and in the Downtown Core Zoning District from 12.1 to 20.0 dwelling units per acre to

20.0 to 35.0 dwelling units per acre, as outlined in Table 3-2. This amendment to the Zoning Code, including all those specified in Table 3-2, will be implemented by December 2025.

Additionally, subjective approval findings in the Municipal Code have the potential to lead to inconsistent and discretionary project approvals. To remove constraints for housing development, the City will amend Municipal Code Chapter 18.18.040E to modify the findings of approval to remove the following language:

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Section 3.0 Housing Action Plan 3-12 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 “The architectural and general appearance of the structures and grounds shall have architectural unity and be in keeping with the character of the neighborhood as not to be detrimental to the orderly and harmonious development of the city, or to the desirability of investment or occupation in the neighborhood.”
Table 3-2 Proposed General Plan and Zoning Amendments to Residential Development Standards
Zoning District Existing Standards Proposed Standards
High Density
Residential
Density: 12.1—20.0
Front setback: 25’
Rear setback: 20’
Height Maximum: 45’ (3 stories)
Distance between main buildings: 25’
Distance between any wall of a main building
containing living room windows and any other wall of
a main building: 35’
Density: 20.1—35.0
Front setback: 15’
Rear setback: 15’
Height Maximum: 45’ (4 stories)
Distance between main buildings: 15’
Distance between any wall of a main
building containing living room windows and
any other wall of a main building: 20’
Neighborhood
Commercial
Density: 3.1—10.0
Height Maximum: 32’ (2 stories)
Density: 12.0—20.0
Height Maximum: 32’ (3 stories)
Downtown Core Density: 12.1—20.0
Height Maximum: 45’ (3 stories)
Density: 20.0—35.0
Height Maximum: 50’ (4 stories)
Development Type Parking Requirements
Single-Family & MultiFamily Residential
Studio or 1-bedroom: 1 covered space
2-bedrooms: 1 covered space and 1 uncovered
space
3+ bedrooms: 2 covered spaces
Studio or 1-bedroom: 1 covered space
2-bedrooms: 1.5 covered spaces
3+ bedrooms: 2 covered spaces
Apartments
Studio: 1 covered space
1-bedroom: 1.5 (1 covered) spaces
2+ bedrooms: 1 covered space and 1 uncovered
space
3+ bedrooms: Plus 1 additional guest parking space
for every 3-bedroom unit
Studio: 1 covered space
1-bedroom: 1 covered space
2+ bedrooms: 1.5 uncovered spaces
3+ bedrooms: 2 covered spaces
Senior Housing
Same number of spaces required for dwellings or
apartments; however, the number of spaces may be
reduced if the planning commission makes a finding
that not all spaces are needed*
n/a
SOURCE: City of Patterson
NOTE: These proposed changes to development standards do not apply to the Zacharias Baldwin Ranch Master Plan areas.

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Section 3.0 Housing Action Plan 3-13 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Timeline:  Amend Municipal Code by December 2025.

Objectives:  Address Zoning Code constraints and facilitate the development of multi-family housing.  Amend Municipal Code residential development standards as outlined in Table 3-2.  2,229 lower-income units developed during the planning period.

Performance Metric:  Number of lower-income housing units developed during the planning period.

Table 3-3 identifies the specific sites that require rezoning, with the City committed to completing the necessary zoning amendments by December 2025.

Pursuant to Government Code section 65583.2, subsection (h), the City shall implement a by-right non-discretionary approval process option for sites requiring rezoning due to a shortfall, when at least 20 percent of the units are affordable to lower-income households during the planning period.

Sites requiring rezoning are identified in Table 3-3 on the following page.

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Section 3.0 Housing Action Plan 3-14 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Table 3-3 Sites Requiring General Plan Land Use Change and Zoning Amendment SOURCE: City of Patterson, 2024
NOTE: All sites identified in this table are analyzed in Chapter 4 of this Housing Element. HR and MU Zoning Districts allow 20.1 – 35.0 dwelling units per acre, as implemented through Program 1.10.

Site ID Land Use Change Zoning
Change
APN Acreage Site Access Available
Infrastructure
Realistic Capacity:

Lower-Income Units
6 General Commercial to
High Density GC to HR 048-042-001 5.5 Unconstrained Yes, current 156 7 General Commercial to
High Density GC to HR 048-042-008 3.97 Unconstrained Yes, current 113 8 General Commercial to
High Density GC to HR 048-043-002 2.08 Unconstrained Yes, current 59 9 General Commercial to
High Density GC to HR 048-043-015 2.55 Unconstrained Yes, current 72 10 General Commercial to
High Density GC to HR 048-048-007 10.21 Unconstrained Yes, current 283 12 Highway Service
Commercial to
Mixed-Use
HSC to MU 021-028-007 3.41 Unconstrained Yes, current 48 13 Highway Service
Commercial to
Mixed-Use
HSC to MU 021-028-008 2.06 Unconstrained Yes, current 29 14 General Commercial to
Mixed-Use GC to MU 021-098-003 8.53 Unconstrained Yes, current 120 Total Units 880
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Section 3.0 Housing Action Plan 3-15 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Pursuant to Government Code section 65583.2 subdivision (i), by-right means a jurisdiction shall not require the following:
 Conditional Use Permit;
 Planned Unit Development Permit;
 Design review other than Objective Development Design Standards; or  Other discretionary, local government review or approval that would constitute a “project” as defined in Section 2100 of the Public Resources Code (California Environmental Quality Act “CEQA”).

Sites 6, 8, and 9, have existing commercial uses, which are required to discontinue to redevelop the land for residential uses as outlined in Chapter 4, Housing Resources and Site Inventory. If the necessary zoning amendments for these sites are not completed by December 2025, the City will identify suitable and appropriately sized alternative site(s) to meet the RHNA within six months of the necessary zoning amendments not being completed. Identified alternative sites will be appropriately zoned, with the appropriate minimum acreage to allow for a capacity of at least 16 units per site, subject to the same by-right requirements pursuant to Government Code section 65583.2, subdivisions (h) and (i), etc., that the currently identified sites are subject to.

Program 1.12 By-Right Approval Requirements
5th Cycle Unaccommodated Need
Program H-1.A from the prior Housing Element included provisions to rezone sites to meet the RHNA for lower-income households. This program was implemented in 2020 through Resolution 2020-25, which approved the rezoning of 13.16 acres at Weber Avenue and First Street to High Density Residential, facilitating the development of approximately 300 lower-income units.

Timeline:  Complete zoning amendments by December 2025.  Identify alternative sites within 6 months of December 2025, if necessary.

Objectives:  880 lower-income units developed by June 2031 Performance Metric:  Sites 6-10 and 12-14 rezoned
 Sites 6, 8, and 9, existing uses discontinued by December 2025 Geographic Targeting: --
Responsible Agencies: Community Development Department
Funding Sources: General Fund
Implementing Policy:  Policy H-1 Ensure Adequate and Diverse Housing Supply Packet Pg. 1385
Section 3.0 Housing Action Plan 3-16 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Pursuant to Government Code Section 65583.2 subdivisions (h) and (i), the City will amend Resolution 2020-25 to include by-right provisions to permit multi-family development without discretionary review. Amendment of the resolution shall be completed by October 2025.

Previously Identified Housing Sites
Pursuant to Government Code Section 65583.2(c), sites identified in the 6th cycle housing inventory that were also included in previous planning periods are required to be approved by-right, with no discretionary review, when at least 20 percent of the residential units are designated as affordable for lower-income households. Table 3-4 outlines the housing opportunity sites subject to these mandatory provisions.

Timeline:  Housing developments with 20 percent affordability to lower-income households on prior identified sites, as described above, will be permitted by-right pursuant to Government Code section 65583.2, subdivision (i) upon adoption of the housing element with supplemental procedures to be established within three months of adoption.  Amend Resolution 2020-25 to include by-right provisions by October 2025.

Objectives:  Remove barriers to affordable housing development.

Performance Metric:  Number of lower-income units permitted during planning period.

Geographic Targeting: --
Responsible Agencies: Community Development Department
Funding Sources: General Fund
Implementing Policy:  Policy H-1 Ensure Adequate and Diverse Housing Supply Table 3-4 Sites Subject to By-Right Approval Provisions with 20% Affordable Units SOURCE: City of Patterson, 2024
NOTE: All sites identified in this table are analyzed in Chapter 4 of this Housing Element.

Program 1.13 Update Permit Database System
Efficient permit processing and enhanced public access to permitting information are essential for providing greater certainty in project development. Comprehensive databases are critical for accurately tracking and recording permit approvals. To improve these processes, the City will allocate resources to implement an online platform, such as iWorq or Accela, to monitor building Site Number APN Realistic Unit Capacity
5 047-034-035 60
10 048-048-007 283
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Section 3.0 Housing Action Plan 3-17 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 permits and increase public accessibility. This system will enhance record-keeping accuracy, support the timely completion of Annual Progress Reports (APR), and allow City staff to focus more directly on housing-related projects rather than addressing public inquiries regarding permit statuses.

Timeline:  Implement online database tracking platform by December 2028 Objectives:  Improve permit processing, increase public accessibility, and support timely completion of APRs.

Performance Metric:  N/A
Geographic Targeting: --
Responsible Agencies: Community Development Department
Funding Sources: General Fund
Implementing Policy:  Policy H-5 Facilitate Streamlined and Efficient Development Processes Program 1.14 Facilitating Development of the Zacharias & Baldwin Ranch Master Plan Areas The Zacharias and Baldwin Ranch Master Plan areas are both planned for within one master plan document.

Infrastructure Improvements
The Master Plan Area requires the expansion of water and wastewater systems to support future growth. To ensure the water and wastewater improvements are constructed in a timely manner, the City is committed to the following actions:
 Continue to actively pursue funding opportunities on an annual basis, such as Proposition 4, congressional funding, State Revolving Loan Funds, and other relevant funding sources to implement the necessary infrastructure to address water supply challenges and support ongoing development;
 The City will facilitate the phasing of infrastructure to enable timely residential development to meet the City’s RHNA;
 The City commits to charge developers their respective fair share payments as part of the larger needed improvements to the infrastructure required for development of the Master Plan Area including water, sewer, and stormwater;
 Require that all new development include stormwater retention and percolation on site;  Make its best efforts to begin design and environmental review of the Del Puerto Creek Project no later than December 2026;
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Section 3.0 Housing Action Plan 3-18 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025  Require purchase of surface water from all new development in the amount required to meet the water demand of developers’ projects;
 Capture storm water for recharge rather than discharge to Salado Creek and will help address the City’s use of the upper and lower aquifers;
 Expand the City’s Water Quality Control Facility by installing a membrane bioreactor superstructure in addition to other water quality improvements. This expansion will provide the City with the opportunity to further treat wastewater and convey it back to the City for nonpotable reuse or transfers with lower aquifer pumpers. Final design for the expansion has already been completed. Construction is anticipated to begin by the end of 2025;  The City is one of 23 Groundwater Sustainability Agencies responsible for implementation and compliance with the Delta Mendota Subbasin Groundwater Sustainability Plan (GSP).

Accordingly, the City is required to monitor and enforce compliance pursuant to State law.1 Program 1.14 is a necessary component of the City’s accountability and compliance with the GSP;
 The City will work with neighboring agencies to maximize beneficial use of the available storm water in the region by working with other water suppliers, including water and irrigation districts in the northern region of the Delta Mendota Subbasin to develop a regional solution for recharge consistent with and as required by the Sustainable Groundwater Management Act; and  The City will collaborate with developers to ensure the timely construction of infrastructure, thereby facilitating the readiness of residential units for occupancy within the eight-year planning cycle.

In December 2027, the City will conduct a mid-cycle review. If infrastructure improvements are not funded or underway by January 2028, the City will consider alternative land use strategies, such as identifying alternative sites with appropriate densities to support lower-income units, amending zoning or other land use documents to make suitable land available for housing development to meet the RHNA or increasing permitted residential densities to ensure no net loss. Alternative actions shall be completed by December 2028. The City will also continue to review potable water supply portfolios to ensure adequate water availability.

Residential Development
To facilitate the development of ADUs and JADUs alongside new single-family homes, the City will require that at least 15 percent of new single-family units in the Master Plan area include either an ADU or JADU. This requirement aims to promote a diverse mix of housing types within the new Zacharias and Baldwin Ranch South communities.
1 Water Code section 10727 et seq.

Packet Pg. 1388
Section 3.0 Housing Action Plan 3-19 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 To ensure housing targets are met, the City will closely monitor project approvals, denials, and postentitlement steps necessary to construct housing. The City will actively monitor building permit issuance for all residential units, including ADUs at least twice during the planning period, with the initial check point in June 2026 followed by June 2027. If development falls short of the target of 3,503 residential units by June 2027, the City will reassess its land use strategies and pursue alternative actions, such as amending zoning or other land use documents to meet RHNA requirements and ensure continued progress toward housing development goals by January 2028.

Subdivision Process
Further, the Master Plan area requires subdivision of parcels to accommodate residential uses. To ensure the subdivision process is completed promptly to facilitate residential development within the planning period, the City is committed to the following actions:
 Annually conducting outreach with property owners and non-profit affordable housing developers to maintain project momentum;
 Providing density bonuses in accordance with State law;  Reducing fees and expediting permitting processes to shorten time to market;  Offering technical assistance and resources, such as navigating regulatory requirements; and  Marketing the SB 35 by-right approval process when development plans include 20 percent affordable units.

Timeline:  Target completion of infrastructure improvements by December 2027  Monitor project approvals, denials, post-entitlement steps with check points in June 2026 and June 2027 in obtaining 3,503 residential building permits by June 2027  Annually apply for funding to support development of infrastructure  Pursue alternative actions, such as making necessary amendments to zoning or other land use documents to make available appropriate land for residential development by January 2028
 Complete alternative actions by December 2028
 Development of 3,840 units anticipated to be constructed in the Master Plan areas by 2031 Objectives:  356 very low-income units; 194 low-income units; 415 moderate-income units; 2,580 above moderate-income units; and 295 ADUs
Performance Metric:  Facilitate development in the Master Plan Area Geographic Targeting: --
Responsible Agencies: Community Development Department
Funding Sources: General Fund
Implementing Policy:  Policy H-1 Ensure Adequate and Diverse Housing Supply; Policy H-2 Promote Affordable Housing Development
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Section 3.0 Housing Action Plan 3-20 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Program 1.15 Water Supply to Support Development
The 2024 Groundwater Sustainability Plan (GSP) establishes a pumping reduction plan which requires the City to reduce its groundwater pumping to 2,626 acre-feet per year by 2030. Despite the pumping reduction plan, the City can still support additional development through the construction and implementation of water infrastructure projects funded by respective fair shares of proposed development, including the Del Puerto Creek Capture and Recharge Project, which was included as part of the Zacharias and Baldwin Ranch Master Plan.

To ensure this does not pose a constraint to the development of low-income residential units during the planning period, the City is committed to prioritizing water resources for low-income residential developments. The City has identified and is pursuing multiple options to support planned and future development, while remaining in compliance with the 2024 GSP. These options include:

1. Require water demand from future development to be offset by the purchase of surface water to be diverted for recharge in the Del Puerto Creek Project basins;

2. Continue to pursue funding opportunities on an annual basis to implement the necessary infrastructure to address water supply challenges and support ongoing development, including applying for the Bureau of Reclamation WaterSMART grant to fund project design of the Del Puerto Creek Project or any other water projects;

3. The City will provide flexibility in permit timing relative to needed infrastructure improvements, and facilitate the phasing of infrastructure to enable timely residential development to meet the City’s RHNA;

4. The City commits to charge developers their respective fair share payments as part of the larger needed improvements to the infrastructure required for development of the Master Plan Area including water, sewer, and stormwater;

5. Upon completion of the Del Puerto Creek Project, the City will recharge the total amount of purchased and delivered surface water to meet the increase in water demand as a result of development projects;

6. The City will require development projects with potable water demand to contribute to funding for an evaluation of a redesign of the existing storm water infrastructure associated with the Black Gulch Drainage Area. This Project will redesign the existing system to capture storm water for recharge rather than discharge to Salado Creek. This will address the City’s use of the upper and lower aquifers for water supply;

7. The City will work with neighboring agencies to maximize beneficial use of stormwater to develop a regional solution for recharge consistent with SGMA;

8. The City will coordinate and collaborate with property owners and developers on at least an annual basis to accelerate housing development;
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Section 3.0 Housing Action Plan 3-21 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025

9. Implement a recycled water program; and

10. Prioritize conservation.

In December 2027, the City will review the status of water infrastructure projects that support development of low-income residential units and assess whether alternative actions are needed to meet RHNA targets. If the City's infrastructure improvements are not underway by January 2028, the City will pursue alternative strategies to meet RHNA, such as identifying alternative sites with adequate infrastructure to support development, upzoning or increasing density to accommodate more residential units. Alternative actions shall be completed by December 2028. The City will also continue to review potable water supply portfolios to ensure adequate water availability.

Refer to Program 3.1 for City actions in support of water conservation.

Timeline:  Annually review overall progress and effectiveness in April and include information in annual report to HCD
 Annually apply for funding to support development of water infrastructure  Mid-cycle evaluation by December 2027
 Pursue alternative actions, such as making necessary amendments to zoning or other land use documents to make available appropriate land for residential development by January 2028
 Complete alternative actions by December 2028
Objectives:  1,770 low-income units permitted by June 2031 Performance Metric:  Ensure adequate water supply to support development of low-income residential units to meet RHNA
Geographic Targeting: City-wide
Responsible Agencies: Community Development Department
Funding Sources: General Fund
Implementing Policy:  Policy H-1 Ensure Adequate and Diverse Housing Supply  Policy H-2 Promote Affordable Housing Development
Program 1.16 Consistency with the General Plan
Being that the Housing Element represents one out of many elements that make up the General Plan, the City will ensure that the 6th Cycle Housing Element maintains uniformity with the remainder of the general plan elements. Implementation of housing element programs primarily impacts the following general plan elements: circulation, land use, and safety elements.

Throughout the planning period, City staff shall cross-compare the policies and programs found within this housing element to the other elements of the general plan to ensure internal consistency.

Any inconsistencies between the housing element and general plan shall be acknowledged and resolved. The City shall make use of zoning amendments to resolve any inconsistencies between the densities set forth in the housing element and zoning densities mentioned in other elements of the general plan. During the planning period, City staff shall set forth a schedule of anticipated updates Packet Pg. 1391
Section 3.0 Housing Action Plan 3-22 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 for the general plan elements. This program correlates to the implementation of Program 1.10 Remove Barriers to Multi-Family Residential Development, which outlines changes to the zoning code, and Program 1.11 Land Use and Zoning Amendments to Achieve RHNA Goals, which outlines several sites that require amendments to land use and zoning designations. See Program

1.10 and Program 1.11 for specific details.

Timeline:  Ongoing throughout the planning period
 Implement Program 1.10 Zoning Code changes by December 2025  Implement Program 1.11 land use and zoning amendments by December 2025 Objectives:  Cross-compare the Housing Element with other General Plan elements to ensure internal consistency
 Amend the zoning code, as necessary, to resolve any discrepancies between the General Plan elements
Performance Metric:  N/A
Geographic Targeting: City-wide
Responsible Agencies: Community Development Department
Funding Sources: General Fund
Implementing Policy:  Policy H-9 Ensure Consistency with the General Plan Program 1.17 Diversify and Expand the Housing Stock
The City is committed to diversifying and expanding Patterson's housing stock to meet the diverse needs of various demographic groups within high-opportunity areas. This effort will focus on regions south of Zacharias Road, west of State Route 33, north of Elfers Road, and east of Baldwin Road, including the City's Master Planned areas. The City is committed to the following actions:
 Review the General Plan, Zacharias and Baldwin Ranch Master Plan, and the Zoning Code and Zoning Map to identify opportunities for removing barriers to housing production, increasing housing capacity, and accommodating a variety of dwelling types, such as "missing middle" housing. Amendments will be recommended as needed to enhance housing capacity in highopportunity areas;  Identify opportunities to promote a greater variety of dwelling types and sizes, particularly those suitable for moderate-income households (e.g., duplexes, triplexes, fourplexes, and townhouses), in lower-density, higher-resource residential areas;
 Identify potential funding sources to support affordable housing developments for special-needs populations, including seniors, homeless individuals, female-headed households, large families, low-income households, and persons with disabilities. This will be achieved by monitoring government websites, grant databases, and leveraging regional resources such as the Stanislaus Regional Housing Authority; and
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Section 3.0 Housing Action Plan 3-23 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025  Facilitate the development of housing for persons with disabilities, including developmental disabilities, through incentives such as reduced development standards, fee waivers, and financial assistance for affordable housing development that includes necessary services, resources, and support.

Timeline:  Review General Plan, Master Plan, Zoning Code and Zoning Map by June 2026, adopt amendments by January 2027.
 Identify opportunities to promote a variety of dwelling units by June 2026, adopt amendments by January 2027.
 Annually identify funding sources to support affordable housing development.  Adopt incentives to facilitate development of housing for persons with disabilities by January 2027.

Objectives:  Diversify and expand the city’s housing stock in higher resource areas with a goal of encouraging the development of 150 missing middle/multifamily units in higher resource areas in the planning period.
 Prioritize and apply for grant opportunities that are most feasible to obtain and best fit the City’s needs, with a goal of obtaining $1 million in grant funding to support affordable housing development for special needs households in the planning period.  Support non-profit organizations and housing developers in creating 50 housing units for special needs households during the planning period or at least five units annually.

Performance Metric:  N/A
Geographic Targeting: City-wide, specifically high resource areas and Master Plan areas Responsible Agencies: Community Development Department
Funding Sources: General Fund
Implementing Policy:  Policy H-1 Ensure Adequate and Diverse Housing Supply Goal 2: Preserve and Improve Existing Housing Stock
Program 2.1 Property Inspection/Code Enforcement
The City will ensure all existing units meet basic health and safety standards by enforcing local codes. Code enforcement staff will regularly monitor neighborhoods, address violations as they arise, and respond to complaints.

In residential areas, especially those located east of State Route 33 and in the downtown area, the City will proactively offer information and assistance to property owners, including grants and loans through the City’s Minor Home Repair Program to address health and safety hazards. Other available programs include weatherization grants (Turlock Irrigation District, PG&E, State LIHEAP), home painting programs, and housing rehabilitation assistance, rebates on home improvements, and energy efficiency.

The City will affirmatively market these resources by:
 Posting information on the City’s website;
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Section 3.0 Housing Action Plan 3-24 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025  Providing written materials to community groups and local organizations representing lowerincome households, including the Patterson Family Resource Center; at City Hall; the Wednesday Farmer’s Market; and through various outlets, such as the quarterly City newsletter; and
 Distributing program details directly to property owners via mail.

The City will evaluate the feasibility of implementing annual rental inspections for multi-family developments with 10 or more units. These inspections, covering building exteriors, interiors, common areas, and basements (where applicable), would provide critical insights for the Housing and Code Enforcement Divisions, enhancing their ability to plan and respond effectively to residents' needs. However, due to current staffing and financial limitations, the City is not able to commit to the program at this time but will continue to assess its viability for future implementation.

Timeline:  Ongoing; review annually.
 Report code violations and enforcement activities to the City Council on monthly basis.  Multi-family rental inspections (December 2030)
Objectives:  Affirmatively market rehabilitation programs and assistance.  Investigate and address at least 5 code violations per month.  56 units rehabilitated (24 very low-, 24 low-, and 8 moderate-income units) during the planning period.
 Assess feasibility of implementing annual rental inspections for multi-family developments.

Performance Metric:  Number of code violations and complaints addresses.  Number of Minor Home Repair applications received annually.  Number of homes rehabilitated during planning period.  Number of inspections completed.

Geographic Targeting: City-wide, specifically east of State Route 33 and downtown Responsible Agencies: Community Development Department
Funding Sources: ARPA funds
Implementing Policy:  Policy H-3 Conserve and Preserve Existing Affordable Housing  Policy H-7 Protect and Stabilize Residential Neighborhoods Program 2.2 Conservation of Existing Affordable Housing The City has an inventory of 254 housing units that are deed-restricted as affordable housing; none are considered to be at-risk of converting to market-rate housing within the next 10 years. The City will continue to monitor the status of its affordable housing resources and work to conserve all units to the extent feasible. Further details regarding the City’s deed-restricted affordable units are provided in Chapter 1, Housing Needs and Constraints Assessment.

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Section 3.0 Housing Action Plan 3-25 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Timeline:  Ongoing; annually monitor.
 Report code violations and enforcement activities to the City Council on monthly basis.

Objectives:  Annually monitor the affordable units by maintaining contact with property owners regarding their intent to maintain the units as affordable housing, with the goal of preserving 254 affordable units in the inventory.
 When a Notice of Intent to convert from low-income housing to market-rate housing is received (three years in advance pursuant to State law), work with property owners to ensure that the tenants are properly noticed and provided information on potential resources for assistance, and any applicable displacement and relocation requirements are complied with. On an ongoing basis, work with nonprofit housing providers to pursue funding to preserve and improve existing affordable housing.

Performance Metric:  Number of units preserved during the planning period.

Geographic Targeting: City-wide, specifically east of State Route 33 Responsible Agencies: Community Development Department
Funding Sources: State HOME Funds
Implementing Policy:  Policy H-3 Conserve and Preserve Existing Affordable Housing  Policy H-7 Protect and Stabilize Residential Neighborhoods Goal 3: Exemplify Sustainable Development and Energy Conservation Program 3.1 Water and Energy Conservation Opportunities The City will continue to enforce Title 24 and California Green Building Standards Code requirements for energy conservation. To enforce water conservation and support the reduction of groundwater pumping, the City will pursue the feasibility of implementing the following measures:
 Water Use Restrictions: By October 2025, the City shall establish limits on water usage during peak demand periods or drought conditions, such as restricting outdoor irrigation or limiting water-intensive activities like car washing;
 Land Use and Development Restrictions: By January 2026, the City shall implement an ordinance establishing land use and development restrictions that mandate water-efficient designs and landscaping for new developments, including drought-resistant plants and efficient irrigation systems; and
 Fines for Non-Compliance: By June 2026, the City shall impose fines or penalties for violators of water conservation rules, such as exceeding water usage limits or failing to follow mandated watering schedules.

In residential areas, the City will continue to proactively offer rebate program assistance to property owners, including the following City rebate programs:
 Cash for Grass Rebate Program: aims to permanently reduce the amount of water used for landscaping purposes. The City offers $1.00 for every square foot of turf removed and replaced with drought-resistant or water-efficient landscaping;
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Section 3.0 Housing Action Plan 3-26 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025  High Efficiency Toilet Rebate Program: involves replacing high-water-use toilets with low-flush toilets, which are estimated to save approximately 38 gallons of water each day. The rebate amount for a qualifying high-efficiency toilet (1.28 gallons per flush or less) is $100; and  Water Conservation Program: provides free low-flow bathroom and kitchen aerators, free showerheads, and free toilet leak detection tablets are available.

Local utility providers, such as Turlock Irrigation District (TID) and Pacific Gas and Electric (PG&E), offer additional rebate programs that assist lower-income households and support city energy conservation goals (see Chapter 2, Table 2-15 for list of these programs).

Based on available resources, the City shall develop and periodically update energy efficiency and water conservation awareness brochures, and provide them in all publicly accessible City buildings and in the City’s quarterly newsletter. All educational materials will be developed in English and Spanish.

Timeline:  Review annually and report in APR
 Establish water use restrictions by October 2025
 Implement land use and development restrictions by January 2026  Impose fines/penalties by June 2026
Objectives:  20 rebate program applications per year.

Performance Metric:  Number of rebate program applications received per year Geographic Targeting: City-wide, specifically east of State Route 33 Responsible Agencies: Community Development Department
Funding Sources: General Fund
Implementing Policy:  Policy H-6 Promote Sustainable and Energy-Efficient Housing  Policy H-7 Protect and Stabilize Residential Neighborhoods Goal 4: Provide New Affordable and Other Special Needs Housing Program 4.1 Reasonable Accommodation and Housing for Persons with Disabilities In 2015, the City amended its Zoning Ordinance to provide a procedure to request reasonable accommodations for persons with disabilities seeking equal access to housing under the Fair Housing laws in the application of zoning laws, building codes, and other land use regulations, policies, and procedures (Municipal Code Chapter 18.89).

The Municipal Code does not restrict who can appeal a request for reasonable accommodation, which could hinder approval if individuals unrelated to the request oppose it. To address this potential constraint, the City will amend the Municipal Code to limit the parties eligible to appeal a request for reasonable accommodation to the applicant or the personal beneficiary.

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Section 3.0 Housing Action Plan 3-27 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 The Municipal Code provides “potential impact on surrounding uses” as one of the determining factors for approval or denial of reasonable accommodation requests. The City recognizes that this language is subjective and may hinder the approval of reasonable accommodation requests. The City will amend the Municipal Code to remove this language.

To affirmatively market fair housing opportunities for persons with disabilities, the City is committed to the following actions:
 Conduct annual meetings with developers to encourage development of projects targeted to persons with disabilities;
 Conduct annual educational workshops for landlords and tenants;  Apply for County, State, and Federal funding as available (ARPA) for housing construction and rehabilitation for persons with disabilities; and
 Continue enforcing Building Code requirements for the inclusion of adaptable disabled accessible units in multifamily development projects that are subject to such requirements.

Timeline:  Amend Municipal Code by December 2026.
 Conduct meetings with developers annually.
 Host educational workshops for landlords and tenants annually.  Apply for Funding as available from State and Federal sources.

Objectives:  5 accessible units for residents with disabilities; match 5 landlords with accessible units to tenants
Performance Metric: Number of accessible units constructed; number of landlord-tenant matches Geographic Targeting: City-wide, with emphasis in areas east of SR 33 Responsible Agencies: Community Development Department
Funding Sources: General Fund
Implementing Policy:  Policy H-1 Ensure Adequate and Diverse Housing Supply  Policy H-4 Support Housing for Special Needs and Vulnerable Populations Program 4.2 Universal Design to Encourage Housing for Seniors and Persons with Limited Mobility
Universal Design allows for new construction and home modifications that enhance the full life cycle use of housing in order to accommodate a wide range of physical abilities or disabilities of a home’s occupants. This is particularly relevant to seniors and allows residents to age in place and remain in a particular unit for a longer period of time.

The City recognizes the California Building Code is integrating many design features for persons with limited mobility. The City will consider adopting an ordinance to allow for Universal Design elements that address limited lifting (e.g. roll-in showers and grab bars), limited mobility Packet Pg. 1397
Section 3.0 Housing Action Plan 3-28 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 (e.g. push/pull lever faucets, wide swing hinges) and limited vision (e.g. additional stairwell and task lighting) pursuant to Health and Safety Code section 17959, at the next International Building Code Update Adoption.

Timeline:  Adopt Universal Design Ordinance by December 2026.

Objectives:  30 accessible units by the end of planning period.

Performance Metric:  Number of accessible units constructed Geographic Targeting: City-wide, with emphasis in areas east of SR 33 Responsible Agencies: Community Development Department
Funding Sources: General Fund
Implementing Policy:  Policy H-1 Ensure Adequate and Diverse Housing Supply  Policy H-4 Support Housing for Special Needs and Vulnerable Populations Program 4.3 Residential Care Facilities
Residential care facilities are a type of supportive housing essential to residents that are living with disabilities. These facilities provide flexible and affordable housing options, and allow persons with disabilities to live in deinstitutionalized settings in a manner that helps them integrate into local communities. In accordance with Health and Safety Code Section 1568.0831, the City will implement the following amendments to the Municipal Code:
 Residential Care Facilities Without Licensable Services: Residential care facilities that function as single-family residences and do not offer licensable services shall be permitted in all zones that permit residential uses. These homes shall only be subject to the general health, safety, and zoning laws applicable to all single-family residences, regardless of having more than six residents. Since these homes do not provide licensable services, they should be treated like any other single-family residence;
 Residential Care Facilities with Licensable Services for Six or Fewer Residents:

Residential care facilities operating as single-family residences and providing licensable services to six or fewer residents shall be permitted in all zones that permit residential uses. They shall only be subject to the general health, safety, and zoning laws applicable to all single-family residences, in compliance with the Health and Safety Code protections for these smaller, licensed group homes; and
 Residential Care Facilities with Licensable Services for More Than Six Residents:

Residential care facilities that provide licensable services to more than six residents shall be permitted in all zones that permit residential uses. They shall be subject only to provisions for residential uses of the same type in the same zone.

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Section 3.0 Housing Action Plan 3-29 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Reasonable accommodations in these permitting processes shall be considered when an application for reasonable accommodation is submitted.

Timeline:  Amend Municipal Code by December 2026.

Objectives:  Amend Municipal Code to define and establish permitting procedures for residential care facilities.

Performance Metric:  N/A
Geographic Targeting: City-wide
Responsible Agencies: Community Development Department
Funding Sources: General Fund
Implementing Policy:  Policy H-1 Ensure Adequate and Diverse Housing Supply  Policy H-4 Support Housing for Special Needs and Vulnerable Populations Program 4.4 Facilitating the Development of Affordable Senior Housing – Phase 2 Las Palmas Senior Apartments
Phase two of the Las Palmas Senior Housing Complex is underway and will provide 16 deedrestricted, very low-income senior housing units. The Housing Authority is currently in the design phase, and these units are included in the site inventory as Site 3.

The City shall support the Stanislaus Regional Housing Authority’s plans for the 16-unit expansion of the Las Palmas Senior Housing Complex by sourcing potential funding opportunities for development, including CDBG, HOME, and other available funding.

Additionally, the City will continue to support and market the efforts of local nonprofit agencies that provide direct housing assistance to seniors. The City will prioritize developments that include units for seniors. In an effort to increase outreach on housing opportunities for seniors, the City will affirmatively market by:
 Posting information on the City website and distributing information via mail;  Providing materials at City Hall and the Hammon Senior Center;  Distributing information at City events like the Wednesday Farmer’s Market; and  Working with local nonprofits that assist low-income households, including the Patterson Family Resource Center and HOST House.

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Section 3.0 Housing Action Plan 3-30 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Timeline:  Complete by June 2031.

Objectives:  16 deed-restricted very low-income senior housing units.

Performance Metric:  Number of deed-restricted very low-income units permitted by end of planning period.

Geographic Targeting: City-wide, specifically, 1075 Las Palmas Avenue Responsible Agencies: Community Development Department
Funding Sources: General Fund
Implementing Policy:  Policy H-1 Ensure Adequate and Diverse Housing Supply  Policy H-2 Promote Affordable Housing Development
 Policy H-4 Support Housing for Special Needs and Vulnerable Populations Program 4.5 Family-Friendly Housing
The City will promote multi-family housing designs and unit mixes that attract multi-generational households by encouraging developers to include housing features such as larger units with more bedrooms (including four-bedroom units) and on-site amenities like usable outdoor open spaces for multigenerational use. Additionally, the City will encourage the inclusion of multi-purpose rooms that can be used for after-school homework clubs, computer labs, art activities, or other resident programs. To incentivize developers, the City will offer expedited permit processing, fee waivers, fee deferrals or reductions by 50 percent for projects that include family-sized deed-restricted units with four or more bedrooms.

To address potential displacement of households with four or more persons, the City will research options to expand regulatory incentives to encourage the development of larger units.

Timeline:  Develop regulatory incentive by June 2026
Objectives:  15 family-friendly designated units (four bedroom units).

Performance Metric:  Number of family-friendly designated units permitted by end of planning period.

Geographic Targeting: City-wide, specifically east of State Route 33 Responsible Agencies: Community Development Department
Funding Sources: General Fund
Implementing Policy:  Policy H-1 Ensure Adequate and Diverse Housing Supply  Policy H-2 Promote Affordable Housing Development
 Policy H-4 Support Housing for Special Needs and Vulnerable Populations Packet Pg. 1400
Section 3.0 Housing Action Plan 3-31 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Program 4.6 Facilitating the Development of Emergency Shelters Pursuant to AB 2339, the City will amend the Zoning Ordinance to amend the definition of emergency shelters to include other interim interventions, including but not limited to, navigation centers, bridge housing, and respite or recuperative care.

Currently, the City of Patterson’s Zoning Ordinance permits emergency shelters in all residential zones with a Conditional Use Permit. However, the City has an Emergency Shelter Overlay Zone, which is detailed in Chapter 18.58 of the City’s Zoning Ordinance, last updated in 2015. The Emergency Shelter Overlay Zone applies to the City’s Heavy Industrial (HI) Zoning District, which does not permit residential uses.

In compliance with Government Code Section 65583(3)(4)(a), the City will amend the Municipal Code, to remove reference to the Emergency Shelter Overlay Zone and permit emergency shelters by-right, without a conditional use or other discretionary permit in the Downtown Core (DC) Zoning District.

Pursuant to SB 2, the City will amend the Zoning Ordinance to revise the development standards for Emergency Shelters to be consistent with State law. The following standard is subjective and increases uncertainty for development, and will be eliminated from Section 18.58.100:
 The size of an emergency facility shall be in character with the surrounding neighborhood.

Additionally, the City will amend the development standards for emergency shelters to allow proximity requirements in compliance with Government Code Section 65583(a)(4), such that emergency shelters shall not be required to be more than 300 feet apart.

In accordance with AB 139, the City will amend the Zoning Ordinance to specify that parking standards for emergency shelters may be limited only to accommodate the number of staff working in the emergency shelter, provided that the standards do not require more parking for emergency standards than other residential or commercial uses within the same zone.

Timeline:  Amend Municipal Code by December 2026.

Objectives: N/A
Performance Metric: N/A
Geographic Targeting: City-wide
Responsible Agencies: Community Development Department
Funding Sources: General Fund
Implementing Policy:  Policy H-1 Ensure Adequate and Diverse Housing Supply  Policy H-4 Support Housing for Special Needs and Vulnerable Populations Packet Pg. 1401
Section 3.0 Housing Action Plan 3-32 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Program 4.7 Low Barrier Navigation Centers
A low barrier navigation center (LBNC) is defined as a housing first, low-barrier, temporary, serviceenriched shelter aimed at helping homeless individuals and families quickly access permanent housing. "Low barrier" refers to practices that minimize entry obstacles, such as allowing partners, pets, personal item storage, and ensuring privacy (Gov. Code, § 65660). Under AB 101, a low barrier navigation center must be permitted by right in areas zoned for mixed-use and nonresidential zones that allow multi-family uses, provided it meets specific criteria, including:
1) Access to permanent housing;
2) Utilization of a coordinated entry system (e.g., Homeless Management Information System); and 3) Implementation of the Housing First approach, as defined in Welfare and Institutions Code section 8255 (Gov. Code, § 65662).

In compliance with AB 101, the City will amend its Municipal Code to define low barrier navigation centers and permit them by right in zones allowing mixed-use and nonresidential zones permitting multi-family uses.

Timeline:  Amend Municipal Code by December 2026.

Objectives:  N/A
Performance Metric:  N/A
Geographic Targeting: City-wide
Responsible Agencies: Community Development Department
Funding Sources: General Fund
Implementing Policy:  Policy H-1 Ensure Adequate and Diverse Housing Supply  Policy H-4 Support Housing for Special Needs and Vulnerable Populations Program 4.8 Supportive Services for Individuals Experiencing Homelessness Since 2012, the City of Patterson has supported Helping Other Sleep Tonight (HOST) House, a nonprofit addressing homelessness in Patterson, by providing a low-interest loan for transitional housing. The City has since expanded its support, including loan forgiveness and collaboration on educational programs, enabling HOST House to operate year-round. To continue supporting local nonprofit agencies assist persons experiencing homelessness, the City is committed to the following actions:
 Providing technical assistance in pursuing funding opportunities, such as Homeless Housing, Assistance, and Prevention (HHAP) Grant funding;
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Section 3.0 Housing Action Plan 3-33 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025  Seeking innovative partnerships to provide services and emergency shelter to unsheltered persons;
 Encouraging developers to set aside units affordable to extremely low-income households; and  Supporting countywide efforts to prevent and end homelessness through the Stanislaus Regional Homeless Strategic Plan. The City will monitor the progress of the Stanislaus Regional Homeless Strategic Plan through participation in collaborative groups, including working committees, and will continue to evaluate actions proposed in the County's Homeless Strategic Plan to provide additional shelter and safe spaces for Newman's unsheltered population.

For residents experiencing homelessness, the City will maintain a list of service providers, and will recommend the following resources to residents in need of shelter or housing:
 HOST House (City of Patterson);
 Patterson Family Resource Center (City of Patterson);  Stanislaus County Habitat for Humanity (City of Modesto);  Haven Women’s Center of Stanislaus (City of Turlock);  We Care Program (City of Turlock); and
 The Salvation Army of Modesto Citadel Corps.

Additionally, the City shall continue to participate in the Stanislaus County Point-in-Time (PIT) Count to quantify local homeless populations and others with a need for emergency shelter.

Timeline:  Ongoing; review annually
Objectives:  10 residents referred.

Performance Metric:  Number of residents referred to service providers.

Geographic Targeting: City-wide
Responsible Agencies: Community Development Department
Funding Sources: General Fund
Implementing Policy:  Policy H-1 Ensure Adequate and Diverse Housing Supply  Policy H-4 Support Housing for Special Needs and Vulnerable Populations Packet Pg. 1403
Section 3.0 Housing Action Plan 3-34 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Program 4.9 Transitional and Supportive Housing
Government Code Section 65583(a)(5) requires local jurisdictions to permit transitional and supportive housing as a residential use only subject to those restrictions that apply to other residential dwellings of the same type in the same zone. Furthermore, recent changes to State law require supportive housing to be permitted by right where multi-family and mixed-uses are permitted, including non-residential zones permitting multi-family uses (Government Code section 65651). AB 2162 prohibits the imposition of parking requirements for supportive housing developments within 0.5 mile of a public transit stop.

Currently, the City of Patterson permits transitional and supportive in accordance with State law.

However, the Municipal Code requires updates to reflect such changes. The City will amend the Municipal Code, in compliance with Government Code Section 65583(a)(5) to permit transitional and supportive housing in all zones that allow residential uses, subject only to the restrictions that apply to other residential dwellings of the same type in the same manner. Additionally, in accordance with AB 2162, the Municipal Code will be amended to permit supportive housing by right in zones where multi-family and mixed-uses are permitted, including nonresidential zones that allow multifamily uses. Amendments to parking requirements for supportive housing will also be implemented in accordance with AB 2162.

Timeline:  Amend Municipal Code by December 2026.

Objectives:  Remove barriers to affordable housing development.

Performance Metric:  N/A
Geographic Targeting: City-wide
Responsible Agencies: Community Development Department
Funding Sources: General Fund
Implementing Policy:  Policy H-1 Ensure Adequate and Diverse Housing Supply  Policy H-4 Support Housing for Special Needs and Vulnerable Populations Program 4.10 Single-Room Occupancy Units (SROs)
Single-room occupancy units provide a valuable source of affordable housing for individuals and can serve as an entry point into the housing market for people who previously experienced homelessness. Pursuant to Government Code Section 65583(c)(1), promote fair housing, and increase the availability of units for lower-income households, the City will amend the Municipal Code to define single-room occupancy units and permit them by-right in all zones that allow mixeduse development.

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Section 3.0 Housing Action Plan 3-35 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Timeline:  Amend Municipal Code by December 2026.

Currently, the City’s Zoning Ordinance does not define employee or farmworker housing and does not distinguish employee or farmworker housing from any other type of single- or multi-family housing. The City shall update the Zoning Ordinance to add a definition for “employee and farmworker housing” to be consistent with Employee Housing Act (Health and Safety Code Section 17021). Additionally, the City will amend the Zoning Ordinance to explicitly list employee and farmworker housing as permitted uses in accordance with Health and Safety code Section 17021.

The City has 40 deed-restricted affordable farmworker housing units managed by the Stanislaus Regional Housing Authority. The City will continue to work with the Stanislaus Regional Housing Authority and the Office of Migrant Services (OMS) to provide services to farmworkers and expand farmworker housing in other areas of the city. Specifically, the City will make an effort to assist in the development of housing for employees and farmworkers and conserve and improve the existing housing stock, by taking the following actions which include, but are not limited to:
 Contacting non-profit developers annually to identify opportunities for the development or improvement of housing for employees and farmworkers;
 Coordinating and participating annually with regional organizations that serve farmworkers, including non-profits, academic institutions, and employers (e.g.: Stanislaus Regional Housing Authority, Office of Migrant Workers, Patterson Family Resource Center, Self-Help Enterprises, Farmworkers Institute of Education and Leadership) to raise awareness, share and employ strategies, and identify or target new resources;
Packet Pg. 1405
Section 3.0 Housing Action Plan 3-36 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025  Reaching out to local farm employers to identify housing needs, and seeking funding to support further development or rehabilitation of farmworker housing;  Working with partner organizations and agencies to conduct an additional survey of farmworker housing needs at least once during the planning period and adjusting farmworker-serving programs to match updated needs if appropriate;
 Coordinating annually with organizations that represent farmworkers;  Annually monitoring the status of farmworker housing as part of their annual report to HCD on Housing Element progress and evaluate if City efforts are effective in facilitating the provision of farmworker housing. If appropriate, the City will make necessary changes to enhance opportunities and incentives for farmworker housing development; and  Providing bilingual materials on available resources and financial assistance on the City’s website and with printed materials at City offices, Patterson Public Library and community centers within the city.

Timeline:  Amend Municipal Code by December 2026.
 Contact non-profit developers to discuss development opportunities annually.  Coordinate with regional organizations annually.

Objectives:  20 additional employee/farmworker units constructed.

Performance Metric:  Number of employee/farmworker residential units permitted during the planning period.

Packet Pg. 1406
Section 3.0 Housing Action Plan 3-37 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 To encourage the development of ADUs, the City will implement the following actions:
 Maintain a webpage on the City’s website to inform the public on the benefits of ADUs; post informational materials, such as the Accessory Dwelling Unit Handbook published by the State Department of housing and Community Development (HCD); post local regulations, and example floor plans;
 Provide pre-approved ADU plans to provide a more streamlined process for property owners and developers, and will City will track the popularity of ADU plans implemented and provide targeted financing and outreach to facilitate the plans that are most viable within the community;  Promote ADU development with an annual workshop on ADU development with building inspector and planners;
 Waive City building permit fees for units that are 749 square feet or less. The City will utilize affordable housing in-lieu fees to cover building permit fees at a specific percentage; and  Evaluate funding, including low-interest loans to promote the development and affordability of ADUs in the City. Funding sources may include CalHFA ADU Grant Program; CalHome Program; LEAP Grants; REAP Grants; and SB 2 Planning Grants.

Amnesty for Unpermitted ADUs
The City understands that unpermitted ADUs and JADUs are present within Patterson, and that these properties are normally subject to code enforcement. The City is currently updating its ADU Ordinance to include a grandfather provision for unpermitted ADUs and JADUs, as well as an approval process for new permit applications that includes ministerial approval consistent with State ADU Law. 2
This will increase the amount of affordable housing available to the city’s students, elderly, in-home health care providers, the disabled, and others, at below market prices within existing neighborhoods. The Amnesty Program will apply to existing ADUs/JADUs in the City and will run from January 2027 through January 2030.

The City will offer the following benefits under the Amnesty Program:
 Low-cost initial inspection of the unpermitted unit;
 Suspension of code enforcement action for necessary improvements made that are identified by Codes and Standards pursuant to inspections under the Amnesty Program;  A certification record, which will be supplied to the applicant and kept on file at the City, memorializing the improvements and assuring that there will be no subsequent code enforcement related to those improvements upon completion and inspection; 2 Government Code section 66314 et seq
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Section 3.0 Housing Action Plan 3-38 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025  Detailed guidance on required improvements;
 Significant reduction or waiver of planning, building, and other permit fees;  Assurance that the accessory dwelling unit is habitable and does not present risks to inhabitants; and
 The opportunity to explore the program, prior to formal application, without risk of any penalty or enforcement.

Timeline:  Amend ADU Ordinance by December 2026.
 Develop ADU informational webpage and pre-approved ADU plans by June 2025.  Host workshop on ADU development annually.
 Pursue funding opportunities annually.
 Formalize and implement Amnesty Program by December 2026.  Host Amnesty Program for 3 years (January 2027 to January 2030).

Objectives:  Construction of 50 ADUs
 25 ADUs/JADUs legalized (permitted) by June 2031
Performance Metric:  Number of ADUs/JADUs permitted by the end of the planning period  Number of ADUs/JADUs brought up to code and permitted under the Amnesty Program Geographic Targeting: City-wide
Responsible Agencies: Community Development Department
Funding Sources: General Fund
Implementing Policy:  Policy H-1 Ensure Adequate and Diverse Housing Supply  Policy H-2 Promote Affordable Housing Development
 Policy H-3 Conserve and Preserve Existing Affordable Housing  Policy H-4 Support Housing for Special Needs and Vulnerable Populations  Policy H-7 Protect and Stabilize Residential Neighborhoods Program 4.13 Affordable Housing Water and Sewer Priority In accordance with Chapter 727, Statutes of 2004 (SB 1087), following the adoption or amendment of a Housing Element, local governments are required to promptly distribute copies to relevant water and sewer service providers. These providers are mandated to prioritize service allocations for developments that include housing units affordable to lower-income households. The purpose of this legislation is to enhance the effectiveness of existing laws in promoting housing development for lower-income families and workers.

Upon certification, the City will forward its adopted Housing Element to the Public Works Department, ensuring that priority is given to affordable housing developments for water and sewer service allocations. Furthermore, the City will establish a water distribution policy to ensure that water allocations are aligned with its regional housing needs.

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Section 3.0 Housing Action Plan 3-39 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Timeline:  Develop written procedures for water and sewer priority by June 2025.  Forward Adopted Housing Element to City’s Public Services Department upon Housing Element certification.

Objectives:  Prioritize water and sewer services for lower-income households.  2,266 lower-income units permitted during the planning period.

Performance Metric:  Number of lower-income units permitted during the planning period.

Geographic Targeting: City-wide
Responsible Agencies: Community Development Department
Funding Sources: General Fund
Implementing Policy:  Policy H-2 Promote Affordable Housing Development  Policy H-4 Support Housing for Special Needs and Vulnerable Populations  Policy H-5 Facilitate Streamlined and Efficient Development Processes Goal 5: Implement meaningful actions to affirmatively further fair housing.

Program 5.1 Affirmatively Furthering Fair Housing
The City is committed to Affirmatively Furthering Fair Housing (AFFH) in the community. Key actions include:
 Collaborating with organizations to eliminate housing discrimination in Patterson;  Supporting diverse housing types to promote mobility; pursuing policies to prevent economic displacement;
 Ensuring affordable housing is distributed citywide to avoid concentrated low-income areas; and  Applying place-based strategies for neighborhood improvement.

A comprehensive list of all programmatic actions to affirmatively further fair housing are listed in Table 3-5 at the end of this section. This table includes associated objectives, metrics, and timelines for completion for each program.

Program 5.2 Anti-Displacement Strategy
In combination with other programs in this Housing Element, the City will adopt a multi-pronged anti-displacement strategy to address the increasing income gap and rising housing costs. This strategy will focus on encouraging affordable housing production, preserving existing affordable housing, and protecting current residents from displacement, especially in areas located east of State Route 33 – where cost burdens overlap with poverty, overcrowding, and a predominantly Hispanic/Latino population.

The City will explore the following strategies and commit to adopting one or more:
 Production: Increase opportunities for multi-family and mixed-use developments citywide to exceed RHNA requirements;
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Section 3.0 Housing Action Plan 3-40 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025  Preservation: Partner with HOST House to promote home-sharing and temporary shelter services. Collaborate with the Stanislaus Regional Housing Authority to acquire affordable units at risk of converting to market rate. Designate a code enforcement specialist to assist property owners of low-income units with code issues, seek funding for rehabilitating substandard multifamily units, and restrict converting existing low-income units to short-term rentals;  Protect Current Residents: Provide links to Stanislaus Regional Housing Authority website for affordable rental units on the City’s Fair Housing webpage. Partner with nonprofits serving underserved residents to share information on fair housing and tenant rights. Implement a first right of refusal for Below Market Rate (BMR) units for displaced residents. Develop a rental assistance program to provide financial assistance to extremely low-income renters; and  Engagement: Develop a strategy to distribute information on tenant protections, including source of income, state rent stabilization, and just cause eviction regulations.

The City will engage the public in developing this Anti-Displacement Strategy through community events focusing in areas located east of State Route 33. Outreach will consider high rates of linguistic isolation and provide materials in Spanish.

Timeline:  Complete targeted engagement in 2025-2026.
 Adopt Anti-Displacement Strategy by March 2027.

Objectives:  50 lower-income units beyond the RHNA, with a target of 20 percent for seniors and residents with a disability.

Performance Metric:  Number of lower-income units permitted beyond the RHNA.

Geographic Targeting: Citywide, specifically, east of SR 33 Responsible Agencies: Community Development Department
Funding Sources: General Fund
Implementing Policy:  Policy H-1 Ensure Adequate and Diverse Housing Supply  Policy H-2 Promote Affordable Housing Development
 Policy H-3 Conserve and Preserve Existing Affordable Housing  Policy H-4 Support Housing for Special Needs and Vulnerable Populations  Policy H-7 Protect and Stabilize Residential Neighborhoods  Policy H-8 Promote Fair Housing and Equal Opportunity Program 5.3 Affirmatively Market Fair Housing Resources The City shall continue to promote equal housing opportunity for all persons regardless of race, religion, sex, sexual orientation, marital status, ancestry, nation origin, or color by supporting efforts of community groups which provide counseling, investigatory, legal or referral to victims of discrimination. The City is committed to the following actions:

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Section 3.0 Housing Action Plan 3-41 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025  Maintain information on state and federal fair housing laws and tenant protections, including source of income, state rent stabilization, just cause eviction regulations, and other related State laws in English and Spanish on the City’s website and at City locations (City Hall, police station, library, fire department, schools, etc.) for public distribution;  Utilize a bilingual individual at the City to refer victims of housing discrimination to Project Sentinel, a HUD-approved housing counseling agency, or to the State Fair Employment and Housing Commission; and
 Work with affordable housing developers and landlords to ensure that affordable housing is affirmatively marketed to households with disproportionate housing needs. The City will notify a broad representation of the community to solicit ideas for housing strategies when they are discussed at Planning Commission or City Council meetings. Specific outreach activities include:
• Send public notices to all interested public and non-profit agencies and affected property owners, including posting notices at City bulletin boards/locations, in local newspapers, and online at the City’s website;
• Conduct outreach (workshops, neighborhood meetings) to the community as Housing Element programs are implemented and announce workshops/meetings in City newsletter; and
• Market listings for affordable housing as available.

Timeline:  Ongoing; review annually
Objectives:  10 fair housing cases reported to local or state agencies during the planning period.  50 affordable units marketed and occupied during the planning period.

Performance Metric:  Number of fair housing cases reported to local or state agencies.  Number of affordable units marketed to the public.

Priority will be given to projects with units affordable to extremely low- and very low-income households. Key funding sources include:
 HUD Funds: The City will apply to HUD funds to facilitate the development of rental housing, homeownership opportunities, special needs housing, and tenant-based rental assistance;  Low Income Tax Credits: The City will seek federal and state tax credits for the development of lower-income housing;
 State-funded programs: The City will utilize available state funds for affordable housing; and  Permanent Local Housing Allocation (PLHA) grant: The City will apply for the PLHA Grant, which provides funding to local governments for housing-related projects and programs that assist in addressing the unmet housing needs of their local communities.

Timeline:  Ongoing; pursue funding opportunities annually Objectives:  Acquire revenue from various state and federal funds for use in affordable housing.

Performance Metric:  Amount of funding gathered and allocated towards low-income households.

Geographic Targeting: City-wide, prioritize areas east of SR 33 Responsible Agencies: Community Development Department
Funding Sources: HUD, PLHA grant, tax credits and other grants and programs, as applicable.

Implementing Policy:  Policy H-1 Ensure Adequate and Diverse Housing Supply  Policy H-2 Promote Affordable Housing Development
 Policy H-3 Conserve and Preserve Existing Affordable Housing  Policy H-4 Support Housing for Special Needs and Vulnerable Populations  Policy H-7 Protect and Stabilize Residential Neighborhoods  Policy H-8 Promote Fair Housing and Equal Opportunity Packet Pg. 1412
Section 3.0 Housing Action Plan 3-43 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Program 5.5 First-Time Homebuyer Downpayment Assistance The City has previously used HOME funds or alternative funding sources to assist with first-time homebuyer down payment assistance scaled to economic conditions for each qualified household as determined by the City Council. During the 5th Cycle, five households took advantage of the FirstTime Homebuyer Downpayment Assistance program. To gauge how the program can be revised, the City will conduct a survey targeting households that previously received downpayment assistance. The City will implement changes to the program by June 2026 aimed at providing assistance to more households.

To advertise and increase use of the First-Time Homebuyer Downpayment Assistance program, the City is committed to the following actions:
 Target Patterson employees to better understand how to restructure the program to meet their housing needs;
 Maintain a webpage on the City’s website to inform the public on the First-Time Home Buyer Downpayment Assistance program;
 Promote the program and educate residents and Patterson employees with an annual workshop on City offered first-time homebuyer assistance; and
 Partner with local developers and the Stanislaus Regional Housing Authority to market the program for income-restricted for-sale units.

The City has funding for approximately two loans per year, totaling about 10 total. If a minimum of six households have not taken advantage of the program by Spring 2028, the City will evaluate alternative actions to increase success of the program, and provide a measurable impact on lowincome households.

Timeline:  Annually
Objectives:  Provide financial assistance to at least six low-income families per year Performance Metric:  Number of residents that receive Down-payment assistance each year Geographic Targeting: City-wide
Responsible Agencies: Community Development Department
Funding Sources: General Fund
Implementing Policy:  Policy H-2 Promote Affordable Housing Development  Policy H-3 Conserve and Preserve Existing Affordable Housing  Policy H-4 Support Housing for Special Needs and Vulnerable Populations  Policy H-8 Promote Fair Housing and Equal Opportunity Packet Pg. 1413
Section 3.0 Housing Action Plan 3-44 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Program 5.6 Housing Choice Voucher (HCV) Program
The City shall continue to cooperate with the Stanislaus Regional Housing Authority in its administration of the Housing Choice (Section 8) rental assistance program. Specifically, the City shall encourage the Housing Authority to seek out and provide assistance to extremely low- and very low-income households. The City shall publicize the Housing Choice Voucher Program rental assistance program through marketing efforts, including brochures made available at City Hall and distributed to local organizations that directly work with lower-income households, such as the Patterson Family Resources Center and HOST House.

Timeline:  Ongoing; review annually
Objectives:  10 vouchers
Performance Metric:  Number of vouchers utilized during the planning period.

Geographic Targeting: City-wide, specifically east of SR 33 Responsible Agencies: Community Development Department
Funding Sources: General Fund
Implementing Policy:  Policy H-2 Promote Affordable Housing Development  Policy H-3 Conserve and Preserve Existing Affordable Housing  Policy H-4 Support Housing for Special Needs and Vulnerable Populations  Policy H-8 Promote Fair Housing and Equal Opportunity Program 5.7 Targeted Capital Improvement Program Investment To ensure adequate infrastructure in all areas, particularly moderate resource areas located east of State Route 33 and in the downtown area, as well as newly annexed master planned areas, the City has identified several infrastructure projects in their Capital Improvement Program (CIP) for the 2025-26 fiscal year. These include park enhancements, lighting upgrades, street improvements, bike trails, pedestrian pathways, ADA crosswalk upgrades, storm drain improvements, sewer system upgrades, and water infrastructure improvements.

These projects will be funded through various sources, including CDBG funds, Measure L funds, Urban Green grants, Highway Bridge Program grants, Congestion Mitigation and Air Quality funds, Proposition 4 funds, congressional funding, State Revolving Loan Funds, Community Facility District funds, and impact fees. To further offset and mitigate project costs, the Public Works Department remains proactive in seeking additional funding opportunities.

The City is committed to initiating a minimum of four CIP projects per year throughout the planning period to prioritize infrastructure development, ensuring the timely facilitation of residential unit construction. Notably, the City currently has several projects in the construction phase, including the installation of non-potable waterlines, well site improvements, the Salado Creek Bike Trail, and Rogers Road Bridge enhancements, among others. Additionally, multiple potable Packet Pg. 1414
Section 3.0 Housing Action Plan 3-45 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 water and sewer improvement projects are in the design phase. Plans are underway to rehabilitate and replace water and sewer infrastructure in the downtown area. This investment is aimed at supporting both current and future commercial and residential development.

TCAC Moderate Resource Areas
As outlined in Appendix A, the area east of State Route 33 is characterized by lower median household incomes, higher poverty rates, a larger proportion of individuals with disabilities, and a concentration of subsidized housing units. Ongoing construction of single-family homes in this area is anticipated to stimulate further investment in infrastructure and amenities, thereby promoting equitable opportunities and improving existing conditions. The area west of Baldwin Road, currently dominated by underutilized industrial land, is a focus of the City's revitalization efforts, with plans to invest in the infrastructure necessary to support future residential development. Consequently, the City will direct CIP resources to these areas to address existing challenges east of State Route 33 and to facilitate revitalization and residential growth west of Baldwin Road.

To further implement revitalization and investment in targeted neighborhoods, the City will host neighborhood clean-ups at least once per year. The City will prioritize areas east of State Route 33 and other low-resource areas for targeted revitalization initiatives.

Master Planned Areas
The City has initiated the planning process to expand the existing wastewater systems within the Zacharias Master Plan area, and is actively exploring various funding sources to secure a construction contract for these expansions. The City is facilitating temporary sewer connections while expansion of the wastewater system is underway and seeking financing for construction of the Zacharias Master Plan area. The City will prioritize infrastructure improvements in the master plan area in an effort to ensure lower-income units are developed to meet the RHNA.

Timeline:  Complete CIP study by June 2026.
 Ongoing; review CIP projects annually.
 Annual neighborhood cleanup by June 2025.

Objectives:  Direct CIP resources to improving conditions in area east of SR 33, and to facilitate revitalization and residential growth west of Baldwin Rd.  4 CIP projects initiated per year during the planning period.

Performance Metric:  Number of CIP projects completed during the planning period.

Geographic Targeting: City-wide, specifically east of SR 33 and west of Baldwin Road Responsible Agencies: Community Development Department
Funding Sources: General Fund
Implementing Policy:  Policy H-2 Promote Affordable Housing Development  Policy H-3 Conserve and Preserve Existing Affordable Housing  Policy H-4 Support Housing for Special Needs and Vulnerable Populations  Policy H-8 Promote Fair Housing and Equal Opportunity Packet Pg. 1415
Section 3.0 Housing Action Plan 3-46 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Program 5.8 Shared Housing Information
Shared housing is another important tool to provide affordable housing units. Shared housing is generally more affordable because a portion of a residence is rented as opposed to an entire unit.

Shared housing can also financially help low-income individuals who own their homes and alleviate loneliness. Benefits to lower-income individuals include provision of safe and secure affordable housing in a high-cost market. The City will distribute informational materials from the Stanislaus Regional Housing Authority, display information at City Hall and provide materials to local organizations, such as the Patterson Family Resource Center, Naomi’s House, and HOST House.

The City will also seek out shared housing providers and resources to expand this housing option.

Timeline:  Ongoing; review program effectiveness annually Objectives:  Distribute informational material at City Hall and coordinate with Patterson Family Resource Center, Naomi’s House, and HOST House.
 15 persons referred to shared housing provider during planning period.

Performance Metric:  Number of persons referred to shared housing provider during the planning period.

1. Partnering with Community-Based Organizations: The City will meet with at least three community-based partners annually to identify and create job opportunities for lower-income residents. These partners will provide job readiness training programs, including skills development, resume building, interview preparation, and career counseling, with a focus on expanding employment opportunities for lower-income households in Patterson.

2. Engaging with the Business Community: The City will collaborate with the Chamber of Commerce to encourage local employers to identify well-paying entry-level positions. These positions will be actively marketed to Below Market Rate (BMR) tenants in Patterson, ensuring that lower-income residents are aware of and have access to these employment opportunities.

The City will aim to connect with at least five employers annually to promote these efforts.

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Section 3.0 Housing Action Plan 3-47 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025

3. Coordinating Job Readiness Outreach: The City will coordinate with job readiness service providers and workforce development agencies to conduct targeted outreach to BMR tenants and property managers. This will include disseminating job training programs, workshops, and job opportunities at least quarterly. Additionally, the City will explore hosting annual job fairs in partnership with local employers, specifically targeting lower-income residents and BMR tenants.

4. Tracking and Reporting: The City will establish a tracking system to monitor the effectiveness of these initiatives, including the number of job placements, participants in training programs, and partnerships formed. A report will be generated annually to assess progress and adjust strategies as needed to improve outcomes for low-income residents.

This comprehensive strategy aims to create meaningful pathways to employment for lower-income residents, ultimately increasing household income and economic mobility within the community.

Timeline:  Ongoing; review program effectiveness annually Objectives:  10 residents assisted per year.

Performance Metric:  Number of low-income residents assisted in obtaining employment annually.

Geographic Targeting: City-wide, specifically east of State Route 33 Responsible Agencies: Community Development Department
Funding Sources: General Fund
Implementing Policy:  Policy H-2 Promote Affordable Housing Development  Policy H-4 Support Housing for Special Needs and Vulnerable Populations  Policy H-8 Promote Fair Housing and Equal Opportunity Packet Pg. 1417
Section 3.0 Housing Action Plan 3-48 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Table 3-5 Affirmatively Furthering Fair Housing Action Matrix Program Specific Commitment Timeline Geographic
Targeting
8-Year Metrics
Fair Housing Enforcement and Outreach
Program 5.3
Affirmatively Market
Fair Housing
Resources
 Maintain information on state and federal fair housing laws and tenant protections, including source of income, state rent stabilization, just cause eviction regulations, and other related State laws in English and Spanish on the City’s website and at City locations (City Hall, police station, library, fire department, schools, etc.) for public distribution;
 Utilize a bilingual individual at the City to refer victims of housing discrimination to Project Sentinel, a HUD-approved housing counseling agency, or to the State Fair Employment and Housing Commission; and
 Work with affordable housing developers and landlords to ensure that affordable housing is affirmatively marketed to households with disproportionate housing needs. The City will notify a broad representation of the community to solicit ideas for housing strategies when they are discussed at Planning Commission or City Council meetings. Specific outreach activities include:
 Send public notices to all interested public and non-profit agencies and affected property owners, including posting notices at City bulletin boards/locations, in local newspapers, and online at the City’s website;
 Conduct outreach (workshops, neighborhood meetings) to the community as Housing Element programs are implemented and announce workshops/meetings in City newsletter; and
 Market listings for affordable housing as available.

Ongoing;
Annual Review
City-wide  10 fair housing cases
reported to local or
state agencies during
the planning period.
 50 affordable units
marketed and occupied
during the planning
period.

Program 5.6 Housing
Choice Voucher
(HCV) Program
 Encourage the Housing Authority to seek out and provide assistance to extremely low- and very low-income households. The City shall publicize the Housing Choice Voucher Program rental assistance program through marketing efforts including brochures made available at City Hall.

Ongoing;
Annual Review
City-wide,
specifically
east of SR 33
10 vouchers (annually)
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Section 3.0 Housing Action Plan 3-49 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Program Specific Commitment Timeline Geographic
Targeting
8-Year Metrics
Program 4.14
Housing for
Extremely LowIncome Residents
 Working with the Housing Authority to provide Housing Choice Vouchers (HCV) to allocate section 8 vouchers to eligible residents;
 Referring ELI residents to wrap-around support services and community organizations (i.e. housing resources, transportation assistance, utility assistance, etc.)
 Research the feasibility of creating an “Affordable Housing Matching” program in which ELI residents are able to sign up for a list of the City’s available affordable housing inventory. If feasible, identify City staff or a consultant to create the program;  Maintain a list on the City’s website of resources available to special needs groups, including ELI residents; and
 Reach out to non-profit organizations and developers to construct affordable units that are suitable for the needs of large households.  Annually coordinate
with the Housing
Authority to
encourage ELI
residents to apply
for HCV
 Semi-annually
update the City’s
website with
resources for ELI
(and other special
needs) residents
 Ongoing referral of
ELI residents to
support services
and community
organizations.
 Annually coordinate
with non-profit
organizations and
developers
City-wide;
specifically
east of SR 33
and downtown
 Match at least 5 ELI
residents with landlords
willing to accept HCV
 Refer at least 10 ELI
residents to social
service organizations
Housing Mobility
Program 1.9
Supporting
Transportation
Demand Strategies &
Reducing Parking
Requirements for
Multi-Family
Residential
Development
 Collaborate with StanRTA to develop an incentive program for developers to provide bike parking and transit passes to residents of new affordable residential units for a minimum of 10 years;  Facilitate use of StanRTA by providing information on bus frequency and transit stop locations in common areas for the life of the program; and
 Reduction of minimum parking standards for multi-family uses in multi-family zones by December 2026.
 Develop
transportation
demand
management
strategy by June
2027
 Amend Municipal
Code to reduce
parking standards
by December 2026
City-wide 50 transit passes (per year)
with new affordable units
Program 4.1:

Reasonable
Accommodation and
 Amend the Zoning Ordinance to revise the findings for approval to remove subjective findings.
 Amend Municipal
Code by December
2026.

City-wide, with
emphasis in
 5 accessible units for
residents with
disabilities;
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Section 3.0 Housing Action Plan 3-50 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Program Specific Commitment Timeline Geographic
Targeting
8-Year Metrics
Housing for Persons
with Disabilities
 Amend the Zoning Ordinance to limit the parties eligible to appeal a request for reasonable accommodation to the applicant or the personal beneficiary.
 Conduct annual meetings with developers to encourage
development of projects targeted to persons with disabilities;  Conduct annual educational workshops for landlords and tenants;  Apply for County, State, and Federal funding as available (including ARPA funds) for housing construction and rehabilitation for persons with disabilities; and
 Continue enforcing Building Code requirements for the inclusion of adaptable disabled accessible units in multifamily development projects that are subject to such requirements.
 Conduct meetings
with developers
annually.
 Host educational
workshops for
landlords and
tenants annually.
 Apply for Funding as
available from State
and Federal
sources.
areas east of
SR 33
 Match 5 landlords with
accessible units to
tenants
Program 4.2
Universal Design to
Encourage Housing
for Persons with
Limited Mobility
 Adopt an ordinance to allow for Universal Design elements that address limited lifting (e.g. roll-in showers and grab bars), limited mobility (e.g. push/pull lever faucets, wide swing hinges) and limited vision (e.g. additional stairwell and task lighting) pursuant to Health and Safety Code section 17959, at the next International Building Code Update Adoption.

Adopt Universal Design
Ordinance by December
2026
City-wide, with
emphasis in
areas east of
SR 33
30 accessible units by the
end of planning period
Program 4.3
Residential Care
Facilities
Implement the following amendments to the Municipal Code:
 Residential Care Facilities Without Licensable Services:

Residential care facilities that function as single-family residences and do not offer licensable services shall be permitted in zones that permit single-family residential uses. These homes shall only be subject to the general health, safety, and zoning laws applicable to all single-family residences, regardless of having more than six residents. Since these homes do not provide licensable services, they should be treated like any other single-family residence;  Residential Care Facilities with Licensable Services for Six or Fewer Residents: Residential care facilities operating as singlefamily residences and providing licensable services to six or fewer residents shall be permitted in zones that permit single-family residential uses. They shall only be subject to the general health, safety, and zoning laws applicable to all single-family residences, in compliance with the Health and Safety Code protections for these smaller, licensed group homes; and
Amend Municipal Code
by December 2026
City-wide Amend Municipal Code to
define and establish
permitting procedures for
residential care facilities
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Targeting
8-Year Metrics
 Residential Care Facilities with Licensable Services for More Than Six Residents: Residential care facilities that provide licensable services to more than six residents shall require a conditional use permit to be permitted in zones that permit residential uses.

Reasonable accommodations in these permitting processes shall be considered when an application for reasonable accommodation is submitted.

Program 4.4
Facilitating the
Development of
Affordable Senior
Housing – Phase 2
Las Palmas Senior
Apartments
Support the Stanislaus Regional Housing Authority’s plans for the 16- unit expansion of the Las Palmas Senior Housing Complex by sourcing potential funding opportunities for development, including CDBG, HOME, and other available funding. Affirmatively market by:
 Posting information on the City website and distributing information via mail;
 Providing materials at City Hall and the Hammon Senior Center;  Distributing information at City events like the Wednesday Farmer’s Market; and
 Working with local nonprofits that assist low-income households, including the Patterson Family Resource Center and HOST House.

Complete by June 2031 City-wide,
specifically,
1075 Las
Palmas
Avenue
16 deed-restricted very lowincome senior housing units Program 4.5 FamilyFriendly Housing
 Promote multi-family housing designs and unit mixes that attract multigenerational households by encouraging developers to include housing features such as larger units with more bedrooms (including four-bedroom units) and on-site amenities like usable outdoor open spaces for multigenerational use.
 Encourage the inclusion of multipurpose rooms that can be used for after-school homework clubs, computer labs, art activities, or other resident programs.
 Incentivize developers by offering expedited permit processing, fee waivers, fee deferrals or reductions by 50 percent for projects that include family-sized deed-restricted units with four or more bedrooms.
 Research options to expand regulatory incentives to encourage the development of larger units.

Develop regulatory
incentive by June 2026
City-wide,
specifically
east of State
Route 33
15 family-friendly designated
units (four-bedroom units)
Program 4.10 SingleRoom Occupancy
Units (SROs)
 Amend the Municipal Code to define single-room occupancy units and permit them by right in all zones that allow mixed-use development.

Amend Municipal Code
by December 2026
City-wide N/A
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Section 3.0 Housing Action Plan 3-52 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Program Specific Commitment Timeline Geographic
Targeting
8-Year Metrics
Program 4.11
Employee
Farmworker Housing
 Contacting non-profit developers annually to identify opportunities for the development or improvement of housing for employees and farmworkers; and
 Coordinating and participating annually with regional organizations that serve farmworkers, including non-profits, academic institutions, and employers (e.g.: Stanislaus Regional Housing Authority, Office of Migrant Workers, Patterson Family Resource Center, Self-Help Enterprises, Farmworkers Institute of Education and Leadership) to raise awareness, share and employ strategies, and identify or target new resources.
 Reaching out to local farm employers to identify housing needs, and seeking funding to support further development or
rehabilitation of farmworker housing;
 Working with partner organizations and agencies to conduct an additional survey of farmworker housing needs at least once during the planning period and adjusting farmworker-serving programs to match updated needs if appropriate;
 Coordinating annually with organizations that represent farmworkers;
 Annually monitoring the status of farmworker housing as part of their annual report to HCD on Housing Element progress and evaluate if City efforts are effective in facilitating the provision of farmworker housing. If appropriate, the City will make necessary changes to enhance opportunities and incentives for farmworker housing development; and
 Providing bilingual materials on available resources and financial assistance on the City’s website and with printed materials at City offices, Patterson Public Library and community centers within the city.
 Amend Municipal
Code by December
2026.
 Contact non-profit
developers to
discuss
development
opportunities
annually.
 Coordinate with
regional
organizations
annually.

City-wide N/A
Program 4.12
Accessory Dwelling
Units (ADUs)
 Amend its ADU Ordinance to comply with State law, including recent changes pursuant to AB 345, AB 3182, AB 68, AB 881, SB 13, AB 587, AB 670, and AB 671.
 Update Building Code to align with State requirements for ADUs.  Develop a webpage on the City’s website to inform the public on the benefits of ADUs; post informational materials, such as the  Amend ADU
Ordinance by
December 2026.
 Develop ADU
informational
webpage and preCity-wide Construction of 25 ADUs
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Section 3.0 Housing Action Plan 3-53 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Program Specific Commitment Timeline Geographic
Targeting
8-Year Metrics
Accessory Dwelling Unit Handbook published by the State Department of housing and Community Development (HCD); post local regulations, and example floor plans;
 Provide pre-approved ADU plans to provide a more streamlined process for property owners and developers;
 Promote ADU development with an annual workshop on ADU development with building inspector and planners;
 Waive City building permit fees for units that are deed restricted for low- or very low-income units and for property owners of households that qualify as moderate to very low-income; and  Pursue funding opportunities to promote the development and affordability of ADUs in the City. Funding sources may include CalHFA ADU Grant Program; CalHome Program; LEAP Grants; REAP Grants; and SB 2 Planning Grants.
approved ADU
plans by June 2025.
 Host workshop on
ADU development
annually.
 Pursue funding
opportunities
annually.

Program 1.6
Affordable Housing
Development
 Conducting outreach to interested developers and assisting with identification of appropriate sites for affordable housing;  Working with or assisting nonprofit developers to pursue affordable housing funds available at local, state, and federal levels to implement the goals and policies of this Housing Element;  Providing expedited planning review and processing for affordable housing projects, and offer pre-application consultation to ensure maximum development potential is achieved;
 Reducing planning permit entitlement fees for affordable housing projects with deed-restricted units by 50 percent and deferring payment of impact fees until prior to issuance of Certificate of Occupancy; and
 Seeking cost-effective methods to reduce housing construction costs.
 Annually meet with
housing developers
to discuss
opportunities for
affordable housing
development.
 Research methods
to reduce
constructions costs
and present to
Planning
Commission by
June 2027.
 Establish
procedures to
comply with AB
2295 by June 2026.
 Develop landlordtenant matching by
June 2027.

City-wide  Direct staff to research
technology driven
construction methods in
an effort to improve
quality, reduce costs,
and decrease time to
occupancy by
conducting an
informational session
with the Planning
Commission by June
2027 with an emphasis
on modular homes,
prefabricated units, and
ADUs.
 Establish procedures to
comply with AB 2295.
 Monitor the number of
lower-income housing
units permitted during
the planning period with
a goal of achieving
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Section 3.0 Housing Action Plan 3-54 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Program Specific Commitment Timeline Geographic
Targeting
8-Year Metrics
 Annually monitor
lower-income
housing units
permitted during the
planning period.
1,770 lower-income
units to satisfy the
RHNA.

Program 1.5
Inclusionary Housing
Requirements
 To encourage the construction of affordable housing amid expected development growth, the City will dedicate staff to manage the housing element, focusing on implementing and enforcing the Inclusionary Ordinance to promote affordable unit construction over in-lieu fee payments.
 Additionally, to ensure compliance with recent changes to State Density Bonus Law, the City will review and update its Inclusionary Ordinance.

Review and update, if
necessary, the City’s
Inclusionary Housing
Ordinance to comply with
State Density Bonus Law
by December 2026.

City-wide  Ensure City’s
Inclusionary Housing
Ordinance complies
with State Density
Bonus Law.
 Achieve 100 lowerincome affordable units
between 2023-2031
through density bonus
and inclusionary
housing.

Program 1.7
Establish Procedures
for SB 35 and SB 330
 Create an SB 35 checklist and written procedures for processing SB 35 applications to ensure efficient and complete application processing and will update the documents in conformance with any changes to state law within twelve months of adoption of new laws.  Develop an application for SB 330 in conformance with State law.

Adopt checklist and
written procedures by
June 2026 and within 12
months of any change to
the law that would impact
the City.

City-wide Expedite review process for
affordable residential
projects.

Place-Based Strategies for Neighborhood Revitalization
Program 5.4 State
and Federal Housing
Programs and
Funding
Opportunities
 Continuously applying for state and federal housing funds to support affordable housing in new and existing units;
 Posting grant and special funding opportunities on the City website with information on housing opportunity sites and potential funding sources to support development; and
 Notifying affordable housing developers, community groups, and organizations serving lower-income households of available housing resources, including the HOST House and Patterson Family Resource Center.

Ongoing; review annually City-wide,
prioritize areas
east of SR 33
Acquire revenue from
various state and federal
funds for use in affordable
housing.

Program 2.1 Property
Inspection/Code
Enforcement
 Ensure all existing units meet basic health and safety standards by enforcing local codes. Code enforcement staff will regularly monitor neighborhoods, address violations as they arise, and respond to complaints.
 Ongoing; review
annually.
 Report code
violations and
City-wide,
specifically
east of State
Route 33
 Investigate and
address at least 5 code
violations per month.

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 Proactively offer information and assistance to property owners, including grants and loans through the City’s Minor Home Repair Program to address health and safety hazards. Other available programs include weatherization grants (Turlock Irrigation District, PG&E, State LIHEAP), home painting programs, and housing rehabilitation assistance.

Affirmatively market these resources by:
• Posting information on the City’s website;
• Providing written materials to community groups and
organizations representing lower-income households, at City Hall, the Wednesday Farmer’s Market, and through various outlets, such as the quarterly City newsletter;
• Distributing program details directly to property owners via mail; and
• Sharing materials with community groups, including the Patterson Family Resource Center, which serves extremelylow- and low-income families.  Monitor the 254 deed-restricted affordable units annually to ensure compliance with protective covenants.
enforcement
activities to the City
Council on monthly
basis.
 Multi-family rental
inspections
(December 2030)
 56 units rehabilitated
(24 very low-, 24 low-,
and 8 moderate-income
units) during the
planning period.

Program 5.7
Targeted Capital
Improvement
Program Investment
 Direct CIP resources to improving conditions in area east of SR 33, and to facilitate revitalization and residential growth west of Baldwin Rd; and
 4 CIP projects completed per year during the planning period.  Complete CIP study
by June 2026.
 Ongoing; review CIP
projects annually.
 Annual
neighborhood
cleanup by June
2025.

City-wide,
specifically
east of SR 33
and west of
Baldwin Road
 Direct CIP resources to
improving conditions in
area east of SR 33, and
to facilitate
revitalization and
residential growth west
of Baldwin Rd.
 4 CIP projects
completed per year
during the planning
period.

Tenant Protection and Anti-Displacement
Program 1.2
Replacement
Housing
Requirements
 Amend the Municipal Code to include the replacement housing requirements on non-vacant sites used to fulfill the City’s lowerincome RHNA.

Amend Municipal Code
by December 2025 City-wide Pursuant to State Law,
amend the Municipal Code
by the end of December
2025 to include the
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8-Year Metrics
 Monitor development on non-vacant sites identified in the Site Inventory and ensure that any development, as a condition of project approval, replace the existing units occupied by or deed restricted for occupancy by lower-income households are replaced. replacement housing
requirements on non-vacant
sites used to fulfill the City’s
lower-income RHNA
Program 2.1 Property
Inspection/Code
Enforcement
 Ensure all existing units meet basic health and safety standards by enforcing local codes. Code enforcement staff will regularly monitor neighborhoods, address violations as they arise, and respond to complaints.
 Proactively offer information and assistance to property owners, including grants and loans through the City’s Minor Home Repair Program to address health and safety hazards. Other available programs include weatherization grants (Turlock Irrigation District, PG&E, State LIHEAP), home painting programs, and housing rehabilitation assistance.

Affirmatively market these resources by:
• Posting information on the City’s website;
• Providing written materials to community groups and
organizations representing lower-income households, at City Hall, the Wednesday Farmer’s Market, and through various outlets, such as the quarterly City newsletter;
• Distributing program details directly to property owners via mail; and
• Sharing materials with community groups, including the Patterson Family Resource Center, which serves extremelylow- and low-income families.  Monitor the 254 deed-restricted affordable units annually to ensure compliance with protective covenants.
 Ongoing; review
annually.
 Report code
violations and
enforcement
activities to the City
Council on monthly
basis.
 Multi-family rental
inspections
(December 2030)
City-wide,
specifically
east of State
Route 33
 Investigate and
address at least 5 code
violations per month.
 56 units rehabilitated
(24 very low-, 24 low-,
and 8 moderate-income
units) during the
planning period.

Program 2.2
Conservation of
Existing Affordable
Housing
 Annually monitor the affordable units by maintaining contact with property owners regarding their intent to maintain the units as affordable housing, with the goal of preserving 254 affordable units in the inventory.
 When a Notice of Intent to convert from low-income housing to market-rate housing is received (three years in advance pursuant to State law), work with property owners to ensure that the tenants are properly noticed and provided information on potential  Ongoing; annually
monitor.
 Report code
violations and
enforcement
activities to the City
Council on monthly
basis.

City-wide,
specifically
east of State
Route 33
Preserve 254 affordable
units in the inventory
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8-Year Metrics
resources for assistance, and any applicable displacement and relocation requirements are complied with. On an ongoing basis, work with nonprofit housing providers to pursue funding to preserve and improve existing affordable housing.

Program 5.2 AntiDisplacement
Strategy
 Adopt a multi-pronged anti-displacement strategy to address the increasing income gap and rising housing costs, with the goal of 50 lower-income units beyond the RHNA.
 Complete targeted
engagement in
2025-2026.
 Adopt AntiDisplacement
Strategy by March
2027
Citywide,
specifically,
east of SR 33
50 lower-income units
beyond the RHNA, with a
target of 20 percent for
seniors and residents with a
disability.

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Section 3.0 Housing Action Plan 3-58 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 This side intentionally left blank.

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Section 4.0 Housing Resources and Sites Inventory 4-1 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025

4.0 Housing Resources and Sites Inventory
This chapter documents the methodology and results of the housing sites inventory analysis conducted to demonstrate the City of Patterson’s ability to satisfy its share of the region’s future housing need. Infrastructure, services, and financial and administrative resources that are available for the development, rehabilitation, and preservation of housing in the City of Patterson are also discussed in this chapter.

4.1 Regional Housing Needs Allocation (RHNA)
State law requires each jurisdiction to play a role in meeting the region’s housing need. Jurisdictions must demonstrate that their land inventory can accommodate their share of the region's projected growth. This section evaluates Patterson’s land inventory to meet future housing needs.

The City’s Housing Element update covers the planning period from June 2023 to December 2031 (6th Cycle Housing Element). Table 4-1 identifies the City’s 2023-2031 RHNA. Patterson’s share of the regional housing need, allocated by the Stanislaus Council of Governments (StanCOG) based on growth trends, income distribution, and growth capacity, is 3,716 units across five income categories.

Table 4-1 City of Patterson Regional Housing Needs Allocation (2023-2031) Income Category Number of Units
Extremely Low-Income (<30% AMI)* 523
Very Low-Income (30-50% AMI) 523
Low-Income (50-80% AMI) 724
Moderate-Income (80-120% AMI) 593
Above Moderate-Income (>120% AMI) 1,353
Total 3,716
SOURCE: StanCOG 6th Cycle Regional Housing Needs Allocation Plan, 2022 NOTE: *The RHNA does not project the need for extremely low-income units, but pursuant to State law (AB 2634), the City must project its extremely low-income housing needs based on Census income distribution or assume 50 percent of the very-low-income units required by the RHNA as extremely low-income units.

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Section 4.0 Housing Resources and Sites Inventory 4-2 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Regional Housing Needs Allocation Buffer
To ensure sufficient capacity in the housing element to meet RHNA requirements throughout the planning period, and in accordance with the No Net Loss Law (Government Code Section 65863), Housing and Community Development (HCD) recommends that jurisdictions include a buffer of at least 15 to 30 percent more capacity than required, particularly for lower-income housing. The No Net Loss Law requires sufficient adequate sites to be available at all times throughout the RHNA planning period to meet the jurisdiction’s remaining unmet housing needs for each income category.1

4.2 Capacity to Accommodate 2023-2031 RHNA
The City has employed a multifaceted approach to meet its RHNA. This includes crediting pipeline projects (approved or pending development), projecting accessory dwelling unit (ADU) construction, and advancing the development of large-scale projects within the Zacharias and Baldwin Master Plan areas. In addition, the City has identified vacant and underutilized sites that are available for development, including two sites previously identified in the 5th Cycle Housing Element.

This approach ensures a diverse range of housing options, evenly distributed throughout the city, to address the varied needs of the community. By targeting specific areas for increased housing options and improvements to infrastructure and public services, the City is addressing housing demands across various income levels and neighborhoods. This strategy promotes balanced growth and fosters community inclusivity by ensuring that new development provides a range of housing opportunities and also enhances the quality of life through improved amenities and services.

Table 4-2 identifies the methods used to accommodate the City’s 2023-2031 RHHA of 3,716 units, including a buffer.

Adjusting RHNA
Due to an unaccommodated need from the 5th cycle planning period, the City’s “adjusted RHNA” includes an additional 196 lower-income units, further increasing the housing targets. In total, the City has identified sufficient capacity for 5,264 housing units, resulting in a surplus of 1,693 units, which represents a 47 percent buffer above the required RHNA. Further discussion of the City’s 5th Cycle Housing Element unaccommodated need, pipeline projects credited toward the RHNA, and ADUs projected to develop during the planning period is provided below. 1 https://www.hcd.ca.gov/community-development/housing-element/docs/sites_inventory_memo_final06102020.pdf page 22
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Section 4.0 Housing Resources and Sites Inventory 4-3 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Table 4-2 Capacity to Accommodate 2023-2031 RHNA
Housing Resource
Very LowIncome
Capacity
LowIncome
Capacity
ModerateIncome
Capacity
Above
ModerateIncome
Capacity
Total
Capacity
2023-2031 RHNA 1,046 724 593 1,353 3,716
5th Cycle Unaccommodated
Need +98 +98 -- -- +196
Adjusted RHNA
(6th Cycle RHNA +5th Cycle
Unaccommodated Need)
1,144 822 593 1,353 3,912
Pipeline Projects -- -- -96 -245 -341
Remaining RHNA 1,144 822 497 1,108 3,571
Zacharias Development Area 356 194 324 2,366 3,240
Baldwin Ranch South
Development Area -- -- 91 214 305
Vacant/Underutilized Sites 703 588 83 -- 1,374
Projected ADUs (not including
MP areas) 15 15 15 5 50
Lakeside Hills 15% ADUs 79 79 79 26 263
Baldwin Ranch South 15% ADUs 10 10 10 2 32
Total Net Capacity 1,163 886 602 2,613 5,264
Surplus Units 19 64 105 1,505 1,693
Percent of Surplus Units 102% 108% 121% 236% 147%
SOURCE: City of Patterson, 2024
5th Cycle Unaccommodated Need
During the 5th Cycle Housing Element planning period, the City of Patterson was assigned a RHNA of 2,491 housing units. Among these, 1,044 units were designated for lower-income housing.

However, the City did not have sufficient capacity to accommodate all 1,044 lower-income units, resulting in a shortfall of 496 lower-income sites. The City committed to rezoning land to High Density Residential to accommodate the shortfall of units. In 2020, the City rezoned 13 acres located at Weber Avenue and First Street to High Density Residential to accommodate approximately 300 lower-income units. This accounts for approximately 60 percent of the rezoning efforts needed to make up the shortfall of 496 units. A remaining shortfall of 196 units must be planned for in the 6th cycle planning period.

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Section 4.0 Housing Resources and Sites Inventory 4-4 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Government Code Section 65584.09 classifies these as an "unaccommodated housing need," which the City must address in addition to the 6th cycle RHNA allocation of 3,716 units. Specifically, the City must ensure the affordability of the 196 unaccommodated units from the 5th cycle, comprising 98 very low-income and 98 low-income units.

Table 4-2 above calculates the City’s "adjusted RHNA," which accounts for the 5th cycle unaccommodated need of 196 lower-income units, resulting in a total of 3,912 units that the City is required to plan for during the 6th cycle planning period. Pursuant to Government Code Section 65584.09, the City is obligated to rezone and/or annex suitable sites to address the 5th cycle unaccommodated housing needs within the first year of the new planning period, ending on December 31, 2024.

To address this adjusted RHNA— affecting very low- and low-income units—the City will implement rezoning efforts to facilitate higher-density developments suitable for lower-income housing. Program 1.11 establishes specific rezoning actions to ensure the City meets its lowerincome RHNA targets (refer to Chapter 3). Through these rezoning efforts, the City’s site inventory identifies sufficient sites to accommodate the City’s lower-income RHNA, including the 5th cycle unaccommodated need.

Credited Pipeline Projects
Approved and permitted residential developments not yet built (“pipeline projects”) can be counted toward the City's RHNA for the 6th Cycle Housing Element, provided the City demonstrates that the units will be completed by the end of the planning period. Similarly, units in projects that received a certificate of occupancy on June 30, 2023 or later, are also eligible for RHNA credit.

Affordability is based on actual or projected sale prices, rent levels, or other mechanisms that establish the income category of the units. Single-family homes are typically sold at market rates without affordability covenants, while multi-family or single-family developments using density bonuses, subsidies, or other affordability mechanisms are subject to rent or sale price restrictions.

Local, state, or federal regulations determine which income categories each development must serve.

The City has two active projects expected to provide 341 market-rate housing units. Table 4-3 identifies these projects, which contribute 96 moderate- and 245 above moderate-income units towards the City's RHNA allocation. Further details on these projects and timelines are provided below.

As reported in Chapter 1, Housing Needs Assessment, housing tenure in Patterson has primarily been owner-occupied, averaging 68 percent from 2010 to 2022, while renter-occupied households averaged 32 percent. The City’s pipeline projects include a mix of townhomes and single-family developments, offering both rental and ownership opportunities. However, none of these developments are expected to be deed-restricted.

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Section 4.0 Housing Resources and Sites Inventory 4-5 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Table 4-3 Pipeline Projects
Site ID Project Name VLI
Units
LI
Units
MI
Units
AM
Units
Total
Units
Entitlement
Status Affordability/Tenure
15 VOP Lot 14 0 0 24 74 98 Approved Market-Rate/rental
16 Sycamore Ranch II 0 0 72 171 243 Approved Market-Rate/ownership Total 0 0 96 245 341 -- --
SOURCE: City of Patterson, 2024
NOTE: VLI = very low-income; LI = low-income; MI = moderate-income; AM = above moderate-income.

VOP Lot 14
The VOP Lot 14 project, a 98-unit townhouse development, is set to be constructed on North First Street in the northeastern quadrant of the city, covering 5.73 acres. Originally designated as Medium Density Residential (MDR), with an allowable density of 5.1 to 12 dwelling units per acre, the City facilitated development of the project by offering a density swap, increasing the density to 17 dwelling units per acre. This initiative demonstrates the City's proactive efforts to support higher density residential development through strategic incentives. The townhouses will range in size from 1,125 to 1,228 square feet and will be priced at market rate available for rent. Given the small size of the units, it is reasonable to assume they will accommodate a mix of moderate- and above-moderateincome households.

The development has obtained planning entitlements but has not yet received building permits. The developer is actively working to secure financing for the project, and the City is supporting these efforts by assisting in identifying funding sources and prioritizing the expedited issuance of building permits. As the site is an infill development, no new or expanded infrastructure is required for construction. As discussed in Chapter 2, Constraints Assessment, potable water supply is a challenge for new development city-wide. However, the City is proactively addressing existing overdraft conditions and working to secure additional supply. Program 1.15 outlines the specific actions the City is taking to enhance water supply and facilitate residential development throughout the planning period (see program in Chapter 3). There are no other known barriers impacting development of this project.

Sycamore Ranch Phase II
The Sycamore Ranch Phase II project, a 243-unit single-family development, is planned along Olive Avenue and Sycamore Avenue in the northeastern section of Patterson, covering 46.23 acres. With an average lot size of 4,600 square feet, each unit will be priced at market rate available for ownership.

The development has obtained both planning entitlements and building permits, and the grading process is currently underway to prepare the site for construction of units, which are anticipated to be completed by summer/fall 2026.

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Section 4.0 Housing Resources and Sites Inventory 4-6 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Similar to VOP Lot 14 above, since the site is an infill development, no new or expanded infrastructure is required for construction. Provisions outlined in Program 1.15 include the City’s commitment to ensuring that sufficient potable water supply will be available for the development (see Chapter 3). There are no other known barriers impacting development of this project.

Several developers are being considered for the project, including KB Homes, the developer of Sycamore Ranch Phase I. The City is actively engaging with multiple developers to encourage a variety of unit sizes that support a broader range of affordability. A key priority is to incorporate an affordable component within the project, with a particular focus on producing units priced to be attainable for moderate-income households—targeting the mid- to high-$300,000 range.

As noted throughout this Housing Element, the City has successfully negotiated the inclusion of affordable units in other projects through the use of development concessions such as density swaps, reduced parking requirements, and other incentives. Building on this success, the City is confident that similar strategies can be applied to Sycamore Ranch Phase II. Through ongoing discussions and the strategic use of development incentives, the City anticipates the inclusion of moderate-income units within this project during the planning period.

KB Homes, a leading developer in the region, is also spearheading the Acacia Homes project in the Patterson Ranch community, further strengthening the housing market in this area. The active development in the northeastern region reflects strong growth, with KB Homes driving increased housing opportunities and contributing to economic development and community expansion.

By introducing market-rate housing to the northeastern region, classified as a moderate resource area, the City aims to stimulate new development opportunities. This strategic initiative is expected to attract investment, improve infrastructure, expand public services, and enhance community amenities. Ultimately, these efforts are intended to drive better economic outcomes for the area, fostering growth and increased quality of life for residents.

Projected Accessory Dwelling Units
Government Code Section 65583.1(a) allows a city or county to identify sites for accessory dwelling units (ADU) and junior accessory dwelling units (JADU) based on the number of ADUs developed in the prior housing element planning period whether or not the units are permitted by-right, the need for these units in the community, the resources or incentives available for their development, and any other relevant factors, as determined by the department.

In accordance with state law, ADUs anticipated to be built between 2023 and 2031 are also credited towards the City’s RHNA. The City of Patterson Building Division permitted two ADUs in both 2020 and 2021, and one in 2022, averaging two ADUs per year. Based on past trends, this would result in 16 ADUs being permitted during the 2023-2031 planning period. However, despite the limited number of ADUs in the previous cycle, public interest in ADU construction has increased significantly. During the November 12 Joint Planning Commission/City Council Community Workshop, residents expressed interest in ADU development, including pre-approved ADU/JADU Packet Pg. 1434
Section 4.0 Housing Resources and Sites Inventory 4-7 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 plans and educational resources for initiating the planning process. The City also conducted a Housing Needs Survey during the public comment period, which confirmed community interest in ADU/JADU development in Patterson.

Furthermore, the FHA recently expanded access to mortgage financing for homes that have or will include ADUs. Specifically, the updated loan policies allow for the inclusion of rental income from the ADU in the borrower’s qualifying income and would allow more borrowers to qualify for FHA financing for properties with ADUs.2 Coupled with increased community and developer interest in constructing ADUs, the City anticipates an increase in ADU development during the planning period.

To encourage ADU development, the City is promoting pre-approved ADU designs to simplify the process, reducing design challenges and facilitating quicker approvals. Additionally, under Program

4.12 of this Housing Element, the City will waive building permit fees for ADUs deed-restricted for at least five years for low- or very low-income units or for property owners qualifying as moderateto very low-income (see Chapter 3). The City will also offer funding, including low-interest loans, to support ADU construction and affordability, and will host annual workshops with building inspectors and planners to engage and educate residents. Additionally, the City proposes Program

4.12, which establishes an ADU Amnesty Program to legalize existing, unpermitted ADUs and JADUs (see Chapter 3). To incentivize property owners to legalize their ADU/JADUs, the City is committed to offering incentives including but not limited to waiver of all fees and penalties for unpermitted units, low-cost initial inspections, and significant reductions or waivers of planning, building, and other permit fees.

Through these efforts, the City anticipates a significant increase in ADU production, projecting a total of 50 ADUs to be permitted during the 6th cycle planning period.

The Association of Bay Area Governments (ABAG) conducted an analysis of ADU affordability and concluded approximately 30 percent of ADUs are affordable to very low-income households, 30 percent affordable to low-income households, 30 percent affordable to moderate-income households, and 10 percent affordable to above-moderate income households.3 HCD has accepted this methodology for distributing ADUs according to income category. Therefore, the City of Patterson ADU assumptions will distribute ADUs according to income as follows: 15 very low-; 15 low-; 15 moderate-; and 5 above moderate-income ADUs for a total of 50 ADUs.

4.3 Residential Site Inventory
Government Code Section 65583(a)(3) requires jurisdictions to demonstrate in the Housing Element that the land inventory is adequate to accommodate their share of regional growth. "Default" density 2 https://www.hcd.ca.gov/sites/default/files/docs/policy-and-research/ADUHandbookUpdate.pdf 3 ABAG. Using ADUs to satisfy RHNA Technical Memo. https://abag.ca.gov/sites/default/files/documents/2022- 03/ADUs-Projections- Memo-final.pdf
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Section 4.0 Housing Resources and Sites Inventory 4-8 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 standards are used to estimate potential units by income range. According to HCD, a density of 20 or more dwelling units per acre, primarily for higher-density multi-family developments, supports housing for low- and very low-income households in cities like Patterson. Further, Government Code Section 65583.2 specifies that parcels between 0.5 and 10 acres, zoned for residential development at 20 dwelling units per acre or more, are suitable for lower-income housing in Patterson.

Following adjustments to the City's RHNA, which include accommodating the 5th Cycle Housing Element's unaccommodated need of 496 lower-income units, crediting pipeline projects, and projecting ADU development, the City faces a remaining RHNA of 3,571 units. Of these, 1,114 units are allocated for very low-income households, 822 for low-income, 497 for moderate-income, and 1,108 for above moderate-income households. To address this remaining need, the City has identified the Zacharias and Baldwin Ranch Master Plan development areas and 12 vacant and underutilized sites. Figure 4-1 illustrates identified housing opportunity sites included in the site inventory.

Zacharias and Baldwin Ranch Master Plan Areas4
Zacharias Development Area
The Zacharias development area covers 1,296.4 acres in the northern part of Patterson, bordered by Rogers Road to the west, Zacharias Road to the north, the California Northern Railroad tracks and Ward Avenue to the east, and existing residential and business park areas to the south. A recharge basin and flood retention area are located north of Zacharias Road. This area was annexed in Spring 2024 and is slated for infrastructural improvements beginning in Summer 2025 and development in Fall 2025. The master-planned community will include a mix of residential and commercial uses, parks, and schools. The City is continuing to work with the developer on the vesting tentative maps.

Residential Potential
The Zacharias development area is designed to accommodate 5,091 residential units across 814.3 acres. Approximately 4,268 units are allocated to low and medium-density developments such as single-family homes, townhouses, and duplexes, and 823 units are designated for high-density and mixed-use developments. The Zacharias development area permits residential densities ranging from

1.0 to 25.0 dwelling units per acre. There are five project areas within the Zacharias development area, including Zacharias Ranch and TPF, expected to provide moderate and above moderateincome units; Keystone Ranch and Lakeside Hills offering housing for all income levels; and Ivy Rose Gardens, anticipated to serve moderate and above moderate-income households. Table 4-4 outlines the residential opportunities according to land use designation. 4 The Zacharias and Baldwin Ranch Master Plan area refers to the Baldwin Ranch South development area.

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Lakeside Hills
Keystone Ranch State Route 33
U.S. Interstate 5
Sperry Ave.

Ward Ave.

Baldwin Rd.

UV1A
UV1B
Rogers Rd.

Baldwin Ranch
W. Las Palmas Ave.

Eagle Ave. American
Olive Ave.

Walnut Ave.

Eucalyptus Ave.

Poppy Ave.

Orange Ave.

Annamarie Ave.

Marble Rd.

UV2
UV3
UV4
UV5
UV6
UV7
UV8
UV9
UV10
UV11
UV12
UV13
UV14
UV15
UV16
Identified Housing Opportunity Sites
City of Patterson 6th Cycle Housing Element
0 4150 feet
Figure 4-1
Source: ESRI 2024,
Stanislaus County GIS 2024
Patterson City Limit
Master Plan Area
Opportunity Sites
Pipeline Sites
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Section 4.0 Housing Resources and Sites Inventory 4-10 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Table 4-4 Zacharias Development Area Residential Land Uses Zoning Land Use Density
Du/Ac.

Area
(Acres) Units
Percent
Total
Units
LR Low Density Residential 1.0 – 5.0 216.4 809 15.9%
MR Medium Density Residential 5.1 – 12.0 539.1 3,459 67.9% HR High Density Residential 12.1 – 25.0 30.6 538 10.6%
MU Mixed Use 12.0 – 25.0 28.2 285 5.6%
Total 814.3 5,091 100%
SOURCE: City of Patterson, Zacharias and Baldwin Ranch Master Plan, August 2022 Keystone Ranch and Lakeside Hills are the only project areas designated to accommodate highdensity and mixed-use developments for lower-income residential units within the Zacharias development area. As such, these are the only project areas included in the Site Inventory.

Inclusionary Housing Requirement
The Master Plan is subject to the City's Inclusionary Housing Ordinance, adopted in 2006, which requires the provision of housing for moderate-, low-, and very low-income households. A minimum of 15 percent of all dwelling units within the Master Plan Area must be designated as affordable for these income categories. For affordable for-sale units, 60 percent must be allocated to moderate-income households, with the remaining 40 percent designated for low-income households.

Similarly, for affordable rental units, 40 percent must be reserved for very low-income households, while 60 percent must accommodate low-income households. These inclusionary housing requirements have been incorporated into the Keystone Ranch and Lakeside Hills development areas included in the Site Inventory.

According to the Master Plan, Keystone Ranch is planned for medium- and high-density residential development, with a total of 719 units. The Site Inventory allocates these units to accommodate 17 very low-, 26 low-, 64 moderate-, and 612 above moderate-income units. Lakeside Hills is planned for medium- and high-density residential development, along with mixed-use residential, totaling 2,521 units. The Site Inventory allocates these units to accommodate 339 very low-income, 168 lowincome, 260 moderate-income, and 1,754 above moderate-income units.

The City has allocated a higher proportion of affordable units in Lakeside Hills, exceeding the requirements of the Inclusionary Housing Ordinance, in anticipation that collaboration with nonprofit affordable housing developers will yield additional affordable housing opportunities. The City has a proven track record of working with organizations such as Self-Help Enterprises, which has successfully resulted in construction of affordable housing units. Additionally, the City is currently working with Lennar to develop single-family homes in the southwest region, incorporating designs Packet Pg. 1438
Section 4.0 Housing Resources and Sites Inventory 4-11 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 to accommodate Accessory Dwelling Units (ADUs) and Junior Accessory Dwelling Units (JADUs) on the parcels. This proactive coordination with developers and the promotion of ADU/JADU development are expected to further expand affordable housing availability in Patterson.

Anticipated Accessory Dwelling Unit Development
The City has noted increased community interest in ADU/JADU development and has proactively responded by offering five free pre-approved ADU building plans on its Accessory Dwelling Unit website.5 These plans are designed to streamline the planning and approval process while reducing design costs for developers and property owners. Additionally, Program 4.12 outlines educational and marketing initiatives to further support ADU/JADU development, addressing common community requests (see Chapter 3). The program also commits the City to seeking funding opportunities to provide low-interest loans to encourage and facilitate ADU/JADU construction.

With strong community interest, the City’s targeted initiatives, and developers such as Lennar actively advancing ADU projects in Patterson, significant growth in ADU development is anticipated during the 2023-2031 planning period. The City remains committed to fostering this development to provide a diverse range of housing options that address the needs of various households, and is in negotiations with developers to facilitate the development of ADUs with single-family homes.

The Site Inventory allocates 15 percent of the anticipated above moderate-income units (1,754 units), equating to 263 ADUs distributed across very low-, low-, moderate-, and above moderateincome categories. Using ABAG's 30-30-30-10 percent distribution methodology, this allocation includes 79 very low-income, 79 low-income, 79 moderate-income, and 26 above moderate-income ADUs within the Lakeside Hills development area.

Available Infrastructure
The City has initiated the planning process to expand the existing wastewater systems within the project area. In the interim, temporary sewer connections must be provided to support early-phase development, with the City enforcing fair share contributions from proposed development to fund the sewer upgrade that will be necessary to serve the entire Master Plan area. Temporary sewer connections are necessary to support development and the City’s fulfillment of its RHNA.

Potable water service will be provided by existing pipelines along Rogers Road, Zacharias Road, and Ward Avenue/State Route 33, while wastewater services will be supported by tying into an existing sewer main along Keystone Pacific Parkway. The sewer utility lines are expected to provide short term service to support initiation of development and are not anticipated to present any constraints to progress as long as developers share the cost of the sewer impacts resulting from proposed development. Potable water can be delivered to the development through existing City wells and infrastructure; however, the groundwater demand underlying potable water service in the City will need to be offset by groundwater recharge through the Del Puerto Creek Recharge Project, a 5 https://www.pattersonca.gov/2000/Accessory-Dwelling-Units-ADUs Packet Pg. 1439
Section 4.0 Housing Resources and Sites Inventory 4-12 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 version of which was always contemplated as part of the Master Plan. Developers will be required to contribute their fair share of financing for the recharge project. Additionally, all new development in the City will be required to purchase surface water to offset their potable water demand for recharge.

Sufficient surface water supplies to offset potable water demand from the Master Plan are believed to be available from local irrigation districts. Program 5.7 outlines key actions for the City, including securing financing for a wastewater system expansion contract, working towards developer accountability to advance housing projects within the planning period, and facilitating temporary sewer connections during system expansion (see Chapter 3).

Development Phasing
The development of the Zacharias development area will be carried out in phases to allow for the timely completion of necessary infrastructure improvements, particularly for water and wastewater systems. This phased approach ensures developer funding of the water and sewer infrastructure.

This is necessary to ensure public health and safety for all the citizens of Patterson, not just the occupants of new development based on the impact of the new development on Patterson. The exact timing and scope of each phase may shift based on factors such as developer commitment, funding, and the progress of infrastructure upgrades.

Initial development is expected to begin in the southeastern portion of the site, specifically in Keystone Ranch, and will progress westward and northward in a clockwise manner. A critical aspect of the phasing strategy is ensuring the timely development of lower-income housing units. The City’s Site Inventory allocates 17 Keystone Ranch units to very low income, 24 to low, income, 64 to moderate income, with the remaining 612 units at above moderate income.

Lakeside Hills, which includes additional lower-income units, is part of the second phase. To facilitate the development of lower-income housing during the planning period, the City is actively collaborating with developers to accelerate this timeline, and to prioritize early development of affordable multi-family residential units. As outlined in Program 1.6, the City proposes to hire a 1.0 Full-Time Equivalent (FTE) to manage housing element implementation, which includes facilitating the development of lower-income units to meet the City’s RHNA. This program proposes several actions to achieve this, including reducing planning permit entitlement fees for affordable housing projects with deed-restricted units by 50 percent and deferring payment of impact fees; expediting planning review and processing; and working with or assisting nonprofit developers to pursue affordable housing funds.

Realistic Capacity Analysis
The City has identified the Keystone Ranch and Lakeside Hills project areas within the Zacharias development area as key sites for development within the eight-year planning period. Together, these areas encompass approximately 431 acres and are projected to accommodate 356 very low-, 194 low-, 324 moderate-, and 2,366 above moderate-income units for a total of 3,240 residential Packet Pg. 1440
Section 4.0 Housing Resources and Sites Inventory 4-13 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 units. Application and enforcement of the City’s Inclusionary Ordinance is paramount to production of these affordable units. Additionally, the Lakeside Hills development area is anticipated to develop 263 ADUs.

The capacity analysis for these two project areas is informed by the Master Plan’s land use designations, which include Medium Density Residential (5.1 to 12.0 dwelling units per acre), High Density Residential (12.1 to 25.0 dwelling units per acre), and Mixed-Use, which adheres to the High Density Residential standards. The Master Plan establishes planned development capacities for both the Keystone Ranch and Lakeside Hills areas based on their assigned land use designations. This Site Inventory reflects the realistic capacity outlined in the Master Plan; however, as discussed below, higher-intensity development may be achievable under the existing land use designations and allowable densities.

Table 4-5 presents the realistic capacity assumptions for the Keystone Ranch and Lakeside Hills project areas. Figure 4-2 illustrates the land uses in the Zacharias development area.

The capacity analysis for the Keystone Ranch project area incorporates two development densities for medium-density residential zones: 6.0 dwelling units per acre and 7.4 units per acre. This approach allows for flexibility in the design of both production and custom housing. Sites developed at 6.0 units per acre achieve 50 percent capacity, while those at 7.4 units per acre reach 62 percent capacity. High-density residential areas will be developed at a rate of 17.1 dwelling units per acre, achieving 68 percent capacity.

The capacity analysis for the Lakeside Hills project area applies a single density of 6.5 dwelling units per acre for medium-density residential zones, resulting in an average development capacity of 54 percent. High-density residential areas will be developed at 18.0 units per acre, achieving 71 percent capacity. Mixed-use residential areas will be developed at 10.5 units per acre, with an average capacity of 41 percent.

Both areas apply conservative densities to account for market demand fluctuations and financing considerations. However, it should be noted that the Lakeside Hills development area permits a maximum density of 25.0 dwelling units per acre for both High-Density Residential and Mixed-Use designations but currently utilizes densities of only 18.0 and 10.5 dwelling units per acre, respectively. Similarly, the Keystone Ranch development area allows a maximum of 25.0 dwelling units per acre for High-Density Residential but utilizes just 17.1 dwelling units per acre. These lower densities may result in the underutilization of limited land resources within the City, particularly in areas like the Zacharias development area, which was recently annexed from agricultural/open space lands. Based on existing land use designations and densities, higher intensity development could be supported for both project areas.

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Section 4.0 Housing Resources and Sites Inventory 4-14 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Table 4-5 Zacharias Development Area Realistic Capacity Site ID Acreage Existing
Zoning
Permitted
Density Utilized Density Percent Capacity
VLI
Units
LI
Units
MI
Units
AM
Units
Total
Units
Keystone Ranch
1A 11.1 MR 5.1 – 12.0 du/ac 6.0 50% 10 57 67

15.4 MR 5.1 – 12.0 du/ac 6.0 50% 12 80 92

15.7 MR 5.1 – 12.0 du/ac 6.0 50% 10 84 94

5.1 MR 5.1 – 12.0 du/ac 7.4 62% 10 28 38

12.5 MR 5.1 – 12.0 du/ac 7.4 62% 10 83 93

16.1 MR 5.1 – 12.0 du/ac 7.4 62% 12 107 119

12.6 HR 12.1 – 25.0 du/ac 17.1 68% 17 26 173 216

88.5 Subtotal 17 26 64 612 719
Lakeside Hills
1B 13.0 MR 5.1 – 12.0 du/ac 6.5 54% 10 74 84

13.9 MR 5.1 – 12.0 du/ac 6.5 54% 10 80 90

13.6 MR 5.1 – 12.0 du/ac 6.5 54% 10 78 88

14.8 MR 5.1 – 12.0 du/ac 6.5 54% 10 86 96

8.8 MR 5.1 – 12.0 du/ac 6.5 54% 57 57

15.6 MR 5.1 – 12.0 du/ac 6.5 54% 10 91 101

16.7 MR 5.1 – 12.0 du/ac 6.5 54% 10 98 108

11.4 MR 5.1 – 12.0 du/ac 6.5 53% 73 73

13.1 MR 5.1 – 12.0 du/ac 6.5 54% 10 75 85

19.4 MR 5.1 – 12.0 du/ac 6.5 54% 15 110 125

19.8 MR 5.1 – 12.0 du/ac 6.5 54% 15 113 128

15.3 MR 5.1 – 12.0 du/ac 6.5 54% 10 89 99
Packet Pg. 1442
Section 4.0 Housing Resources and Sites Inventory 4-15 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Site ID Acreage Existing
Zoning
Permitted
Density Utilized Density Percent Capacity
VLI
Units
LI
Units
MI
Units
AM
Units
Total
Units

13.2 MR 5.1 – 12.0 du/ac 6.5 54% 10 75 85

12.6 MR 5.1 – 12.0 du/ac 6.5 54% 10 71 81

10.0 MR 5.1 – 12.0 du/ac 6.5 53% 64 64

11.6 MR 5.1 – 12.0 du/ac 6.5 54% 75 75

6.3 MR 5.1 – 12.0 du/ac 6.5 53% 40 40

10.3 MR 5.1 – 12.0 du/ac 6.5 53% 66 66

14.7 MR 5.1 – 12.0 du/ac 6.5 54% 10 85 95

12.2 MR 5.1 – 12.0 du/ac 6.5 54% 79 79

13.7 MR 5.1 – 12.0 du/ac 6.5 54% 10 78 88

16.6 MR 5.1 – 12.0 du/ac 6.5 54% 10 97 107

13.0 HR 12.1 – 25.0 du/ac 18.0 71% 150 62 20 232

5.0 HR 12.1 – 25.0 du/ac 18.0 72% 70 20 90

2.7 MU 12.1 – 25.0 du/ac 10.5 39% 15 11 26

2.8 MU 12.1 – 25.0 du/ac 10.5 39% 17 10 27

3.1 MU 12.1 – 25.0 du/ac 10.5 40% 21 10 31

3.5 MU 12.1 – 25.0 du/ac 10.5 40% 10 10 15 35

6.4 MU 12.1 – 25.0 du/ac 10.5 41% 21 12 33 66

4.2 MU 12.1 – 25.0 du/ac 10.5 41% 10 21 12 43

5.5 MU 12.1 – 25.0 du/ac 10.5 42% 25 12 20 57
Subtotal
acreage
342.8 Subtotal 339 168 260 1,754 2,521
Lakeside Hills 15% ADUs 79 79 79 26 263
Total
acreage
431.3 Grand Total 435 273 403 2,392 3,503
SOURCE: City of Patterson, Zacharias and Baldwin Ranch Master Plan, August 2022 Packet Pg. 1443
Conceptual Land Use Plan Breakdown
August 1, 2022
City of Patterson, Stanislaus County, California
Zacharias Master
Planning Area
31323334353637383940414243444546474849505152535455
P-6P-7P-8P-9
P-10
OS-1OS-2
High Density Residential 13.0 18.0 232 ~
Medium Density Residential 13.0 6.5 84 ~Medium Density Residential

13.9 6.5 96
~
Medium Density Residential 13.6 88 ~

14.8 ~
Medium Density Residential 8.8 6.5 57 ~

15.6 6.5 101 ~16.7 6.5 108 ~11.4 6.5 73 ~13.1 6.5 85 ~
Medium Density Residential 19.4 6.5 125 ~Medium Density Residential 19.8 6.5 128 ~

15.3 6.5 99 ~13.2 6.5 85 ~
Medium Density Residential 12.6 6.5 81 ~Medium Density Residential 10.0 6.5 64 ~

11.6 6.5 75 ~
Medium Density Residential 6.3 6.5 40 ~
Medium Density Residential 10.3 6.5 66 ~
Mixed Use 2.7 10.5 26
Mixed Use 2.8 10.5 27 48,500
Mixed Use 3.1 10.5 31Mixed Use 3.5 10.5 35
Medium Density Residential 14.7 6.5 95 ~

6.4 10.5 664.5 ~ ~ ~4.5 ~ ~ ~

10.5 ~ ~ ~

4.0 ~ ~ ~
Park 5.0 ~ ~ ~

5.4 ~ ~ ~
Open Space / Lake 8.0 ~ ~ ~
PA Land Use Acreage (Gross) Density # of Units Bldg. Sq. Ft.

LAKESIDE HILLS DEVELOPMENT - TOTAL 387.7 ~ 2,521 505,000 626364
Low Density Residential 34.7 3.0 104 ~
Low Density Residential 26.4Low Density Residential 55.3 PA Land Use Acreage (Gross) Density # of Units Bldg. Sq. Ft.

IVY ROSE GARDENS IVY ROSE GARDENS - TOTAL 143.7 3.0 431 ~ 3.0 79 ~ 3.0 166 ~ 12345678
Light Industrial 66.4 ~ ~ 1,360,500

36.725.431.029.562.665.9
Medium Density Residential 47.9
PA Land Use Acreage (Gross) Density # of Units Bldg. Sq. Ft.

ZACHARIAS RANCH
ZACHARIAS RANCH - TOTAL 478.7 ~ 700 7,260,000
9 General Commercial 22.2
10 Medium Density Residential 42.211 Medium Density Residential 39.4 P-1 Park 3.0P-2 Park 3.0P-3 Park 3.5
~ 845,500~ 523,500~ 720,500~ 585,250~ 1,420,500~ 1,454,250

5.4 259 ~
~ ~ 350,000

5.4 228 ~5.4 213 ~
~~ ~
~~ ~
~~ ~
Light IndustrialLight IndustrialLight IndustrialLight IndustrialLight IndustrialLight Industrial ~~~~~~
1213141516171819
Low Density Residential 9.0 5.1 47

9.49.39.6 10.1

9.29.29.5 PA Land Use Acreage (Gross) Density # of Units Bldg. Sq. Ft.

TPF DEVELOPMENT - TOTAL 119.7 ~ 720 ~
20 9.121 7.922 7.923 9.6
P-4 Park 9.9
878750538484

5.1 49 ~5.1 475.1 41 ~5.1 41 ~5.1 50 ~
~~ ~
Medium Density ResidentialMedium Density Residential

9.49.45.15.19.49.4 Low Density ResidentialLow Density Residential Medium Density ResidentialMedium Density Residential
Low Density ResidentialLow Density ResidentialLow Density ResidentialLow Density ResidentialLow Density Residential ~~~~~~~~
24252627282930
P-5
Medium Density Residential 11.1
Medium Density Residential 15.4

15.7 Medium Density Residential 5.1Medium Density Residential 12.5Medium Density Residential 16.1 High Density Residential 12.6
Park 8.8
PA Land Use Acreage (Gross) Density # of Units Bldg. Sq. Ft.

KEYSTONE RANCH - TOTAL 97.3 ~ 719 ~
Medium Density Residential
~~ ~

17.1 216 ~

7.4 250 ~6.0 253 ~
Open Space / Lake
ParkParkParkPark
Medium Density ResidentialMedium Density ResidentialMedium Density ResidentialMedium Density ResidentialMedium Density Residential 65 Low Density Residential 27.3 3.0 82 ~
Zacharias Ranch 478.7 ~ 700 7,260,000
TPF Development 119.7
Keystone Ranch 97.3
Acreage
(Gross) Density # of Units Bldg. Sq. Ft.

PROJECT SUMMARY
BY DEVELOPMENT ~ 720 ~ ~ 719 ~
Development
Lakeside Hills Development 387.7 ~ 2,521 505,000
Ivy Rose Gardens 143.7 3.0 431 ~
PROJECT TOTAL 1,296.6 ~ 5,091 7,765,000
Color

1. Areas for B-1 through B-5 are INCLUDED in the Planning Area Acreages. Exact size to be determined with Development of each Planning Area

2. Future ±14 Acre Elementary School to be located East of Baldwin Road (acreage not included in calculations above)

3. Future ±15 Acre Middle School to be located West of Baldwin Road (acreage not included in calculations above)
P-11 Park 3.0 ~ ~ ~
56 4.2 10.5 4357 5.5 10.5 5758 High Density Residential 5.0 18.0 90 ~59 Medium Density Residential 12.2 6.5 79 ~60 Medium Density Residential 13.7 6.5 88 ~61 Medium Density Residential 16.6 6.5 107 ~ Medium Density ResidentialMedium Density ResidentialMedium Density Residential Mixed UseMixed UseMixed Use

6.5 906.5
50,50058,50061,500
113,500
74,00098,500

TPF DEVELOPMENT KEYSTONE RANCH

LAKESIDE HILLS DEVELOPMENT
11 Light Industrial 317.5 ~ ~ 6,910,000
General Commercial 22.2
Low Density Residential 216.4
Acreage
(Gross) Density # of Units Bldg. Sq. Ft.

PROJECT SUMMARY

BY LAND USE
~ ~ 350,000

3.7 809 ~
Land Use
Medium Density Residential 539.1 6.4 3,459 ~
High Density Residential 30.6 17.6 538 ~
PROJECT TOTAL 1,296.6 ~ 5,091 7,765,000
Color
Mixed Use 28.2 10.4 285 505,000
Park / Bike & Pedestrian Pathways 59.7 ~ ~ ~
PA Land Use Acreage (Gross) Density # of Units Bldg. Sq. Ft.

OS-3OS-4
Flood Control / Park 39.4 ~ ~ ~
Recharge Basin 30.1 ~ ~ ~

STORMWATER RECHARGE
& FEMA SOLUTION - TOTAL 69.5 ~ ~ ~ STORM RECHARGE
& FEMA SOLUTION
Stormwater Recharge & FEMA Solution 69.5 ~ ~ ~

82.9 ~ ~ ~ Open Space / Lake / Flood Control /
Park / Recharge Basin
City of Patterson 6th Cycle Housing Element
Zacharias Master Plan Area Land Use Diagram
Figure 4-2
Source: GDR Engineering 2022
Packet Pg. 1444
Section 4.0 Housing Resources and Sites Inventory 4-17 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 The City has previously demonstrated success in collaborating with nonprofit affordable housing developers, such as Self-Help Enterprises, which developed the 138-unit affordable Stonegate Village Apartments in 2021. To facilitate this project, the City provided several development concessions, including an increase in density from a maximum of 12.0 to 20.0 dwelling units per acre, enabling the developer to qualify for the State Density Bonus. The City remains committed to leveraging such partnerships and providing necessary development concessions to facilitate affordable housing in the Master Plan Area. This approach reflects the City's proactive efforts to balance land use efficiency with the delivery of needed housing.

Potential Limitations to Development
The Zacharias development area faces development limitations. While the area is already annexed, vacant, and ready for construction, the primary challenge lies in developer accountability to contribute fair share funding to expand the potable water and wastewater infrastructure needed to accommodate projected growth. However, temporary connections to existing wastewater systems in the Keystone Ranch and Lakeside Hills areas are available to support the very initial phases of development. To secure potable water supplies for the project, developers will need to contribute their fair shares to finance the Del Puerto Creek Recharge Project and the project will need to be constructed. The City is open to working with developers who are accountable and invested in the long-term growth and development of affordable housing within the Master Plan Areas.

Baldwin Ranch South Development Area
The Baldwin Ranch South development area covers 66 acres at the southern end of Baldwin Road, bordered by the Delta-Mendota Canal to the west, the City of Patterson Corporation Yard to the north, and agricultural land to the east and south. Annexed in Spring 2024, the area is scheduled for development starting in Summer 2025, with 305 residential units planned in a single phase. The master-planned community will also include five acres of parkland, featuring a bike path to enhance recreational opportunities for residents. The tentative maps for the master plan area have not yet been recorded.

Residential Potential
The Baldwin Ranch South development area is designed to accommodate 305 residential units across 60.9 acres. All 305 units are allocated to medium-density developments such as single-family homes, townhouses, and duplexes. Medium Density Residential uses permit residential densities ranging from 5.1 to 12.0 dwelling units per acre.

The site inventory allocates the 305 residential units to accommodate 91 moderate- and 214 above moderate-income units. Table 4-6 outlines the residential opportunities in the Baldwin Ranch South development area.

Packet Pg. 1445
Section 4.0 Housing Resources and Sites Inventory 4-18 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Table 4-6 Baldwin Ranch South Development Area Residential Land Uses Zoning Land Use Density
(du/ac) Acres Units Percent Total Units
MR Medium Density
Residential 5.1 – 12.0 60.9 305 100%
Total 60.9 305 100%
SOURCE: City of Patterson, Zacharias and Baldwin Ranch Master Plan, August 2022 Anticipated Accessory Dwelling Unit Development
Similar to the Zacharias development area, the City anticipates development of ADUs in the Baldwin Ranch South development area in response to increased community and developer interest in ADU construction. Lennar and DR Horton are among the developers building residential units in Baldwin Ranch North, including parcels designed to accommodate ADUs. The City anticipates this trend will extend seamlessly into Baldwin Ranch South and is actively engaging with these developers to encourage and facilitate ADU development.

Active developers in the Baldwin Ranch South development area offer floorplans with JADU options at the time of purchase—such as layouts featuring a first-floor bedroom with a private bathroom and kitchenette—and many buyers are choosing to include this integrated option. For those who opt not to add a JADU during the initial purchase, the floorplans are designed to allow for easy retrofitting. In most cases, only minor modifications—such as adding a door to separate the entryway from the main living space and installing a small kitchenette or wet bar—are needed. This type of development supports aging in place and multigenerational living, offering flexible housing solutions for extended families and individuals with evolving needs. These creative, forward-thinking strategies provide a cost-effective way to expand affordable housing options through new construction, without placing the burden of building separate units on homeowners. By leveraging thoughtful design integration, the City is advancing its commitment to attainable housing that aligns with both state housing goals and local community needs. The Site Inventory allocates 15 percent of the anticipated above moderate-income units (214 units), equating to 32 ADUs distributed across very low-, low-, moderate-, and above moderate-income categories. Using ABAG's 30-30-30-10 percent distribution methodology, this allocation includes 10 very low-income, 10 low-income, 10 moderate-income, and two above moderate-income ADUs within the Baldwin Ranch South development area.

Available Infrastructure
Lennar and LGI are currently developing residential communities north of the Baldwin Ranch South development area, with infrastructure expected to be completed by December 2025. The Baldwin Ranch South development area will be designed to build upon and expand the infrastructure from the adjacent northern developments. It is likely that Lennar and LGI will continue expanding Packet Pg. 1446
Section 4.0 Housing Resources and Sites Inventory 4-19 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 residential development into the Baldwin Ranch South development area, supporting the seamless extension of infrastructure. This development area is also subject to the provisions of the Groundwater Sustainability Plan (GSP). Developers will be required to contribute their fair share of financing for improvement projects to meet the state-imposed timeline to mitigate water shortages.

Development Phasing
Due to the small number of residential units to be developed and fewer necessary infrastructure improvements, development of the Baldwin Ranch South development area will be carried out in a single phase. As previously mentioned, Lennar and LGI are actively developing communities just north of the recently annexed Baldwin Ranch South development area, making it likely they will continue expanding in this region. Their established presence, ongoing projects, and investment in the area suggest they are well-positioned to pursue further development. Additionally, the proximity of these communities to Baldwin Ranch South offers strategic advantages, such as shared infrastructure and streamlined approvals, further encouraging continued growth by these developers.

Realistic Capacity Analysis
The capacity analysis for the Baldwin Ranch South development area is informed by the Master Plan’s residential land use designations, which for Baldwin Ranch South includes Medium Density Residential (5.1 to 12.0 dwelling units per acre). Unit allocations for the Medium Density Residential land use category are based on the available acreage and the permissible development density. Table 4-7 presents the realistic capacity assumptions for the Baldwin Ranch South development area.

The capacity analysis for the Baldwin Ranch South development area applies a single density of 5.1 dwelling units per acre for medium-density residential zones, resulting in an average development capacity of 42 percent resulting in a total 305 residential units Packet Pg. 1447
Section 4.0 Housing Resources and Sites Inventory 4-20 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Table 4-7 Baldwin Ranch South Development Area Realistic Capacity Site ID Acreage Existing
Zoning
Permitted
Density
Utilized
Density
Percent
Capacity
VLI
Units
LI
Units
MI
Units
AM
Units
Total
Units
Baldwin Ranch South
2 60.9 MR 5.1 – 12.0 du/ac 5.1 42% 91 214 305
Total 60.9 Subtotal 0 0 91 214 305
15% ADUs 10 10 10 2 32
Grand
Total 10 10 101 216 337
SOURCE: City of Patterson, Zacharias and Baldwin Ranch Master Plan, August 2022 Packet Pg. 1448
Section 4.0 Housing Resources and Sites Inventory 4-21 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Vacant and Underutilized Sites
The City has identified 12 vacant and underutilized sites capable of supporting 1,374 residential units. Of these, 703 units are designated for very low-income households, 588 for low-income households, and 83 for moderate-income households. Table 4-8 provides detailed information on these sites, excluding master-planned areas and pipeline projects.

Site Suitability
Pursuant to Government Code Section 65583.2(c)(2)(A), (B), and (C), all sites identified in the inventory to accommodate lower-income housing are adequately sized, with each site being at least half an acre and no larger than 10 acres.

Land use controls and site improvement requirements have been analyzed for constraints within Chapter 2, Constraints Assessment, and necessary changes to the review process are included as Programs within Chapter 3, Goals, Policies and Programs. The realistic development capacity for the site inventory begins with assuming those process changes to be in place by or prior to December 2025.

In accordance with Government Code Section 65583.2(c)(3), all sites planned to accommodate lower-income units are zoned to support appropriate densities of 20 dwelling units per acre, or they are undergoing rezoning to permit higher densities to better facilitate housing development.

Program 1.10 proposes an amendment to the Zoning Code to revise development standards in the High Density Residential and Downtown Core Zoning Districts, including increasing residential densities. These increases are detailed in Table 3-2 of the program (see Chapter 3). These changes to density do not apply to the Zacharias and Baldwin Ranch Master Plan areas.

All sites planned to accommodate lower-income units are zoned one of the following:
 High Density Residential: permits 20.1 to 35.0 dwelling units per acre;  Mixed-Use: permits 20.1 to 35.0 dwelling units per acre; or  Downtown Core: permits 20.0 to 35.0 dwelling units per acre.

Sites Requiring Rezoning
The City of Patterson has an unaccommodated housing need of 196 lower-income units from the 5th Cycle Housing Element. In accordance with Government Code Section 65584.09, this deficit must be addressed in addition to the 6th Cycle RHNA allocation of 3,716 units, resulting in a total housing need of 3,912 units. To accommodate this requirement and to meet the lower-income RHNA, the City will rezone land to facilitate high-density residential development. Table 4-9 identifies the specific sites that require rezoning, with the City committed to completing the necessary zoning amendments by December 2025. Program 1.11 in Chapter 3 of this Housing Element proposes these zoning amendments.

Packet Pg. 1449
Section 4.0 Housing Resources and Sites Inventory 4-22 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Table 4-8 Vacant and Underutilized Sites
Site
ID APN Existing General Plan Existing Zoning
Proposed
General
Plan
Proposed
Zoning Area MaxDensity
Yield %
of Max
Density
VLI
Units
LI
Units
MI
Units
AM
Units Total Vacant By-Right with 20% affordable
High Density Residential
3 021-040-055 High Density Residential HR -- -- 0.80 20.0* 100% 16 16 Yes No 4 047-024-024 High Density Residential HR -- -- 2.8 35.0 81% 43 36 79 Yes No 5 047-034-035 High Density Residential HR -- -- 2.13 35.0 81% 60 60 Yes Yes Sites requiring rezone
6 048-042-001 General Commercial GC HDR HR 5.5 35.0 81% 79 77 156 Existing business No
7 048-042-008 General Commercial GC HDR HR 3.97 35.0 81% 58 55 113 Yes No 8 048-043-002 General Commercial GC HDR HR 2.08 35.0 81% 29 30 59 Existing storage yard No
9 048-043-015 General Commercial GC HDR HR 2.55 35.0 81% 36 36 72 Existing special event center No
10 048-048-007 General Commercial GC HDR HR 10.00 35.0 81% 155 128 283 Yes Yes Subtotal 29.83 -- -- 476 362 0 0 838
Downtown Core
11 047-031-062 Downtown Commercial DC -- -- 9.01 35.0 81% 128 128 256 Yes No Subtotal 9.01 -- -- 128 128 0 0 256
Mixed-Use
Sites requiring rezone
12 021-028-007 Highway Service
Commercial HSC Mixed-Use MU 3.41 35.0 57% 24 24 20 68 Yes No 13 021-028-008 Highway Service
Commercial HSC Mixed-Use MU 2.06 35.0 57% 15 14 12 41 Yes No 14 021-098-003 General Commercial GC Mixed-Use MU 8.53 35.0 57% 60 60 51 171 Yes No Subtotal 14.0 -- -- 99 98 83 0 280
Total 52.84 -- -- 703 588 83 0 1,374
SOURCE: City of Patterson, 2024
NOTES: Sites 6-10 and 12-14 require rezoning to accommodate higher residential densities.

Packet Pg. 1450
Section 4.0 Housing Resources and Sites Inventory 4-23 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Table 4-9 Sites Requiring Zoning Amendment
SOURCE: City of Patterson, 2024
NOTE: HR and MU Zoning Districts allow 20.1 – 35.0 dwelling units per acre, as implemented through Program 1.10 in Chapter 3.

Previously Identified Sites
Notably, Sites 5 and 10 were previously identified in the 5th Cycle Housing Element. These sites are subject to the provisions of Government Code Section 65583.2(c), which requires that undeveloped sites from a previous housing element be rezoned to accommodate lower-income housing needs, specifically allowing a density of 20 dwelling units per acre, and allow residential use by-right for housing developments in which at least 20 percent of the units are affordable to lower-income households. Program 1.12 establishes by-right approval of these sites when developers include 20 percent affordable units (see Chapter 3).

Non-Vacant Sites
Government Code Section 65583.2(g)(2) states that housing elements relying on non-vacant sites for greater than 50 percent of its lower-income households need to demonstrate that the existing use does not constitute an impediment to additional residential development. Over 70 percent of the sites included in the site inventory (excluding pipeline projects) are vacant. Sites 6, 8, and 9, currently have existing commercial uses, with none of the identified sites containing residential uses. The following sections discuss several factors considered for inclusion of these non-vacant sites in the Site Inventory.

Site ID Land Use Change Zoning Change APN Acreage Realistic Capacity:

Lower-Income Units
6 General Commercial to
High Density GC to HR 048-042-001 5.5 156
7 General Commercial to
High Density GC to HR 048-042-008 3.97 113
8 General Commercial to
High Density GC to HR 048-043-002 2.08 59
9 General Commercial to
High Density GC to HR 048-043-015 2.55 72
10 General Commercial to
High Density GC to HR 048-048-007 10.21 290
12 Highway Service
Commercial to Mixed-Use HSC to MU 021-028-007 3.41 48
13 Highway Service
Commercial to Mixed-Use HSC to MU 021-028-008 2.06 29
14 General Commercial to
Mixed-Use GC to MU 021-098-003 8.53 120
Total Units 887
Packet Pg. 1451
Section 4.0 Housing Resources and Sites Inventory 4-24 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Improvement-to-Land Value Ratio
All non-vacant sites identified in the Sites Inventory exhibit characteristics that strongly suggest a high likelihood of redevelopment. One such indicator is a parcel’s improvement-to-land value ratio, which compares the assessed value of on-site structures to the value of the land. A ratio of less than

1.0 suggests that the market values the land more than the existing improvements, signaling that the site may be underutilized. These parcels present opportunities for property owners and developers to invest in higher-value improvements that better align with the site's potential.

It is important to note that while the improvement-to-land value ratio can be a useful screening tool, it does not account for development standards or environmental constraints that may affect the feasibility of redevelopment.

Table 4-10 summarizes redevelopment trends for non-vacant sites across Stanislaus County. As shown, the average improvement-to-land value ratio for these parcels is 0.92, indicating that many properties may be positioned for higher-intensity residential development.

Table 4-10 Redevelopment Trends of Non-Vacant Sites throughout Stanislaus County Jurisdiction Previous Use Zoning Site
Acreage
Total
Units
Improvementto-Land Value
Ratio
Year
Built FAR
Keyes Two single family
dwellings with extra land R-1 13.20 62 0.74 1978 0.03
Keyes Single family dwelling
with extra land R-1 9.54 28 0.07 -- --
Denair Single family dwelling
with extra land P-D 1.32 10 0.54 1930 0.05
Keyes Single family dwelling
with extra land R-1 2.11 8 1.51 1988 0.02
Denair Single family dwelling
with extra land
Rezoned
to P-D 4.82 17 1.18 1950 0.01
Keyes Single family dwelling
with extra land R-1 6.70 26 0.29 1992 0.02
Denair Single family dwelling
with extra land R-A 18.20 69 0.93 1908/1979 0.01
Modesto Commercial building,
medical office UGD 0.20 14 1.0 1982 0.82
Modesto Warehouse TD 0.93 79 2.1 1957 0.16
Average 0.92 1960 0.14
SOURCE: Stanislaus County 6th Cycle Housing Element January 2025 Packet Pg. 1452
Section 4.0 Housing Resources and Sites Inventory 4-25 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Table 4-11 presents improvement-to-land value ratio, the year existing structures were built, and the existing FAR. Notably, Sites 6, 8, and 9 in the Patterson Sites Inventory have an average improvement-to-land value ratio of 0.55, suggesting that the land value significantly exceeds the value of existing improvements. This indicates these sites are underutilized and strong candidates for redevelopment. Based on patterns observed in recent residential redevelopment projects across the county—most of which involved sites with similarly low improvement-to-land value ratios—it is reasonable to conclude that redevelopment of Sites 6, 8, and 9 is likely, and that the market would support more intensive residential use on these parcels.

Age of Structure
The age of existing structures is a valuable indicator of a parcel’s redevelopment potential. Parcels with recently constructed buildings are less likely to undergo further improvements or redevelopment in the near term, as the investment in new construction suggests the property is already being utilized to its intended capacity. Development trends across the county show that successful redevelopment of non-vacant parcels has typically occurred on sites with structures more than 50 years old (see Table 4-11).

Of the non-vacant sites identified in the Patterson Sites Inventory, structure age data was available only for Site 6, which contains a building that is 51 years old. This further supports the site's redevelopment potential, as older structures are more commonly associated with successful redevelopment efforts observed throughout the county.

Floor Area Ratio
Floor Area Ratio (FAR) values that fall below the maximum allowed by the zoning ordinance often indicate underutilized parcels, particularly in downtown or mixed-use areas where infill development is highly encouraged. In contrast, sites that are already developed with higher FARs are generally less likely to redevelop, as the cost of land and demolition may outweigh potential returns. Development trends across the county show that successfully redeveloped non-vacant parcels had an average FAR of 0.14, although in some cases, such as one notable project, the FAR reached as high as 0.82.

Of the non-vacant sites identified in the Patterson Sites Inventory, the average FAR is 0.2, indicating significant underutilization of these parcels. This further justifies their inclusion in the Site Inventory, despite their current non-vacant uses, as they present opportunities for redevelopment and more intensive land use.

Adequate Size and Density
Each of the non-vacant sites identified in the Patterson Sites Inventory is of sufficient size to accommodate high-density residential development, making them suitable for the inclusion of affordable housing. These sites are anticipated to undergo the necessary land use and zoning amendments to re-designate them as High-Density Residential, allowing for 20.1 to 35 dwelling units per acre.

Packet Pg. 1453
Section 4.0 Housing Resources and Sites Inventory 4-26 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Table 4-11 Non-Vacant Sites Identified for Residential Use Site Number Existing Use Existing
Zoning
Site
Acreage
Anticipated
Units After
Rezone
Improvementto-Land Value
Ratio
Year
Built FAR Aerial Image
6 Trucking company with extra
land GC 5.5 156 0.95 1974 0.03
8 Trucking company LR 2.08 59 0.64 -- 0.01
9 Special event center GC 2.55 72 0.06 -- 0.03
Average 0.55 0.02
SOURCE: Parcel Quest Lite, 2025
NOTE: All properties were last assessed in 2024.

Packet Pg. 1454
Section 4.0 Housing Resources and Sites Inventory 4-27 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Program 1.11 outlines a clear schedule of actions and monitoring measures to implement these amendments, including increasing allowable densities within the High-Density Residential Zoning District. In addition, the program includes provisions requiring by-right approval for qualifying projects in which at least 20 percent of units are affordable, thereby streamlining the entitlement process and facilitating the production of affordable housing.

Existing Uses
Existing uses on Sites 6, 8, and 9 would likely need to be demolished to accommodate housing development. Details of existing uses on each site are provided below.

Site 6, located at 154 Poppy Avenue, is currently occupied by Cartel Transportation, a trucking company. The parcel totals 5.5 acres and is largely underutilized. A single building is located in the center of the parcel; approximately 1.43 acres remain undeveloped to the east/northeast; and 2.31 acres are unpaved and used for truck parking to the west/southwest. Due to the underutilization of the site, the land value significantly exceeds the market demand for its current use.

Site 8 is currently used as a truck storage/scrap yard. Located at 440 Sperry Avenue, the site totals

2.08 acres. The site’s current uses as truck storage and a scrap yard provide limited economic value and face low market demand, particularly when compared to the higher and more sustainable economic potential associated with residential redevelopment.

Site 9, located at 125 Poppy Avenue, currently operates as a special event center; however, it has not hosted an event in ten years, rendering the existing use economically obsolete. The 2.55-acre site is, underutilized and would experience significantly higher market demand if redeveloped for residential use.

To facilitate the necessary zoning changes and promote residential development, the City is actively engaging with property owners to discuss redevelopment opportunities. The City is committed to working diligently and collaboratively to ensure these sites are successfully redeveloped for residential use in alignment with its housing goals. Program 1.11 sets forth a schedule of actions and monitoring to amend land use designations and rezone Sites 6-10 and 12-14 (see Chapter 3). If the necessary land use and zoning amendments for these sites are not completed by December 2025, the City will identify suitable and appropriately sized alternative site(s) to meet the RHNA.

As evidenced above, each of the non-vacant sites included in the Site Inventory presents a high likelihood of redevelopment based on factors such as improvement-to-land value ratio, age of existing structures, and floor area ratio (FAR). Additionally, all non-vacant sites are of adequate size and are proposed for land use and zoning amendments to allow for increased residential density.

The market demand for current uses—such as truck yards and a special event center—is not considered an impediment to redevelopment, given the nature of these uses and the City’s planning objectives.

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Section 4.0 Housing Resources and Sites Inventory 4-28 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Further, the City has notified these property owners of the inclusion of their properties in the Housing Element Site Inventory and the need to rezone the parcels to High-Density Residential to accommodate residential use. To date, none of the property owners have opposed the rezoning. The City continues to engage with these property owners to ensure they are fully informed about the potential for redevelopment and its role in helping the City meet its RHNA obligations. As such, the City does not foresee these existing uses precluding or constraining development. In the event that sites 6, 8, and 9 do not develop as anticipated in the Site Inventory, the City is committed to identifying alternative sites that are suitable for lower-income development.

History of Converting Existing Uses
Although the City has no recent history of formal land use conversions from non-vacant/nonresidential to residential uses, it has actively pursued strategies to facilitate such transitions. In particular, the City has made zoning concessions to allow multi-family residential development within industrial districts on non-vacant sites. These efforts have been supported by property owners, several of whom have engaged in discussions with City staff regarding the redevelopment of non-vacant, non-residential parcels for housing. To streamline the process, the City has explored allowing certain residential redevelopment projects to proceed through the building permit process without requiring discretionary planning entitlements.

One such example is a project at 720 N 2nd Street, where an abandoned non-residential building is currently being converted into a three-unit residential development and is currently in the building permit review stage. These proactive efforts demonstrate the City’s commitment to supporting infill residential development, even in areas not historically designated for housing.

The City recognizes the need to adapt governmental processes to facilitate residential development, often through creative and unconventional methods. Its willingness to collaborate with both property owners pursuing small-scale redevelopment and developers undertaking larger projects reflects the City’s broader commitment to expanding housing opportunities, meeting its RHNA targets, and transforming Patterson’s housing landscape in a meaningful way.

Non-Residential Zoned Sites
The site inventory identifies four vacant sites (Sites 11-14) zoned for mixed-use development, including residential uses. Recent development interest in the downtown area has prompted the City to propose increasing allowable densities from 12.1–20.0 to 20.0–35.0 dwelling units per acre and raising the maximum building height from 45 feet (three stories) to 50 feet (four stories). These measures, outlined in Program 1.10 of Chapter 3 in this Housing Element, aim to incentivize development.

Site 11 is a vacant parcel encompassing approximately nine acres within the Downtown Core (DC) Zoning District, which permits a variety of uses, including restaurants, retail, offices, hotels, multifamily residential units, and public and quasi-public services. Site 11 is projected to accommodate 256 lower-income housing units. Recent discussions with the City have revealed that the property Packet Pg. 1456
Section 4.0 Housing Resources and Sites Inventory 4-29 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 owner is interested in developing the site with apartments. The City is working closely with the property owner to provide incentives aimed at facilitating the development of 256 affordable housing units to meet the needs of lower-income households. Incentives include actions such as expedited planning review and processing, reducing planning permit fees by 50 percent with inclusion of deed-restricted affordable units, and deferred payment of impact fees. These ongoing discussions demonstrate a strong commitment to transforming the site into a viable residential development.

Sites 12 and 13, two adjacent vacant parcels totaling 5.47 acres, are currently zoned General Commercial (GC) and slated for rezoning to Mixed-Use (MU). The single property owner has expressed interest in developing a mixed-use project that includes residential apartments, and the City is in negotiations to support the development of 77 lower-income and 32 moderate-income units across both parcels.

Similarly, Site 14, a vacant parcel zoned General Commercial (GC) and also planned for rezoning to Mixed-Use (MU), has been approved for a commercial center with a residential component. The property owner has specifically expressed interest in residential development, and the City is actively negotiating to incentivize the inclusion of 120 lower-income, deed-restricted units, as well as 51 moderate-income units.

The City has successfully negotiated with property owners and developers to secure residential development. In 2021, the City partnered with Self-Help Enterprises to develop a 138-unit deedrestricted affordable rental building (Stonegate Village Apartments). The City provided concessions, such as increased densities and reduced parking requirements, enabling Self-Help Enterprises to qualify for State Density Bonus and Affordable Housing and Sustainable Community funding, which were crucial for the project's financial viability. This demonstrates the City's commitment to housing development and its willingness to offer development concessions to ensure project success and address housing needs.

Local Development Trends
Recent residential development in the City of Patterson has been predominantly single-family residential; however, multi-family and ADU production has seen an uptick in development.

In the eastern region, Self-Help Enterprises completed Stonegate Village in 2021, delivering 138 affordable rental units consisting of one- to three-bedroom apartments. Nearby, KB Home began construction of Sycamore Ranch and Acacia at Patterson Ranch in 2022, with both communities currently under construction. These ownership-based subdivisions offer three- to six-bedroom single-family homes targeted toward moderate-income households and are anticipated for full buildout by 2025.

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Section 4.0 Housing Resources and Sites Inventory 4-30 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 In the western region, which includes newly annexed master-planned areas and former industrial lands, private developers are leading large-scale residential projects. Lennar began developing the Holly Oak and Magnolia communities in 2023, while DR Horton launched construction of the Meadows community in the same year—each located within the Baldwin Ranch North Master Plan Area and offering three- to four-bedroom single-family homes currently available for purchase.

Landsea Homes commenced development of the Blossom community in 2023, delivering larger single-family homes with flexible floorplans to accommodate a range of household needs. While most of these western projects are market-rate ownership opportunities, select units—such as those with ADU options—support multi-generational living and may provide more affordable pathways to homeownership. Full buildout of these western communities is anticipated by 2026.

The programs outlined under Goal 1: Facilitate Housing Construction in Chapter 3 of this Housing Element are designed to support the production of affordable housing and include a range of actions the City is committed to implementing in order to encourage the development of affordable and diverse housing options.

Realistic Capacity Assumptions
Like many cities in Stanislaus County and the Central Valley region, the City of Patterson experienced limited multi-family development during the 5th cycle planning period. The most recent multi-family project is the previously mentioned, 138-unit deed-restricted affordable rental apartment building completed in 2021. To support density assumptions for its Site Inventory, the City reviewed multi-family projects developed across Stanislaus County over the past 10 years. As shown in Table 4-12, cities such as Turlock and Modesto have experienced multi-family residential development across various scales and zoning districts. On average, multi-family developments throughout the county achieved densities of 24 dwelling units per acre and utilized 81 percent of the maximum allowed density.

The site characteristics of these projects—including zoning and the percentage of allowable density achieved—align with the assumptions used for Patterson's site inventory.

High Density Residential and Downtown Core Realistic Capacity Assumptions Table 4-8 above identifies vacant and underutilized housing opportunity sites in Patterson. The City's Site Inventory assumes an 81 percent development capacity for projects zoned High Density Residential (HR) and Downtown Core (DC) to allow flexibility in project design, potential land use controls, site improvements, and to reflect typical densities for the region.

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Section 4.0 Housing Resources and Sites Inventory 4-31 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Table 4-12 Typical Densities of Multi-Family Projects in Stanislaus County Project Jurisdiction Zoning Max
Density
Site
Acreage
Total
Units
Achieved
Density
(du/ac)
Percent
Yield
Avena Bella,
Phase 2 Turlock Planned Development 30.0 2.20 61 27.7 92% Archway
Commons
Phase 1
Modesto Planned
Development 29.0 4.50 76 16.9 58%
Archway
Commons
Phase 2
Modesto Planned
Development 29.0 3.17 74 23.3 80%
3600 Dale Modesto Planned
Development 29.0 1.7 44 25.6 88%
112 James
Street Modesto R-3 29.0 0.3 7 25.6 88%
Average 23.8 81%
SOURCE: Stanislaus County Draft 6th Cycle Housing Element To calculate realistic residential capacity for sites currently zoned and proposed to be rezoned to High Density Residential or Downtown Core, the City applied adjustment factors to account for land use controls and site improvements, realistic capacity of the site, and typical densities in the region. The adjusted capacity for sites 3 through 11 is calculated as follows:
 Site 3: (0.80 acres × 20 du/ac × 0.85 × 0.85 × 0.80) = 16 units, 100 percent realistic yield;  Site 4: (2.80 acres × 35 du/ac × 0.95 × 0.95 × 0.90) =80 units, 81 percent realistic yield;  Site 5: (2.13 acres × 35 du/ac × 0.95 × 0.95 × 0.90) = 61 units, 81 percent realistic yield;  Site 6: (5.50 acres × 35 du/ac × 0.95 × 0.95 × 0.90) = 156 units, 81 percent realistic yield;  Site 7: (3.97 acres × 35 du/ac × 0.95 × 0.95 × 0.90) = 113 units, 81 percent realistic yield;  Site 8: (2.08 acres × 35 du/ac × 0.95 × 0.95 × 0.90) = 59 units, 81 percent realistic yield;  Site 9: (2.55 acres × 35 du/ac × 0.95 × 0.95 × 0.90) = 72 units, 81 percent realistic yield;  Site 10: (10 acres × 35 du/ac × 0.95 × 0.95 × 0.90) = 284 units, 81 percent realistic yield; and  Site 11: (9.01 acres × 35 du/ac × 0.95 × 0.95 × 0.90) = 256 units, 81 percent realistic yield.

Site 3 is the exception, projected to develop at full capacity due to its ownership. The Stanislaus Regional Housing Authority owns the property and plans to develop Phase 2 of the Las Palmas Senior Housing Complex. Zoned for High Density Residential, the site will be built to the existing permitted maximum density of 20 dwelling units per acre, accommodating 16 very low-income, deed-restricted units. The project utilizes the existing densities, as it is too advanced in the planning process to accommodate any changes to the proposed density. However, if the project does not Packet Pg. 1459
Section 4.0 Housing Resources and Sites Inventory 4-32 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 proceed as planned and the Housing Authority is interested in applying the proposed increased density for the High Density Residential Zoning District to accommodate additional units, that option would be available.

Site 11, which is currently zoned Downtown Core, is not proposed for rezoning. Although the zoning allows for non-residential uses, the City remains optimistic that residential development will occur due to the site’s strategic location near public amenities, transit options, and essential services.

City staff are actively engaged in discussions with the property owner to facilitate the development of residential units on this prime infill site.

Mixed-Use Realistic Capacity Assumptions
For projects planned to be rezoned to Mixed-Use (MU), a 57 percent development capacity is assumed, utilizing the minimum density of 20.1 dwelling units per acre, accounting for the inclusion of ground-floor commercial development alongside residential uses.

To calculate realistic residential capacity for sites proposed to be rezoned to allow mixed-use development, the City applied adjustment factors to account for land use controls and site improvements, realistic capacity of the site, and typical densities in the region. The adjusted capacity for sites 12 through 14 is calculated as follows:
 Site 12: (3.41 acres × 35 du/ac × 0.80 × 0.85 × 0.85) = 68 units, 57 percent realistic yield;  Site 13: (2.06 acres × 35 du/ac × 0.80 × 0.85 × 0.85) = 41 units, 57 percent realistic yield; and  Site 14: (8.53 acres × 35 du/ac × 0.80 × 0.85 × 0.85) = 171 units, 57 percent realistic yield.

Higher adjustment factors were applied to reflect the potential for ground-floor commercial uses being incorporated alongside residential development. This conservative approach serves as a safeguard against overestimating development potential, ensuring the City does not rely on unrealistic capacity projections that could result in a net loss of available housing sites if full development is not realized. This strategy helps maintain a balanced and reliable inventory for future growth. Residential development may be constructed at higher densities.

The City has included these three non-residential sites in the Site Inventory based on property owner interest in redeveloping for mixed commercial and residential uses during the 2023-2031 planning period. The City is actively negotiating with the owners to promote optimal land use and incentivize affordable multi-family development.

To ensure no net loss is achieved, the City will annually monitor built densities and make adjustments if development densities are not achieved as outlined in the Site Inventory. Program 1.1 establishes these actions for monitoring purposes, and sets alternative actions to be pursued, if multi-family projects are not achieving at least the densities set forth in the Site Inventory (see Chapter 3).

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Section 4.0 Housing Resources and Sites Inventory 4-33 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025

4.4 Availability of Infrastructure and Services
Potable Water System
The City of Patterson relies on groundwater from the Delta-Mendota Subbasin as its sole source of potable water. Despite the subbasin being designated as critically over drafted, the City has taken proactive steps to ensure long-term water sustainability. As an active stakeholder in the DeltaMendota Groundwater Sustainability Agency (GSA), Patterson is participating in the Groundwater Sustainability Plan (GSP), which aims to achieve groundwater sustainability by 2040. Key projects, such as the Percolation Ponds for Stormwater Capture and Recharge, demonstrate the City's commitment to maintaining adequate water resources. As noted in the Constraints Assessment, the City is subject to a new GSP that was adopted in November 2024. Accordingly, the City has taken the actions outlined in Program 1.15 to address the constraint on development.

Wastewater System
The City of Patterson's Water Quality Control Facility collects and treats all wastewater for the city and the nearby community of Diablo Grande, with a daily treatment capacity of 2.25 million gallons and current usage of 1.8 million gallons per day. The City's Urban Water Management Plan and Capital Improvement Program Master Plan ensure sufficient wastewater capacity through 2045, with no current capacity issues due to successful conservation efforts. Therefore, the City’s wastewater infrastructure will not pose a constraint to meeting RHNA obligations during the 6th Cycle planning period.

Storm Water and Drainage
Housing projects on identified sites must comply with Chapter 13.32, Urban Storm Water Quality Management and Discharge Control, of the Patterson Municipal Code, which mandates eliminating illegal discharges, protecting watercourses, and following best management practices for construction to minimize impacts on stormwater facilities. Implementation of these policies ensure the City can meet its RHNA requirements.

Circulation System
The City of Patterson is committed to enhancing accessibility and infrastructure through comprehensive planning and strategic investments in transportation and pedestrian safety. The City’s General Plan, particularly the Transportation Circulation Element, outlines long-term plans for roadways, transit systems, goods movement, and nonmotorized travel like bicycle and pedestrian infrastructure to meet future population growth.

In 2022, Patterson adopted the Active Transportation Plan, which aims to create a safe and accessible network of bike and pedestrian facilities, connecting existing trails and improving access to schools and community destinations. This plan emphasizes promoting walking and biking, enhancing pedestrian safety, improving air quality, and overall quality of life in the city.

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Section 4.0 Housing Resources and Sites Inventory 4-34 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Following the approval of Measure L by Stanislaus County voters in 2016, the City has used sales tax revenue to fund key projects, including citywide sidewalk replacements, Sperry Avenue improvements, and the Pedestrian Safety Improvement Project along Las Palmas and Ward Avenue.

Ongoing projects include the Local Roadway Safety Plan, funded by the Department of Transportation to improve mobility and safety, and the Urban Bicycle Trail Project, which will connect the city's northern and southern areas with a new trail along American Eagle Avenue. These initiatives demonstrate the City’s dedication to ensuring safe, accessible, and efficient infrastructure for its growing community.

Dry Utilities
Turlock Irrigation District (TID) supplies electricity to the city, while Pacific Gas and Electric (PG&E) provides natural gas. Telephone, internet, and cable TV services are offered by providers such as Frontier Communications and Comcast Xfinity.

Infrastructure Improvements Required to Support RHNA
The following discussion outlines infrastructure requirements for the Sites Inventory, identifying where expansion or extension of utilities and services is necessary to support residential development.

Future growth in the Zacharias and Baldwin Ranch Master Plan areas will require expansion of existing wastewater and water systems. To confront this development constraint, contribution from developers and long-term planning is essential to support anticipated growth.

Currently, wastewater services are available through temporary utility connections along Keystone Pacific Parkway, while potable water services are accessible via existing pipelines along Rogers Road, Zacharias Road, and Ward Avenue/State Route 33. These connections will support the initial phases of development in the Zacharias and Baldwin Ranch Master Plan areas.

To support the expansion of water and wastewater infrastructure in the Zacharias and Baldwin Ranch Master Plan areas to accommodate long-term growth, the City will partner with developers, as well as pursue state and federal grants, such as Proposition 1, Integrated Regional Water Management Grant, CDBG Fund, Clean Water State Revolving Fund, and Drinking Water State Revolving Fund. Developers are required to finance the necessary infrastructure to support residential development. Next steps include securing funding commitments, finalizing infrastructure design plans, and coordinating with utility providers to ensure phased implementation aligns with development timelines. Program 5.7 proposes several actions for the City in order to ensure completion of infrastructure improvements during the planning period.

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Section 4.0 Housing Resources and Sites Inventory 4-35 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 The Baldwin Ranch South portion of this Master Plan is designed to build upon and expand existing infrastructure from adjacent developments to the north. Lennar and LGI, currently developing residential communities in the Baldwin Ranch North area, are expected to continue their expansion into the Baldwin Ranch South area, ensuring a seamless extension of infrastructure.

All other sites in the inventory have adequate existing infrastructure and do not require the construction of new or expanded facilities.

Capital Improvement Program Investment
To support existing and future growth, the City updates its Capital Improvement Program (CIP) annually. Appendix A, Assessment of Fair Housing, analyzes access to resources throughout the city, detailing the City includes both high and moderate resource areas according to TCAC data. The CIP includes infrastructure projects targeting moderate resource areas, where needs are more pressing.

These projects focus on pedestrian improvements, ADA compliance, enhanced connectivity between the western and eastern areas, and upgrades to potable water, sewer, and stormwater systems. The City's investment in these projects aims to ensure equitable access to services, improve circulation, and enhance accessibility to essential public services.

As noted above, Program 5.7 in Chapter 3 outlines actions for the City to ensure the CIP prioritizes moderate resource areas for investment to support housing development. It also establishes specific actions for infrastructure improvements needed in the Master Plan area. These efforts aim to address the greater needs in these areas and facilitate the development of housing while improving overall infrastructure across the City.

4.5 Environmental Constraints
The City participated in the 2022 Stanislaus County Multi-Jurisdictional Hazard Mitigation Plan, which addresses vulnerabilities from natural and human-caused hazards, including flooding, drought, wildfire, landslides, severe weather, terrorism, cyber threats, pandemics, and the impacts of climate change. Patterson is located in a region with high seismic activity and is about 20 miles from the Greenville Fault and 15 miles from the Ortigalita Fault, making the city susceptible to earthquake impacts. While the overall earthquake risk in Stanislaus County is medium, it is high for western and southern communities, including Patterson. Small areas in northern Patterson fall within the Federal Emergency Management Agency’s (FEMA) 1 percent annual chance flood zone. Although the city is not in a Fire Hazard Severity Zone, it is adjacent to areas with high wildfire risk.

The City implements regulations and programs to minimize risks from seismic, flood, and wildfire hazards, including the Land Use Element, Community Design Element, Health and Safety Element, City Building Code, and building permit process. There are no known environmental constraints on the identified sites in the Site Inventory, and each project will undergo site-specific environmental review to ensure compliance with safety regulations.

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Section 4.0 Housing Resources and Sites Inventory 4-36 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Parcel Shape and Access of Identified Housing Opportunity Sites The shape of a parcel can significantly impact development by influencing site layout, building design, and infrastructure placement. Regularly shaped parcels, such as rectangles or squares, are generally easier to develop, allowing for efficient use of space and standard construction practices.

Irregularly shaped parcels, like triangles or narrow lots, may require creative design solutions to maximize buildable area and ensure proper access, parking, and setbacks. While unusual shapes can present challenges, they do not necessarily prevent development if the parcel is large enough to accommodate the intended use.

Site 3, owned by the Stanislaus Regional Housing Authority, is the only triangular-shaped parcel, and has access potential on four sides. However, its size is sufficient to support the planned housing, so its shape does not pose any constraints. All other identified housing opportunity sites have regular parcel shapes and adequate access to existing city streets and roads.

Easements
As part of the Zacharias development area, two key easements will be required: one for the Patterson Irrigation District (PID) canal and another for the West Stanislaus Irrigation District (WSID). The PID easement is planned to run north to south along the eastern edge of the Keystone Ranch and Lakeside Hills development areas. It will be placed underground and designed to accommodate a Class I bike path paseo above the approximately 40-foot-wide corridor. Similarly, the WSID easement will run north to south along Baldwin Road, west of the Lakeside Hills and Keystone Ranch development areas, and will also be located underground with a bike and pedestrian pathway constructed over the approximately 30-foot-wide corridor. The City has been in active communication with both irrigation districts and does not anticipate these easements posing any constraints to the development of residential uses within the Master Plan Area.

Site Contamination
None of the identified housing opportunity sites are located on a parcel that is included on any list compiled pursuant to Section 65962.5 of the Government Code, including:
 California Environmental Protection Agency’s Cortese List (Health and Safety Code Section 25187.5);
 State Water Resources Control Board’s GeoTracker (Health and Safety Code Section 25295 and Water Code Sections 13273 and 13301); and
 California Environmental Protection Agency’s list of solid waste sites identified by the Water Board with waste constituents above hazardous waste levels outside the waste management unit (Health and Safety Code Section 116395).

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Section 4.0 Housing Resources and Sites Inventory 4-37 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025

4.6 Financial Resources for Affordable Housing
The City of Patterson promotes affordable housing through its Inclusionary Housing Program (Chapter 18.86 of the Municipal Code), requiring new developments to include a minimum percentage of affordable units for lower- and moderate-income households. The City of Patterson does not receive direct CDBG (Community Development Block Grant) or HOME funds from the U.S. Department of Housing and Urban Development (HUD). Instead, it participates in the Stanislaus County Block Consortium, which includes several cities within the county. Through this consortium, Patterson is able to access CDBG and HOME funds for affordable housing development and community projects
Community Development Block Grant
Non-entitlement jurisdictions, including cities with populations under 50,000 and counties under 20,000 that do not participate in the federal CDBG entitlement program, can apply for funding through HCD’s CDBG Program. This program supports rural cities and counties in expanding community and economic development opportunities for low- and moderate-income residents. The City is committed to applying for CDBG funding to support program implementation to assist lower-income households and to facilitate the development of affordable housing.

Permanent Local Housing Allocation
HCD released approximately $24 million in funding through the Permanent Local Housing Allocation (PLHA) program to support local governments in addressing housing needs, including those of unhoused and low-income residents. The City of Patterson is committed to applying for PLHA funds to acquire land to facilitate the development of deed-restricted affordable residential units, and to implement other housing-related programs.

Low Income Housing Tax Credits
The Low-Income Housing Tax Credit (LIHTC) program incentivizes private developers and investors to create affordable housing by offering federal and state tax credits to offset construction costs. These federal tax credits are allocated to each state based on population, with the California Tax Credit Allocation Committee managing both the federal and state LIHTC programs in California. These tax credits support both new construction and the rehabilitation of existing properties, prioritizing projects that serve lower-income households and maintain affordability for the longest period.

Self-Help Enterprises is a local nonprofit in Patterson that leverages LIHTC to develop affordable housing. One notable project is Stonegate Village, a 138-unit affordable rental community. This development, funded in part by LIHTC, provides housing for low-income residents and includes various community amenities. Self-Help Enterprises has been instrumental in supporting affordable housing efforts in Patterson, combining LIHTC with other funding sources to meet local housing needs.

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Section 4.0 Housing Resources and Sites Inventory 4-38 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025

4.7 Local Housing Developers
Over the past eight years, the City of Patterson has seen increased interest from developers such as Self-Help Enterprises, KB Homes, Lennar, and DR Horton, which have significantly expanded housing options in the city's western and eastern areas. The City has partnered with these developers to focus on residential projects, public amenities, and infrastructure in the city’s western and eastern regions.

The eastern region, a moderate resource area, has long needed investment to boost housing availability and improve infrastructure and resources. Self-Help Enterprises and KB Home have paved a path for new residential opportunities and increased resources for residents in the eastern region of the city.

Self-Help Enterprises, a nonprofit providing affordable housing across the San Joaquin Valley, completed Stonegate Village in 2021. This 138-unit affordable rental development features 46 onebedroom, 46 two-bedroom, and 46 three-bedroom apartments. Amenities include a playground, basketball court, picnic areas, BBQ grills, and an on-site laundry room. A central community building offers a computer lab, site-wide Wi-Fi, and space for resident services like exercise classes, afterschool programs, and wellness initiatives. Energy-efficient features include a Solar PV system and transit-friendly additions such as a bus pullout and shelter with solar lighting. Self-Help Enterprises also partnered with Spectrum Energy Development Inc. to develop a pilot Net Energy Metering program. Monthly rents, based on unit size and resident income, range from $364 to $1,011, ensuring long-term affordability.

KB Homes’ Sycamore Ranch community at Patterson Ranch offers three to six-bedroom homes starting at $476,990, catering to large households, while Acacia at Patterson Ranch provides three to four-bedroom units starting at $453,990. Both communities feature parks, easy access to State Route 33 and I-5, and public transit to promote commuter-friendly options. These communities are both currently under construction.

In the western region of Patterson, marked by underutilized industrial land, newly annexed areas, and recent development, Lennar, DR Horton, and Landsea Homes are spearheading significant residential projects. Lennar is currently developing two communities, Holly Oak and Magnolia, within the Baldwin Ranch North development area. Holly Oak features three- to four-bedroom homes priced between $472,000 and $583,880, while Magnolia offers similar units, priced from $499,880 to $579,880. Both communities contribute to expanding housing options in the city’s southwestern region and are actively marketing units for sale.

Similarly, DR Horton is constructing the Meadows community, also within the Baldwin Ranch North development area. Meadows offers three- to four-bedroom homes ranging from 1,602 to 2,065 square feet, priced between $485,000 and $543,000. These homes are designed to cater to families, featuring open-concept kitchens and shared living spaces, with units currently available for purchase. Additionally, DR Horton offers a plan with an ADU which is popular with buyers.

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Section 4.0 Housing Resources and Sites Inventory 4-39 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Landsea Homes is constructing the Blossom community, which features larger three- to fourbedroom homes ranging from 1,766 to 2,449 square feet, priced between $504,403 and $599,815.

With three floorplans available, Blossom accommodates a variety of household needs, with units currently on the market.

Located just south of these up-and-coming communities, the Baldwin Ranch South development area further enhances the appeal of these communities by providing approximately six acres of parkland. Additionally, residents will benefit from the proximity to the Patterson Joint Unified School District, which includes Apricot Valley Elementary, Creekside Middle School, and Patterson High School, offering convenient access to educational facilities.

Affordable Housing Providers
Affordable housing providers are a critical resource to achieving the goals and objectives outlined in this Housing Element, often through private/public partnerships. Table 4-13 highlights the active affordable housing providers and the related affordable housing developments in Patterson, showcasing the collaborative efforts to meet the community's housing needs.

City of Patterson’s Commitment to Facilitating Housing Production As previously mentioned, Self-Help Enterprises is an experienced affordable housing developer managing 1,347 affordable rental units across 28 sites in the San Joaquin Valley. They leverage LowIncome Housing Tax Credits and Affordable Housing and Sustainable Communities programs to finance their projects, which often require complex capital structures and development concessions from local jurisdictions to ensure feasibility.

Table 4-13 Affordable Housing Providers in Patterson
Organization Development
Name Address Housing Type
Self-Help Enterprises Stonegate Village 625 Logan Way, Patterson, CA 95363 Multi-Family
Stanislaus Regional Housing
Authority
Las Palmas Senior
Housing Complex
1075 W. Las Palmas Avenue,
Patterson, CA 95363 Senior
The Michael’s Organization El Solyo Village 850 N 2nd Street, Patterson, CA 95363 Senior
Stanislaus Regional Housing
Authority
Patterson Place
Apartments
670 N 6th Street, Patterson,
CA 95363 Multi-family
Stanislaus Regional Housing
Authority
Patterson Migrant
Farmworker Housing
Center
N/A Farmworker
SOURCE: City of Patterson, 2024
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Section 4.0 Housing Resources and Sites Inventory 4-40 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 The City of Patterson partnered with Self-Help Enterprises to develop Stonegate Village, an affordable multi-family rental housing project in the city’s eastern region. To incentivize Self-Help Enterprises and ensure feasibility of the project, the City employed several strategies, including accepting development concessions that made the project more feasible. These included increasing densities to 20 dwelling units per acre, above the standard 5.1 to 12 dwelling units per acre for medium-density residential areas, and reducing parking requirements. These concessions ensured the project met eligibility for the State Density Bonus and Affordable Housing and Sustainable Community funding, which were essential for its financial viability.

The City's willingness to collaborate with the developer by accepting development concessions directly enabled the successful development of affordable housing at Stonegate Village. Patterson remains committed to working with nonprofit affordable housing developers to ensure that affordable housing for lower-income households is built to meet the city's growing housing needs.

Dedicated housing staff will lead the effort to guide developers toward areas where targeted investment and residential development are most needed to create a balanced community.

Developer incentives and project concessions will be evaluated and negotiated on a case-by-case basis, with assistance provided in securing funding to ensure project feasibility (see Program 1.6 Affordable Housing Development in Chapter 3).

4.8 Administrative Resources
This section outlines the City of Patterson’s available administrative resources, including building services, code enforcement, housing programs, and collaborations with nonprofit organizations.

These resources help the city achieve the goals and objectives set forth in this Housing Element.

City of Patterson Planning Services
The Planning Division of the Community Development Department provides and coordinates development information and services to the public. Specifically, the Planning Division provides staff support to the City Council and Planning Commission in formulating and administering plans, programs, design guidelines, and legislation for guiding the city’s development in a manner consistent with the community’s social, economic, and environmental goals.

The Planning Division is tasked with ensuring that land uses and new development in Patterson comply with City codes, the General Plan, City Council and Planning Commission policies, and state law. Approval of projects through the planning process is required before the City issues grading or building permits. Advanced planning programs provided by the Planning Division include a comprehensive General Plan update (including periodic update of the Housing Element), preparing and amending specific plans and design guidelines, and conducting special land use studies as directed by the City Council.

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Section 4.0 Housing Resources and Sites Inventory 4-41 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 The City's Planning Division includes a dedicated Housing Program Coordinator, providing focused oversight and management of housing initiatives. This role streamlines processes, improves efficiency, and ensures compliance with local and state regulations. During the planning period, the coordinator will lead the implementation of housing programs, oversee the execution of the city's Housing Element, and manage affordable housing projects. Additionally, the coordinator will foster partnerships with nonprofit organizations, all contributing to the City's long-term housing goals.

County of Stanislaus
The Stanislaus Regional Housing Authority applies for and administers several federal housing programs, primarily through HUD. These include:
 Housing Choice Voucher (Section 8) Program: This program helps very low-income families, the elderly, and the disabled afford decent and safe rental housing in the private market by providing rental assistance;
 Public Housing Program: The Housing Authority manages conventional public housing units funded by federal assistance, offering affordable housing to low-income families, the elderly, and people with disabilities; and
 Migrant and Farm Labor Housing Programs: These programs provide affordable housing to seasonal and year-round farmworkers.

These programs are designed to assist residents in Stanislaus County with affordable housing options through rental subsidies and housing assistance initiatives. The Housing Authority works to ensure compliance with HUD guidelines while providing these essential services.

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Assessment of Fair Housing A

APPENDIX
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Table of Contents
APPENDIX A ASSESSMENT OF FAIR HOUSING ............................................................A-1 A.1 Introduction and Overview..................................................................................................A-1 A.2 Approach to Analysis............................................................................................................A-2 A.3 Fair Housing Methodology ..................................................................................................A-4 A.4 Fair Housing Resources........................................................................................................A-6 A.5 Segregation and Integration .................................................................................................A-9 A.6 Concentrated Areas of Poverty and Segregation ............................................................A-26 A.7 Disparities in Access to Opportunities.............................................................................A-30 A.8 Disproportionate Housing Needs.....................................................................................A-46 A.9 Fair Housing Issues and Contributing Factors...............................................................A-60 A.10 Fair Housing Goals and Priorities.....................................................................................A-62 A.11 Local Data and Knowledge................................................................................................A-64 A.12 Identified Housing Opportunity Sites and Affirmatively Furthering Fair Housing ..A-64 Tables
Table A-1 Fair Housing Cases Filed, City of Patterson, 2016 .............................................. A-7 Table A-2 Fair Housing Issues, Contributing Factors, and Programmatic Actions........ A-63 Table A-3 Distribution of Housing Opportunity Sites by Quadrant, City of Patterson A-67 Figures
Figure A-1 Identified Housing Opportunity Sites According to Quadrant......................... A-3 Figure A-2 Percent Total Non-White Population, Stanislaus County and City of Patterson .................................................................................................................. A-11 Figure A-3 High Segregation and Poverty, Stanislaus County and City of Patterson ...... A-13 Figure A-4 Percent Population with One or More Disabilities, Stanislaus County and City of Patterson ............................................................................................. A-16 Figure A-5 Adults in Households Living Alone, Stanislaus County and City of Patterson .................................................................................................................. A-20 Packet Pg. 1472
Figure A-6 Female Headed Households with Children, No Spouse/Partner, Stanislaus County and City of Patterson ............................................................. A-21 Figure A-7 Median Household Income, Stanislaus County and City of Patterson........... A-23 Figure A-8 Poverty Status, Stanislaus County and City of Patterson.................................. A-25 Figure A-9 Racially or Ethnically Concentrated Areas of Poverty, Stanislaus County and City of Patterson ............................................................................................. A-28 Figure A-10 Racially Concentrated Areas of Affluence, Stanislaus County and City of Patterson ............................................................................................................. A-29 Figure A-11 TCAC Opportunity Areas Composite Score, Stanislaus County and City of Patterson..................................................................................................... A-32 Figure A-12 TCAC Opportunity Areas, Education Domain, Stanislaus County and City of Patterson..................................................................................................... A-34 Figure A-13 TCAC Opportunity Areas, Economic Domain, Stanislaus County and City of Patterson..................................................................................................... A-37 Figure A-14 Jobs Proximity Index, Stanislaus County and City of Patterson...................... A-39 Figure A-15 AllTransit Performance Score, Stanislaus County and City of Patterson....... A-42 Figure A-16 CalEnviroScreen 4.0 Percentile Scores, Stanislaus County and City of Patterson .................................................................................................................. A-45 Figure A-17 Percent Households with any of the Four Severe Housing Problems, Stanislaus County.................................................................................................... A-48 Figure A-18 Housing Cost Burden by Renters, Stanislaus County and City of Patterson .................................................................................................................. A-50 Figure A-19 Housing Cost Burden by Homeowners, Stanislaus County and City of Patterson .................................................................................................................. A-51 Figure A-20 Overcrowded Households, Stanislaus County and City of Patterson............. A-53 Figure A-21 Sensitive Communities (2023), Stanislaus County and City of Patterson ...... A-58 Figure A-22 Estimated Displacement Risk Among Very Low-Income Households (2023), City of Patterson........................................................................................ A-59 Figure A-23 Distribution of Site Inventory by Income Designation & Opportunity Areas......................................................................................................................... A-66 Packet Pg. 1473
Appendix A Assessment of Fair Housing A-1 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Appendix A
Assessment of Fair Housing
A.1 Introduction and Overview
California Government Code Section 8899.50 requires local agencies to affirmatively further fair housing (AFFH). Under California law, AFFH means “taking meaningful actions, in addition to combatting discrimination, that overcome patterns of segregation and foster inclusive communities free from barriers that restrict access to opportunity based on protected characteristics.” Government Code Section 8899.50 stipulates that an assessment of fair housing (AFFH) includes the following components:
▪ A summary of fair housing issues in the jurisdiction and an assessment of the jurisdiction’s fair housing enforcement and fair housing outreach capacity; ▪ An analysis of available federal, state, and local data and knowledge to identify integration and segregation patterns and trends, racially or ethnically concentrated areas of poverty, disparities in access to opportunity, and disproportionate housing needs within the jurisdiction, including displacement risk;
▪ An assessment of the contributing factors for the fair housing issues identified under Government Code Section 65583 (10)(A)(ii);
▪ An identification of the jurisdiction’s fair housing priorities and goals, giving highest priority to those factors identified in Government Code Section 65583 (10)(A)(iii) that limit or deny fair housing choice or access to opportunity, or negatively impact fair housing or civil rights compliance, and identifying the metrics and milestones for determining what fair housing results will be achieved; and
▪ Strategies and actions to implement those priorities and goals, which may include, but are not limited to, enhancing mobility strategies, and encouraging development of new affordable housing in areas of opportunity, as well as place-based strategies to encourage community revitalization, including preservation of existing affordable housing, and protecting existing residents from displacement.

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Appendix A Assessment of Fair Housing A-2 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 A.2 Approach to Analysis
This AFFH has been prepared consistent with the California Department of Housing and Community Development (HCD) Affirmatively Furthering Fair Housing Guidance for All Public Entities and for Housing Elements (AFFH Guidance Memo), which provides guidance on the preparation of housing elements and ensures statutory requirements are satisfied, pursuant to Government Code Section 65583(c)(10).

This AFFH evaluates fair housing issues on the following topics:
▪ Fair Housing Enforcement and Outreach Capacity;
▪ Integration and Segregation Patterns and Trends;
▪ Racially and Ethnically Concentrated Areas of Poverty; ▪ Disparities in Access to Opportunity;
▪ Disproportionate Housing Needs; and
▪ Other Relevant Factors, including historical disinvestment, lack of infrastructure improvements, and presence of older affordable housing units that may be at risk of conversion to market-rate housing.

This AFFH addresses impediments through AFFH specific goals and actions based on the contributing factors for each identified fair housing issue. To identify specific areas in Patterson, the analysis divides the city into quadrants as follows:
▪ Northwest Quadrant: north of Sperry Avenue and west of Ward Avenue; ▪ Southwest Quadrant: south of Sperry Avenue and west of Ward Avenue; ▪ Northeast Quadrant: north of Sperry Avenue and east of Ward Avenue; and ▪ Southeast Quadrant: south of Sperry Avenue and east Ward Avenue.

Figure A-1 illustrates the location of housing opportunity sites according to quadrant.

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Lakeside Hills
Keystone Ranch State Route 33
U.S. Interstate 5
Sperry Ave.

Ward Ave.

Baldwin Rd.

UV1A
UV1B
Rogers Rd.

Baldwin Ranch
W. Las Palmas Ave.

Eagle Ave. American
Olive Ave.

Walnut Ave.

Eucalyptus Ave.

Poppy Ave.

Orange Ave.

Annamarie Ave.

Marble Rd.

UV2
UV3
UV4
UV5
UV6
UV7
UV8
UV9
UV10
UV11
UV12
UV13
UV14
UV15
UV16
Northwest
Quadrant
Northeast
Quadrant
Southwest
Quadrant
Southeast
Quadrant
Identified Housing Opportunity Sites by Quadrant
City of Patterson 6th Cycle Housing Element
0 4150 feet
Figure A-1
Source: ESRI 2024,
Stanislaus County GIS 2024
Patterson City Limit
Master Plan Area
Opportunity Sites
Pipeline Sites
Quadrant Boundary Line
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Appendix A Assessment of Fair Housing A-4 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 A.3 Fair Housing Methodology
Government Code Section 65583 (10)(A)(ii) requires cities and counties to analyze areas of segregation, racially or ethnically concentrated areas of poverty, disparities in access to opportunity, and disproportionate housing needs, including displacement risk.

To conduct this analysis, the City utilized data from a variety of sources, including:
▪ The HCD AFFH Data Viewer;
▪ Urban Displacement Project (UDP);
▪ U.S. Housing and Urban Development (HUD);
▪ California Communities Environmental Health Screening Tool (CalEnviroScreen); ▪ California Tax Credit Allocation Committee (TCAC);
▪ The Comprehensive House Affordability Strategy (CHAS); and ▪ U.S. Census American Community Survey (ACS).

Additionally, the analysis includes a discussion of historic land use and segregation patterns and input from sources of local knowledge, including advocates for people with special needs, advocacy organizations, housing and social services providers, and Patterson residents.

California Department of Housing and Community Development Affirmatively Furthering Fair Housing Data Viewer
The AFFH Data Viewer is a tool developed by HCD that features census block group and tractlevel data from an expansive collection of sources, including ACS, HUD, TCAC, UDP, and CHAS.

The Data Viewer tool serves as a resource for local and regional governments and provides the ability to explore spatial data patterns concerning fair housing enforcement, segregation, and integration, racially and ethnically concentrated areas of poverty, and disparities in access to opportunities and housing. The Data Viewer is intended to assist in the creation of policies that alleviate disparities, combat discrimination, and increase access to safe and affordable homes.

Urban Displacement Project
The UDP was developed to track neighborhood change and identify areas that are vulnerable to gentrification and displacement in California. Indicators of gentrification and displacement are measured at the census tract level based on data from the 2015-2019 ACS. UDP indicators examine census tracts to identify areas that qualify as disadvantaged neighborhoods. Additionally, census tracts identified as disadvantaged neighborhoods by UDP’s criteria are further analyzed to explore changes in the percentage of college educated residents, non-Hispanic white population, median household income, and median gross rents over time to determine levels of gentrification and displacement risk.

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Appendix A Assessment of Fair Housing A-5 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 CalEnviroScreen
The California Office of Environmental Health Hazard Assessment developed a screening methodology to identify communities disproportionately burdened by multiple sources of pollution.

CalEnviroScreen utilizes existing environmental, health, and socioeconomic data to rank census tracts based on 20 distinct indicators. In general, if a community has a high score for that indicator, it is more impacted by pollution burdens and population vulnerabilities compared to other communities. Designated disadvantaged communities are those with CalEnviroScreen percentile scores of 75 or higher, meaning that they scored within the highest 25 percent of census tracts across California. Patterson continues to explore programs and policies to address community pollution, environmental health, access to open space, and government decision-making through existing policies of the General Plan.

California Tax Credit Allocation Committee
To assist fair housing analysis, HCD and TCAC created the California Fair Housing Task Force to provide research, evidence-based policy recommendations, and other strategic recommendations to HCD and other related state agencies and departments to further the state’s fair housing goals. The California Fair Housing Task Force created Opportunity Maps to identify resource levels across the state to accompany new policies aimed at increasing access to high-opportunity areas for families with children.1 Opportunity Maps are made from composite scores of the following three domains and associated indicators:
▪ Economic Domain: Indicators include poverty, adult education, employment, job proximity, median home value;
▪ Environmental Domain: Indicators include CalEnviroScreen 4.0 pollution indicators and values; and
▪ Education Domain: Indicators include math proficiency, reading proficiency, high school graduation rates, student poverty rates.

The Opportunity Maps include filters to identify areas with poverty and racial segregation. To identify these areas, census tracts were first filtered by poverty and then by a measure of racial segregation. The criteria for these filters were:
▪ Poverty Status: census tracts with at least 30 percent of population that earned an income that was below the federal poverty level; and
▪ Racial Segregation: census tracts with a location quotient that is higher than 1.25 for Black, Hispanic/Latino, Asian, or all non-white populations in comparison to the county. 1 Office of The State Treasurer. 2021. https://www.treasurer.ca.gov/ctcac/opportunity/2020-tcaF-hcdmethodology.pdf Packet Pg. 1478
Appendix A Assessment of Fair Housing A-6 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 AllTransit
AllTransit is an online database that details transit opportunities for communities. The website explores metrics that reveal the social and economic impact of transit, specifically looking at connectivity, access to jobs, and frequency of service. The AllTransit performance score explores metrics that reveal the social and economic impact of transit, such as connectivity, access to jobs, and frequency of service.

A.4 Fair Housing Resources
Ability to Address Complaints
For the purposes of addressing discrimination complaints, the City of Patterson relies on Project Sentinel. Project Sentinel is a non-profit organization whose primary function is to assist individuals with housing problems such as discrimination, mortgage foreclosure & delinquency, rental issues including repairs, deposits, privacy, dispute resolution, home buyer education, post purchase education and reverse mortgages. Project Sentinel has a regional office, situated in Modesto, that handles the fair housing complaints for Stanislaus County.

Enforcement and Outreach Capacity
Fair housing complaints can be used as an indicator to identify characteristics of households experiencing discrimination in housing. Pursuant to the California Fair Employment and Housing Act Government Code Section 12921(b), the opportunity to seek, obtain, and hold housing cannot be determined by an individual’s “race, color, religion, sex, gender, gender identity, gender expression, sexual orientation, marital status, national origin, ancestry, familial status, source of income, disability, veteran or military status, genetic information, or any other basis prohibited by Section 51 of the Civil Code.”
Fair housing issues that may arise in any jurisdiction include, but are not limited to:
▪ Housing design that makes a dwelling unit inaccessible to an individual with a disability; ▪ Discrimination against an individual based on race, national origin, familial status, disability, religion, sex, or other characteristics when renting or selling a housing unit; and ▪ Disproportionate housing needs, including cost burden, overcrowding, substandard housing, and risk of displacement.

The City refers discrimination complaints directly to Project Sentinel in Modesto. The following resources are available to Patterson residents:
▪ Stanislaus Regional Housing Authority;
▪ Project Sentinel Central Valley Services;
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Appendix A Assessment of Fair Housing A-7 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 ▪ State of California Civil Rights Department;
▪ California Rural Legal Assistance; and
▪ Center for Community Advocacy.

To expand outreach and capacity efforts, the City has partnered with the Patterson Family Resource Center to disseminate resources and information about fair housing rights and how to file a fair housing complaint, in conjunction with the Stanislaus Regional Housing Authority.

Regional and Local trends
The AFFH Data Viewer indicates that the majority of incorporated areas in Stanislaus County had at least one Fair Housing and Equal Opportunity (FHEO) inquiry between 2013 and 2022. Notably, Ceres received 12 inquiries, Turlock 15, and Modesto 99. While most inquiries in the County were categorized as "no basis given," a small number were related to retaliation, sex, and disability. In Patterson, nine FHEO inquiries were recorded, with seven listed as "no basis given" and one each citing religion and national origin. Regarding FHEO cases filed during the same period, most incorporated areas also had at least one case. Ceres had four cases filed, Turlock had 14, and Modesto had 64. In Patterson, one case was filed.

Local Perspective
Although the AFFH Data Viewer reported only one FHEO case in Patterson between 2013 and 2022, Project Sentinel recorded 13 FHEO cases in Patterson in 2016. Table A-1 identifies reported cases according to basis. These cases addressed a range of issues, including national origin, familial status, race, disability, source of income, gender, and sex discrimination. To ensure residents are aware of fair housing resources, the City has implemented Program 5.3, which promotes equal housing opportunities for all (see Chapter 3). This program includes educating residents on fair housing laws and tenant protections, providing translation services to assist with fair housing discrimination case referrals, and conducting extensive outreach to residents, landlords, and developers to ensure affordable housing options are accessible in Patterson.

Table A-1 Fair Housing Cases Filed, City of Patterson, 2016 Basis of Case Number of Cases Filed
National Origin 3
Disability 3
Race 2
Source of Income 2
Gender 1
Sex 1
Familial Status 1
SOURCE: Project Sentinel, FHEO Case Reports, 2016
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Appendix A Assessment of Fair Housing A-8 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Compliance with Existing Fair Housing Laws
The City of Patterson complies with existing fair housing laws and regulations by ensuring all residents have equal access to housing programs, services, and resources and supporting any resident in filing complaints on housing discrimination. The City also ensures that the City’s zoning regulations do not result in segregation or discriminatory practices and complies with the following fair housing laws:
▪ Fair Housing Act; Title VI of the Civil Rights Act of 1964 – the City has adopted housing policies that prohibit housing discrimination based on protected characteristics and ensuring equal access to housing programs and services;
▪ Rehabilitation Acts of 1973 – see Fair Housing Act; also, the City does not discriminate against persons with disabilities and promotes equal opportunities, accessibility, and independence for individuals with disabilities;
▪ Americans with Disabilities Act – the City complies with the ADA through building permit review and issuance;
▪ California Fair Employment and Housing Act (FEHA) and FEHA Regulations ((Part 2.8 commencing with section 12900) of Division 3 of Title 2) – the City complies with FEHA and its regulations by upholding policies that prohibit housing discrimination based on protected characteristics and enforces these policies by supporting residents seeking to file a complaint to the FHEO or who wish to pursue legal action;
▪ Anti-Discrimination in Zoning and Land Use (Government Code Section 65008) – the City does not discriminate or deny any individual or group of individuals the right to residence, land ownership, tenancy, or other land use on the basis of one’s membership or perceived membership in a protected class, method of financing, and/or the intended occupancy. The City has adopted housing policies that prohibit discrimination based on protected characteristics.

Programs 5.1 – 5.8 in this Housing Element commit the City to providing information on fair housing and services offered in the region (see Chapter 3). Additionally, Table 3-5 in Chapter 3 provides a comprehensive list of all programmatic actions to affirmatively further fair housing; ▪ Government Code Section 8899.50 – Appendix A of this Housing Element documents compliance with Affirmatively Furthering Fair Housing requirements; ▪ Equal Access (Government Code Section 11135 et. seq.) – the City does not discriminate or deny any individual or group of individuals access to programs or activities operated, administered, or funded with financial assistance from the state, regardless of one’s membership or perceived membership in a protected class. The City included Programs 5.1 – 5.8 in this Housing Element to promote affordable housing opportunities and resources, including Housing Choice Vouchers, shared housing programs, and fair housing resources (see Chapter 3); Packet Pg. 1481
Appendix A Assessment of Fair Housing A-9 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 ▪ Density Bonus Law (Government Code Section 65915) – the City last updated their Density Bonus provisions in the Municipal Code in 2013. In compliance with State law, the City will update its Density Bonus provisions outlined in the Municipal Code to be consistent with recent changes to the State Density Bonus Law. Program 1.4 will regulate this amendment to the Code (see Chapter 3);
▪ Housing Accountability Act (Government Code Section 65589.5) – the City has documented compliance with the HAA as described in Chapter 1 (Housing Needs and Constraints Assessment). The City will approve any eligible housing development projects, including those with at least 20 percent affordable units to lower-income households; ▪ Least Cost Zoning Law (Government Code Section 65913.1) – the City includes programs in this Housing Element to ensure that sufficient land is zoned with appropriate standards to accommodate its RHNA;
▪ Excessive subdivision standards (Government Code Section 65913.2) – the City’s subdivision standards are typical or not excessive in compliance with Government Code; ▪ Limits on growth control (Government Code Section 65302.8) – the City complies with the Limits on Growth Controls Law. The City has not adopted any mandatory general plan elements which limit the number of housing units; and
▪ Housing Element Law (Government Code Section 65583) – this Housing Element documents compliance with Housing Element Law.

The City has not been involved in any past lawsuits, consent decrees or other related fair housing legal matters.

A.5 Segregation and Integration
To guide priorities, policies, and actions, the housing element must analyze integration and segregation patterns and trends. Integration refers to a condition where there is not a high concentration of people based on race, color, religion, sex, familial status, national origin, or disability in a specific area. Conversely, segregation indicates a high concentration of these characteristics in certain areas. This analysis examines integration and segregation trends both regionally (in Stanislaus County) and locally (in Patterson). It utilizes data from sources such as the 2016–2020 ACS, HCD’s AFFH Data Viewer, HUD, UDP, the CDC, and other regional and federal agencies, along with input from community engagement.

Residential segregation and exclusion, whether by race, ethnicity, disability, or income, result from various public and private housing policies, practices, and procedures that have had long-lasting negative impacts. Discriminatory land use policies, housing market shifts, and patterns of investment Packet Pg. 1482
Appendix A Assessment of Fair Housing A-10 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 and disinvestment have restricted fair housing choices and equitable access to opportunities, particularly for communities of color. Despite the Fair Housing Act of 1968 mandating federal agencies and grantees to affirmatively further fair housing, historic segregation patterns persist in California. Past and present discriminatory policies, including disinvestment, have led to neighborhoods with concentrated poverty, poor housing conditions, limited opportunities, unsafe environments, underfunded schools, and inadequate infrastructure. Additionally, government policies have subsidized the development of segregated, high-resourced suburbs by constructing highways through lower-income communities of color to ensure access to urban job centers. This infrastructure perpetuates discrimination and segregation patterns that continue to exist in California and across the nation, despite over 50 years of fair housing obligations.2 Race and Ethnicity
Examining the demographic, ethnic, and racial composition of a region is vital to understanding fair housing concerns including access to economic opportunity and safe and affordable housing.

Historic exclusionary governmental policies, biased mortgage lending practices, and other tactics have caused racial and ethnic segregation and spatial inequities. This section provides an overview of racial/ethnic composition and segregation patterns within Stanislaus County and Patterson.

Regional and Local Trends
According to 2022 ACS 5-year estimates, the largest population represented in Stanislaus County and the City of Patterson is Hispanic or Latino, which comprise 48.6 percent in the county and 68.2 percent in Patterson. The second largest population is non-Hispanic White group, which represents

38.5 percent in the County and 17.6 percent in Patterson. Figure A-2 illustrates the percent of total non-White population in Stanislaus County and Patterson. Throughout the county, there is great variation in the percentage of total non-White population based on geographic area. The eastern region of the county, beyond Modesto, is predominantly characterized by the non-Hispanic White population. Whereas, in the western region, where Patterson is located, and along State Route 33, the Hispanic or Latino population is most predominant. In Patterson, the eastern quadrant of the city has higher percentages of Hispanic or Latino populations compared to the central and western quadrants.

In February 2017, the Department of Housing and Community Development (HCD) and the California Tax Credit Allocation Committee (CTCAC) partnered with independent organizations and research centers, collectively known as the "research partners," to provide evidence-based policy recommendations supporting HCD's fair housing goals. This collaboration led to the creation of Opportunity Maps, aimed at improving access to high-opportunity areas for families with children living in housing financed by Low-Income Housing Tax Credits (LIHTCs). 2 https://www.hcd.ca.gov/community-development/affh/docs/affh_document_final_4-27-2021.pdf Packet Pg. 1483
Sperry Ave.

Rogers Rd.

Ward Ave.

Bartch Ave.

E. Las Palmas Ave.

Baldwin
Ranch
Zacharias
Master Plan
U.S. Interstate 5
State Route 33
Baldwin Rd.

Zacharias Rd.
0 8300 feet
Source: Stanislaus County GIS 2024,
California HCD 2024
Figure A-2
Percent Total Non-White Population
City of Patterson 6th Cycle Housing Element
Modesto
Ceres Hughson
Oakdale
Riverbank
Waterford
Turlock
Newman
0 83000 feet
City Limit
Master Plan Area
Streets
Percent Total Non-White Population

55.800001% - 76.700000%

76.700001% - 100.000000%
Percent Total Non-White Population

55.800001% - 76.700000%

76.700001% - 100.000000%

19.100001% - 36.300000%

36.300001% - 55.800000%

0.000000% - 19.100000%
City Limit
Stanislaus County Line
Note: Satellite parcel to the northwest is a part of Zacharias MP Area Packet Pg. 1484
Appendix A Assessment of Fair Housing A-12 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Opportunity mapping measures and visualizes place-based characteristics linked to critical life outcomes, such as educational attainment, earnings, and economic mobility. These maps help guide investments and policies by considering how different places affect economic, educational, and health outcomes. A hybrid approach was used to create an objective mapping tool, considering regional differences while applying stricter standards to high-poverty, racially segregated areas. Areas meeting consistent standards for poverty (30 percent of the population below the federal poverty line) and racial segregation (overrepresentation of people of color relative to the county) were classified as "High Segregation & Poverty." The share of each region that falls into the High Segregation and Poverty category varies from region to region.

Figure A-3 illustrates high segregation and poverty in Stanislaus County and Patterson. As shown, high segregation and poverty in the county is concentrated along State Route 33, including the cities of Modesto and Turlock. There are no areas classified as high segregation and poverty in Patterson.

Localized Perspective
Based on local knowledge from County officials, Stanislaus County has a history of implementing race-based discriminatory practices and enforcing segregation through the use of restrictive covenants. Despite this practice being illegal for more than 50 years, the racist language of racially restrictive covenants still appears on Stanislaus property records during home-buying transactions to date.3 The Stanislaus County clerk-recorder’s office is in the process of searching millions of records for these discriminatory covenants that restricted property ownership in white-only sections and isolated minority families in substandard segregated neighborhoods. Stanislaus County is in compliance with AB 1466, which requires County Recorders to modify and/or redact restrictive and discriminatory language from official records. The County has developed a “Restrictive Covenant Modification” form for relevant real estate transactions.4 While County officials are not certain of the exact number of racially restrictive covenants still in existence in the City of Patterson, Stanislaus County is working to update its ArcGIS database and mapping software to compile all restrictive covenants within the County. Recently, Stanislaus County has mapped out the locations of historically segregated communities and areas where racially restrictive covenants were implemented within the City of Modesto.5 While the mapping has not yet been updated for the City of Patterson, County officials anticipate compiling this data in the next few years.
3 https://www.modbee.com/news/local/article273097685.html 4 https://www.stancounty.com/clerkrecorder/pdf/restrictive-covenant-modification.pdf 5 https://www.arcgis.com/apps/View/index.html?appid=5fe582a3eb0847949e5ce994a2761b73 Packet Pg. 1485
Sperry Ave.

Rogers Rd.

Ward Ave.

Bartch Ave.

E. Las Palmas Ave.

Baldwin
Ranch
Zacharias
Master Plan
U.S. Interstate 5
State Route 33
Baldwin Rd.

Zacharias Rd.
0 8300 feet
Source: Stanislaus County GIS 2024,
California HCD 2024
Figure A-3
TCAC Areas of High Segregation and Poverty
City of Patterson 6th Cycle Housing Element
Modesto
Ceres Hughson
Oakdale
Riverbank
Waterford
Turlock
Newman
0 83000 feet
City Limit
Master Plan Area
Streets
City Limit
Stanislaus County Line
High Segregation & Poverty
Note: Satellite parcel to the northwest is a part of Zacharias MP Area Packet Pg. 1486
Appendix A Assessment of Fair Housing A-14 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 As a means to address and mitigate the effects of historical patterns of segregation, the City of Patterson has included the following programs within the Housing Action Plan (Chapter 3 of the Housing Element):
▪ Program 1.5: Inclusionary Housing Requirements;
▪ Program 4.5: Family-Friendly Housing;
▪ Program 5.1: Affirmatively Furthering Fair Housing;
▪ Program 5.2: Anti-Displacement Strategy;
▪ Program 5.6: Housing Choice Voucher (HCV) Program;
▪ Program 5.7: Targeted Capital Improvement Program Investment; and ▪ Program 5.9: Expanding Economic Mobility.

In the eastern quadrant of the city, a concentration of subsidized housing has likely contributed to the higher percentages of Hispanic or Latino populations in the area. Meanwhile, the western quadrant, characterized by newer single-family homes, remains less accessible to lower-income households due to affordability issues. However, this Housing Element targets multi-family residential development in the western quadrant of the city, where single-family homes are already under construction, including master-planned developments that will feature new public amenities like parks and schools. This strategic focus aims to break the existing geographic divide, ensuring that affordable housing is integrated into well-resourced, livable communities, rather than perpetuating segregation by income and ethnicity.

Persons with Disabilities
For persons with disabilities, fair housing choice and access to opportunity includes access to housing in the most integrated setting appropriate to an individual’s special needs and disability related services as required under federal civil rights law. For example, persons with disabilities who are unable to use stairs or need a zero-step shower may not have actual housing choice without the presence of housing units with these accessibility features.6 High spatial segregation of persons with disabilities may indicate fair housing issues related to not only physical needs, but also economic disparities. According to the 2020 Annual Report on People with Disabilities in America, more than 25 percent of persons with disabilities (including physical, intellectual, and developmental; sensory; and other disability categories) live below the Census Bureau-designated poverty line, which is 14.5 percentage points higher than people without a disability.7 Persons with disabilities may be more reliant than persons without disabilities on fixed incomes or access to public transit.
6 HCD 2021. https://www.hcd.ca.gov/community-development/affh/docs/affh_document_final_4-27-2021.pdf 7 The Rehabilitation Research and Training Center on Disability Statistics and Demographics 2020. https://disabilitycompendium.org/annualreport
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Appendix A Assessment of Fair Housing A-15 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Regional and Local Trends
Figure A-4 illustrates the percentage of the population living with a disability in Stanislaus County and Patterson. Stanislaus County has higher percentages of individuals with disabilities, specifically along State Route 33 in Modesto, Ceres, and Turlock, where the concentrations range from 20 percent to 30 percent. In contrast, Patterson has a lower percentage of its population living with a disability, ranging from less than 10 percent to 20 percent. As shown in Figure A-4, the northeastern and southeastern quadrants of Patterson (east of State Route 33) have the highest concentrations, between 10 percent and 20 percent. According to the HCD AFFH Data Viewer, 772 individuals in this area have at least one disability (14.6 percent of the total population). This area also coincides with higher poverty rates (16.2 percent of the total population) and lower median income ($55,000 to $90,100). While the concentration of individuals with a disability in this area is low, the combination of poverty and lower median income may indicate a barrier to fair housing in the city.

Detailed discussions of poverty status and median income in Stanislaus County and Patterson are provided in Section 4.5 Household Income and Poverty Status. Based on records of the Valley Mountain Regional Center8and the California Department of Social Services9, there are no concentrations of residential care facilities or group homes in this region of the city.

Title II of the Americans with Disabilities Act (ADA) of 1990 prohibits discrimination against qualified individuals with disabilities from the participation of and/or benefit of services, programs, and activities. It may be used by anyone who believes that they have been discriminated against and wishes to file a complaint with the City of Patterson. In accordance with Title II of the ADA, the City has developed an ADA webpage, which includes information regarding the Act and procedures for submitting an ADA Complaint Grievance. This information is provided in both English and Spanish.
8 https://www.vmrc.net
9 https://www.ccld.dss.ca.gov/carefacilitysearch/
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Rogers Rd.

Ward Ave.

Bartch Ave.

E. Las Palmas Ave.

Baldwin
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Zacharias
Master Plan
U.S. Interstate 5
State Route 33
Baldwin Rd.

Zacharias Rd.
0 8300 feet
Source: Stanislaus County GIS 2024,
California HCD 2024
Figure A-4
Percent Population with One or More Disabilities
City of Patterson 6th Cycle Housing Element
Modesto
Ceres Hughson
Oakdale
Riverbank
Waterford
Turlock
Newman
0 83000 feet
City Limit
Master Plan Area
Streets
Population With a Disability (Tract)
- ACS (2017-2021)
< 10%
10% - 20%
City Limit
Stanislaus County Line
< 10%
10% - 20%
20% - 30%
30% - 40%
> 40%
Note: Satellite parcel to the northwest is a part of Zacharias MP Area Packet Pg. 1489
Appendix A Assessment of Fair Housing A-17 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 As mentioned in Chapter 1, Housing Needs and Governmental and Non-Governmental Constraints Assessment, the City implements ADA and California Building Code compliant standards for both public and private projects and offers exceptions to land use policies, procedures, and development standards to ensure that the needs of people with disabilities are taken into account. In accordance with Federal Fair Housing Amendments Act of 1988 and the California Fair Employment and Housing Act (hereinafter “Acts”), the City’s reasonable accommodation policy provides individuals with disabilities reasonable accommodation to rules, policies, practices, and procedures to ensure equal access to housing and facilitate the development of housing for individuals with disabilities.

The policy further discusses the procedure and requirements to file for reasonable accommodation.

These resources are highly important to reduce lack of mobility, poverty, and overcrowding issues that individuals with disabilities in Patterson may face. Additional resources available to individuals with disabilities are provided in Chapter 1. The City has not received any requests for reasonable accommodation in the past eight years. Additionally, the City continues to implement capital improvement projects throughout the city, focusing on pedestrian safety. Several projects are underway, including the Las Palmas Overlay, which involves repaving sidewalks with rubberized pavement and reconstructing curb ramps and crosswalks to meet ADA standards. This project is located in the southeastern quadrant of the city, along Las Palmas Avenue, stretching from State Route 33 to the eastern city limits.

Localized Perspective
According to the Stanislaus County Fiscal Year 2020-2025 Regional Analysis of Impediments (hereinafter “analysis of impediments”), disability was the most common basis for housing discrimination complaints to the Department of Fair Employment and Housing (DFEH) in the county in 2019. In Patterson, a total of six fair housing complaints were reported (2014-2019). The specific basis for the complaints was not identified. This is relatively low compared to nearby jurisdictions, including Ceres (30 complaints), Modesto (165 complaints), and Oakdale (21 complaints). The analysis of impediments identified the following impediments to fair housing related to protected classes, including individuals with disabilities:
▪ Insufficient supply of affordable housing;
▪ Shortage of subsidies and strategies to promote affordable, accessible housing for low-, very low-, and extremely low-income households, including protected classes; ▪ Limited knowledge of fair housing rights;
▪ Discrimination in rental housing;
▪ Local development standards and their implementation, e.g., zoning, building, or design standards, may constrain development of housing opportunities for minority and low-income households; and
▪ Inadequate access to employment opportunities, transportation, and public and social services, and infrastructure to support increased housing opportunities for lower-income households.

Packet Pg. 1490
Appendix A Assessment of Fair Housing A-18 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 To address these impediments and mitigate impacts, the City is actively engaging with both nonprofit affordable housing developers and reputable for-profit developers interested in constructing affordable multi-family housing. Additionally, the City is committed to applying for various funding sources, such as CDBG Funds, LEAP and REAP grants, and Prohousing Designation funds, to support affordable housing development. As part of its efforts, the City complies with Title II of the ADA, providing residents with guidance on how to submit an ADA Complaint Grievance form, ensuring that individuals can report disability-based discrimination. The City's Municipal Code also outlines procedures for requesting reasonable accommodation, allowing for exceptions to development standards for individuals with disabilities.

Furthermore, the City has developed a suite of place-based strategies, detailed in Chapter 3, to specifically target the northeastern and southeastern quadrants of the city, aiming to improve economic mobility, educational outcomes, and infrastructure in these areas. These actions are intended to improve existing conditions in this region of the city as they relate to fair housing issues for individuals with disabilities.

Familial Status
According to the Fair Housing Act, familial status refers to the presence of children under the age of 18 in a household with a legal guardian or designee of such guardian.10 HUD provides examples of familial discrimination as (a) refusing to rent to families with children; (b) evicting families once a child joins the family through, e.g., birth, adoption, custody; (c) requiring families with children to live on specific floors or in specific buildings or areas; (d) imposing overly restrictive rules about children’s use of the common areas (e.g., pools, hallways, open spaces); (e) and in advertising that prohibits children.11 Single-parent households are protected by Government Code Section 65583(a)(7). Because of their relatively lower incomes and higher living expenses, single-parent households can have limited options for affordable, decent, and safe housing. As a result, single parents are among the groups most at risk of experiencing poverty.

In addition to barriers to fair housing for single-parent households, large families (defined as families with 5 or more persons) can also experience housing discrimination as property owners impose occupancy limitations that can preclude large families with children. HUD data shows that familial status discrimination ranks third in discrimination of protected classes, behind discrimination due to disability and race.12
10 U.S. Code sections 3601, et seq., the Fair Housing Act. 11 U.S. Department of Housing and Urban Development.
12 U.S. Department of Housing and Urban Development. “Annual Report on Fair Housing FY 2017.” Packet Pg. 1491
Appendix A Assessment of Fair Housing A-19 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Regional and Local Trends
Figure A-5 illustrates the percentage of adults in households living alone in Stanislaus County and Patterson. In Stanislaus County, the percentage of adults living alone (18 years and over) varies slightly. Most jurisdictions in the county have populations of adults living alone that are less than 20 percent. Areas in the cities of Modesto and Hughson are the only exceptions, with concentrations ranging from 20 percent up to 40 percent. In Patterson, the percentage of adults living alone is below 20 percent. The northwest quadrant of the city has the lowest percentage, at 1.8 percent.

Conversely, the northeast quadrant of Patterson, between Ward Avenue and State Route 33, has the highest percentage, with 16.9 percent of adults living alone. This area coincides with a highest resource designation, lower poverty rates, lower population of individuals with disabilities, and lower median income ($55,000 to $90,100).

Figure A-6 illustrates the percentage of children in single, female-headed household households in Stanislaus County and Patterson. In Stanislaus County, the percentage of children in single, femaleheaded households varies geographically, ranging from less than 20 percent to as high as 60 percent.

Most jurisdictions in the county have percentages between 20 percent and 40 percent. Higher concentrations, ranging from 40 percent to 60 percent, are less common and primarily found in larger cities such as Modesto, Ceres, Hughson, and Turlock.

In Patterson, the percentage of children in single, female-headed households is below 20 percent.

The northwest quadrant of Patterson, between Baldwin Road and Ward Avenue, has the lowest percentage, with only 1 percent of children living in single, female-headed households. Conversely, the northeast and southeast quadrants of the city have the highest percentage, at 16.2 percent. This area also coincides with higher rates of individuals living with disabilities (14.6 percent), poverty (16.2 percent), and lower median incomes ($55,000 to $90,100). This indicates that in Patterson, the areas with higher percentages of children in single, female-headed households also tend to experience higher rates of poverty, disability, and lower median incomes. Specifically, the northeast and southeast quadrants, where 16.2 percent of children live in single, female-headed households, are also the areas with elevated levels of socioeconomic challenges. This correlation suggests that these regions may face significant barriers to economic mobility and access to resources, highlighting the need for targeted support and interventions to address these interconnected issues.

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Rogers Rd.

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Bartch Ave.

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Master Plan
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State Route 33
Baldwin Rd.

Zacharias Rd.
0 8300 feet
Source: Stanislaus County GIS 2024,
California HCD 2024
Figure A-5
Adults in Households Living Alone
City of Patterson 6th Cycle Housing Element
Modesto
Ceres Hughson
Oakdale
Riverbank
Waterford
Turlock
Newman
0 83000 feet
City Limit
Master Plan Area
Streets
Percent of Population 18 Years and Over
in Households Living Alone
0% - 20%
City Limit
Stanislaus County Line
0% - 20%
20% - 40%
40% - 60%
60% - 80%
80% - 100%
Note: Satellite parcel to the northwest is a part of Zacharias MP Area Packet Pg. 1493
Sperry Ave.

Rogers Rd.

Ward Ave.

Bartch Ave.

E. Las Palmas Ave.

Baldwin
Ranch
Zacharias
Master Plan
U.S. Interstate 5
State Route 33
Baldwin Rd.

Zacharias Rd.
0 8300 feet
Source: Stanislaus County GIS 2024,
California HCD 2024
Figure A-6
Female Headed Households with Children, No Spouse/Partner City of Patterson 6th Cycle Housing Element
Modesto
Ceres Hughson
Oakdale
Riverbank
Waterford
Turlock
Newman
0 83000 feet
City Limit
Master Plan Area
Streets
Percent of Children in Female Householder,
No Spouse/Partner Present Households
Less than 20%
City Limit
Stanislaus County Line
Less than 20%
20% - 40%
40% - 60%
60% - 80%
80% - 100%
Note: Satellite parcel to the northwest is a part of Zacharias MP Area Packet Pg. 1494
Appendix A Assessment of Fair Housing A-22 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Localized Perspective
The City suspects that a possible reason for a larger concentration of single-female households within the northeast quadrant of the city is due to a higher concentration of subsidized housing in the area. According to the California Housing Partnership, there are five state and federally subsidized housing developments in the city providing a total of 254 deed-restricted affordable units, of which four are located in the northeast quadrant of the city. Additionally, the California Department of Social Services Care Facility Search reports there are two licensed childcare facilities in Patterson, one of which is located in the northeast quadrant of the city where percentages of single, female-headed households are higher. However, there do not appear to be any concentrations of childcare facilities in the city.

There is no other localized data identifying contributing factors nor are there any factors indicating that there is a significant detrimental effect to the residents of the city. To mitigate impediments to fair housing related to single-parent households, the City is committed to providing a list of affordable housing locations and contact information on their website that include housing for protected status households (Program 5.2, Chapter 3). Additional resources available to assist singleparent households in Patterson are listed in Chapter 1.

Household Income & Poverty Status
Identifying low- or moderate-income (LMI) geographies and individuals is important to overcome patterns of segregation. HUD defines an LMI area as a census tract or block group where over 51 percent of the population is LMI (based on HUD income definition of up to 80 percent of the area median income or AMI). Household income is directly connected to the ability to afford housing.

Higher-income households are more likely to own rather than rent housing. As household income decreases, households tend to pay a disproportionate amount of their income for housing, and they are more likely to occupy structurally unsound and overcrowded housing.

Regional and Local Trends
Figure A-7 illustrates median household income in Stanislaus County and Patterson in 2021. In 2021, the Stanislaus County Area Median Income (AMI) was $70,700. Median household income across the county varies geographically, ranging from less than $55,000 to more than $175,000. Most households earn between $55,000 and $90,100. Households earning between $90,100 and $120,000 are mainly concentrated in Oakdale, Modesto, Hughson, Turlock, and Patterson, while Riverbank and Modesto are the only cities with significant concentrations of households earning over $175,000.

In Patterson, median household income ranges from $55,000 to $120,000. Figure A-6 indicates that the northeast and southeast quadrants of Patterson have the lowest median household incomes, between $60,461 and $83,531. A portion of the northwest quadrant, between Rogers Road and Baldwin Road, also has a lower median income of $81,895. In contrast, households in the northwest quadrant between Baldwin Road and American Eagle Avenue earn around $94,100, and those in the southwest quadrant have the highest median income at $104,783.

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Sperry Ave.

Rogers Rd.

Ward Ave.

Bartch Ave.

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Master Plan
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State Route 33
Baldwin Rd.

Zacharias Rd.
0 8300 feet
Source: Stanislaus County GIS 2024,
California HCD 2024
Figure A-7
Median Household Income
City of Patterson 6th Cycle Housing Element
Modesto
Ceres Hughson
Oakdale
Riverbank
Waterford
Turlock
Newman
0 83000 feet
City Limit
Master Plan Area
Streets
Median Household Income
$55,000 - $90,100
$90,100 - $120,000
City Limit
Stanislaus County Line
Less than $55,000
$55,000 - $90,100
$90,100 - $120,000
$120,000 - $175,000
Greater than $175,000
Note: Satellite parcel to the northwest is a part of Zacharias MP Area Packet Pg. 1496
Appendix A Assessment of Fair Housing A-24 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Figure A-8 illustrates the percentage of the population whose income is below the poverty level in Stanislaus County and Patterson in 2021. In Stanislaus County, the percentage of the population living below the poverty level varies geographically, ranging from less than 10 percent to over 40 percent. The cities of Riverbank, Oakdale, Hughson, and Patterson have the lowest percentages of residents living in poverty. In contrast, poverty concentrations are highest in Modesto and Turlock, with some areas exceeding 40 percent.

In Patterson, most of the population has a poverty rate of less than 10 percent. However, the eastern quadrants of the city have a concentrated poverty rate of 16.2 percent, which aligns with a higher percentage of individuals with disabilities, a higher percentage of single-parent households, and lower median income.

As previously discussed, the eastern quadrants of Patterson, which have the lowest median household incomes, are also areas with higher concentrations of individuals with disabilities, elevated poverty rates, and higher percentages of single-parent households. This suggests that households in these areas are likely facing multiple socioeconomic challenges, which could lead to increased vulnerability and limited access to opportunities. The combination of these factors highlights the need for targeted interventions and resources to address the disparities in these regions.

Local Perspective
As previously discussed, the City has a total of 254 state and federally subsidized deed-restricted affordable housing units, with 215 of these units located in the eastern quadrants of the city.

According to the HCD AFFH Data Viewer, approximately 2.5 percent of renter-occupied households use Housing Choice Vouchers (HCV), but this data is reported for the central region of the city, between Baldwin Road and State Route 33, where median household income is higher. Data for the eastern quadrants of the city, where income levels are lower, is not reported. The City suspects that one possible reason for a concentration of lower median household income within the eastern quadrants of the city is due to a higher concentration of subsidized housing in the area.

As discussed in Chapter 1, Housing Needs and Governmental and Non-Governmental Constraints Assessment, Patterson residents are primarily employed in educational services, healthcare, and social assistance (20 percent), followed by construction (15 percent), retail trade (13 percent), manufacturing (11 percent), and arts, entertainment, and recreation, and accommodation and food services (8 percent). According to the Bureau of Labor Statistics' "Usual Weekly Earnings of Wage and Salary Workers" report for the second quarter of 2024,13 the median weekly earnings for fulltime wage and salary workers were $1,143, equating to an annual income of $59,436. This figure is approximately $33,164 below the 2024 median household income for Stanislaus County ($92,600)14 and about $26,595 below the 2022 median household income for Patterson ($86,031).15 13 https://www.bls.gov/news.release/pdf/wkyeng.pdf
14 https://www.hcd.ca.gov/sites/default/files/docs/grants-and-funding/income-limits-2024.pdf 15 U.S. Census Bureau, ACS 5-Year Estimate, Table S1901, 2022 Packet Pg. 1497
Sperry Ave.

Rogers Rd.

Ward Ave.

Bartch Ave.

E. Las Palmas Ave.

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Ranch
Zacharias
Master Plan
U.S. Interstate 5
State Route 33
Baldwin Rd.

Zacharias Rd.
0 8300 feet
Source: Stanislaus County GIS 2024,
California HCD 2024
Figure A-8
Poverty Status
City of Patterson 6th Cycle Housing Element
Modesto
Ceres Hughson
Oakdale
Riverbank
Waterford
Turlock
Newman
0 83000 feet
City Limit
Master Plan Area
Streets
Poverty Status (Tract)
- ACS (2017-2021)
< 10%
10% - 20%
City Limit
Stanislaus County Line
< 10%
10% - 20%
20% - 30%
30% - 40%
> 40%
Note: Satellite parcel to the northwest is a part of Zacharias MP Area Packet Pg. 1498
Appendix A Assessment of Fair Housing A-26 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 A significant portion of Patterson's workforce is employed in construction, retail trade, manufacturing, and arts, entertainment, recreation, accommodation, and food services (totaling 47 percent). This employment distribution likely contributes to the city's lower income levels and higher poverty rates. The City of Patterson acknowledges that improving incomes is largely dependent on access to better-paying jobs and the necessary education to qualify for those jobs. Workforce education and business attraction and retention are crucial to boosting incomes for Patterson residents. The City has actively worked to enhance educational skill sets, particularly among special needs groups such as individuals experiencing homelessness. As discussed in Chapter 1, Patterson developed a partnership with the Helping Others Sleep Tonight (HOST) House in 2012, which has since expanded to include educational workforce programs to help homeless residents gain the skills needed to enter the workforce while also providing essential shelter assistance.

The City demonstrates a strong commitment to the wellbeing of its residents and their success in the workforce, which is closely linked to securing adequate housing and financial stability. To further support residents in acquiring the education and skills necessary for better-paying jobs, the City is committed to collaborating with the Chamber of Commerce and community-based partners. This collaboration will focus on expanding job opportunities in Patterson, offering job readiness training and resume/interview assistance, and encouraging local employers to identify well-paying entry-level positions that can be advertised to Below Market Rate (BMR) tenants. The City also plans to market these positions to BMR tenants and property managers of buildings with BMR residents. Program

5.9 outlines this strategy, including the schedule of actions, associated metrics, and timelines for completion (see Chapter 3).

A.6 Concentrated Areas of Poverty and Segregation
Racially and Ethnically Concentrated Areas of Poverty
To help communities identify racially and ethnically concentrated areas of poverty (R/ECAP), HUD uses a definition based on two criteria: a racial/ethnic concentration threshold and a poverty test. In metropolitan or micropolitan areas, an area is considered to have a racial and ethnic concentration if 50 percent or more of the population is non-white. In non-metropolitan areas, where non-White populations are typically smaller, the threshold is 20 percent. The poverty test defines "extreme poverty" as areas where 40 percent or more of the population lives at or below the federal poverty line, or where the poverty rate is three times the metropolitan area's average, whichever is lower. An area that meets both the racial/ethnic concentration threshold and the poverty test is classified as a R/ECAP.16
16 HCD. April 2021. AFFH Guidance for all Public Entities and for Housing Elements. https://www.hcd.ca.gov/community- development/affh/docs/affh_document_final_4-27-2021.pdf Packet Pg. 1499
Appendix A Assessment of Fair Housing A-27 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Regional and Local Trends
Figure A-9 illustrate R/ECAPs in Stanislaus County and Patterson. According to HUD data from 2009-2013, there are four R/ECAPs (Racially/Ethnically Concentrated Areas of Poverty) in Stanislaus County. Three of these R/ECAPs overlap with the Airport, Rouse, and Bret Harte census designated places (CDP), which correspond to the areas where a significant portion of the population earns an income below the poverty level. In the Airport and Bret Harte areas, 30 to 40 percent of the population falls below the poverty line. All four R/ECAPs in the county consist of unincorporated islands substantially surrounded by the city of Modesto. These census tracts are predominantly Hispanic/Latino, with over 81 percent of residents identifying as non-white.

According to the Stanislaus County Draft 6th Cycle Housing Element, public feedback indicates that these areas have consistently lacked public investment, including sewer connections, stormwater improvements, sidewalks, and street lighting.

There are no areas within the City of Patterson identified as R/ECAPs nor are there any within the immediate vicinity of the city that could be affected by actions taken by the City. While there are no R/ECAPs identified in Patterson, the eastern quadrant of the city has higher rates of poverty (16.2 percent). This is discussed in detail in Section 4.5, Household Income and Poverty Status above.

Racially Concentrated Areas of Affluence
Racially or Ethnically Concentrated Areas of Affluence (RCAAs) are neighborhoods in which there are both high concentrations of non-Hispanic White households and high household income rates.

Based on research from the University of Minnesota Humphrey School of Public Affairs, RCAAs are defined as census tracts where 80 percent or more of the population is White, and the median household income is $125,000 or greater (which is slightly more than double the national median household income in 2016).17 HCD further adjusted the RCAA methodology to track more closely with California’s higher levels of diversity by setting the white population threshold to 50 percent.

Regional and Local Trends
Figure A-10 illustrates RCAAs in Stanislaus County and Patterson in 2019. As shown, there are two concentrated RCAAs in Stanislaus County: one in the northeastern part of the county, encompassing the CDPs of East Oakdale, Orange Blossom, Knights Ferry, and Valley Home, and another in and around Denair. Each RCAA overlaps with areas of highest/high resource opportunity and is situated far from job centers.

There are no areas within the City of Patterson identified as RCAAs nor are there any within the immediate vicinity of the city that could be affected by actions taken by the City. 17 HCD. April 2021. AFFH Guidance for all Public Entities and for Housing Elements. https://www.hcd.ca.gov/community- development/affh/docs/affh_document_final_4-27-2021.pdf Packet Pg. 1500
Sperry Ave.

Rogers Rd.

Ward Ave.

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E. Las Palmas Ave.

Baldwin
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Zacharias
Master Plan
U.S. Interstate 5
State Route 33
Baldwin Rd.

Zacharias Rd.
0 8300 feet
Source: Stanislaus County GIS 2024,
California HCD 2024
Figure A-9
Racially or Ethnically Concentrated Areas of Poverty
City of Patterson 6th Cycle Housing Element
Modesto
Ceres Hughson
Oakdale
Riverbank
Waterford
Turlock
Newman
0 83000 feet
City Limit
Master Plan Area
Streets
Racially or Ethnically Concentrated
Areas of Poverty RECAPs
Not a (RECAP)
City Limit
Stanislaus County Line
Not a (RECAP)
(RECAP)
Note: Satellite parcel to the northwest is a part of Zacharias MP Area Packet Pg. 1501
Sperry Ave.

Rogers Rd.

Ward Ave.

Bartch Ave.

E. Las Palmas Ave.

Baldwin
Ranch
Zacharias
Master Plan
U.S. Interstate 5
State Route 33
Baldwin Rd.

Zacharias Rd.
0 8300 feet
Source: Stanislaus County GIS 2024,
California HCD 2024
Figure A-10
Racially Concentrated Areas of Affluence
City of Patterson 6th Cycle Housing Element
Modesto
Ceres Hughson
Oakdale
Riverbank
Waterford
Turlock
Newman
0 83000 feet
City Limit
Master Plan Area
Streets
Racially Concentrated
Areas of Affluence (RCAA)
Not a RCAA
City Limit
Stanislaus County Line
Not RCAA
RCAA
Note: Satellite parcel to the northwest is a part of Zacharias MP Area Packet Pg. 1502
Appendix A Assessment of Fair Housing A-30 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 A.7 Disparities in Access to Opportunities
TCAC Opportunity Areas
Since 2017, the Tax Credit Allocation Committee (TCAC) and the California Department of Housing and Community Development (HCD) have developed annual "opportunity maps" to assess access to resources such as high-paying jobs, quality schools, and safe neighborhoods. These maps provide evidence-based research to support policy recommendations and are available to all jurisdictions.

The TCAC/HCD Opportunity Maps identify areas with varying levels of access to opportunity within a community. This information highlights the need for housing policies that address conditions in low-resource areas and areas with high segregation and poverty while promoting access to high-resource areas for lower-income households and communities of color. TCAC/HCD categorizes census tracts as high-, moderate-, or low-resource areas based on factors like school proficiency, median income, and housing prices, which influence poverty and segregation. The 2022 Opportunity Maps compare each tract within its council of governments (COG) region. "Highest resource" areas represent the top 20 percent of census tracts in the region, offering the best outcomes in health, economic opportunities, and education. "High resource" areas rank in the 21st to 40th percentiles, providing strong but slightly lower access to positive outcomes. "Moderate resource" areas fall within the next 30 percent, offering mixed or improving outcomes in health, economics, and education. "Moderate resource (rapidly changing)" areas show rapid improvements in key indicators like income and job opportunities. "Low-resource" areas are in the bottom 30 percent, indicating limited access to positive outcomes.

Areas labeled "high segregation and poverty" have a significant overrepresentation of people of color and at least 30 percent of the population living below the federal poverty line ($19,720 for a two-person household and $30,000 for a family of four in 2023).

Regional and Local Trends
Figure A-11 illustrates TCAC opportunity area composite scores in Stanislaus County and Patterson.

In Stanislaus County, the TCAC opportunity area composite score varies widely. Low-resource areas are concentrated in the central county CDPs of South Modesto, Empire, and Crows Landing.

Moderate-resource areas are in the southwestern CDPs of Westley, Grayson, and parts of Salida, including a portion of the City of Patterson. High-resource areas include northern Salida, Keyes, Denair, and Patterson. The highest resource areas are scattered throughout the county, particularly in the northwestern CDPs of East Oakdale, Orange Blossom, Knights Ferry, Valley Home, and Hickman. In contrast, the CDPs of Airport and Bystrom exhibit high segregation and poverty.

Access to opportunity, based on composite scores of economic, educational, and environmental Packet Pg. 1503
Appendix A Assessment of Fair Housing A-31 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 factors, varies significantly across the county. Areas with high segregation, poverty, and low resources, particularly in the southwestern and central regions, overlap with predominantly Hispanic/Latino populations and areas with lower median household incomes and higher poverty rates.

In Patterson, most of the city is designated as a high-resource area, with some areas classified as moderate-resource. As shown in Figure A-11, high-resource areas are located in both the western and eastern parts of the city, primarily bordered by Baldwin Road and State Route 33. Moderateresource areas are found west of Baldwin Road and north of Sperry Avenue, as well as east of State Route 33.

Areas located west of Baldwin Road and outside of the Zacharias Master Plan Area are primarily zoned for industrial uses, do not permit residential development, and are situated farther from public services, transportation, and other key amenities. These factors contribute to the area's designation as a moderate resource area. These moderate-resource areas coincide with lower median household incomes ($55,000 to $90,100) and, specifically in the area east of State Route 33, higher poverty rates (16.2 percent).

In contrast, the City’s new master planned areas—the Zacharias Master Plan Area (located in the northern part of the city between Baldwin Road and Ward Avenue) and the Baldwin Ranch South Master Plan Area (located south of Sperry Avenue, between Baldwin Road and Rogers Road)—are both designated as high resource areas. Although these master planned areas are currently undeveloped, they are adjacent to established neighborhoods that contain a mix of residential and commercial uses and offer better access to schools, employment opportunities, public services, and transit. These high-resource areas correspond to higher median household incomes ($90,100 to $120,000) and lower poverty rates (averaging 3.5 percent).

Older residential neighborhoods are primarily located east of State Route 33, as well as within the downtown core, just west of State Route 33. These areas feature a blend of residential and commercial uses but are generally characterized by aging infrastructure, older housing stock, lower household incomes, and higher rates of housing-related problems.

Together, these conditions highlight the importance of prioritizing new affordable residential development in high-resource areas while also investing in the revitalization of older neighborhoods to promote equitable access to housing, infrastructure, and community amenities across the city.

Striking this balance will ensure existing conditions are mitigated and future imbalances are avoided.

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Sperry Ave.

Rogers Rd.

Ward Ave.

Bartch Ave.

E. Las Palmas Ave.

Baldwin
Ranch
Zacharias
Master Plan
U.S. Interstate 5
State Route 33
Baldwin Rd.

Zacharias Rd.
0 8300 feet
Source: Stanislaus County GIS 2024,
California HCD 2024
Figure A-11
TCAC Opportunity Areas Composite Score
City of Patterson 6th Cycle Housing Element
Modesto
Ceres Hughson
Oakdale
Riverbank
Waterford
Turlock
Newman
0 83000 feet
City Limit
Master Plan Area
Streets
COG Geography TCAC/HCD Opportunity Map
- Composite Score (HCD, 2023) - Tract
Moderate Resource
City Limit
Stanislaus County Line
Highest Resource
High Resource
Moderate Resource
Low Resource
High Segregation & Poverty
No Data
Note: Satellite parcel to the northwest is a part of Zacharias MP Area High Resource
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Appendix A Assessment of Fair Housing A-33 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Local Perspective
Overall, the city has adequate access to resources. However, as mentioned earlier, limited educational and economic mobility are significant factors affecting the city's TCAC opportunity area composite score. Additionally, challenges in providing sufficient affordable housing impact residents' ability to contribute to the local economy and support their households.

To improve equal access to resources and increase investment potential throughout the City, the City’s Capital Projects Division has identified capital improvement projects across the city, focusing on pedestrian improvements such as sidewalks, ADA compliance, and better connectivity between the western, eastern areas, and the downtown core. Notably, the City is leveraging CDBG funds to initiate the Washburn Street/Sidewalk Project, which focuses on repairing and enhancing existing sidewalks in the northeast quadrant of the city. Potable water, sewer, and stormwater projects are also planned for both the western and eastern quadrants. Program 5.7 outlines actions the City will take to improve conditions in the eastern quadrants and revitalize underutilized industrial land in the western quadrants (see Chapter 3).

Below is an analysis of each TCAC opportunity area domain, along with the City's focused efforts to improve the overall composite score.

Access to Education
Educational attainment is directly linked to housing opportunities. TCAC education domain scores measure educational outcomes using math and reading proficiency (the percentage of 4th graders who met or exceed math proficiency standards), high school graduation rates (the percentage of high school cohorts that graduate on time) and student poverty indicators (the percent of students not receiving free or reduced-priced lunch). The TCAC education domain scores are derived from 2018- 2019 Department of Education data. This analysis incorporates demographic and socio-economic measures to spatially evaluate access to educational opportunities at the census tract level.

Regional and Local Trends
Figure A-12 illustrates TCAC opportunity areas according to education domain in Stanislaus County and Patterson. Stanislaus County shows significant contrasts in access to educational opportunities, posing an impediment to fair housing. Low education scores (<0.25) are concentrated in and around South Modesto's CDPs, Airport, and West Modesto, as shown in Figure A-12. Empire and Salida also have low scores, ranging from 0.25 to 0.5. In contrast, most northeastern and southern areas of the county near Turlock, including CDPs around East Oakdale, Westley, and Crows Landing, score more positively (0.5-0.75). La Grange, Hickman, Keyes, and Denair have the most positive education outcomes (0.75-1). Areas with lower education outcomes often overlap with predominantly Hispanic/Latino populations, higher poverty rates, and a greater percentage of children in female-headed households with no spouse present.

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Sperry Ave.

Rogers Rd.

Ward Ave.

Bartch Ave.

E. Las Palmas Ave.

Baldwin
Ranch
Zacharias
Master Plan
U.S. Interstate 5
State Route 33
Baldwin Rd.

Zacharias Rd.
0 8300 feet
Source: Stanislaus County GIS 2024,
California HCD 2024
Figure A-12
TCAC Opportunity Areas, Education Domain
City of Patterson 6th Cycle Housing Element
Modesto
Ceres Hughson
Oakdale
Riverbank
Waterford
Turlock
Newman
0 83000 feet
City Limit
Master Plan Area
Streets
COG Geography TCAC/HCD Opportunity Map
- Education Score (HCD, 2023) - Tract
< .25 (Less Positive Outcomes)
City Limit
Stanislaus County Line
< .25 (Less Positive Outcomes)
.25 - .50
.50 - .75
> .75 (More Positive Outcomes)
Note: Satellite parcel to the northwest is a part of Zacharias MP Area .25 - .50
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Appendix A Assessment of Fair Housing A-35 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 In Patterson, most of the city has low educational scores (0.25-0.50), with some areas having scores of less than 0.25. The lowest educational scores are found east of State Route 33 and north of Olive Avenue, while the areas west of State Route 33 and south of Olive Avenue have slightly higher scores (Figure A-12). The area east of State Route 33 also coincides with lower median household incomes ($55,000 to $90,100), higher poverty rates (16.2 percent), and a higher percentage of residents with disabilities (14.6 percent).

The data findings point to a need for targeted interventions city-wide to address educational disparities, with specific attention to areas east of State Route 33, which are likely linked to the broader economic and social conditions in that area. Improving access to resources and support in these communities could help raise educational outcomes and reduce inequalities across the city.

Local Perspective
According to the California Assessment of Student Performance and Progress, the 2023 graduation rate for the Patterson Joint Unified School District (PJUSD) was 86.5 percent, comparable to the statewide (86.4 percent) and county averages (86.2 percent).18 The PJUSD consists of nine schools:

Northmead Elementary, Apricot Valley Elementary, Walnut Grove Elementary, Grayson Elementary, Las Palmas Elementary, Creekside Middle, Patterson High, Del Puerto High, and Open Valley Independent Study. Only two schools, Walnut Grove Elementary and West Valley Learning Center, are located east of State Route 33, while Del Puerto High and Patterson High are centrally located along Ward Avenue. This distribution may create geographic challenges for lower-income households in accessing schools and is considered a contributing factor to access to education opportunities. Further, the City suspects that one possible reason for a concentration of moderate educational scores within the eastern quadrants of the city is due to a higher concentration of subsidized housing in the area.

The Zacharias Master Plan Area is expected to include two new schools, an elementary and a middle school, enhancing educational opportunities in the northwestern part of the city. However, this development does not address the eastern quadrants, where educational scores are moderate (0.5 to

0.75).

The City acknowledges that city-wide targeted investment, specifically in the eastern quadrant, is necessary to support and expand educational and economic opportunities for residents. As previously mentioned in Chapter 1, Housing Needs and Constraints Assessment, the City and HOST House have partnered in 2017 to offer educational classes for persons experiencing homelessness, aimed at helping participants transform their lives by developing skills, competencies, and work habits that lead to financial self-sufficiency. Educational classes continue to be offered at the HOST House, and since beginning the program, Cambridge Academics Enterprise Centers has 18 https://caaspp-elpac.ets.org/caaspp/
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Appendix A Assessment of Fair Housing A-36 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 joined the initiative to create an Enterprise Restart Program. This is a year-long program broken into Phase 1, consisting of a transformative curriculum and work experience, and Phase 2, consisting of work support and training for independent living.

The City will collaborate annually with the PJUSD, HOST House, and interested nonprofit institutions to determine any outside factors that may impede school performance that can be alleviated at the City level. It is intended that through targeted investment and support, educational opportunities will expand in Patterson.

Economic Outcomes
Housing opportunities are closely linked to economic outcomes. Access to high-quality jobs near affordable housing leads to more housing options and shorter commutes. This economic analysis uses TCAC economic indicators, employment participation data from the ACS, and the HUD Jobs Proximity Index. TCAC economic opportunities are assessed by census tract and include factors such as poverty (percent of the population above 200 percent of the federal poverty line), adult education (percent of adults with a bachelor’s degree or higher), employment (percent of adults aged 20-64 employed in the civilian labor force or armed forces), job proximity (number of jobs for those with less than a bachelor’s degree within a set radius), and median home values. A higher economic index score indicates better economic outcomes. The HUD Jobs Proximity Index measures job accessibility at the census block group level.

Regional and Local Trends
Figure A-13 illustrates TCAC opportunity areas according to economic domain in Stanislaus County and Patterson. Stanislaus County has generally moderate economic opportunity scores and adequate job access, with most areas scoring between 0.25 and 0.75. More positive economic outcomes are found in the northeastern CDPs of East Oakdale, Orange Blossom, Knights Ferry, Valley Home, and Salida. In contrast, less positive outcomes are seen in South Modesto, Empire, and Crows Landing, with similar trends in the surrounding cities. Areas with more positive economic outcomes typically overlap with predominantly white populations and higher median household incomes (above $87,100, the state median). Conversely, areas with less positive outcomes are predominantly Hispanic/Latino and have lower median household incomes (generally under $55,000).

In Patterson, economic scores vary by geography, with some areas scoring low (0.0 to 0.2) and others moderate (>0.4 to 0.6). The highest scores are in the city's outer edges, particularly in the northwestern and northeastern quadrants, while the lowest scores are east of State Route 33. These low-score areas align with lower median household incomes ($55,000 to $90,100), higher poverty rates (16.2 percent), and a higher percentage of residents with disabilities (14.6 percent). The central area of the city, bounded by Baldwin Road and State Route 33, has moderate scores (>0.2 to 0.4).

These moderate-score areas are designated as high-resource and correlate with higher median household incomes ($90,100 to $120,000), lower poverty rates, and fewer residents with disabilities.

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Sperry Ave.

Rogers Rd.

Ward Ave.

Bartch Ave.

E. Las Palmas Ave.

Baldwin
Ranch
Zacharias
Master Plan
U.S. Interstate 5
State Route 33
Baldwin Rd.

Zacharias Rd.
0 8300 feet
Source: Stanislaus County GIS 2024,
California HCD 2024
Figure A-13
TCAC Opportunity Areas, Economic Domain
City of Patterson 6th Cycle Housing Element
Modesto
Ceres Hughson
Oakdale
Riverbank
Waterford
Turlock
Newman
0 83000 feet
City Limit
Master Plan Area
Streets
COG Geography TCAC/HCD Opportunity Map
- Economic Score (HCD, 2023) - Tract
0 – 0.2 (Less Positive Economic Outcomes)
City Limit
Stanislaus County Line
0 – 0.2 (Less Positive Outcomes)
> 0.2 – 0.4
> 0.4 – 0.6
> 0.6 – 0.8
> 0.8 – 1 (More Positive Outcomes)
Note: Satellite parcel to the northwest is a part of Zacharias MP Area > 0.2 – 0.4
> 0.4 – 0.6
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Appendix A Assessment of Fair Housing A-38 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 The HUD jobs proximity index measures employment accessibility in residential neighborhoods by calculating distances to potential job locations in the area, with larger employment centers weighted more heavily, and factoring in the population size of the local workforce. The higher the index value, the better the access to employment opportunities for residents in a neighborhood.

Figure A-14 illustrates the Jobs Proximity Index in Stanislaus County and Patterson. Much of Stanislaus County falls within the middle range (40 to 60) of HUD’s Jobs Proximity Index, indicating relatively good access to jobs. There is no clear racial or ethnic disparity in job proximity across the county. The highest job proximity scores are in the CDPs of Diablo Grande and parts of Salida, due to their proximity to employment centers like Modesto, parts of San Joaquin County, and agriculture. Lower job proximity scores are found in CDPs such as Denair, East Oakdale, Orange Blossom, Knights Ferry, and Valley Home, as well as parts of West Modesto and Bret Harte.

Interestingly, areas with higher economic scores often overlap with lower job proximity, particularly in rural areas where agricultural job opportunities are more accessible than in city centers.

In Patterson, most of the city falls within the lowest range (<20) on the Jobs Proximity Index, indicating the city is largely comprised of smaller employment centers in combination with the furthest proximity to jobs. Areas with the lowest Jobs Proximity Index are characterized by a mix of residential and commercial uses. However, due to the small scale of employment centers compared to the number of households, it is likely that households must travel outside of city limits to obtain employment. The northwestern and northeastern outskirts show the highest range (>80), characterized by light and heavy industrial land uses that provide jobs to residents. These areas are near single-family residential zones, positioning these households close to industrial employment centers, which tend to be larger in nature than commercial employment centers.

Local Perspective
As previously discussed in Section 4.5 Household Income and Poverty Status, a significant portion of Patterson's workforce is employed in construction, retail trade, manufacturing, and arts, entertainment, recreation, accommodation, and food services (totaling 47 percent).

While single-family residential is the most abundant housing typology in the city, its distribution extends well beyond that of commercial land uses. This disparity may pose difficulties for households that lack personal transportation and do not have access to public transportation. Multifamily housing is primarily permitted in the central region and eastern quadrants of the city. This distribution benefits households without private transportation and in need of public transportation, as it is located near transit stations. Disparities in access to employment centers may be more significant for households located in the outskirts of Patterson, where public transportation service is not easily accessible.

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Sperry Ave.

Rogers Rd.

Ward Ave.

Bartch Ave.

E. Las Palmas Ave.

Baldwin
Ranch
Zacharias
Master Plan
U.S. Interstate 5
State Route 33
Baldwin Rd.

Zacharias Rd.
0 8300 feet
Source: Stanislaus County GIS 2024,
California HCD 2024
Figure A-14
Jobs Proximity Index
City of Patterson 6th Cycle Housing Element
Modesto
Ceres Hughson
Oakdale
Riverbank
Waterford
Turlock
Newman
0 83000 feet
City Limit
Master Plan Area
Streets
Jobs Proximity Index (2014-2017)
- HUD (Block Group)
< 80 (Closest Proximity)
City Limit
Stanislaus County Line
< 20 (Furthest Proximity)
20 - 40
40 - 60
60 - 80
< 80 (Closest Proximity)
Note: Satellite parcel to the northwest is a part of Zacharias MP Area 60 - 80
< 20 (Furthest Proximity)
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Appendix A Assessment of Fair Housing A-40 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 The City has consistently prioritized enhancing educational skill sets, especially for vulnerable populations, including those experiencing homelessness. As outlined in Chapter 1, Housing Needs and Constraints Assessment, the City initiated a partnership with the HOST House in 2012, which has grown to encompass educational workforce programs aimed at equipping homeless residents with the necessary skills to enter the workforce. This initiative also continues to provide critical shelter assistance, reflecting the City's commitment to addressing educational, economic, and basic needs concurrently.

The City recognizes the importance of economic growth and mobility for its residents and overall well-being. The City does not have an Economic Development Department with dedicated staff to foster and grow businesses; however, the City Manager and Community Development Director fulfill this role. To ensure economic opportunities are fostered, the City has included Program 5.9 (see Chapter 3). This program aims to support and assist low-income households by expanding lowbarrier, low-skill job opportunities. The City plans to meet with community-based partners and the Chamber of Commerce to identify strategies to increase economic opportunity.

Transit Access and Walkability
Reliable public transit and active transportation options (walking and biking) are essential for lowincome residents and persons with disabilities to access employment opportunities. These options can reduce income burden and increase housing mobility, allowing residents to find housing in more areas. A lack of transportation options can limit fair housing choices and reinforce barriers for lowincome residents in accessing opportunities.

Access to transportation is measured using AllTransit Metrics, which include a Performance Score assessing connectivity, job access, service frequency, and the percentage of commuters using transit.

The score ranges from 0 to 10, with 10 indicating the highest level of transit performance. The HUD and Department of Transportation's Location Affordability Index estimates household and transportation costs at the census tract level, considering auto ownership, housing costs, and transit use for both homeowners and renters. It also accounts for block density, local job density, and the number of households per acre, as denser development often supports walkability and reduces transportation costs.

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Appendix A Assessment of Fair Housing A-41 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Regional and Local Trends
Figure A-15 illustrates AllTransit Performance for Stanislaus County and Patterson.19 Stanislaus County has an AllTransit Performance Score of 3.6, indicating low weekly trip frequency and limited job access, resulting in only 0.84 percent of commuters using transit. Despite this, 73.5 percent of households and 71.4 percent of jobs are within a half-mile of transit. State law defines high-quality transit stops as those with rail or bus rapid transit stations, ferry terminals served by bus or rail, or intersections of major bus routes with service intervals of 15 minutes or less during peak commute times. In Stanislaus County, high-quality transit stops are mostly found in urban areas of Modesto, Ceres, Turlock, and Patterson. Unincorporated areas, including those near cities, generally lack highquality transit stops, with community feedback indicating unreliable transit access in these regions.

Patterson has an AllTransit Performance Score of 1.9, reflecting low weekly trip frequency and limited job access, with only 0.07 percent of commuters using transit. As shown in Figure A-15, connectivity, job access, and service frequency are highest in the eastern quadrants near downtown.

This benefits lower-income households, as subsidized housing and a mix of medium- and highdensity residential areas are concentrated in the northeast quadrant. Additionally, schools like Del Puerto High School and Patterson High School are located in this area of increased connectivity and transit access. While the city’s downtown area has the greatest connectivity, access to jobs, and frequency of service in Patterson, the rest of Patterson lacks the same level of transportation accessibility. An improvement in transportation services and accessibility would lead to greater access to job opportunities and a higher economic score. 19 https://alltransit.cnt.org/metrics/#map
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Appendix A Assessment of Fair Housing A-42 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Figure A-15 AllTransit Performance Score, Stanislaus County and City of Patterson SOURCE: AllTransit, 2024
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Appendix A Assessment of Fair Housing A-43 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Local Perspective
As discussed in Chapter 1, Housing Needs and Constraints Assessment, the Stanislaus Regional Transit Authority operates Route 45, connecting Patterson to Newman and Turlock, Route 40, that provides service to Modesto, and the BART Commuter bus links Patterson to Turlock and Pleasanton BART station. All transit services are centered around downtown, which may pose challenges for residents on the outskirts, a common issue for rural cities. To improve accessibility, the City has actively pursued infrastructure improvements focused on transportation and pedestrian safety. Measure L, approved by Stanislaus County voters in November 2016, raised sales tax in April 2017 to enhance local streets, improve connectivity, and reduce congestion. Projects funded by Measure L include the following:
▪ Citywide Sidewalk Replacement Project – city-wide;
▪ Sperry Avenue Improvements – located between Baldwin Road and American Eagle Avenue; and
▪ Pedestrian Safety Improvement Project – located along Las Palmas (between 7th and 9th Streets) and Ward Avenue (between 9th Street and Salado Avenue).

In addition to recently completed infrastructure projects, the City has a number of transportation and roadway safety projects underway that are rooted in expanding transportation opportunities, including the following:
▪ Active Transportation Program (ATP) – the City received funding through the ATP Funding Cycle Four to create a city-wide plan. This plan will identify pedestrian and bicycle infrastructure deficiencies, recommend solutions, and address future demands for active transportation expansion;
▪ Local Roadway Safety Plan – the City was awarded $72,000 of funding through the Department of Transportation. These funds will be used to address mobility and transportation safety in the city; and
▪ Urban Bicycle Trail Project – the City received funding from the Urban Greening Grant Program to build a 1,300-foot asphalt bike and pedestrian trail along American Eagle Avenue, from Calvinson Parkway to Sperry Avenue. This will connect the city's northern and southern quadrants in the western area.

These projects are intended to improve connectivity and accessibility throughout the city. Program

1.9 establishes a schedule of actions and metrics to ensure transportation improvements target areas that currently lack adequate transit (see Chapter 3).

Healthy Environment
This analysis examines disparities in environmental health indicators by neighborhood and population, focusing on air quality, water quality, neighborhood safety, environmental hazards, social Packet Pg. 1516
Appendix A Assessment of Fair Housing A-44 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 services, and cultural institutions. California legislation (SB 535, AB 1550, SB 1000) and federal HUD regulations emphasize the importance of environmental justice in fair housing, ensuring equal protection of the environment and human health for all, regardless of race, color, national origin, or income. Federal regulations require assessing the impact of federally assisted projects on minority and low-income populations. The California Office of Environmental Health Hazard Assessment's CalEnviroScreen identifies communities disproportionately affected by multiple pollution sources, with higher scores indicating greater pollution burdens and vulnerability.

Regional and Local Trends
Figure A-16 illustrates CalEnviroScreen Percentile Scores for Stanislaus County and Patterson. The CalEnviroScreen map for Stanislaus County shows varying pollution burdens, with scores ranging from the 38th to the 100
th percentile. Pollution is highest in the western county, especially near and west of the San Joaquin River, and lowest in parts of Modesto, Patterson, and Turlock. High pollution levels are due to drinking water contaminants, pesticide use, groundwater threats, and proximity to solid waste sites. Western areas also face additional pollution from nearby cleanup sites and impaired waters. These regions have a high prevalence of factors that increase vulnerability to pollution, such as low education levels, high poverty, and high unemployment.

In Patterson, the CalEnviroScreen map indicates a fairly consistent level of pollution burden citywide, with scores ranging from the 60th to 80th percentiles. The eastern quadrants have a slightly lower pollution burden, scoring in the 61st percentile, while the western quadrants have a higher burden, scoring in the 67th percentile. The city’s top pollutant burdens consist of ozone, particulate matter 2.5, and diesel particulate matter. The western quadrants of the city, specifically the area between Rogers Road and Baldwin Road, are primarily characterized by light industrial uses. Heavy industrial uses are located in the northern quadrants, bordered by Rogers Road and State Route 33, as well as in the eastern quadrants along State Route 33 near the downtown area. Additionally, the city is largely surrounded by unincorporated areas of Stanislaus County that are characterized by agricultural uses. These combined land uses have likely contributed to the city's high CalEnviroScreen Percentile Score, indicating potential environmental concerns related to industrial and agricultural activities.

Local Perspective
The City's general plan includes policies that regulate the location of sites involving the storage or use of hazardous materials and policies aimed at protecting local water quality. It also regulates open space areas and sets standards for the number of parks required to serve city residents, maintaining a standard of five acres of developed parkland per 1,000 residents. Additionally, the general plan outlines requirements for new developments, such as land dedications, improvements, payment of in-lieu fees, or a combination of these options. These measures ensure that adequate open space is provided as new developments are constructed.

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Sperry Ave.

Rogers Rd.

Ward Ave.

Bartch Ave.

E. Las Palmas Ave.

Baldwin
Ranch
Zacharias
Master Plan
U.S. Interstate 5
State Route 33
Baldwin Rd.

Zacharias Rd.
0 8300 feet
Source: Stanislaus County GIS 2024,
California HCD 2024
Figure A-16
CalEnviroScreen 4.0 Percentile Scores
City of Patterson 6th Cycle Housing Element
Modesto
Ceres Hughson
Oakdale
Riverbank
Waterford
Turlock
Newman
0 83000 feet
City Limit
Master Plan Area
Streets
CalEnvioScreen 4.0 - Percentile Score
> 60 - 80
City Limit
Stanislaus County Line
0 - 20 (More positive factors)
> 20 - 40
> 40 - 60
> 60 - 80
> 80 - 100 (More negative factors)
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Appendix A Assessment of Fair Housing A-46 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Parks are distributed throughout the city, providing ample open space for all residents. The development of the Zacharias and Baldwin Ranch Master Plan areas will include additional parks and open space, ensuring there are sufficient outdoor areas to support the anticipated increase in residential units in both the northwestern and southwestern regions of Patterson.

To address environmental health outcomes and support positive environmental conditions, actions such as buffering, site planning, and other techniques are enforced to ensure that new developments are located in safe and healthy environments.

The City has identified Program 5.7, which establishes targeted capital improvements moderate resource areas situated east of State Route 33 and west of Baldwin Road (see Chapter 3). The City will direct CIP resources to these areas to address existing challenges east of State Route 33 and to facilitate revitalization and residential growth west of Baldwin Road.

A.8 Disproportionate Housing Needs
Disproportionate housing needs refer to significant disparities in the proportion of members of a protected class experiencing housing-related challenges. To assess the extent of these needs in Patterson, this section examines data on various types of housing needs, including housing cost burden, severe housing cost burden, overcrowding, homelessness, and substandard housing conditions.

Housing Problems
Many federal and state programs use the age of housing to assess a community’s housing rehabilitation needs, as older housing can indicate a need for repairs. Over time, housing deteriorates physically and technologically, potentially leading to issues like plumbing and roof repairs, foundation work, and the presence of health hazards such as lead paint and asbestos. Homes over 30 years old are particularly likely to require rehabilitation. According to HUD, a housing unit has a problem if it lacks complete kitchen or plumbing facilities, is overcrowded, or is cost-burdened.20 Issues like mold can exacerbate health conditions such as asthma. Often, renters are at higher risk of exposure to poor housing conditions due to concerns about rent increases or losing their housing. 20 HUD 2021. https://www.huduser.gov/portal/datasets/cp/CHAS/bg_chas.html Packet Pg. 1519
Appendix A Assessment of Fair Housing A-47 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Regional and Local Trends
Figure A-17 illustrates the percentage of households in Stanislaus County with any of the four severe housing problems, including lacking complete kitchen or plumbing facilities, overcrowding, or costburdened. Regionally, 20-40 percent of households in most incorporated areas of Stanislaus County experience of any four severe housing problems. Like the cities of Turlock, Ceres, and Oakdale, Patterson falls within this range. According to ACS 2022 data, 100 percent of households in Patterson had complete plumbing, and 98 percent had complete kitchen facilities.21 However, cost burden and overcrowding rates in Patterson vary geographically, with some areas more affected by these issues. Cost burden and Overcrowding are discussed further below.

The City’s Building Department estimates that approximately 5 percent of the housing stock (roughly 350 units) requires substantial rehabilitation or replacement. The eastern and downtown areas, which feature older infrastructure and a higher concentration of lower-income households, are particularly in need of residential rehabilitation. These regions include a mix of single-family homes and multi-family apartments.

In single-family homes, rehabilitation decisions are made by individual homeowners, who consider factors such as property size, layout, and potential historic designations. In multi-family housing, rehabilitation is typically managed by property management or housing associations, which must balance tenant needs with compliance with building codes.

The ownership structure and housing tenure significantly impact the timing, scope, and financial responsibility of repairs. Homeowners have control over repair decisions and bear the costs, while renters typically have limited control and are not financially responsible for repairs.

Program 2.1 outlines the actions the City will take to ensure all housing units meet basic health and safety standards by enforcing local codes (see Chapter 3).

Housing Cost Burden
Housing cost burden is defined as the percentage of a household’s total gross income spent on housing expenses. Households spending 30 percent or more of their income on housing (including rent, mortgage, and utilities) are considered cost burdened, while those spending over 50 percent are severely cost burdened. Higher housing cost burdens increase the likelihood of residents living in overcrowded or substandard conditions and reduce their ability to afford relocation. 21 ACS 2022. https://data.census.gov/table/ACSST5Y2022.S2504?q=housing&g=160XX00US0656112&d=ACS%205- Year%20Estimates%20Subject%20Tables&moe=false
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Percent Households with any Four Severe Housing Problems, Stanislaus County
City of Patterson 6th Cycle Housing Element
0 50000 feet
Figure A-17
Source: CA HCD 2024,
Stanislaus County GIS 2024
City Limit
Stanislaus County Line
Percent of all households with any of the 4 severe housing problems < 20%
20% - 40%
40% - 60%
60% - 80%
> 80%
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Appendix A Assessment of Fair Housing A-49 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Regional and Local Trends
Figure A-18 and Figure A-19 illustrate housing cost burden among renter-occupied and owneroccupied households in Stanislaus County and Patterson, respectively. Throughout Stanislaus County, the percentage of renter households spending 30 percent or more of their income on gross rent (including contract rent and tenant-paid utilities) is concentrated in urban areas and is notably high in the South Modesto CDPs. In neighborhoods like Rouse, Bystrom, and Bret Harte, 60 percent to 80 percent of renter-occupied households experience cost burden (Figure A-18). Bystrom and Rouse also see high cost burden rates among owner-occupied households with mortgages exceeding 30 percent of their income. In Westley, Grayson, and Diablo Grande, 40 percent to 60 percent of owner-occupied households face similar cost burden issues (Figure A-19). Unlike renter cost burden, homeowner cost burden is common in both urban and rural areas. Most areas with high renter cost burden are predominantly Hispanic/Latino, and these overlap significantly with areas experiencing higher poverty rates.

In Patterson, the percentage of cost-burdened renter-occupied households varies widely, from less than 20 percent to as high as 80 percent (Figure A-18). The highest concentrations of cost-burdened renters are mainly found in the eastern quadrants (61 percent) and some parts of the northwestern quadrants (60 percent), specifically between Baldwin Road and Ward Avenue. The eastern quadrants are designated as moderate to high resource areas but have higher poverty rates (16.2 percent), a higher percentage of individuals with disabilities (14.2 percent), and lower median household incomes ($55,000 to $90,100). In contrast, the western quadrants are primarily high-resource areas with higher median incomes ($90,100 to $120,000), lower poverty rates, and fewer individuals with disabilities. The percentage of cost-burdened owner-occupied households shows less geographic variation compared to renter-occupied households, with about 40 percent to 60 percent of homeowners city-wide experiencing cost burden (Figure A-19). However, one area in the northeastern quadrant, bordered by Ward Avenue and State Route 33, has a notably low percentage of cost-burdened owner-occupied households at 14 percent. This area features downtown residential, downtown core, and commercial uses, whereas surrounding areas to the east and west are predominantly single-family homes.

The differences in cost burden between renter-occupied and owner-occupied households in Patterson suggest varying economic challenges. Renters, especially in the eastern and some northwestern quadrants, face higher cost burden, linked to higher poverty rates and lower median incomes in those areas. In contrast, the cost burden among homeowners is more evenly spread across the city, with a notable exception in the northeastern quadrant, where fewer owners are costburdened. This disparity highlights a greater vulnerability among renters and suggests a need for targeted housing affordability support for renter households.

Packet Pg. 1522
Sperry Ave.

Rogers Rd.

Ward Ave.

Bartch Ave.

E. Las Palmas Ave.

Baldwin
Ranch
Zacharias
Master Plan
U.S. Interstate 5
State Route 33
Baldwin Rd.

Zacharias Rd.
0 8300 feet
Source: Stanislaus County GIS 2024,
California HCD 2024
Figure A-18
Housing Cost Burden by Renters
City of Patterson 6th Cycle Housing Element
Modesto
Ceres Hughson
Oakdale
Riverbank
Waterford
Turlock
Newman
0 83000 feet
City Limit
Master Plan Area
Streets
Overpayment by Renters
(2017-2021) - ACS Tract Level
< 20%
City Limit
Stanislaus County Line
< 20%
20% - 40%
40% - 60%
60% - 80%
> 80%
Note: Satellite parcel to the northwest is a part of Zacharias MP Area 20% - 40%
60% - 80%
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Sperry Ave.

Rogers Rd.

Ward Ave.

Bartch Ave.

E. Las Palmas Ave.

Baldwin
Ranch
Zacharias
Master Plan
U.S. Interstate 5
State Route 33
Baldwin Rd.

Zacharias Rd.
0 8300 feet
Source: Stanislaus County GIS 2024,
California HCD 2024
Figure A-19
Housing Cost Burden by Homeowners
City of Patterson 6th Cycle Housing Element
Modesto
Ceres Hughson
Oakdale
Riverbank
Waterford
Turlock
Newman
0 83000 feet
City Limit
Master Plan Area
Streets
Overpayment by Home Owners
(2017-2021) - ACS Tract Level
40% - 60%
City Limit
Stanislaus County Line
< 20%
20% - 40%
40% - 60%
60% - 80%
> 80%
Note: Satellite parcel to the northwest is a part of Zacharias MP Area < 20%
Packet Pg. 1524
Appendix A Assessment of Fair Housing A-52 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Localized Perspective
Based on local knowledge, the City attributes the higher rates of cost-burdened households in the eastern quadrant and central core to distinct development and land use patterns. The areas west of Baldwin Road are primarily characterized by light industrial uses, which do not permit residential development. Similarly, regions west of Ward Avenue and south of Sperry Avenue feature a mix of commercial and limited residential uses, while the western quadrant, particularly west of American Eagle Avenue and south of Sperry Avenue, has seen recent residential development following annexation over the past 20 years. In contrast, the central core and eastern areas, particularly east of State Route 33, are predominantly residential. Additionally, the eastern quadrant experiences lower median household income and higher rates of poverty, further contributing to the concentration of cost-burdened households in this area. The greater proportion of residential land in the eastern quadrant compared to the west may also contribute to a skewed perception of concentrated cost burden across the city. The City is not aware of any patterns of eviction in the city.

Overcrowding
Overcrowding is defined as having more than one person per room in a housing unit, excluding bathrooms and kitchens, while severe overcrowding involves more than one and a half persons per room. This issue arises when a unit is too small for a household's needs, extended family members live together, or unrelated individuals or families share a unit. Large families often face overcrowding due to lower per-capita income and the limited availability or high cost of larger units. These families may rent smaller units or share housing to manage costs. Fair housing issues can arise if nontraditional households are denied housing due to perceptions of overcrowding. Addressing overcrowding is challenging because there are no standardized guidelines for determining maximum unit capacity, and policies limiting overcrowding could disproportionately affect specific racial or ethnic groups.

Regional and Local Trends
Figure A-20 illustrates household overcrowding in Stanislaus County and Patterson. Overcrowding in Stanislaus County varies geographically, ranging from less than 5 percent to over 20 percent. It is most prevalent in urban areas, particularly in the Modesto region. The highest overcrowding rates, exceeding 20 percent, are in Rouse, Bystrom, and Airport. According to the 2020 ACS 5-year estimates, overcrowding rates in Stanislaus County were similar to the state average. However, severe overcrowding was much higher at the state level (6.4 percent) compared to Stanislaus County (3.4 percent). Areas with higher overcrowding rates often overlap with low-resource areas and those characterized by high segregation, poverty, poorer economic outcomes, and lower environmental scores.

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Sperry Ave.

Rogers Rd.

Ward Ave.

Bartch Ave.

E. Las Palmas Ave.

Baldwin
Ranch
Zacharias
Master Plan
U.S. Interstate 5
State Route 33
Baldwin Rd.

Zacharias Rd.
0 8300 feet
Source: Stanislaus County GIS 2024,
California HCD 2024
Figure A-20
Overcrowded Households
City of Patterson 6th Cycle Housing Element
Modesto
Ceres Hughson
Oakdale
Riverbank
Waterford
Turlock
Newman
0 83000 feet
City Limit
Master Plan Area
Streets
Overcrowding (ACS, 2017 - 2021) - Tract
Less than 5%
City Limit
Stanislaus County Line
Less than 5%
5% - 10%
10% - 15%
15% - 20%
More than 20%
Note: Satellite parcel to the northwest is a part of Zacharias MP Area 5% - 10%
10% - 15%
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Appendix A Assessment of Fair Housing A-54 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 In Patterson, overcrowding varies geographically, ranging from less than 5 percent to as high as 11 percent (Figure A-20). Most of the city experiences overcrowding levels between 5 percent and 10 percent. The highest prevalence of overcrowding, around 11 percent, is concentrated in the northwestern quadrant, specifically between Baldwin Road and American Eagle Avenue. This area is designated as a high-resource area, characterized by higher median household incomes, and lower rates of poverty and disability. The presence of overcrowding in these areas suggests that housing supply may not be keeping pace with demand and/or the housing types available are not suited for large families (5+ persons), leading to situations where households are forced to accommodate more people than ideally suited for the available space.

In the eastern quadrants of the city, where median household income is lower and both poverty rates and the proportion of individuals with disabilities are higher, overcrowding levels are lower than in high-resource areas, ranging from 5 percent to 10 percent. Additionally, overcrowding levels are lower in the southern quadrants of the city. This is indicative of more available housing units relative to demand and/or that households in these areas may be smaller or less likely to accommodate additional family members. It may also reflect differences in housing types, such as the availability of affordable multi-family housing options that can accommodate larger households, reducing the need for overcrowding. This pattern suggests that while economic disadvantage is present, overcrowding is not as pronounced a problem in these areas compared to more high resource parts of the city.

Localized Perspective
In the northwestern quadrant of the city, where household overcrowding is highest at 11 percent, the area is primarily characterized by low-density, single-family developments. Despite being a highresource area with higher median household incomes, there is a lack of housing diversity. In contrast, the eastern and southern quadrants, which have slightly lower overcrowding rates, offer a mix of housing types, including medium- and high-density residential options such as townhomes, duplexes, triplexes, and apartments. The northeastern quadrant also includes 254 subsidized deedrestricted affordable units, providing affordable housing options for families in need. The City suspects that the limited variety of housing types and fewer opportunities to rent versus own in the northwestern quadrant contribute to the higher levels of overcrowding observed there. There is no other local knowledge regarding overcrowding or “doubling-up” of families in one house.

Homelessness
California Government Code Section 65583(1)(6) requires municipalities to address the special needs of persons experiencing homelessness within their boundaries. Homelessness, as defined by HUD, describes an individual, who is not imprisoned or otherwise detained, who:
▪ Lacks a fixed, regular, and adequate nighttime residence; Packet Pg. 1527
Appendix A Assessment of Fair Housing A-55 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 ▪ Has a primary nighttime residence that is:
• A supervised publicly or privately operated shelter designed to provide temporary living accommodations (including welfare hotels, congregate shelters, and transitional housing for the mentally ill);
• An institution that provides a temporary residence for individuals intended to be institutionalized; or
• A public or private place not designed for, or ordinarily used as, a regular sleeping accommodation for human beings.

Regional and Local Trends
The primary source of data on homelessness and shelters is the Point-in-Time (PIT) count, organized by the Stanislaus Community System of Care (CSOC). In 2024, the PIT count identified 2,052 people experiencing homelessness in Stanislaus County, with 980 unsheltered and 1,072 sheltered individuals. Of those counted, approximately 26 percent reported having a mental illness, 16 percent reported having a substance abuse disorder, and 11 percent were survivors of domestic violence. The majority were White, Hispanic/Latino, or Black/African American. In unincorporated communities, 78 individuals were counted, with the highest numbers in Empire. Stanislaus County has 14 emergency shelters, with approximately 93 percent of beds occupied, according to 2019 HUD data. Of the 1,072 sheltered individuals, 880 stayed in emergency shelters, including hotel/motels paid by non-profit organizations.22
According to the 2024 point-in-time count, there is an estimated 61 homeless persons in Patterson, which was the fourth highest homeless count in the county. Local knowledge indicates that most of Patterson's homeless population is concentrated near the city's urban core. Code enforcement, responsible for addressing homeless encampments, has identified concentrations of homeless individuals in downtown parks, such as South Park and Veteran Park, and along the railroad tracks that run north to south along State Route 33. As of September 2024, three encampments were reported along the railroad tracks, with one having been removed.

Localized Perspective
Concentrations of homeless persons in Patterson are located in close proximity to public transit and resources, including the Helping Other Sleep Tonight (HOST) House, which provides Patterson’s homeless population with temporary housing, meals, clothing, toiletries, and educational training courses. The City has partnered with HOST House since 2012, and together they have greatly expanded the services available to the homeless population. Naomi’s House is also located in Patterson and provides resources for women and children experiencing housing insecurity, including 20 beds for emergency housing.
22 https://csocstan.com/wp-content/uploads/2024/07/English-2024-Stanislaus-County-PIT-Homeless-CountExecutive-and-Data-Summary.pdf Packet Pg. 1528
Appendix A Assessment of Fair Housing A-56 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 The City currently permits emergency shelters in the Heavy Industrial Zoning District; however, Program 4.6 proposes an amendment to permit emergency shelters by-right in the Downtown Core Zoning District (see Chapter 3). Given the prevalence of homeless persons in the City’s downtown area, development of an emergency shelter in this area would address the present need. Additionally, this location provides a central point to access public transit, services, and employment centers. Due to limited funding, the City does not currently provide emergency rental assistance.

Displacement
Displacement, as defined by HCD, is any involuntary household move due to landlord actions or market changes. It is often driven by established patterns of racial inequity and segregation, shifts in neighborhood composition, public policies, capital investments, and private capital flows. Factors such as rising housing costs, income inequality, stagnant wages, and insufficient market-rate housing exacerbate displacement. Disinvestment in low-income communities, combined with investor speculation, can create a rent gap, where current rental income is lower than potential income if the property is repurposed for maximum profit. Displacement disproportionately affects people of color, lower-income households, persons with disabilities, large households, and those at risk of or experiencing homelessness.23
The Urban Displacement Project (UDP) categorizes displacement vulnerability levels as follows:
▪ Areas susceptible to displacement are typically low- or mixed-income neighborhoods with some stability but potential for future displacement risk;
▪ Areas at risk of or experiencing gentrification show rising housing costs and changes in housing supply, often near other gentrifying communities;
▪ Stable moderate/mixed-income areas have residents with moderate to high incomes and are not at immediate risk of exclusivity; and
▪ Stable/advanced exclusive areas have long been characterized by exclusionary practices.

Communities are designated sensitive if they currently have populations vulnerable to displacement in the event of increased redevelopment and drastic shifts in housing cost. The following criteria is used to determine a community as sensitive:
▪ The share of very low-income residents is above 20 percent; and ▪ The census tract must also meet two of the following criteria:
• The share of renters is above 40 percent; and
• The share of people of color is above 50 percent.
23 HCD 2021. https://www.hcd.ca.gov/community-development/affh/docs/affh_document_final_4-27-2021.pdf Packet Pg. 1529
Appendix A Assessment of Fair Housing A-57 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025  The share of very low-income households (50 percent AMI or below) that are severely rent burdened (spending 50 percent of income on rent) is above the county median;  The census tract, or areas in close proximity, have been experiencing displacement pressures. Displacement pressure is defined as:
 The percentage change in rent in a selected census tract, divided by county median rent increases; or
 Median rent in a selected census tract, minus median rent for all surrounding tracts, divided by median rent for all tracts in county (rent gap).24 Regional and Local Trends
Figure A-21 illustrates the presence of sensitive communities in Stanislaus County and Patterson. In Stanislaus County, nearly all incorporated cities, except Oakdale, Waterford, and Newman, had sensitive communities. Unincorporated areas with sensitive communities were mainly concentrated in CDPs near Modesto and west of Patterson. In these sensitive areas, more than 40 percent of residents are renters, over 50 percent are people of color, the share of very low-income households that are severely rent burdened exceeds the county median, and rent increases are above the county median.

Neighborhoods in the eastern quadrant of Patterson, specifically east of State Route 33, are considered sensitive communities vulnerable to displacement. This area is characterized by lower median household incomes, higher poverty rates, and a greater share of residents with disabilities.

Figure A-22 illustrates displacement risk for very low-income households (0-50 percent AMI) in Patterson, showing that the entire city is classified as having a lower displacement risk. According to the UDP, a lower displacement risk indicates that the loss of low-income households is less than the gain. However, in the eastern quadrants, specifically east of State Route 33, where sensitive communities are located, 61 percent of renter-occupied households experience cost burden and 9 percent experience overcrowding. As previously discussed, this area is characterized by a mix of residential uses, including low-, medium-, and high-density residential. Additionally, the area includes a total of 254 state and federally subsidized deed-restricted affordable rental units. While the City does plan for infrastructure improvements to support equitable access and connectivity and to support future development in this area, these improvements would not result in the loss of any housing units or displace any existing residents. Additionally, the Sites Inventory does not include any housing opportunity sites that would result in displacement. 24 https://www.urbandisplacement.org/blog/sensitive-communities-in-california-mapping-vulnerability-anddisplacement-pressure/ Packet Pg. 1530
Sperry Ave.

Rogers Rd.

Ward Ave.

Bartch Ave.

E. Las Palmas Ave.

Baldwin
Ranch
Zacharias
Master Plan
U.S. Interstate 5
State Route 33
Baldwin Rd.

Zacharias Rd.
0 8300 feet
Source: Stanislaus County GIS 2024,
California HCD 2024
Figure A-21
Sensitive Communities
City of Patterson 6th Cycle Housing Element
Modesto
Ceres Hughson
Oakdale
Riverbank
Waterford
Turlock
Newman
0 83000 feet
City Limit
Master Plan Area
Streets
Sensitive Communities - UCB
- Urban Displacement Project
Vulnerable
City Limit
Stanislaus County Line
Vulnerable
Note: Satellite parcel to the northwest is a part of Zacharias MP Area Packet Pg. 1531
Sperry Ave.

Ward Ave.

Rodgers Rd.

Zacharias Rd.

Baldwin Rd.

State Route 33
E. Las Palmas Ave.

Bartch Ave.

Baldwin
Ranch
Zacharias
Master Plan
U.S. Interstate 5
Estimated Displacement Risk Among Very Low-Income Households City of Patterson 6th Cycle Housing Element
0 3500 feet
Figure A-22
Source: Stanislaus County GIS 2024, Note: Satellite parcel to the northwest is a part of Zacharias MP Area California HCD 2024 City Limit
Master Plan Boundary
Streets
Estimated Displacement Risk - 0% - 50%
Area Median Income Households
Lower Displacement Risk
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Appendix A Assessment of Fair Housing A-60 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Localized Perspective
While the UDP designates the city as low-risk for displacement, the combination of inadequate housing and economic stressors suggests that lower-income renters may still face significant displacement risks, warranting targeted mitigation strategies. Specific attention should be paid to the areas located east of State Route 33. To mitigate displacement throughout the city, particularly in areas east of State Route 33, the City is committed to developing a multi-pronged AntiDisplacement Strategy (Program 5.2, see Chapter 3). This strategy will address displacement pressures from the growing income gap and rising housing costs. It will include measures to encourage affordable housing production, preserve existing units, and protect current residents from displacement. These initiatives will be supported by affirmative marketing efforts to ensure lowerincome residents are aware of available city assistance.

Further, the City’s Inclusionary Housing Ordinance applies to the Villages of Patterson project in the northeastern quadrant of the city, which will include 15 percent deed-restricted lower-income units. This initiative aims to alleviate housing affordability and displacement pressures in this area, where lower-income households are most affected by cost burden, lower median household incomes, and poverty.

The City is not aware of any local events that have led to displacement of Patterson residents, nor is there local knowledge on patterns of eviction. The City recently partnered with Self-Help Enterprises to develop a 138-unit affordable rental apartment, including public amenities to spur affordable housing development in Patterson. The City is committed to continue working with SelfHelp Enterprises and other non-profit affordable housing developers to ensure affordable housing is accessible in the City and to mitigate displacement.

A.9 Fair Housing Issues and Contributing Factors
Based on guidance from HUD, contributing factors are those that create, perpetuate, or increase the severity of one or more fair housing issues. To inform the goals, policies, and actions in this Housing Element, the contributing factors are prioritized based on their impact on access to fair housing choice and access to opportunity in Patterson. Contributing factors are analyzed based on outreach and stakeholder input, AFFH analyses, and site inventory.

Fair Housing Issues
Fair housing issues can cause a variety of adverse effects within a locality. Likewise, the manner in which these issues are mitigated or managed can either support the City’s residents or cause further harm to the residents, depending on the background and history within the region. Some of the most common fair housing issues include: lack of education and economic mobility, substandard housing conditions, and overall lack of fair housing enforcement.

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Appendix A Assessment of Fair Housing A-61 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 In the City of Patterson, the following fair housing issues were identified as being the most prominent:
▪ Disparities in access to economic and educational resources; ▪ Disproportionate housing needs;
▪ Segregation within the City; and
▪ Fair Housing Discrimination.

In order to accurately develop strategies that would be effective in combatting the City’s fair housing issues, it is first imperative that the jurisdiction have a close understanding of the factors that have contributed to the fair housing issues to begin with.

Prioritization of Contributing Factors
The disparities in housing choice and access to opportunity discussed above stem from historical actions, socioeconomic factors that limit employment and economic growth, barriers to open housing choice, and limited resources to respond to needs.

While there are several strategies identified to address the fair housing issues, the most pressing issues are the prevalence of poverty, which can impact educational attainment, economic mobility, patterns of concentration of lower-income households, including female-headed households, and higher rates of cost burden. In Patterson, most of the lower-income households are located within the moderate-resource areas, specifically in the area east of State Route 33, where there are higher poverty rates (16.2 percent) and more moderate educational attainment rates. As corrective and mitigative actions, the City has developed a place-based revitalization and fair housing strategies (Chapter 3) to expand access to opportunities and to provide adequate public resources and infrastructure that support the needs of lower-income households.

As a result of the housing needs and fair housing analysis, the City of Patterson has prioritized the following contributing factors to the fair housing issues:
▪ Limited variety of affordable housing stock (high priority); ▪ Limited opportunity sites for affordable housing development (high priority); ▪ Limited financial resources available to low-income households (high priority); ▪ Fair Housing Discrimination (high priority);
▪ Lack of fair housing enforcement (medium priority);
▪ Substandard housing conditions (medium priority);
▪ Lack of public investment in specific neighborhoods east of State Route 33 (medium priority); Packet Pg. 1534
Appendix A Assessment of Fair Housing A-62 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 ▪ Lack of City promotion of fair housing resources and outreach (medium priority); and ▪ Lack of effective programmatic action and City resources (medium priority).

A.10 Fair Housing Goals and Priorities
The City has established goals and actions to address the contributing factors identified in the AFFH analysis. While all contributing factors are considered significant, priority has been given to those that restrict fair housing choice or adversely impact fair housing, as outlined in Government Code Section 65583(c)(10)(A)(iv).

Table A-2 outlines the identified fair housing issues, contributing factors, actions taken to address these factors, and the priority level assigned to each issue. Relevant programs are noted in the action column for each contributing factor, with full program details provided in Chapter 3 of this Housing Element. Table 3-4, Affirmatively Furthering Fair Housing Matrix, in Chapter 3 of this Housing Element includes a comprehensive list of programs that are aimed at affirmatively furthering fair housing. The table summarizes the specific commitment, timeline, geographic targeting, and eightyear metric for each program.

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Appendix A Assessment of Fair Housing A-63 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Table A-2 Fair Housing Issues, Contributing Factors, and Programmatic Actions Identified Fair
Housing Issue Contributing Factor Programmatic Action Priority Disparities in Access to
Economic and Educational
Resources
▪ Lack of public investment in specific
neighborhoods (east of State Route 33);
▪ Limited opportunity sites for affordable
housing development;
▪ Fair Housing Discrimination
▪ Lack of City promotion of fair housing
resources and outreach
▪ Program 1.1 Provide Adequate Sites for RHNA and Monitoring of No Net Loss
▪ Program 1.5 Inclusionary Housing Requirements
▪ Program 1.6 Affordable Housing Development
▪ Program 5.3 Affirmatively Market Fair Housing Resources ▪ Program 5.4 State and Federal Housing Programs and Funding Opportunities
▪ Program 5.7 Targeted Capital Improvement Program Investment High
Segregation within the City
▪ Lack of public investment in specific
neighborhoods (east of State Route 33);
▪ Limited variety of affordable housing stock;
▪ Fair housing discrimination
▪ Program 1.5 Inclusionary Housing Requirements
▪ Program 4.1: Reasonable Accommodation and Housing for Persons with Disabilities
▪ Program 5.6 Housing Choice Voucher (HCV) Program
▪ Program 5.7 Targeted Capital Improvement Program Investment High
Disproportionate Housing
Needs
▪ Disparities in access to water, sewer,
sidewalk infrastructure;
▪ Limited availability of affordable housing
options;
▪ Increased homeless population;
▪ Substandard housing conditions
▪ Program 1.6 Affordable Housing Development
▪ Program 2.1 Property Inspection/Code Enforcement
▪ Program 4.2 Universal Design to Encourage Housing for Persons with Limited Mobility
▪ Program 4.5 Family-Friendly Housing
▪ Program 5.7 Targeted Capital Improvement Program Investment Medium
Fair Housing Discrimination
▪ Limited access to materials in appropriate
languages;
▪ Lack of City promotion of fair housing
education and resources
▪ Lack of fair housing enforcement
▪ Lack of public investment in specific
neighborhoods (east of State Route 33)
▪ Program 2.1 Property Inspection/Code Enforcement
▪ Program 5.2 Anti-Displacement Strategy
▪ Program 5.7 Targeted Capital Improvement Program Investment ▪ Program 5.9 Expanding Economic Mobility
Medium
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Appendix A Assessment of Fair Housing A-64 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 A.11 Local Data and Knowledge
Zoning Policies
The City’s zoning policies discourage single-family development in higher density residential zones, such as Medium Density and High Density Residential zones, by requiring a conditional use permit (CUP) for single-family units. This acts as a deterrent, encouraging the development of higherdensity residential uses like apartments or multi-family units in these zones. However, multi-family units are restricted to Medium and High Density Residential Zoning Districts and require a CUP for development in Downtown Residential, Neighborhood Commercial, and Downtown Core Zoning Districts. This effectively limits the development of higher density residential uses in these zones.

The City proposes Program 1.10 in this Housing Element to address restrictive zoning policies and promote the development of multi-family housing and mixed-use projects, particularly in downtown and commercial areas located near transit and public services (see Chapter 3). This program aims to increase housing density and create more diverse housing options, supporting a vibrant and inclusive community.

Subsidized Housing
As previously discussed, the City has 254 state and federally subsidized deed-restricted affordable housing units, with 215 located in the eastern quadrant of the city. Of the 254 subsidized units, none are anticipated to expire until 2048 at the earliest. The California Housing Partnership has reported a low level of risk of converting to market rate for each unit. Approximately 2.5 percent of renteroccupied households in Patterson use Housing Choice Vouchers, primarily in the central city area where median incomes are higher. However, data for the eastern quadrant, which has lower income levels, is not available.25 The site inventory identified housing opportunity sites to accommodate 2,311 lower-income units, which would alleviate some need for subsidized housing.

A.12 Identified Housing Opportunity Sites and Affirmatively Furthering Fair Housing
The Housing Element must show that there are enough appropriately zoned sites to meet the new housing unit needs at each income level identified by the Regional Housing Needs Allocation (RHNA). Within the context of AFFH, site identification involves not only analyzing site capacity to meet RHNA goals but also ensuring these sites help replace segregated living patterns with integrated, balanced communities, transforming racially and ethnically concentrated areas of poverty into areas of opportunity.
25 HUD. AFFH Data Viewer, Housing Choice Vouchers, Tract, 2021 Packet Pg. 1537
Appendix A Assessment of Fair Housing A-65 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Access to Opportunity
HCD/TCAC opportunity maps identify areas statewide that offer positive economic (low poverty, high employment, high median income), educational (high reading and math proficiency, high graduation rates, low student poverty), and environmental outcomes (low pollution exposure) for low-income families. These maps rank census tracts from High Resource to Low Resource based on these factors. A High Resource designation indicates strong educational and economic opportunities for residents.

Figure A-23 illustrates the location of housing opportunity sites in relation to TCAC/HCD opportunity areas in Patterson. Patterson consists of both High Resource and Moderate Resource Areas. High Resource Areas are centrally located, spanning both the western and eastern quadrants, bordered by Baldwin Road to the west, State Route 33 to the east, Zacharias Road to the north, and Bartch Avenue to the south. Moderate Resource Areas are situated in the eastern quadrant, east of State Route 33, and the western quadrant, west of Baldwin Road. The area west of Baldwin Road is primarily light industrial, with minimal residential use, and thus has little impact on housing.

Housing opportunity sites are evenly distributed throughout Patterson, located in both High and Moderate Resource Areas. These sites were strategically selected to promote mixed-income neighborhoods and increase affordable housing availability near transit, retail, and services, aligning with community and stakeholder feedback. The City’s goals, policies, and programs implemented as part of this Housing Element will mitigate impediments to opportunity and promote investment in the downtown, areas east of State Route 33, and areas west of Baldwin Road. Program 5.7 establishes actions the City is committed to taking to ensure targeted investment in these areas (see Chapter 3).

Table A-3 outlines the distribution of housing opportunity sites throughout the city, categorized by income level and AFFH indicators. This distribution helps ensure that housing opportunities are balanced across different income groups and resource areas, promoting mixed-income neighborhoods and improving access to affordable housing in alignment with fair housing goals. By categorizing sites according to these criteria, the table aids in understanding how the city's housing strategy addresses economic integration and fair access to housing.

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Lakeside Hills
Keystone Ranch State Route 33
U.S. Interstate 5
Sperry Ave.

Ward Ave.

Baldwin Rd.

UV1A
UV1B
Rogers Rd.

Baldwin Ranch
UV2
UV3
UV4
UV5
UV6
UV7
UV8
UV9
UV10
UV11
UV12
UV13
UV14
UV15
UV16
Distribution of Site Inventory by Income
Designation and Opprtunity Areas
City of Patterson 6th Cycle Housing Element
0 3150 feet
Figure A-23
Source: ESRI 2024,
Stanislaus County GIS 2024
Patterson City Limit
Master Plan Area
Very Low/Low
Very Low
Moderate/
Above-Moderate
All Income Levels
Moderate Resource
(Composite Score)
High Resource
(Composite Score)
Mixed Income
Affordable
Very Low/Low/
Above Moderate
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Appendix A Assessment of Fair Housing A-67 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Table A-3 Distribution of Housing Opportunity Sites by Quadrant, City of Patterson Site ID Project Name/APN
RHNA Capacity AFFH Indicators
Total VL L M AM
Median
Household
Income
Predominant
Race
Poverty
Level

TCAC/HUD
Opportunity
Area
Cost
Burden
Renter
Cost
Burden
Owner
Overcrowding
Northwestern Quadrant
1A Keystone Ranch
67 10 57
$94,100 Hispanic/Latino 2% High Resource 22% 49% 11%
92 12 80
94 10 84
38 10 28
93 10 83
119 12 107
216 17 26 173
1B Lakeside Hills
84 10 74
90 10 80
88 10 78
96 10 86
57 57
101 10 91
108 10 98
73 73
85 10 75
125 15 110
128 15 113
99 10 89
85 10 75
81 10 71 $94,100 Hispanic/Latino 2% High Resource 22% 49% 11% Packet Pg. 1540
Appendix A Assessment of Fair Housing A-68 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Site ID Project Name/APN
RHNA Capacity AFFH Indicators
Total VL L M AM
Median
Household
Income
Predominant
Race
Poverty
Level

TCAC/HUD
Opportunity
Area
Cost
Burden
Renter
Cost
Burden
Owner
Overcrowding
64 64
75 75
40 40
66 66
95 10 85
79 79
88 10 78
107 10 97
232 150 62 20
90 70 20
26 15 11
27 17 10
31 21 10
35 10 10 15
66 21 12 33
43 10 21 12
57 25 12 20
- Lakeside Hills ADUs 263 79 79 79 26
3 021-040-055 16 16 $86,779 9% High Resource 60% 46% 9% 12 021-028-007 68 24 24 20 $81,895
7% Moderate
Resource 36% 47% 4%
13 021-028-008 41 15 14 12
Subtotal 3,628 490 311 435 2,392
Net RHNA % 102% 43% 38% 88% 216%
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Appendix A Assessment of Fair Housing A-69 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Site ID Project Name/APN
RHNA Capacity AFFH Indicators
Total VL L M AM
Median
Household
Income
Predominant
Race
Poverty
Level

TCAC/HUD
Opportunity
Area
Cost
Burden
Renter
Cost
Burden
Owner
Overcrowding
Southwestern Quadrant
2 Baldwin Ranch South MP 305 91 214
- Baldwin Ranch South MP ADUs 32 10 10 10 2 $104,783 Hispanic/Latino <10% High Resource 14% 49% 8% 14 021-098-003 171 60 60 51
Subtotal 508 70 70 152 216
Net RHNA % 14% 6% 9% 31% 19%
Northeastern Quadrant
4 047-024-024 79 43 36
$60,461
Hispanic/Latino
16% Moderate
Resource 5 047-034-035 60 60 60% 42% 9%
10 048-048-007 283 155 128
11 047-031-062 256 128 128 $86,779 7% High Resource 23% 14% 5% Subtotal 678 386 292 0 0
Net RHNA % 19% 34% 36% 0% 0%
Southeastern Quadrant
6 048-042-001 156 79 77
$104,783 Hispanic/Latino <10% High Resource 14% 49% 8%
7 048-042-008 113 58 55
8 048-043-002 59 29 30
9 048-043-015 72 36 36
Subtotal 400 202 198 0 0
Net RHNA % 11% 18% 24% 0% 0%
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Appendix A Assessment of Fair Housing A-70 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Site ID Project Name/APN
RHNA Capacity AFFH Indicators
Total VL L M AM
Median
Household
Income
Predominant
Race
Poverty
Level

TCAC/HUD
Opportunity
Area
Cost
Burden
Renter
Cost
Burden
Owner
Overcrowding
Total 5,214 1,148 871 587 2,608
Projected ADUs 50 15 15 15 5
Grand Total 5,264 1,163 886 602 2,613
Adjusted Net RHNA 3,571 1,144 822 497 1,108
% of Net RHNA 147% 102% 108% 121% 236%
SOURCE: City of Patterson, 2024; HCD AFFH Data Viewer, 2024 Packet Pg. 1543
Appendix A Assessment of Fair Housing A-71 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Improved Conditions
Northwest Quadrant
The northwestern quadrant, located north of Sperry Avenue and west of Ward Avenue, is planned to accommodate 3,628 new residential units, including 801 lower-income units, 435 moderateincome units, and 2,392 above-moderate-income units. These units are distributed across sites 1A, 1B, 3, 12, and 13, with sites 1A and 1B accounting for approximately 96 percent of the planned units in this quadrant. This is possible due to the inclusion of the Zacharias Master Plan Area, a newly annexed 1,296.4-acre area. The Zacharias Master Plan is planned to provide 708 lower-income units, fulfilling 36 percent of the City's lower-income net RHNA, including the unaccommodated need of 196 lower-income units from the 5th cycle. Overall, the northwest quadrant is planned to accommodate approximately 41 percent of the City’s lower-income net RHNA.

The northwestern quadrant is primarily characterized by low-density residential uses, bounded by Baldwin Road to the west, Rose Avenue to the north, and Ward Avenue to the east, with light industrial uses dominating west of Baldwin Road. The Zacharias Master Plan introduces mediumand high-density residential uses, extending north of Rose Avenue. This area is designated a High Resource Area, characterized by higher median incomes and lower housing needs disparities. The Master Plan Area features planned parks, commercial centers providing employment opportunities, and public schools. The City Manager and Mayor regularly meet with the Stanislaus Regional Transit Authority (StanRTA) to explore expansion opportunities and enhance existing transit stops. With the development of the Master Plan Area, discussions will also focus on integrating the Master Plan Area into the city's transit network, with priority given to connections between the area and downtown.

The City’s higher density residential land uses are primarily concentrated in the northeastern quadrant, east of State Route 33, designated as moderate resource areas with lower median incomes and higher poverty rates. Introducing medium- and high density residential uses in the northwestern quadrant would promote balanced growth, offering affordable housing near new public services, amenities, and infrastructure. This approach would also help mitigate existing and future segregated development patterns.

Southwest Quadrant
The southwestern quadrant, located south of Sperry Avenue and west of Ward Avenue, is planned to accommodate 508 new residential units, including 140 lower-income units, 152 moderate-income units, and 216 above-moderate-income units. These units are distributed across sites 2 and 14 with site 2 accounting for approximately 66 percent of the planned units in this quadrant. This is possible due to the inclusion of the Baldwin Ranch South Master Plan Area, a 66-acre area planned for medium density residential and park uses. The Baldwin Ranch South Master Plan area is planned to provide 91 moderate-income and 214 above moderate-income units. Additionally, the City is Packet Pg. 1544
Appendix A Assessment of Fair Housing A-72 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 anticipating the development of at least 32 ADUs with the development of single-family residences.

This assumption is based on community and developer interest, as well as City actions to facilitate ADU construction. Overall, the southwest quadrant is planned to accommodate approximately 7 percent of the City’s lower-income net RHNA, including the unaccommodated need of 196 lowerincome units from the 5th cycle.

The southwestern quadrant includes low- and medium-density residential, park, commercial, light industrial, and public/quasi-public uses. Low-density residential uses are concentrated between Baldwin Road and Ward Avenue, while the Baldwin Ranch Master Plan introduces medium-density uses west of Baldwin Road. This area is a designated High Resource Area east of Annamarie Avenue and designated a Moderate Resource Area west of Annamarie Avenue.

Development of the Baldwin Ranch Master Plan Area is expected to revitalize the western quadrant generally, as the majority of land west of Baldwin Road is currently used for light industrial purposes. The City plans to use CIP funds to prepare this area for residential development. Working closely with local developers, including Lennar, LGI, and DR Horton, the City has initiated development in the Baldwin Ranch North development area bordered by Niels Hanson Road to the west, Sperry Avenue to the north, and Baldwin Road to the east. These developments will feature single-family homes and ADUs with various floor plans to meet the needs of different household types. The Baldwin Ranch South development area (site 2) is anticipated to begin development in Summer 2025.

The single-family homes in the southwestern quadrant will pave the way for affordable multi-family housing via mixed-use developments adjacent to the north side of the Baldwin Ranch Master Plan and the areas currently being developed by Lennar, LGI, and DR Horton. Over the next eight years, this area will undergo significant revitalization through CIP investment, resulting in a balanced neighborhood with single-family homes, ADUs, multi-family units, parks, and commercial uses.

Northeast Quadrant
The eastern quadrants of the city, east of Ward Avenue, are characterized by older residential and commercial uses and includes a concentration of 254 subsidized deed-restricted affordable rental units. Historically, the City has prioritized annexing new lands for development, but more recently, efforts have shifted toward reinvesting in the City's east side through infill development. Local developers, including KB Homes and Self-Help Enterprises, have been instrumental in driving this change. In 2021, Self-Help Enterprises completed a 138-unit deed-restricted affordable rental apartment building with community amenities, and KB Homes is currently constructing Sycamore Ranch Phase 1, which includes single-family homes.

This new development is expected to generate additional interest in the area, prompting further residential development and investment. With an increasing focus on revitalizing the eastern quadrant, future developments are likely to enhance access to resources, improve infrastructure, and Packet Pg. 1545
Appendix A Assessment of Fair Housing A-73 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 create a more balanced and vibrant community. These improvements will address current deficiencies, such as limited access to services and amenities, while fostering long-term growth and enhancing the quality of life for residents in the eastern region.

Specifically, the northeast quadrant, located north of Sperry Avenue and east of Ward Avenue, is planned to accommodate 678 new lower-income residential units, including 386 very low-income units and 292 low-income units. This fulfils approximately 34 percent of the City’s lower-income net RHNA, including the unaccommodated need of 196 lower-income units from the 5th cycle. These units are distributed across sites 4, 5, 10, and 11.

The northeast quadrant features a mix of low, medium, and high-density residential uses, along with commercial and public/quasi-public uses, supporting lower-income housing due to its proximity to amenities, transit, and public services. This quadrant currently includes 254 subsidized housing units and is currently seeing new single-family development, driving infrastructure investment in a historically underserved region.

This quadrant experiences higher rates of poverty, lower median household incomes, and greater housing cost burdens among renters and overcrowding compared to other areas of the city.

Expanding affordable housing opportunities in this quadrant aims to address these disparities by providing more equitable access to safe, quality housing options for lower-income households. This effort seeks to alleviate high rates of poverty, reduce cost burden, and improve living conditions, ultimately fostering a more balanced and inclusive community. By meeting existing housing needs and creating opportunities for new development, the City aims to enhance the quality of life for residents in the northeast quadrant, while promoting long-term economic and social stability citywide.

Southeast Quadrant
The southeast quadrant, located south of Sperry Avenue and east of Ward Avenue, is planned to accommodate 400 new lower-income residential units, including 202 very low-income units and 198 low-income units. This fulfils approximately 20 percent of the City’s lower-income net RHNA, including the unaccommodated need of 196 lower-income units from the 5th cycle. These units are distributed across sites 6, 7, 8, and 9.

The southeast quadrant is predominantly characterized by low-density residential uses and some commercial. Vacant commercial parcels are proposed to be rezone to accommodate residential uses.

This initiative seeks to integrate affordable housing into an area primarily dominated by single-family homes. As a designated High Resource area—marked by higher median household incomes and low poverty rates—the inclusion of lower-income housing is intended to foster a more balanced urban fabric and ensure equitable access to housing opportunities within well-resourced neighborhoods.

Packet Pg. 1546
Appendix A Assessment of Fair Housing A-74 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Summary
The City's focused revitalization efforts in both the western and eastern regions underscore its commitment to improving access to resources and expanding housing opportunities citywide. These initiatives also play a key role in helping the City meet its lower-income RHNA goals, ensuring a balanced approach to growth and development that supports all income levels.

Exacerbated Conditions
The City has identified sites for lower-income housing on vacant properties in the eastern quadrant, specifically east of State Route 33. This area has higher percentages of Hispanic/Latino populations, a higher concentration of lower-income residents, and higher poverty rates with fewer economic opportunities compared to the western quadrant. However, these lower-income housing sites are near transit, retail, and other services, offering affordable options to existing residents, helping to reduce displacement risk. The addition of affordable multi-family housing addresses the current need in this area. Lower-income units are also planned for the western quadrant, west of Ward Avenue, to promote mixed-income neighborhoods. Thus, the site inventory supports balanced development without worsening conditions in vulnerable areas.

To address economic mobility challenges in the eastern quadrant, the City is committed to a placebased strategy that focuses on increasing economic opportunities and providing educational and jobreadiness training for lower-income residents. This approach aims to help residents secure stable employment, enhancing economic stability and housing security. Additionally, the City’s Capital Projects Division has identified several infrastructure improvements, targeting both the eastern and western regions to enhance essential infrastructure and improve accessibility and connectivity to employment centers across the city.

Racially/Ethnically Concentrated Areas of Poverty and Affluence While Patterson has no R/ECAPs or RCAAs by HUD's definition, some tracts in the northeast quadrant, east of State Route 33, have higher percentages of Hispanic/Latino populations and higher poverty rates. This area will accommodate approximately 678 lower-income units.

In the northwest and southwest quadrants, within High Resource Areas characterized by higher median incomes, a higher percentage of White residents, and lower poverty rates, approximately 941 lower-income and 587 moderate-income units are anticipated for development. This distribution of sites promotes a balanced residential environment by mitigating the concentration of populations based on race and income level.

Packet Pg. 1547
Appendix A Assessment of Fair Housing A-75 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Disproportionate Housing Needs
As illustrated in Figure A-19, the percentage of cost-burdened renter-occupied households in Patterson varied significantly by location, ranging from less than 20 percent to as high as 61 percent.

In contrast, the rate of cost-burdened owner-occupied households was relatively consistent across the city, with the exception of areas that are newly annexed (Zacharias Master Plan and Baldwin Ranch Master Plan areas), averaging around 33 percent. Household overcrowding in Patterson also varied geographically, but averaged approximately 8 percent. While all neighborhoods in Patterson are considered to have a lower displacement risk, the northeast quadrant is identified as a sensitive community. The combination of inadequate housing and economic stressors indicates that lowerincome renters may still face significant displacement risks. The fair housing assessment highlights the need for more affordable housing, better protection against displacement, and permanent housing for the homeless. The Site Inventory includes locations for lower-income housing across the city and avoids areas with existing housing units to minimize displacement risks (see Chapter 4).

Further, the City has developed Program 5.2 establishing an Anti-Displacement Strategy with specific actions the City is committed to (see Chapter 3).

Summary
The City’s revitalization efforts in both the eastern and western regions demonstrate a strong commitment to improving housing access and resources citywide. In the northeast quadrant, where there are higher concentrations of lower-income households and housing issues, approximately 678 lower-income units are planned, representing 34 percent of the City’s lower-income net RHNA.

Recent developments by Self-Help Enterprises and KB Homes have spurred further interest in this area, and future developments are expected to contribute to enhanced infrastructure and services.

Similarly, broader investment in the northwest and southwest quadrants will drive revitalization, with the planned development of 941 lower-income units helping to create a more balanced community in an area currently characterized by higher-income households and less housing disparity. New master-planned communities, such as the Zacharias and Baldwin Ranch Master Plan Areas, will contribute thousands of housing units across various income levels, fostering mixed-income neighborhoods.

The City’s balanced development strategy further supports equity by dispersing affordable housing throughout the city, rather than concentrating it in specific areas. With planned infrastructure improvements and a focus on economic opportunities, the City’s place-based strategies are designed to address existing challenges while minimizing displacement risk. These efforts aim to create a more balanced residential environment and help the City achieve its housing goals. Chapter 3 of this Housing Element includes a suite of programmatic actions aimed to affirmatively further fair housing citywide (Table 3-5).

Packet Pg. 1548
Appendix A Assessment of Fair Housing A-76 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 This side intentionally left blank.

Packet Pg. 1549
Review of 2015-2023 Housing Element

APPENDIX
B
Packet Pg. 1550
Table of Contents
APPENDIX B REVIEW OF 2015-2023 HOUSING ELEMENT ........................................B-1 B.1 Introduction ...........................................................................................................................B-1 B.2 Effectiveness in Meeting Special Needs.............................................................................B-1 Tables
Table B-1 Review of 5th Cycle Housing Element Policies and Programs............................B-3 Packet Pg. 1551
Appendix B Review of 2015-2023 Housing Element B-1 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Appendix B
Review of 2015-2023 Housing Element
B.1 Introduction
In order to effectively plan for the future, it is important to reflect back on the goals of the previous Housing Element and to identify those areas where progress was made and those areas where continued effort is needed. State Housing Element guidelines require communities to evaluate their previous Housing Element according to the following criteria:
▪ Effectiveness of the Element;
▪ Progress in implementation; and
▪ Appropriateness in Goals, Objectives and Policies.

B.2 Effectiveness in Meeting Special Needs
During the update of the 5th Cycle Housing Element, the City of Patterson committed to enact various programs that targeted some of the special needs populations, and not all. The City acknowledges that these policies and programs were not comprehensive, and inclusive of all of the special needs groups. However, the 6th Cycle Housing Element includes policies and programs that are designed to increase access to affordable housing options for all special needs groups, including:

ELI residents and households, seniors, persons with disabilities, large households, female-headed households, farmworkers, and persons experiencing homelessness. Many of these policies and programs from the 5th cycle were supportive in nature, with the intent to support the County or other service providers and community organizations in their efforts to address the needs of the protected groups. As such, the effectiveness most of the 5th cycle policies and programs is subjective, and difficult to be measured.

In an effort to affirmatively further fair housing and provide measurable impact for special needs groups during the 6th Cycle Housing Element and beyond, the City of Patterson has committed to using programmatic action as a means to facilitate affordable housing construction, increase housing mobility and choice, and connect the community to much needed housing and social service resources. The policies and programs that fall under Goal 4 in Chapter 3, Housing Action Plan, of the Housing Element are specifically designed to meet the needs of households that fall into any of the “special needs” categories. Through programmatic actions such as zoning code amendments, Packet Pg. 1552
Appendix B Review of 2015-2023 Housing Element B-2 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 community engagement and outreach, fee reductions, downpayment assistance, and other initiatives, the City aims to fill in the gaps that were present after the 5th Cycle Housing Element update, and continuously monitor the effectiveness of 6th cycle policies and programs through quantified objectives, mid-cycle reviews, and discrete timelines.

Table B-1 assesses the implementation status and effectiveness of the City of Patterson's 5th Cycle Housing Element policies and programs. It also identifies necessary modifications to enhance their effectiveness and specifies whether each program will be retained or discontinued.

Packet Pg. 1553
Appendix B Review of 2015-2023 Housing Element B-3 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Table B-1 Review of 5
th Cycle Housing Element Policies and Programs
Program Name Summary Program Description Accomplishments Program Effectiveness Policy H-1.1: The City shall ensure an adequate supply of residentially zoned land at sufficient densities is available to accommodate its fair share of existing and future housing needs.

H-1.A: Rezone Program The City shall rezone enough land to accommodate the remaining housing need of 496 lower-income units within two years of adoption of the Housing Element. Rezoned sites may include those identified in the Rezone Program section in the Housing Element, or will include other sites that provide at least the same capacity.

Consistent with Government Code Section 65583.2(h), the City shall ensure that the rezoned sites are large enough to accommodate a minimum of 16 units per site, will permit owneroccupied and rental multifamily residential uses by-right (without a conditional use permit, planned unit development permit, or other discretionary action), and that at least 50 percent of the remaining need will be accommodated on sites zoned for exclusively residential uses. The zone shall allow residential development at an intensity of at least 20 dwelling units per acre.

In 2020, the City rezoned 13 acres
located at Weber Avenue and First
Street to High Density Residential to
accommodate approximately 300
units.

Modify
This program was moderately
effective, meeting approximately 60
percent of rezoning efforts. The
remaining shortfall of 196 lowerincome units is being accommodated in the Site Inventory in Chapter 4.

The City has re-committed existing
staff capacity and resources.

Additionally, the City is adding a new
staff position to focus on all housing
needs, including rezoning efforts to
ensure no net loss.

The City has included Program 1.1 to
ensure that adequate sites are
available for rezoning to meet the 6
th
cycle RHNA.

H-1.B: Vacant Land
Inventory
The City shall continue to maintain an inventory of vacant residentially-zoned parcels and associated development potential and a list of recently approved residential projects to assist developers in identifying land suitable for residential development.

To ensure adequate sites are available throughout the planning period to meet the City’s RHNA, the City shall continue to annually update the inventory. The City shall continue to make this information available to the public and developers through the City’s website.

The City successfully updated the
vacant land inventory annually during
the 5th cycle. The inventory was
updated to include the recently
annexed Baldwin Zacharias Master
Plan area.

Continue
This program was effective and will be
continued in Chapter 3 of the Housing
Element (Program 1.1).

Packet Pg. 1554
Appendix B Review of 2015-2023 Housing Element B-4 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Program Name Summary Program Description Accomplishments Program Effectiveness H-1.C: Lot
Consolidation
The City shall encourage and, based on available resources, facilitate the consolidation of vacant and underutilized lots for residential development, especially those identified in the Sites Inventory in order to develop vacant and underutilized lots to their fullest potential. The City will evaluate the appropriateness of a variety of incentives and provide this information to the developers, owners, and other interested parties through the City’s website and/or print material at City Hall.

No lot mergers/consolidations took
place during the 5th Cycle due to a lack
of developer incentives and developer
interest.

Modify
Due to limited staff capacity and
funding, the program was not
implemented during the 5th Cycle.

However, as included in Program 1.6,
the City is committed to facilitating the
development of affordable housing
during the planning period, and plans
to hire a dedicated staff to focus on
housing issues and needs.

This program has been modified to
include specific actions the City will
take to facilitate lot consolidation to
fulfill the lower-income RHNA. This
program is now called Program 1.3
(see Chapter 3).

H-1.D: City-Owned
Land
The City shall develop and maintain a database of all City-owned land, particularly surplus land, for opportunities to rezone, where appropriate, for affordable housing development.

The City uses a GIS database for site
tracking, and the Public Works
Department maintains a list of these
City-owned sites
Modify
This program has been expanded and
modified to build a more robust
database for tracking City-owned lands
(Program 1.1) in the Housing Action
Plan (Chapter 3).

H-1.E: Second Units The City shall, based on available staff resources, develop and maintain information on the City’s website and at City offices (e.g., brochures) about the development of second family units in existing and new single-family residential developments.

The City has a guideline and checklist
for ADUs, and the City provides the
County’s pre-approved plans and
brochures for ADU information to
interested residents
Modify in the following ways:
1) The City will include a program to
update the Municipal Code to comply
with ADU legislation;
2) The City will include ADU
information on City website; and
3) ADU info will be incorporated into
the Building Codes.

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Appendix B Review of 2015-2023 Housing Element B-5 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Program Name Summary Program Description Accomplishments Program Effectiveness Policy H-1.2: The City shall encourage development of a range of housing types affordable to various income groups, including single family and multifamily dwellings, “move-up” housing, senior housing, secondary and other smaller units, and special needs housing.

N/A
Policy H-1.3: The City shall monitor the amount of land zoned for all types of housing and initiate zone changes, as necessary, to ensure an appropriate mix of housing types
N/A
Policy H-1.4: The City shall encourage the development of multi-family housing throughout the city, especially in locations near transit stops, shopping and services, and schools.

N/A
Policy H-1.5: The City shall encourage residential projects to develop at the higher end of the allowable density range.

N/A
Policy H-1.6: Consistent with “no-net-loss” density provisions contained in Government Code Section 65863, the City shall consider the potential impact on the City’s ability to meet its share of the regional housing need when reviewing proposals to downzone residential properties, reclassify residentially-designated property to other uses, or develop a residential site with fewer units than what is assumed for the site in the Housing Element sites inventory.

N/A
Policy H-1.7: The City shall encourage the development of second family units in existing and new single-family residential developments.

N/A
Policy H-1.8: The City shall encourage development of well-planned and designed projects that provide for the development of compatible residential, commercial, industrial, institutional, open space, or public uses within a single project or neighborhood.

N/A
Policy H-1.9: The City shall ensure the development of housing has, to the extent possible, easily accessible shopping, services, transit, parks and open space, schools, and jobs.

N/A
Packet Pg. 1556
Appendix B Review of 2015-2023 Housing Element B-6 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Program Name Summary Program Description Accomplishments Program Effectiveness Policy H-2.1: The City shall strive to conserve the existing housing stock, including existing rental housing that is affordable to lower- and moderate- income households an affordable housing that is at-risk of being converted to market rate housing.

N/A
Policy H-2.2: The City shall impose long-term restrictions on the maximum rents and sale prices of affordable housing that is developed with City assistance as well as inclusionary units provided by private developers.

N/A
Policy H-2.3: The City shall continue to apply to HUD and HCD for grant funds for the development of affordable housing and provision of housing-related programs.

H.2.A: New Funding
Sources
The City shall work to secure additional funding from State, Federal, and regional sources and support applications for funding that can be used to help increase the supply of affordable housing in Patterson. The City shall review NOFAs annually to determine the City’s eligibility and competitiveness for grant funding. Based on available staff resources, funding availability, and expected competitiveness, the City shall prepare and submit one or more funding applications on an annual basis.

Such programs may include, but are not limited to:
• HUD Section 811 funding for supportive housing for extremely low-income residents;
• HCD Local Housing Trust Fund Program;
• The state Infill Infrastructure Grant program, sponsored by the Department of Housing and Community Development (HCD); and • The state Multifamily Housing Program (MHP), sponsored by HCD.
• The City shall also identify Community Development Block Grant (CDBG), City revolving bond funds, and other sources of funding to assist with the purchase of land for affordable housing. (New Program, Consultants, replaces similar program)
The City is an entitlement community,
and receives CDBG and HOME grants
from the Stanislaus County Block
Consortium.

Continue
This program has been effective in that
it provided funding to the Disability
Resources Agency for Independent
Living (DRAIL) program and other
programs for special needs
populations serving approximately 200
residents.

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Appendix B Review of 2015-2023 Housing Element B-7 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Program Name Summary Program Description Accomplishments Program Effectiveness Policy H-2.4: The City shall use techniques such as mortgage revenue bonds or other mortgage-backed securities to assist in the development of affordable ownership and rental housing.

N/A
Policy H-2.5: The City shall assist developers, nonprofit housing developers, and other qualified private sector interests in pursuing and applying for Federal, State, NGO, and private financing and grants for the development of affordable housing.

N/A
Policy H-2.6: The City shall facilitate partnerships between non-profit and for-profit housing developers to encourage affordable housing production.

H-2.B: Meetings with
the Development
Community
The City shall conduct annual meetings with the development community to publicize available incentives and housing programs, such as the density bonus ordinance, and foster partnerships between for-profit and non-profit developers.

Not much discussion has taken place
with developers throughout the 5th
Cycle due to the Covid-19 pandemic
and lack of developer interest;
however, City staff met with
developers, in 2024, to discuss
transitional housing.

Continue
The City has expanded this program in
the Housing Action Plan to include
information on public outreach to
developers (Programs 1.6 and 5.3).

H-2.D: Regulatory and
Financial Incentives
The City shall coordinate with affordable housing developers to develop regulatory and financial incentives for the development of extremely low-income housing. The City will annually identify its eligibility and competitiveness for grant funding, and shall pursue or support funding and grant applications to encourage and assist in the development of SROs and/or other housing types consistent with existing City standards and State law. Based on available staff resources, interest from developers, funding availability, and expected competitiveness, the City shall prepare and submit one or more applications on an annual basis
In 2024, the City staff discussed
financial incentives and site locations
with the following developers for
transitional housing:
- DignityMoves.org
- Hope House
Continue
This program was moderately effective
during the 5th cycle due to limited
coordination with developers that took
place due to the Covid-19 pandemic
and limited staffing. The City will
include updated developer resources
on the City’s website and continue to
meet proactively with the development
industry.

Policy H-2.7: The City shall allocate funds from available sources to the first-time homebuyer program.

H-2.C: First Time
Homebuyer Down
Payment Assistance
The City shall use HOME funds or alternative funding sources to assist with first time homebuyer down payment assistance scaled to current economic conditions for each qualified household as determined by the City Council. The City shall annually determine households eligible for homebuyer down payment assistance, with City staff has publicized the HOME
funds that is available, but due to the
current housing market conditions
(rising prices), the program had limited
appeal.

Modify
This program was limited in
effectiveness during the 5th cycle due
to the gap in the amount of CPA
funding available and rising housing
costs within Patterson. This program
Packet Pg. 1558
Appendix B Review of 2015-2023 Housing Element B-8 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Program Name Summary Program Description Accomplishments Program Effectiveness a goal of assisting four households per year, based on available staff resources and funding.

The biggest concern for the City is that
most home prices in Patterson are
unaffordable to residents. A gap exists
between what is affordable despite
City’s financial assistance for lowincome households. Therefore, the Down-payment assistance that the
City offers to residents is not sufficient
to offset the high costs of housing.
has been modified and updated in the
Housing Action Plan (Chapter 3) in
order to reach potential applicants.

Policy H-2.8: In accordance with the provisions of State law, the City shall encourage the use of density bonuses for qualifying projects to facilitate the development of affordable and senior citizen housing.

H-2.E: City Incentives To preserve affordability, the City shall provide incentives such as density bonus units, fee reductions, fee deferral, and fast-tracking to developers of residential projects who agree to enter into a longterm contract to provide the specified percentage of units mandated by State law at a cost affordable to extremely low-, very low-, and/or low-income households. The City shall strive to create 100 affordable housing units by 2023 through the aforementioned activities, subject to availability of staff resources and funding and subject to developer interest, In addition, the City shall annually review its zoning and permit processing procedures, and may propose changes to the City Council based on prudent fiscal planning and staff availability, to assist in reducing housing costs and average permit processing time.

The City provided fee reductions and
waivers for low-income apartments;
Continue
This program was effective. The
Stonegate Village Project was
developed by Self Help Enterprises.

Self Help Enterprises developed 66
affordable units with a density bonus,
and parking reductions, which the City
facilitated and approved.

Policy H-2.9: The City shall provide information to Patterson residents about affordable housing programs and opportunities.

H-2.F: Project
Information Booklet
The City shall prepare a Project Information Booklet outlining City participation and incentives, housing needs from the Housing Element (or other market source), a definition of the State and Federal funding for which the City is willing to apply, and other pertinent information. The City shall distribute the booklet to local, regional, and national non-profit and for-profit development groups and regional agencies.

The City has brochures posted on the
City website and in City Hall.

Information regarding the Downpayment Assistance and Minor Repair Program has been posted online.

Continue
This program was effective, and has
been expanded to include an
“Affirmative Marketing” strategy for
public outreach (Program 5.3).

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Appendix B Review of 2015-2023 Housing Element B-9 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Program Name Summary Program Description Accomplishments Program Effectiveness H-2.G: Section 8
Housing Assistance
The City shall continue to collaborate with the Stanislaus County Housing Authority to qualify city residents for Section 8 housing assistance. The City shall provide information on the availability of Housing Authority programs to qualified residents.
11 Housing Choice Vouchers were
issued and used for a senior complex
within the City of Patterson
Continue
This program is being continued as the
Housing Choice Voucher program in
the Housing Action Plan (Chapter 3).

The program has been effective, and
the City continues to refer individuals
to the Stanislaus County HCV
program. The County continues to
have a long waitlist for the program,
but it is effective for those in need of
rental assistance.

Policy H-2.10: The City shall encourage sweat equity programs (allowing buyers to contribute labor hours to lower housing costs) for the construction of homes for first-time homebuyers.

N/A
Policy H-2.11: The City shall encourage the construction of affordable units with three or more bedrooms to accommodate the needs of large households.

N/A
Policy H-2.12: The City shall continue to allocate staff resources to pursuing partnerships that result in the development of affordable housing.

N/A
Policy H-3.1: The City shall prioritize the development of housing that meets the needs of extremely low-income residents and special needs groups, including: seniors, person with disabilities, single female-headed households with children, large families, farmworkers, and the homeless.

H-3.A: Development of
Housing for Persons
with Disabilities
The City shall conduct annual meetings with developers of supportive housing to encourage development of projects targeted to persons with disabilities, including developmental disabilities.

Support applications for County, State, and Federal funding for housing construction and rehabilitation for persons with disabilities, including developmental disabilities.

City collaborates with local non-profit;
part of allocation for public service
grants received are distributed to the
non-profit (DRAIL).

Continue
The City has included a program for
Universal Design and to encourage
construction of multi-family and
accessible units for Seniors and/or
residents with disabilities. The
Stanislaus HOME Consortium and
Urban County assisted approximately
Packet Pg. 1560
Appendix B Review of 2015-2023 Housing Element B-10 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Program Name Summary Program Description Accomplishments Program Effectiveness 802 individuals with disabilities with
emergency food, shelter, and/or utility
assistance.

H-3.B: Disabled-Access
Units
The City shall enforce Building Code requirements for the inclusion of adaptable disabled accessible units in multifamily development projects that are subject to such requirements.

The City has enforced building code
requirements, for ADA accessible units
in multi-family development projects
Continue
The City has effectively enforced the
Building Codes, therefore a number of
accessible units have been
constructed. To further increase
accessibility, the City will adopt
Universal Design Guidelines for Senior
units (Program 4.2)
H-3.C: Incentives for
Large-Family Housing
The City shall coordinate with developers and non-profit developers to develop regulatory and financial incentives to encourage the development of multi-family housing, including larger units (i.e. 3-4 bedrooms).

The City has successfully implemented
the following incentives:
- Adjusted fees so there is a
reduction per unit for multifamily development
completed in 5th cycle
- Density bonuses
- Parking Reductions
A recent development constructed
multi-generational suites to include full
bathrooms and bedrooms on the
ground floor, and ADUs with singlefamily development.

Lennar Homes is constructing a variety
of homes of up to 5 bedrooms with a
mixture of single floor and two-story
homes within the City of Patterson.

Continue
Stonegate Village had a mix of
bedroom sizes including:
22 (3-bedroom) units oriented towards
larger families along with familyfriendly amenities (i.e. playground, computer room, etc.)
The incentives utilized for this
development included Density Bonus
and Parking Reduction.

H-3.D: Las Palmas
Senior Apartments
The City shall support the Stanislaus County Housing Authority’s plans for the 16-unit expansion of the Las Palmas Senior Apartments with the use of CDBG, HOME, and other available funding.

For this program, the City of Patterson
sought to build on the previous
development work that took place
during initial phase of construction of
the Las Palmas Senior Apartments.

Continue
The program was effective – as City
staff have been in discussion with the
Stanislaus Regional Housing Authority,
Packet Pg. 1561
Appendix B Review of 2015-2023 Housing Element B-11 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Program Name Summary Program Description Accomplishments Program Effectiveness While no further construction took
place during the 5th Cycle, City staff
has been in contact with developers
and the regional Housing Authority
regarding initiating phase 2 of the
development.

Stanislaus County, and the City of
Turlock regarding Phase 2 of the
project (16 units). City staff awaits the
site plan and additional funding.

The City has included Program 4.4 in
Chapter 3 of the Housing Element to
facilitate Phase 2 of the development
for the Las Palmas Senior Apartments
Policy H-3.2: The City shall support efforts to provide emergency shelter, transitional housing, and permanent supportive housing for homeless persons.

H-3.E: Homeless Count The City shall participate in the Stanislaus County Point in Time Count to quantify local homeless populations and others with a need for emergency shelter.

The City has maintained the annual
Point-in-Time count of homeless
individuals within the City of Patterson.

Modify
This program will continue during the
6 th Cycle, but has been modified in
Chapter 3 of the Housing Element
(Program 4.8) to include provisions for
emergency shelters and supportive
housing.

H-3.I: Single Room
Occupancy (SRO) Units
The City shall amend the Zoning Ordinance to allow development of Single Room Occupancy (SRO) units in appropriate zones (e.g., those that allow multifamily housing). The Zoning Ordinance will include development standards for SRO units.

The City did not complete the
amendment to the Zoning Ordinance
to include Single Room Occupancies,
due to limited staffing.

Modify
This program has been continued and
modified in Chapter 3 of the 6th Cycle
Housing Element (Program 4.10) as a
means of providing transitional and/or
supportive housing to special needs
populations in the City.

Policy H-3.3: The City shall support efforts of homeless service providers in establishing additional short-term beds for all segments of the homeless population by ensuring that development standards will only subject shelters to the same development and management standards that apply to other allowed uses in the approved zones.

N/A
Policy H-3.4: The City shall work with homeless service providers and social services organizations to expand shelter opportunities for specialized homeless groups, such as children and families, those with chronic mental illness, and the disabled.

N/A
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Appendix B Review of 2015-2023 Housing Element B-12 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Program Name Summary Program Description Accomplishments Program Effectiveness Policy H-3.5: The City shall coordinate with homeless shelters to pursue funding for the ongoing maintenance and expansion of their services. The City shall continue to provide individuals with disabilities reasonable accommodation through flexibility in the application of land use, zoning, or building regulations, when necessary to eliminate barriers to housing opportunities.

N/A
Policy H-3.6: Where practical and feasible, the City shall support applications for County, State, and Federal funding for the construction and rehabilitation of supportive housing for persons with disabilities, including developmental disabilities.

N/A
Policy H-3.7: The City shall maintain a housing rehabilitation program to provide a one-time grant or loan to extremely low- and very lowincome disabled persons and senior citizens to improve accessibility and safety.

H-3.F: Mobility Device
Grants
The City shall, based on available resources, provide accessibility and mobility enhancing device grants to persons with disabilities.

This program was not implemented
due to limited staffing.

Discontinue
The program was not implemented due
to limited staff capacity, and will not be
continued.

Policy H-3.8: The City shall support developers and non-profit housing developers of farmworker housing by assisting in potential site identification and applying for or supporting applications for funding, such as the Joe Serna Jr. Farmworker Housing Grant Program.

H-3.G: Employee
Housing Act
The City shall update the Zoning Code to be consistent with the Employee Housing Act (Health and Safety Code 17021), which generally requires employee housing to be permitted by-right, without a CUP, in single-family zones for less than six persons, and in all zones that allow agricultural uses with no more than 12 units or 36 beds.

The City did not complete this program
during the 5th Cycle due to limited
staffing and capacity.

Continue
The City has included Program 4.11 in
Chapter 3 of the 6th Cycle Housing
Element to implement the
requirements of the Employee Housing
Act.

H-3.H: Farmworker
Housing
The City shall seek to coordinate programs and funding from state and federal programs through the Stanislaus County Housing Authority. The City will work with the Housing Authority to explore opportunities for locating farmworker housing within the city, as demand necessitates. Through the Housing Authority and Farm Bureau, the City will meet with stakeholders to discuss the demand for farmworker housing and whether pursuit of funding for this type of housing is needed. The City, through the Housing Authority, will provide assistance to the farming community and housing developers in obtaining loans and grants and processing No action has been taken on this
program to further expand the
farmworker housing supply within the
jurisdiction, as the City has adequate
housing within city limits to
accommodate the housing needs of
the City’s farmworkers.

Continue
Program 4.11 in Chapter 3 of the 6th
Cycle Housing Element addresses
farmworker housing to ensure that the
City complies with the requirements of
the Employee Housing Act. The City
will continue to work with the
Stanislaus Regional Housing Authority
and the Office of Migrant Services
(OMS) to provide services to
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Appendix B Review of 2015-2023 Housing Element B-13 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Program Name Summary Program Description Accomplishments Program Effectiveness applications for the rehabilitation and/or establishment of new farm labor housing under USDA Rural Development and California Department of Housing and HCD programs and other funding sources that may become available. The City will assist, based on available staff resources, nonprofit groups and stakeholders in pursuing funding resources, water and sewage availability, and entitlements. In addition, the City will provide, based on available resources, development incentives for the provision of farmworker housing and expediting the permitting process for all farmworker housing projects, to the extent feasible.
farmworkers and expand farmworker
housing in other areas of the city.

Policy H-4.1: The City shall maintain entitlement procedures that provide the City sufficient oversight of the development and design process while offering residential developers a fair, timely, consistent, and predictable process.

H-4.C: Design Review The City shall monitor the outcomes of its Design Review process for multifamily projects to ensure findings and project requirements do not result in unreasonable costs being added to the
development of affordable housing. The City shall annually report to the City Council the types of findings and requirements resulting from design review.

The City reviewed the Design Review
process and noted that multi-family
permitting process takes on average, 6
months. While the City has Community
Design Guidelines, they are not
specific to multi-family housing.

Most of the multi-family units are
located within Master Plan Areas, and
multi-family development above 4 units
has to be reviewed by the Planning
Commission.

Continue
The City has discovered subjective
language within its Design Guidelines.

The City will remove language
subjectivity, especially for reasonable
accommodation requests or multifamily housing geared towards residents with disabilities.

Additionally, Program 1.8 commits the
City to developing Objective Design
Standards.

Policy H-4.2: The City shall encourage continue to monitor and refine its processes and regulations to barriers to the production of housing, particularly affordable- and higher-density housing.

H-4.A: Annual Action
Plan
The City shall publish the City’s Housing Element and updates, Annual Action Plan, and respective notices and post these documents on the City’s website, and shall provide an annual funding application workshop for interested agencies and developers.

The City has implemented this
program, and will continue to do so
going forward.

Continue
Chapter 3 of the Housing Element
reflects the City’s update Housing
Action Plan.

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Appendix B Review of 2015-2023 Housing Element B-14 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Program Name Summary Program Description Accomplishments Program Effectiveness Policy H-4.3: The City shall ensure adequate infrastructure and public services are provided to serve existing and planned residential development.

N/A
Policy H-4.4: The City shall encourage developers to "piggyback" or file concurrent applications (i.e., rezones, tentative tract maps, conditional use permits, variance requests, etc.) if multiple approvals are required, and if consistent with applicable processing requirements, to reduce processing times.

N/A
Policy H-4.5: The City shall ensure that the development community (both non-profit and for profit) is aware of the housing programs and technical assistance available from the City.

N/A
Policy H-4.6: The City shall continue to facilitate the review of development applications, encourage pre-application meetings with planning and building staff, and streamline the overall planning application and building process for all residential development.

N/A
Policy H-4.7: The City shall facilitate lot consolidation to encourage the development of housing for lower-income households.

N/A
Policy H-4.8: The City shall consider, on a case-by-case basis, deferring payment of fees until housing units are sold, ready for occupancy, or long-term financing is in place, as a means of assisting affordable housing projects.

H-4.B: Development
Fees for Low-Income
Housing
Based on available resources, prudent fiscal planning, and applications for housing projects, the City shall provide developers of low-, very low-, and extremely low-income housing reduced and or deferred development fees. The City shall strive to assist in the development of 100 affordable housing units through 2023.

The city’s fee schedules were last
updated in 2022.

Continue
The City has included Program 4.5 in
Chapter 3 of the 6th Cycle Housing
Element to continue incentivizing fee
waivers and reductions for multi-family
and family-friendly housing.

Policy H-5.1: The City shall protect and stabilize existing residential neighborhoods from the encroachment of incompatible or potentially disruptive land uses and/or activities.

N/A
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Appendix B Review of 2015-2023 Housing Element B-15 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Program Name Summary Program Description Accomplishments Program Effectiveness Policy H-5.2: The City shall prioritize code enforcement activities for housing and provide adequate funding and staffing to support code enforcement and graffiti abatement programs.

H-5.A: Neighborhood
Preservation
The City shall promote neighborhood preservation and code compliance by regularly monitoring neighborhoods for code violations and graffiti vandalism, and taking action to abate or remedy identified violations as soon as they occur.

The overall objective of Code
Enforcement is to promote and
maintain a safe and desirable living
and working environment. The City of
Patterson does this by working in
partnership with City residents and
business owners by applying a fair and
unbiased enforcement program
designed to increase public awareness
of City's Municipal Codes (e.g.
property maintenance, public nuisance
violation(s), abandoned vehicle(s),
zoning, etc.) and to facilitate the
correction of said code violations as
they arise.

The City proactively monitors and
reports any code violations related to
graffiti and vandalism.

Continue
This program was effective during the
5 th cycle, and the program has been
continued (Program 2.1) in Chapter 3
(Housing Action Plan) of the Housing
Element.

H-5.B: Code
Enforcement
The City shall continue to investigate complaints and take action concerning Code Enforcement violations to encourage
rehabilitation of substandard residential properties by homeowners and landlords and improve overall housing quality and conditions in the city.

This program has been effective in
maintaining property and housing
conditions. The following are some
common code violations:
• Building Code violations
such as construction without
permits; including but not
limited to room additions,
garage conversions,
construction of patio covers,
re-roofs, electrical, plumbing
and mechanical
improvements such as water
Continue
This program has been effective, but
was modified to include outreach about
rehabilitation resources (Program 2.1)
in the Housing Action Plan (Chapter 3).

Packet Pg. 1566
Appendix B Review of 2015-2023 Housing Element B-16 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Program Name Summary Program Description Accomplishments Program Effectiveness heater installations and
HVAC installations.
• Accumulation of junk and
debris in public view in
residential and commercial
areas.
• Unpermitted businesses in
residential neighborhoods.
• Inoperable or abandoned
vehicles on private property.
• Zoning violations for
structures and land use
requirements, including the
use of the structure, size and
location.
• Hazardous and overgrown
vegetation which can be a
fire hazard.
• Vacant and unsecured
properties.
• Parking violations on
unimproved surfaces such
as landscaped areas.

Policy H-5.3: The City shall promote orderly growth of neighborhoods by phasing the approval of building permits to one area of a subdivision at a time to allow for timely extension of infrastructure and efficient use of resources.

N/A
Policy H-5.4: The City shall provide technical and financial assistance through grants or low interest loans to all eligible homeowners and residential property owners to rehabilitate existing dwelling units.

H-5.C: Housing
Rehabilitation Funds
The City shall continue to use HOME housing rehabilitation funds for the rehabilitation of 18 units.

The City of Patterson receives
Community Development Block Grant
(CDBG) and HOME funds from the
U.S. Department of Housing and
Urban Development through the
Continue
The use of HOME housing
rehabilitation funds has been effective
and the City has met its target for units.

The program offers up to $20,000 in
Packet Pg. 1567
Appendix B Review of 2015-2023 Housing Element B-17 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Program Name Summary Program Description Accomplishments Program Effectiveness Stanislaus County Block Consortium.

The consortium includes Stanislaus
County and the Cities of Patterson,
Oakdale, Newman, Ceres, Waterford,
and Turlock (for the HOME program
only).

This program is designed to repair or
eliminate conditions that present
critical health and safety hazards and
provides assistance for disabled
people in making their homes more
accessible.
assistance in a combination of grants
and/or loans and income limits apply.

There is an ongoing use of funds.

H-5.D: Publicize
Rehabilitation Programs
The City shall provide information about available housing rehabilitation loan programs to qualifying households.

The City identifies prospective
applicants through outreach at a
variety of locations including the City’s
website, tabling at Farmer’s markets
and partnerships with non-profits
including the Westside Resource
Center regular meetings. In addition,
Code Enforcement staff provide
information when related Code
violations are identified.

Continue
This program was effective, and has
been continued and expanded
(Program 2.1) in the Housing Action
Plan (Chapter 3).

Policy H-5.5: The City shall install and upgrade public service facilities (streets, curb, gutter, drainage facilities, and utilities) to encourage increased private market investment in declining or deteriorating neighborhoods.

N/A
Policy H-5.6: The City shall strive to preserve existing affordable housing units.

H-5.E: At-Risk Units Based on available staff resources, the City shall maintain contact with the operators of at-risk affordable housing to ensure the preservation of affordable units. Based on the likelihood of units being converted to market rate, the City shall strive to preserve 24 units through 2023.

The City has a dedicated staff person
focused on housing within the city. City
staff is in regular contact with
operators of at-risk affordable units in
order to ensure preservation of the
units.

Continue
This program was effective, and has
been expanded (Program 2.2) in the
Housing Action Plan (Chapter 3).

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Appendix B Review of 2015-2023 Housing Element B-18 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Program Name Summary Program Description Accomplishments Program Effectiveness H-5.F: Technical
Assistance
The City shall provide technical assistance to potential purchasers of at-risk affordable housing, including non-profits, developers, and tenants to help preserve affordable housing in Patterson.

The City has a dedicated staff person
focused on housing within the city. City
staff provides technical assistance to
potential purchasers of at-risk
affordable units.

Continue
This program has been modified and
combined with the one above in the
Housing Action Plan (Chapter 3).

Policy H-6.1: The City shall establish a development pattern that helps reduce vehicle miles traveled and promotes transit ridership, and pedestrian and bicycle access.

N/A
Policy H-6.2: The City shall continue to promote sustainable housing practices that incorporate a “whole system” approach to siting, designing, and constructing housing that is integrated into the building site; consumes less energy, water, and other resources; and is healthier, safer, more comfortable, and durable.

N/A
Policy H-6.3: The City shall ensure that all new residential development meets or exceeds the standards contained in Title 24, Part 6 of the California Code of Regulations (Energy Efficiency Standards for Residential and Nonresidential Buildings), and encourage the retrofitting of existing development to improve energy and conservation.

N/A
Policy H-6.4: The City shall encourage homeowners and property owners of existing residential buildings to incorporate energy and water efficient features and renewable energy facilities in structures.

H-6.A: Energy
Efficiency and Water
Conservation
Awareness
Based on available resources, the City shall develop and periodically update energy efficiency and water conservation awareness brochures and provide them in all publicly accessible City buildings and in City information sources (e.g. the Citizen’s Newsletter).

The city’s Citizen’s Newsletter is
distributed on a quarterly basis and
included this information which
reaches the broader community.

Additionally, brochures are available in
all publicly accessible city buildings.

Continue
This program has been effective, and
is expanded and included in the
Housing Action Plan (Program 3.1).

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Appendix B Review of 2015-2023 Housing Element B-19 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Program Name Summary Program Description Accomplishments Program Effectiveness Policy H-7.1: The City shall promote fair housing opportunities for all people regardless of race, color, religion, sex, sexual orientation, marital status, national origin, ancestry, familial status, disability, or source of income.

H-7.A: Fair Housing
Materials
Based on available resources, the City shall develop, periodically update, and regularly distribute fair housing materials at a number of locations throughout the city, such as City government buildings, the post office, and the library and to service organizations, nonprofits, and other groups to educate property owners and managers about housing discrimination.

The city has a dedicated staff person
focused on housing within the city.

Information on Fair Housing is
regularly distributed and included in
the Citizens newsletter.

Continue
This program has been modified and
expanded in the Housing Action Plan
(Chapter 3) to contain more proactive
steps to educate residents on fair
housing issues (Program 5.3).

Policy H-7.2: The City shall assist in the enforcement of fair housing laws by providing information and referrals to the public.

H-7.B: Project Sentinel The City shall refer housing discrimination complaints to Project Sentinel, a HUD-approved housing counseling agency.

The city has a dedicated staff person
focused on housing within the city. City
staff refers housing discrimination
complaints to Project Sentinel.

Continue
This program has been combined with
the program above (H-7.A) and
expanded in the Housing Action Plan
(Chapter 3) to provide a clearer path
forward for handling fair housing cases
(Program 5.1).

SOURCE: City of Patterson, 2024
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Appendix B Review of 2015-2023 Housing Element B-20 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 This side intentionally left blank.

Packet Pg. 1571
Public Participation and Outreach C

APPENDIX
Packet Pg. 1572
Table of Contents
APPENDIX C PUBLIC PARTICIPATION AND OUTREACH.............................................C-1 C.1 Public Noticing ......................................................................................................................C-1 C.2 Community Workshops........................................................................................................C-2 C.3 Public Draft Review Period .................................................................................................C-3 C.4 Housing Needs Survey........................................................................................................C-43 C.5 Tribal Consultation..............................................................................................................C-43 C.6 List of Contacted Organizations.......................................................................................C-44 C.7 City of Patterson Contact List...........................................................................................C-44 Tables
Table C-1 Public Comment Response Matrix .........................................................................C-4 Attachments
Attachment A Housing Needs Survey Report
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Appendix C Public Participation and Outreach C-1 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 Appendix C
Public Participation and Outreach
The Housing Element must reflect the values and preferences of the community. Accordingly, community participation is an important component of the development of this Housing Element.

Section 65583(c)(8) of the Government Code states that the local government must make “a diligent effort to achieve public participation of all economic segments of the community in the development of the housing element.” This process not only includes community members, but also includes participation from local agencies and housing groups, community organizations, and housing sponsors.

The primary purpose of this appendix is to describe the effort made by the City of Patterson to engage all economic segments of the community (including residents and/or their representatives) in the development and update of the housing element. Included in this appendix is a list of contacted organizations, tribal units, and other stakeholders that were contacted during the preparation of Patterson’s 6th Cycle Housing Element.

C.1 Public Noticing
The City of Patterson employed an assortment of methods to generate awareness and maximize public engagement during the Housing Element update process. The City developed and continuously updated a page on the City’s website dedicated to information on the Housing Element update.1 The City distributed bilingual (English and Spanish) informational flyers to inform the community of the Housing Element update, housing needs survey, property owner interest forms, community workshops, and other opportunities for participation. In addition, the City promoted informational flyers and links to engagement opportunities on the City’s social media outlets, such as Facebook.
1 https://www.ci.patterson.ca.us/150/City-of-Patterson-Housing-Element Packet Pg. 1574
Appendix C Public Participation and Outreach C-2 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 C.2 Community Workshops
November 12, 2024 Workshop
The City of Patterson hosted a joint Planning Commission and City Council Community workshop on November 12, 2024 to engage the community in the Housing Element update process. The workshop was hosted in-person at City Hall.

The workshop introduced the Housing Element process and state requirements, as well as the Public Draft Housing Element. The workshop consisted of an informative PowerPoint presentation on the Housing Element update process and timeline, providing contextual information on the contents and key issues of the Housing Element. The workshop also included a discussion on housing challenges in Patterson and potential strategies to improve housing opportunities. The Housing Needs Survey and Property Owner Interest Survey were both advertised at the meeting as well.

The following housing concerns were raised by participants during the community workshop:
▪ Zoning standards;
▪ Increasing housing densities;
▪ Parking and height requirements in the
downtown area;
▪ Potential for underground parking for
multi-family housing;
▪ Universal Design requirements;
▪ Comparing impacts of a 30 percent
RHNA buffer vs. 15 percent RHNA
buffer;
▪ Timeline to build required units;
▪ Accessory Dwelling Units (ADU);
▪ Inclusion of infill and small lots in the
housing plan;
▪ Management of new housing types;
▪ Apartment inspections;
▪ Closure of buildings;
▪ Ensuring impact fees align with inflation;
▪ Reducing traffic congestion and
emissions;
▪ Water and sewer requirements for new
housing;
▪ StanRTA transit program considerations;
and
▪ Financial challenges associated with
building in the downtown area.

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Appendix C Public Participation and Outreach C-3 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 C.3 Public Draft Review Period
In accordance with Government Code Section 65585(b)(1), the Housing Element was released for a 30-day public comment period. The review period began on November 5, 2024 and ended on December 5, 2024. During the public-review period of the Public Draft Housing Element, the City received comments from representatives of the general public and the Rutan and Tucker, LLP, on behalf of Keystone Ranch, LLC.

Table C-1 reports all comments received on the Public Draft Housing Element and City staff responses to comments.

C.4 Revised Draft Public Review Period
Pursuant to Assembly Bill (AB) 215 requirements, the April 16, 2025 Revised Draft Housing Element was released for a seven-day public review period. The review period began on April 16, 2025 and ended on April 23, 2025. During the public review period of the Revised Draft Housing Element, the City received a comment letter from Rutan and Tucker, LLP, on behalf of Keystone Ranch, LLC. In addition, the City received a comment letter from YIMBY Law on May 29, 2025, outside of the formal public comment period.

The City posted a Revised Draft Housing Element on the City’s Housing Element webpage on August 6, 2025 for public review. The public review period ran from August 6 through August 22, 2025. Public comments were received from Rutan and Tucker, LLP and YIMBY Law.

All comments are included in Table C-1 below, as well as page numbers where revisions were made in response.

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Date
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Topic Comment Response
11/12/2024
Public Review
Draft
Accessible Transit Kandace Weyhrauch, Patterson Resident – expressed concern about the meeting not being accessible via Zoom. Weyhrauch also stated that StanRTA transportation is not inherently a problem but emphasized the need for advocacy and spreading awareness about available options. Additionally, Weyhrauch highlighted the importance of making Accessory Dwelling Units (ADUs) more affordable for the community.

The City is committed to collaborating with the Stanislaus Regional Transit Authority (StanRTA) to expand transportation access to the western and eastern regions of the city, enhancing overall connectivity. To support this, Program 1.9 has been included in Chapter 3 of the Housing Element to commit the City to specific actions and goals to expand transit access in Patterson. See Chapter 3 for full program details.

The City recognizes that Accessory Dwelling Units (ADUs) are an important resource for providing affordable housing solutions.

To support this, the City has proposed Program 4.12, which outlines specific actions to facilitate ADU construction and provide assistance to residents interested in building an ADU on their property. See Chapter 3 for full program details. 11/12/2024
Public Review
Draft
ADUs and Universal
Design
Sheryll Lex, Patterson Resident – emphasized the need to make Accessory Dwelling Units (ADUs) more affordable. Lex also addressed the universal design principles, as well as considering underground parking and improved transportation options.

See response above related to ADUs and expanding transit access in Patterson.

Program 4.2 proposes the adoption of a Universal Design ordinance to establish provisions in new developments that accommodate a wide range of physical abilities and disabilities, including limited mobility, lifting, and vision impairments.

Feedback from the City’s Housing Needs Survey highlighted a demand for housing tailored to seniors and individuals with disabilities. Implementing a Universal Design ordinance would expand housing options that better meet the needs of these groups. See Chapter 3 for full program details.
12/05/24
Public Review
Draft
Various Rutan & Tucker, LLP

1. The City has delayed acting on Keystone’s housing development project for 12 years and is likewise delinquent in updating its Housing Element.

As you know, the City’s Housing Element was required to be adopted and certified by December 31, 2023. The Department of Housing & Community Development (“HCD”) sent the City a letter on May 13, 2024, urging it to submit a draft Housing Element and obtain compliance with State Housing Element Law This comment has been noted. The City is submitting its draft Housing Element to HCD for review. No revisions were made to the Housing Element in response to this comment.

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no later than June 10, 2024. HCD’s letter outlined the consequences to the City of non-compliance, including: (1) ineligibility to receive state funds that require a compliant housing element as a prerequisite, (2) being subject to the Builder’s Remedy and other loss of local planning control, and (3) facing financial and legal ramifications such as legal suit brought by the Attorney General and the payment of court-imposed penalties (up to $100,000 per month). Despite the need for urgent action, the City did not release the DHE until nearly one year after the statutory deadline and six months after HCD’s letter.

The City’s delays in processing the DHE are consistent with its delays in processing Keystone’s request for approval of a 719-unit housing development project (the “Project”). That development, known as Keystone Ranch, is identified as one of the key developments needed in order for the City to meet its Regional Housing Needs Allocation (“RHNA”). Keystone first applied for the Project in 2012. Yet still now some 14 years after first being proposed, the City still has not deemed the Project application complete. Instead, it has sent three “incompleteness” letters since May 2024 on the latest application submittal.

The City’s incompleteness letters demand additional information that is not specified on the City’s submittal checklist, request new information, and seek items that are not based on objective development standards. The City’s unjustified refusal to process Keystone’s Project application is posing a major constraint to residential development in the City.

2. Among other errors, the Draft Housing Element understates the City’s RHNA obligations.

The DHE references the City’s RHNA as 3,716 units. This includes 523 extremely low-income units, 523 very low-income units, 724 low-income units, 593 moderate-income units, and 1,353 above-moderate income units. (DHE, p. 1-25.) That understates the City RHNA obligations. Due to an unaccommodated need of 196 lower-income units from the 5th Cycle Housing Element, the City’s adjusted RHNA is actually 3,912 units, increasing the very low and low RHNA by 98 units each. (DHE, p. 3-3.) The City is supposed to provide a 15-30 percent buffer. But DHE Table 4-2 shows only an 11% and 17% buffer for very lowincome and low-income units, respectively.

The DHE says units in projects that received a certificate of occupancy by June 30, 2023 will be eligible for RHNA credit. (DHE, p. 4-4.) It seems those units would more appropriately be counted in the 5th Housing Element Cycle. This The City's Housing Element addresses the 5th cycle
unaccommodated need in Chapter 4, Housing Resources and Sites Inventory (pages 4-2 and 4-3). The Sites Inventory is designed to accommodate both the unaccommodated need and the 6th cycle RHNA.

Per HCD guidance, jurisdictions are encouraged to provide a 15-30 percent buffer when preparing the site inventory (HCD Site Inventory Guidebook, June 2020, page 22). This is only a recommendation, not a requirement.

Per HCD guidance, RHNA credit for units with certificates of occupancy is based on the applicable projection period, not the planning period (HCD Site Inventory Guidebook, June 2020, pages 5-6). Crediting units with certificates of occupancy within the applicable timeframe (June 30, 2023 - December 31, 2031) Packet Pg. 1578
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also has the effect of understating the City’s RHNA obligations for the 6th Housing Element Cycle.
does not result in an understatement of the City's RHNA obligation.

The Draft Housing Element has been revised to clarify that projects that received a certificate of occupancy on June 30, 2023 or later, are eligible for RHNA credit (page 4-4).

3. The City is improperly attempting to revise and re-write the Master Plan through the Draft Housing Element.

Keystone Ranch is comprised of 75.9 acres of land designated Medium Density Residential or “MDR” (503 units) and 12.6 acres designated High Density Residential or “HDR” (216 units). The Zacharias and Baldwin Ranch Master Plan (“Master Plan”) indicates that areas designated MDR will include attached and detached housing units and may include traditional subdivisions as well as alternative layouts. (Master Plan, p. 27.) The Master Plan makes clear that alternative layouts will be focused in the Core Area, which will be closer to retail, services, and recreation activity. (Master Plan, p. 13.) The majority of the Project site is situated within the Non-Core Area. (Master Plan, p. 14.) The Master Plan states that HDR areas will include apartments, townhomes, flats, and condominiums. (Master Plan, p. 36.) In accordance with the Master Plan, Keystone has submitted an application for 503 single-family detached units and approximately 216 attached multi-family units.

The DHE purports to revise or amend the Master Plan in ways that are not supported by the law or logic. For instance, it states that while “detached singlefamily homes are permitted, the regulations are better suited for smaller, attached units, reflecting a clear emphasis on medium-density development that supports housing variety.” (DHE, p. 2-12 [further noting the development standards for MDR “are optimized for attached housing types such as townhomes and duplexes.”].) There is nothing in the Master Plan to support the above statements. The City cannot amend the Master Plan through the guise of the DHE. While the City Staff may desire alternative developments, the reality is that ninety percent of the City’s housing stock is traditional single-family development and the Master Plan explicitly allows such development. (DHE, p. 1-14; Master Plan, p. 27.)
The proposed density range for HDR in Table 2-5 [20.1-35 units per acre] is not consistent with the density range for HDR in the Master Plan (see DHE, Table 2- 7 [specifying densities of 12.1 to 25 units per acre]. The DHE should be revised There is no attempt to amend the standards described in the Master Plan through the Housing Element. Revisions are
included to clarify that there are no amendments being made to the Master Plan (see pages 2-7 in Table 2-5, 2-13, 3-11, and 3- 12 in Table 3-2).

The Site Inventory utilizes the densities described in the Master Plan, which for Keystone Ranch parcels are: 6.0, 7.4, and 17.1 dwelling units per acre. The number of units assumed in the Site Inventory aligns with those outlined in the Master Plan (216 High Density Residential and 503 Medium Density Residential).

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to make clear that the proposed density ranges for HDR in Table 2-5 do not apply in the Master Plan area. (See also Program 1.10 at DHE, p. 3-11.) Again, the City cannot amend the Master Plan through the Housing Element process.

4. In accordance with the law, the City must adopt and apply objective development standards to all housing development projects.

The DHE acknowledges that the City lacks objective design standards (“ODS”) and instead applies Community Design Guidelines adopted in 2002 to residential development. (DHE, p. 2-18.) The DHE also acknowledges that the absence of ODS “poses a constraint to residential development,” correctly noting that “[s]ubjective guidelines and unclear zoning standards increase uncertainty and risk for housing developers” while ODS offer clarity for developers and assurance to the community. (DHE, p. 2-18.) But instead of committing to adopt ODS for all residential developments, as required by law, the DHE includes a program to establish ODS for mixed-use and multi-family residential projects only. (DHE, p. 3-9).

The Housing Accountability Act has long required cities to evaluate all housing projects based on objective planning, zoning, and subdivision standards, including design review standards. (Gov. Code § 65589.5(j).) The Housing Crisis Act likewise forbids affected cities (including Patterson) from imposing or enforcing design standards that are not objective in nature on any land where housing is an allowable use. (Gov. Code § 66300(b)(1)(C).) In accordance with the law, we urge the City to revise Program 1.8 and commit to adopting ODS for all housing/residential projects, not just multi-family or mixed-use ones.

This comment has been noted. No revisions were made to the Housing Element in response to this comment.

The City acknowledges the requirements of the Housing
Accountability Act and the Housing Crisis Act.

In the case of Keystone Ranch, development would be subject to the development standards contained in the Zacharias Master Plan.

5. The City Council has made constraints on new housing much worse by recently voting to increase development impact fees by 483%.

In terms of other governmental constraints on new housing, the DHE acknowledges that the City has the highest impact fees among nearby jurisdictions. (DHE, p. 2-36 [“Patterson has the highest total fees for singlefamily and multi-family dwellings among nearby jurisdictions . . . ..”].) This statistic was based on 2021 information pre-dating the substantial increase in impact fees by the City Council in October and November 2024. (See City Council Resolution Nos. 2024-59 and 2024-65 [increasing fees overall by 483%, with parkland in-lieu fees increasing by nearly 1000%].) As a condition to certification of the Housing Element, HCD should order the City to re-examine its fees and demonstrate that any new fees have a nexus to the This comment has been noted.

Revisions were added to pages 2-35 and 2-37, explaining the City’s recent development impact fee updates and reflecting the City’s current development impact fee schedule.

All ordinances, resolutions, nexus studies, and other information pertaining to the City’s development impact fees are available for public review.

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impacts of new development, were based on an adopted capital improvement plan to fairly apportion costs between new and existing development, and comply with all other procedural and substantive requirements of law.

6. The City is not serious about expediting local processing and permit procedures, as evidenced by Keystone’s attempts over 12 years to get a housing development approved.

The DHE also acknowledges that local processing and permit procedures “can pose a considerable constraint to the production and improvement of housing,” including “lengthy processing time, unclear permitting procedures, layered reviews, multiple discretionary review requirements, and costly conditions of approval.” (DHE, p. 2-37.) Keystone has experienced almost all of these delays in connection with the City’s processing of its Project application.

For the past 12 years, Keystone has attempted to secure approvals for its housing development Project. In April 2024, it submitted its latest Project application. The application still has not been determined to be complete by Staff, which has instead wasted months in sending three letters asserting “incompleteness” based on unwarranted demands for additional information that the City cannot lawfully demand. The key question is what exactly will the City do to rectify this situation.

Policy H-5 calls for facilitating streamlined and efficient development processes.

It states the City will “promote timely, consistent, and predictable development procedures by streamlining the approval process for residential developments.” (DHE, p. 3-2.) But it contains no other details or commitments. The DHE says the City will advance the development of large-scale projects within the Zacharias and Baldwin Master Plan areas. (DHE, p. 4-2.) But that has not how the City has treated Keystone’s Project application over the last 12 years.

It has been more than six months since Keystone submitted its full and detailed Project application and City Staff still has not found it to be complete. The DHE’s intended timeframes of 5-6 months for single-family development to obtain a building permit (DHE, Table 2-14) are not consistent with the City’s dilatory treatment of Keystone’s Project. They are also inconsistent with the text on the previous page, indicating one month processing time for single-family projects and four to six months processing time for multi-family projects. What are the time-frames in Table 2-14 based on?
This comment has been noted.

Programs 1.6 and 1.7 (pages 3-7, 3-8) include actions to implement expedited planning review and processing for
affordable housing projects, including hiring 1.0 Full Time Equivalent staff to oversee housing priorities aligned with meeting the City's RHNA.
(Pages 2-39, 2-40, 2-41) The Housing Element explains that planning entitlements and architecture/site plan review are completed in 1 month for single-family projects, while issuance of building permits may take 5-6 months after approval of planning entitlements. The timing for issuance of building permits is influenced by many factors beyond the City’s control.

Multifamily project applications are lengthier and more detailed, resulting in longer entitlement processing time frames. The processing time for multifamily projects is estimated to be 4-6 months.

The following language was added to clarify that annexation and large subdivision projects may experience lengthier processing timelines:
"Permit processing for large annexation projects can take years and involve extended timelines, for a number of reasons.

Annexations are contingent upon Local Agency Formation
Commission (LAFCO) approval and may require elections.

Other variables include agricultural land impacts; sphere of influence amendments and municipal service reviews;
processing applications through LAFCO; if the annexation is City or landowner-initiated; preparation of planning documents and environmental impact reports; infrastructure analysis;
coordination with neighboring public agencies; the number of landowners; public review and outreach; impacts to City finances; negotiation of development agreements; and litigation.

Many of these factors can also apply to large subdivision projects which result in extended timelines. The Baldwin Ranch Packet Pg. 1581
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North subdivision, which was already within City limits, was processed within approximately two years (2021–2023).

Planning permits were approved in 2023, followed by the issuance of building permits in less than six months. Currently under development, Baldwin Ranch North is a typical processing timeline for large subdivisions within City limits. Part of the Baldwin Ranch North project application also included a development agreement between the developer and the City." (page 2-42).

Keystone’s project application is an example of an annexation influenced by many of the factors mentioned above. The
Zacharias Master Plan was a City-initiated annexation. With the Zacharias Master Plan having been formally annexed in 2024, Keystone’s tentative map application is currently being processed with public hearings to occur in the near future.

Furthermore, the City Council chose to adopt the Master Plan and initiate annexation at its discretion, to add approximately 1,300 acres to City limits with the potential for 5,091 new dwelling units.

7. The Draft Housing Element acknowledges that the City has adequate infrastructure but Staff still refuses to process Keystone’s application unless it agrees to pay the City’s exorbitant new impact fees.

The DHE states that the City has adequate water supplies and wastewater treatment facilities to serve new development. (DHE, pp. 2-52 to 2-53; see also DHE, p. 4-10 [noting that “temporary connections to existing water and wastewater systems in the Keystone Ranch and Lakeside Hills areas are available to support initial phases of development” and that the “City is actively pursuing financing to advance development within the Zacharias Master Plan area.”].) On page A-67, the DHE states the City “plans to use CIP funds to prepare this area for residential development.”
In light of the City’s representations in the DHE regarding the adequacy of water and wastewater infrastructure, why has the City not settled a suit brought by the Patterson Irrigation District and the West Stanislaus Irrigation District against the Master Plan Environmental Impact Report (“EIR”) alleging lack of adequate This comment has been noted. No revisions were made to the Housing Element in response to this comment.

City staff is not authorized to provide comments on active litigation. For individual project applications filed with the City, the City conducts CEQA review at that time, which typically begins with an initial study, as required by CEQA.

All ordinances, resolutions, nexus studies, and other information pertaining to the City’s development impact fees are available for public review.

Development agreement negotiations with the major developers of the Zacharias Master Plan are ongoing. City staff is not Packet Pg. 1582
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water supplies? The DHE is silent as to what form of environmental review will be conducted pursuant to the California Environmental Quality Act (“CEQA”) for this major planning project. We assume that the City intends to rely on the Master Plan EIR at least for the two major developments located in the Master Plan area, e.g., Keystone Ranch and Lakeside Hills. Resolving the litigation and ensuring the validity of the Master Plan EIR thus has some urgency. What other CEQA document is the City planning to rely on for the other developments in the DHE’s Housing Sites Inventory?
And further, why has the City Manager stated that City Staff will not even talk to Keystone about an interim sewer connection until the City and Keystone reach “an agreeable solution” with respect to payment of development impact fees.1 Staff has indicated that “an agreeable solution” equates to Keystone waiving its rights under its SB 330 Preliminary Application and requiring Keystone to pay the City’s newly-proposed higher and unjustified impact fees. If that is not accurate, please explains what it meant by “an agreeable solution.” authorized to disclose information pertaining to active negotiations of development agreements.

Keystone’s tentative map application has been deemed
complete and is being processed, with hearings scheduled in the near future. The Planning Commission and the City Council are the bodies that vote on formal development applications.

City staff is charged with processing applications and making recommendations to its commissions and legislative bodies.

8. The Draft Housing Element’s assumptions about affordable housing units are not reasonable or justified.

In terms of “affordability” assumptions, the DHE assumes—without any explanation or substantiation—that the Master Plan will produce 508 very lowincome units, 315 low-income units, and 604 moderate-income units along with 1,813 above moderate-income units. (DHE, p. 4-3.) The assumed “affordable” units will supposedly be provided by Keystone Ranch and Lakeside Hills. But Lakeside Hills is not even intended to be in the first phase of development of the Master Plan. (Master Plan, p. 115 [identifying Keystone Ranch as Phase 1A and Lakeside Hills as Phase 2B].)
Further, why is the percentage of low-income units supposedly required for Keystone substantially higher than the percentage of low-income units for Lakeside Hills? (DHE, pp. 4-11 to 4-12.) The DHE seems to simply identify two larger developments in the Master Plan and load all of the City’s affordability requirements onto them, without explanation or justification.

As to Keystone Ranch, the DHE assumes that 108 units will be very-low income, 108 units will be low-income, 150 units will be moderate-income, and 353 units will be above moderate-income. (DHE, pp. 4-11, A-62, A-63.) To the contrary, all of Keystone’s units are proposed as market-rate units and Keystone has not This comment has been noted.

Similar to any other development project in the City of Patterson, new development is subject to the City’s Inclusionary Ordinance. (Patterson Mun. Code, § 18.86.)
The Site Inventory capacity assumptions for Keystone Ranch parcels (Site #1) have been revised (see pages 4-9, page 4-12 at Table 4-5). The sites are appropriately sized and zoned to accommodate lower-income units, as per HCD guidance.

The Housing Element Sites Inventory serves as an inventory of available land for potential development during the planning period, along with a capacity analysis of how identified sites could be developed. It does not assume what a developer will build, but demonstrates that the City has zoned adequate sites to accommodate its RHNA based on realistic development
potential.

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expressed any interest nor provided the City any information to indicate that it is proposing to construct affordable housing units—nor has the City previously expressed any intention to impose such affordability restrictions, other than compliance with the City’s existing inclusionary ordinance.

The DHE assumes that 366 of Keystone Ranch’s 716 units will be “affordable.” This equates to more than 50 percent of the Project units. However, the City’s inclusionary ordinance only requires that 15 percent of the units be affordable. (Patterson Municipal Code § 18.86.020.) The affordability assumptions— especially given lack of owner interest—are not reasonable or justified. (Gov.

Code §§ 65583, 65583.2.)
Moreover, the default density assumption of 20 units per acre as needed for lower income households cannot be relied on to assume that Keystone will provide 108 very low- and 108 low-income units. (DHE, p. 4-10; Gov. Code § 65583.2(c)(3).) Keystone’s proposed 216 apartments will be developed at a density of 17.1 units per acre in accordance with the Master Plan. (Master Plan, p. 11.) Further, the default densities pertaining to moderate income households (4-100 units per acre) do not apply because the City is not a metropolitan jurisdiction. (Gov. Code § 65583.2(c)(4).) Instead, Patterson is classified as a suburban jurisdiction.2 No explanation is given or provided for the assumption of moderate-income units assigned to Keystone Ranch.

Finally, the DHE states the City is collaborating with local developers to incentivize affordable housing projects in the Master Plan area in line with lowerincome RHNA goals. (Master Plan, p. 2-14.) Specific details of projects and number of units should be provided.

In closing, Keystone has submitted an application to the City to develop Keystone Ranch, one of the key sites relied on by the DHE’s Housing Sites Inventory. Despite the need for residential development of Keystone Ranch in order to enable the City to meet its RHNA obligations, City Staff has arbitrarily delayed, prolonged, and otherwise refused to process Keystone’s application in a reasonable or straight-forward manner. The City’s delays in processing Keystone’s Project application are posing a major constraint to the development of needed housing in the City. In accordance with the DHE’s statements about the critical importance of providing “expedited review,” we urge the City to process and approve Keystone’s Project application as quickly as possible.

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Thank you for your consideration of Keystone’s comments on the DHE. Please do not hesitate to contact me or Keith Schneider at (209) 892-5727 with any questions regarding this correspondence.

Thank you for your consideration of Keystone’s comments on the DHE. Please do not hesitate to contact me or Keith Schneider at (209) 892-5727 with any questions regarding this correspondence.

This comment has been noted.

As referenced above, revisions were made to the Housing Element based on comments on the text and analysis contained in the Housing Element.

Nov 18, 2022
Public Review
Draft
*Letter sent
directly to HCD
prior to the start of
the Housing
Element update
CEQA timelines David Kellog (Contra Costa County Resident); 350 Contra Costa; Greenbelt Alliance; CaRLA; Scott O’Neil (Palo Alto resident); Watson Ladd (Berkeley resident); Marven Normal (San Bernadino resident); Dara Dadachanji (San Francisco resident); George Grohwin (San Francisco resident)

1. The Housing Element from PATTERSON should include an analysis of compliance in its approval process with PRC 21080.1 & 21080.2.

2. The Housing Element from PATTERSON should add a program to specify (i) who is responsible for making the CEQA determination of PRC 21080.1, specify (ii) that their decision will be made within the timeframe permitted by PRC 21080.2, and specify that (iii), when they determine a project is exempt from CEQA, their determination triggers the Permit Streamlining Act (PSA) 60-day deadline (Gov. Code 65950(a)(5)). If existing local practices or regulations are incompatible with these state laws, the program should commit to enacting reforms necessary to achieve compliance within a reasonable and definite timeline.

This comment has been addressed in Chapter 2, Housing
Constraints Assessment on page 2-45.

February 20, 2025
HCD Initial Draft
Various John R. Beckman, CEO of BIA Greater Valley This comment has been noted.

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1. Notes that the Housing Element is out of compliance and should have been approved prior to January 1, 2024

2. Asks for HCD to not certify the draft Housing Element until the City of Patterson “demonstrates a commitment to solving the state housing crisis”.

April 23, 2025
Revised Draft
Housing Element
(published on
April 16, 2025)
Various Rutan & Tucker, LLP

1. The City Council recently denied Keystone’s housing Project, one of the key opportunity sites identified in the City’s Draft Housing Element.

Keystone acquired the Project site in May 2007 and has been attempting to build housing on the site ever since. The City’s 2010 General Plan identified the Zacharias area for housing and other development and designated it Low Density Residential. (General Plan, pp. II-17, LU-3.)1 But the City subsequently indicated that it would not accept subdivision maps or plans for development in this area until a master plan was adopted.

In August 2022, the City approved the Zacharias & Baldwin Ranch Master Plan (the “Master Plan”) and certified an associated Environmental Impact Report (“EIR”). The Master Plan EIR finds that the Master Plan will decrease water demand by 60 percent compared to the existing agricultural uses and concludes that the Master Plan will not have a significant impact to groundwater supplies. (Draft EIR, pp. 3.15-5 to 3.15-22 [finding Impact US-1 to be less than significant with no mitigation required]; Draft EIR, pp. 3.9-23 to 3.9-26 [finding Impact HYD2 to be less than significant with no mitigation required]; Final EIR, p. 3-70.) The EIR cites the City’s Urban Water Management Plan and the Master Plan’s Water Supply Assessment, both of which find that Patterson has sufficient water supplies to meet the Master Plan’s water demand over the next 20 to 30 years during normal, dry, and multiple dry years. (Draft EIR, pp. 3.15-20 to 3.15-21, 4- 13 to 4-14; Final EIR, pp. 3-39 to 3-40; see also Master Plan, p. 97 [Table 8 shows sufficient supplies for Project water demand currently and in future years].)
As to storm drainage, the Master Plan EIR noted that each development site would construct its own stormwater retention/detention basin that would ultimately be routed to the Zacharias Recharge Basin. (Draft EIR, pp. 2-9 to 2- 11, 3.9-28 to 3.9-29, 3.15-25 to 3.15-26.) The Zacharias Recharge Basin is described in the Master Plan and EIR as a single-basin supplied by stormwater runoff from Master Plan developments. The Master Plan indicated that all backbone infrastructure (storm drain, water, sewer and transportation) would be funded through a Community Facilities District (“CFD”) that the City was obligated to form as part of the approvals of the Master Plan. (Master Plan, pp.

The matrix was prepared by HCD staff in response to the Initial Draft Housing Element and utilized to show where revisions were made in response to HCD preliminary comments.

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93, 113-114; Master Plan Condition No. 41; Memorandum of Understanding between City and Stanislaus County dated May 2, 2023.) Keystone is and remains committed to paying its fair share of the backbone infrastructure identified in the Master Plan and Master Plan EIR for the Master Plan area, including the Zacharias Recharge Basin.

Keystone’s Project consists of approximately 719 housing units located on an approximately 95 acre site in the southeast portion of the Master Plan area, adjacent to existing development to the south and east. The Project is comprised of 506 single-family residential units and 213 multi-family residential units. The Project has an estimated potable water demand of 138 acre feet per year (“afy”). The Master Plan and EIR included a phasing plan with the Project being the first to develop, and noting that the “phasing plan reflects the economic factors associated with the costs of new infrastructure and, therefore, the areas that require the least costly infrastructure would develop first.” (Draft EIR, p. 2-13; see also Master Plan, p. 114 [“The phasing of the infrastructure will be planned so that initial project construction will not be burdened with construction of improvements not needed until later in the project build-out.”].) The Master Plan specifically refers to Keystone Ranch as an area to be “developed prior to the installation of the major storm drain facilities (lakes, FEMA basin, and recharge basin) . . ..” (Master Plan, p. 98.) Keystone submitted a SB 330 Preliminary Application for the Project on November 6, 2023. The City reacted very negatively to this submittal. City Staff refused to acknowledge its validity of it due to the then-pending annexation of the Master Plan area. The City questioned whether SB 330 applied to the Project because it was not an urban, infill site. City Staff and officials told Keystone that it would pay more in fees than other developers if it were to proceed under SB 330. The City even canceled a scheduled election on the annexation until Keystone and other Zacharias stakeholders agreed to fund a series of public improvements for the benefit of the Ivy-Rose neighborhood. At the hearing where the City Council denied the Project, the Mayor claimed that Keystone was seeking preferential treatment by submitting a SB 330 Preliminary Application.

Keystone attempted to submit its application for a vesting tentative map (“VTM Application”) for the Project to the City on April 17, 2024. City staff refused to even receive the application, saying that they were instructed by “higher ups” not to accept it until the annexation was finalized. Staff’s position in this regard violated the Subdivision Map Act, which allows subdividers to submit applications for subdivisions on land proposed to be annexed to a city. (Gov.

Code § 66454.) Keystone sued, and the City relented and accepted the VTM Packet Pg. 1587
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Application. However, Staff proceeded to issue three (3) incompleteness letters that violated the Permit Streamlining Act and State Housing Laws by citing information not on the City’s submittal requirement checklist, inapplicable and subjective design standards, and new information not in the first incompleteness letter. (Gov. Code §§ 65943(a)-(b), 65589.5(h)(6)(F).) None of the incompleteness letters raise any issues related to the adequacy of water supplies or infrastructure.

On November 15, 2024, Keystone appealed the application incompleteness determination on the grounds that it violated the Permit Streamlining Act and amounted to a denial of the Project under the Housing Accountability Act. On December 20, 2024, the City reversed course and deemed the VTM Application “sufficiently complete” for processing. On February 20, 2025, the City’s Planning Commission recommended “approval” of the VTM Application but with 159 conditions of approval—including a moratorium on development until the estimated $20 million City of Patterson Percolation Ponds for Stormwater Capture and Recharge (“City Perc Pond Project”) was fully funded by developers and substantially complete. The City Council purported to impose these same conditions of approval on the Project. (Patterson City Council Staff Report, April 1, 2025, Item 8.1.a [the “Staff Report”], p. 176 [“The City will require developers of the Master Plan Area to fully fund and construct the [City Perc Pond Project] . . . before building permits are issued for the Master Plan Project.”]; Staff Report, p. 177 [City Perc Pond Project “must be funded and constructed prior to the issuance of building permits”]; VTM Application Condition No. 4 at Staff Report, p. 208 [“Prior to issuance of the first building permit in the Master Plan areas, the [City Perc Pond Project] shall be sufficiently completed for the delivery of water for recharge at the Del Puerto Creek Project location.”].)
The July 2024 Delta Mendota Groundwater Sustainability Plan (“GSP”) describes the City Perc Pond Project as a City water supply project to be supplied with stormwater from Del Puerto Creek and to be implemented by 2040, with an estimated cost of $7.8 million to be funded by State Grant Funds and the City of Patterson.3 (GSP, Table PMA-2, p. 5; see also GSP, p. 300 [referring to project/management actions as being funded through local GSA funds or future grant opportunities] and GSP, Table PMA-1, p. 9 [further noting that “[i]mplementation of this project may be phased such that the ponds are constructed over a number of years.”].) A mere nine (9) months later, in its proposed conditions of approval on the Project, the City attempted to impose all of the costs of this major improvement project, which it now estimates to cost nearly $20 million and require immediate implementation, onto the Keystone Packet Pg. 1588
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Ranch Project.4 Unlike the single-basin Zacharias Recharge Facility to be supplied by stormwater from new development, the City Perc Pond Project is described as four recharge basins to be supplied by stormwater from Del Puerto Creek and from surface water purchased from the Irrigation Districts.

Even though the Master Plan EIR found that the Master Plan development would have no significant impacts to groundwater supplies, the conditions also required Keystone to purchase surface water to “offset” the water demands of new development. No such condition or mitigation was contained in the Master Plan or Master Plan EIR. As recently as January 3, 2025, the City’s Community Development Director notified responsible agencies that the VTM Application was being scheduled for hearing based on the Master Plan EIR (and mitigation measures contained therein). Further, in a July 17, 2023 letter to the Stanislaus Local Agency Formation Commission, the City Attorney wrote that a condition requiring the Zacharias stakeholders to “purchase and deliver additional surface water supplies . . . is unnecessary because the Project does not adversely impact the basin’s groundwater supply.”5
In light of Keystone’s objection to fully fronting the $20 million cost of the City Perc Pond Project, refusal to pay for surface water to “offset” its minimal groundwater demand, and opposition to delaying implementation of its Project for at least five (5) plus years, the City Council voted to deny the VTM Application at its April 1, 2025 meeting.

On April 2, 2025, the day after the City Council denied the Project, City Staff had a conversation with HCD Staff to discuss the City’s Housing Element. A matrix prepared by City Staff indicates HCD’s comments and the City’s responses.

Nowhere does the Staff disclose that the City Council had just denied the Keystone Ranch Project or imposed a five (5) year water moratorium on development in the Zacharias Master Plan area. Instead, in response to HCD’s comment on the status of development in the Master Plan, Staff simply states:
“Tentative maps not yet recorded for either Zacharias or Baldwin Ranch South Master Plan areas.” Staff goes on to state that the realistic capacity for the Master Plan area is based on the Master Plan. The realistic capacity of the Master Plan should be assumed to be zero based on the City’s recent action denying the Keystone Ranch Project and imposing a minimum five (5) year moratorium on development in the Master Plan area.

2. The alleged infrastructure constraints in the RDHE contradict the information in the November 2024 Public DHE and February 2025 HCD DHE and completely undermine the requirement that Housing Opportunity A. The sites on the inventory are suitable and available. The City is working collaboratively to address water supply constraints.

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Sites (including the Keystone Ranch and Lakeside Hills projects) be “suitable” and “available” for development.

The City is relying on the 719 units Keystone Ranch Project and another Master Plan development—the 2,521 unit Lakeside Hills project—to meet almost all of its Regional Housing Needs Allocation (“RHNA”) of 3,716 units. (RDHE, pp. 3- 17, 4-16 to 4-17, Figure A-1, Figure A-23, and Table A-3.) Yet, in its latest draft of the Housing Element, the City revised portions of the prior Housing Element to claim that instead of having sufficient water supplies and infrastructure to serve new development (as substantiated by, among others, the Master Plan and EIR), it lacks such supplies and infrastructure. As a result, the RDHE does not contain sites that are “suitable” and “available” for development as required by State law.
a. State law requires the Housing Element contain an inventory of sites that are suitable and available for development.

By law, the City’s Housing Element must include an inventory of land suitable and available for residential development to meet the City’s regional housing need by income level. (Gov. Code §§ 65583, 65583.2.) “The housing element must identify specific sites or parcels that are available for residential development. Land suitable for residential development must be appropriate and available for residential use in the planning period.” (Inventory of Suitable Land, California Department of Housing and Community Development (last visited April 22, 2025), https://www.hcd.ca.gov/planning-and-communitydevelopment/housing-elements/building-blocks/inventory-of-land-suitable.) “A thorough sites inventory and analysis will help the locality determine whether program actions must be adopted to ‘make sites available’ with appropriate zoning, development standards, and infrastructure capacity to accommodate the new construction need.” (Id.) “The inventory of land suitable for residential development shall be used to identify sites that can be developed for housing within the planning period.” (Id.)
Through its revisions to the RDHE, the City has made two of the major projects relied on by its Housing Sites Inventory—Keystone Ranch and Lakeside Hills— not “suitable” and not “available” for residential development within the Sixth Cycle. The City has done so by precluding construction of these housing development projects until the $20 million City Perc Pond Project is fully funded and substantially completed. By the City’s own estimates, this will not occur until October 2030, at the very earliest. As a result of these revisions, there are insufficient sites to accommodate the housing allocation for each income category in the City’s Sixth Cycle Housing Element.

B. The City prepared the Draft Housing Element in good faith.

The City has identified numerous actions to address water supply constraints. Water for affordable units will be prioritized.

C. This comment has been noted. Revisions were made in
Chapter 3 to Program 1.14 (page 3-17) and Chapter 4 (page 4- 11; 4-22; and 2-56) to clarify that the Groundwater Sustainability Program applies the entire Master Plan area.

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b. The November 2024 Public DHE and February 2025 HCD DHE both confirmed that there were no major constraints on development and that adequate water supplies exist.

In earlier versions of the Housing Element, including the one circulated for public review in November 2024 and the one provided to HCD in February 2025, the City reported that the Master Plan area “faces few development limitations, as it is already annexed, vacant, and ready for construction.” (HCD DHE, p. 4-14; Public DHE, p. 4-10.) It identifies challenges with securing funding for water and wastewater infrastructure for Master Plan build-out, but notes that “temporary connections to existing water and wastewater systems in the Keystone Ranch and Lakeside Hills area are available to support initial phases of development.” (HCD DHE, p. 4-14 and Public DHE, 4-10; see also HCD DHE, p. 4-10 and Public DHE, p. 4-9 [“temporary sewer connections will be provided to support early phase development, with the funds collected from these connections dedicated to the infrastructure expansion project” and “[p]otable water and wastewater services are available to commence project development through temporary utility connections.”].) As a result, the prior versions of the Draft Housing Element stated that commencement of these housing projects will commence in the Summer and Fall of 2025. (HCD DHE, p. 4-7; Public DHE, p. 4-8.) The City’s November 2024 and February 2025 versions of the Housing Element also observe that “Patterson has sufficient water supplies to meet projected demand through 2045” and therefore the City “has sufficient water to serve all identified pipeline projects and identified housing opportunity sites.” (HCD DHE, p. 4-23; Public DHE, p. 4-21.) Those versions of the Housing Element cite the City’s 2020 Urban Water Management Plan (“UWMP”), which “indicates that Patterson has sufficient water supplies to meet . . . projected water demands over the next 20 years.” (HCD DHE, p. 2-50; Public DHE, p. 2-

52.) Likewise, the HCD DHE notes that the City’s UWMP and Capital Improvement Plan “ensure sufficient wastewater capacity through 2045, with no current capacity issues” and that the City’s “wastewater infrastructure will not pose a constraint to meeting RHNA obligations during the 6th Cycle planning period.” (HCD DHE, p. 4-23 and Public DHE, p. 4-22; see also HCD DHE, p. 2- 51 and Public DHE, p. 2-53 [noting “wastewater infrastructure availability is not expected to be a constraint on residential development during the 6th Cycle planning period.”].)
The City’s prior versions of the Draft Housing Element state that Patterson is a stakeholder in the Delta Mendota Subbasin Groundwater Sustainability Plan (“GSP”), which aims to achieve groundwater sustainability by 2040. (HCD DHE, p. 2-56; Public DHE, p. 2-52.) It states that as part of the GSP, “Patterson is Packet Pg. 1591
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responsible for the Percolation Ponds for Stormwater Capture and Recharge Project . . ..” (HCD DHE, p. 2-56; Public DHE, p. 2-52.) As previously noted, the GSP identifies that project as a Tier 3 project, estimated to be operational by 2040, depending on grant funding and environmental review. (GSP, Table PMA1, p. 9 and Table PMA-2, p. 5.) c. The April 2025 RDHE claims that sufficient water supplies do not exist, at least for Keystone and other Zacharias stakeholders.

The RDHE directly contradicts, retracts, and refutes the above statements about the sufficiency of infrastructure and water supplies contained in the November 2024 Public DHE and the February 2025 HCD DHE. While those drafts reported to the public and HCD that the Zacharias Master Plan “faces few development limitations,” the RDHE now claims the area “faces development limitations.” (RDHE, p. 4-19.)7
The RDHE claims the limitations are due to “developer accountability to contribute fair funding to expand potable water and wastewater infrastructure.” (RDHE, p. 4-19.) This is not true, at least as to Keystone. Keystone stands ready, willing, and able to fund its fair share of the backbone infrastructure improvements identified in the Master Plan and Master Plan EIR. What Keystone is not willing to do is completely advance funding for larger City improvements with no essential nexus or rough proportionality to the impacts of its development. Specifically, Keystone refuses to fully fund a 3,000 afy recharge facility to “offset” the Project’s 138 afy per year of potable water demand. In the RDHE, the City struck the language about Patterson being responsible for the City Perc Pond Project. (RDHE, p. 2-56.) But the controlling GSP continues to list the City Perc Pond Project as a City project to be supplied with stormwater from Del Puerto Creek and to be implemented by 2040, not 2030 as now claimed by the City. (GSP, Table PMA-1, p. 9 and Table PMA-2, p. 5.) The RDHE cites demand data from the UWMP, but then strikes the next sentence stating that the “plan indicates that Patterson has sufficient water supplies to meet these projected demands over the next 20 years.” (RDHE, p. 2-56.) The adopted UWMP continues to say this irrespective of City Staff striking this sentence from the Housing Element.

The RDHE claims that under the GSP, there is “a pumping reduction plan in effect which requires the City to reduce its groundwater pumping to 2,626 acrefeet per year by 2030.” (RDHE, pp. 2-56, 3-20.) This is not true. The GSP does refer to pumping reduction plan that the agencies adopted to achieve a collective reduction in existing overdraft pumping by 42,000 afy. (GSP, pp. 291, 321; Table PMA-1, p. 6.) For the Northern-Delta Mendota Region as a whole, the reduction in overdraft pumping needed by 2030 is 9,023 afy. (PRP, p. 3.) Packet Pg. 1592
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Patterson’s share of this pumping reduction is 460 afy. (Id.) There is no reference to the City Perc Pond Project or to any recharge facility in the PRP let alone to any reduction in groundwater pumping to 2,626 acre feet per year by 2030. Nor does the GSP or PSP pose any constraint on development as incorrectly stated on page 4-34 of the RDHE.

Further, the City Perc Pond Project is a water supply project, not a pumping reduction project. And it was not included as an infrastructure improvement in the Master Plan, contrary to the statements on pages 2-56 and 4-12 of the RDHE. The infrastructure improvement in the Master Plan was the Zacharias Recharge Basin. The Master Plan calls for development of the Zacharias Recharge Basin to provide storm drain recharge and flood control to the Master Plan area. (Master Plan, pp. 1, 3, 9-11, 97-100.) The Zacharias Recharge Basin was to be supplied with stormwater from the Master Plan area, not with surface water purchased from the Irrigation Districts or from stormwater from Del Puerto Creek. (Draft EIR, pp. 2-10, 3.9-29, 3.15-26.) And contrary to the estimated $20 million price tag for the City Perc Pond Project, the Zacharias Recharge Basin was estimated to cost $2.1 million.

The other options the City claims to be “exploring” include requiring new development to purchase surface water to “offset” its demand through recharge if and when the City Perc Pond Project is completed,8 contribute to an evaluation of the redesign of the stormwater infrastructure for the Black Gulch Drainage Area, apply for funding for design of the City Perc Pond Project, implement a recycled water program, and prioritize conservation. (RDHE, p. 2-

57.) While these are described as options the City is exploring, the City Council denied the Keystone Ranch Project because it would not agree to the City’s demand that it fully fund the The RDHE claims that “groundwater demand underlying potable water service in the City will need to be offset by groundwater recharge through the Del Puerto Creek Recharge Project” and that “[d]evelopers in the Zacharias Master Plan Area will be required to contribute their fair share of financing for the recharge project.” (RDHE, p. 4-12.) But in the RDHE, the City purports to exempt the Baldwin Ranch South project from the requirement to pay for the City Perc Pond Project even though that development is part of the same Master Plan and covered by the same EIR. (RDHE, pp. 3-17, 4-19 to 4-20, 4-22, 4-36, A-69.)9 Such a purported carve-out is directly contrary to the statements made by Staff in its April 1, 2025 report to the City Council on the Keystone Ranch Project. (See Staff Report, p. 176 [“The City will require developers of the Master Plan Area to fully fund and construct the Del Puerto Creek Capture and Recharge Project . . . before building permits are issued for the Master Plan Project.”] and Packet, p. 177 [City Perc Pond Project “must be funded and Packet Pg. 1593
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constructed prior to the issuance of building permits”].) The City made similar statements in the Settlement Agreement with the Irrigation Districts to impose the obligation to “fully fund” the City Perc Pond Project on “developers of the Baldwin Master Plan/Zacharias Master Plan Project” and to not issue any building permits “for the Baldwin Master Plan/Zacharias Master Plan Project” until the City Perc Pond Project is “sufficiently completed.” (Settlement Agreement, p. 3.)
The City states that it needs to reduce pumping by 2,626 afy by 2030. (RDHE, pp. 2-56, 3-20.) As noted above, there is nothing in the GSP or PRP to support this statement. Even if it were supported, this obligation would apply equally to all development, existing and new, including Baldwin Ranch South. Yet, the RDHE states the pumping reduction requirements apply only to Zacharias. (RDHE, p. 3-18.) The City should explain and justify through substantial evidence why there is water for some new developments but not others.

Moreover, there is no recognition or acknowledgment in the RDHE of the EIR’s conclusion that the Master Plan will reduce pumping by 3,225 afy. (Final EIR, p. 3-70.)
The RDHE also purports to strike declaratory statements in the Public DHE and HCD DHE that temporary water connections are available for Keystone Ranch and Lakeside Hills, two of the key sites in the Housing Sites Inventory. (RDHE, pp. 4-19.) Instead now, the temporary water connections are conditioned on Keystone and other Zacharias stakeholders (but apparently not Baldwin Ranch South or any other developers) fully funding the City Perc Pond Project.10 (RDHE, p. 4-19.) The City claims that it will complete infrastructure improvements (including presumably the City Perc Pond Project) by December 2028. (RDHE, p. 3-21.) But, in its agreement with the Irrigation Districts, the City estimates the timing to be October 2030, at the earliest. (See also Staff Report, p. 177 [city will use best efforts to ensure completion of City Perc Pond Project by 2030].) The City has precluded and prohibited Zacharias development from moving forward until the City Perc Pond is substantially completed. Moreover, as a market reality, lower income units will not be built in advance of market-rate units as stated on RDHE page 3-19. These assumptions do not reflect reality.

As to sewer, the RDHE continues to indicate that the City has initiated the planning process to expand the existing wastewater systems, but then strikes the language about the City actively exploring funding sources to secure a construction contract for these expansions or to seek financing to support the broader development efforts within the Master Plan area. (RDHE, p. 4-11.) Even though the Master Plan EIR found the Master Plan would have no significant impact to wastewater (Draft EIR, pp. 3.15-22 to 3.15-24), the RDHE inexplicably Packet Pg. 1594
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requires Zacharias development to fund a sewer upgrade to serve the entire Master Plan area. (RDHE, p. 4-12.) This requirement is inconsistent with the Master Plan EIR and imposes a significant and unnecessary constraint on development.

In terms of phasing, RDHE struck language about Keystone Ranch being planned for the first phase of development and also the text about early stages not being burdened with infrastructure required for later build out stages. (RDHE, p. 4-12.) Those statements still exist in the Master Plan and Master Plan EIR, irrespective of Staff removing them from the Housing Element. (See Master Plan, pp. 114-115 [identifying Keystone Ranch as the first to develop and noting that “[t]he phasing of the infrastructure will be planned so that initial project construction will not be burdened with construction of improvements not needed until later in the project build-out”]; Master Plan, p. 98 [identifying Keystone Ranch as an area to be developed “prior to the installation of the major storm drain facilities (lakes, FEMA basin, and recharge basin) . . ..]; and Draft EIR, p. 2-13 [identifying Keystone Ranch as among the first to develop and noting that the “phasing plan reflects the economic factors associated with the costs of new infrastructure and, therefore, the areas that require the least costly infrastructure would develop first.”].) More fundamentally, the only Zacharias developments included in the Housing Sites Inventory are Keystone Ranch and Lakeside Hills.

3. As evidenced by its denial of the Keystone Ranch Project on April 1, 2025, the City is not committed to approving additional housing development.

The statement that the City “is continuing to work with the developer on the vesting tentative maps” is not true or accurate. (RDHE, p. 4-8.) The City denied the Keystone Ranch Project on April 1, 2025 after delaying it for years. The RDHE should be updated to reflect the City’s denial of the Keystone Ranch Project. (RDHE, pp. C-9 to C-10.)
Likewise, the actions the City claims it is undertaking to ensure prompt development of Keystone Ranch and Lakeside Hills ring hallow. (RDHE, p. 3-

19.) For instance, the City contends that it will conduct outreach with property owners. Yet City Staff and officials refused to meet with Keystone representatives to discuss the VTM Application.

The claim that fees will be reduced and permitting processes expedited also does not reflect Keystone’s reality. (RDHE, p. 3-19.) The RDHE admits that Patterson “has the highest total fees for single-family and multi-family dwellings among nearby jurisdictions,” with fees of $60,000 per single-family unit, which is This comment has been noted.

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approximately 50 percent higher than the next highest jurisdiction in Stanislaus County. (RDHE, pp. 2-41 to 2-42.)
Keystone has been trying to get its Project approved for over 15 years—the City Council denied it on April 1, 2025. The City refused (and continues to refuse to acknowledge) the validity of Keystone’s SB 330 Preliminary Application by imposing the City Perc Pond Project cost and other fees and charges not in effect when the Preliminary Application was submitted, adding an estimated $40 million in costs to the Project. City Staff would not meet or offer technical assistance on navigating regulatory requirements. At the hearing where the City Council voted to deny the Project, the Mayor claimed that Keystone was seeking preferential treatment by submitting a SB 330 Preliminary Application.

Finally, in response to Keystone’s comments on the Public DHE that the City must adopt and apply objective development standards to all housing development projects, not just multi-family housing projects, the response by City Staff was comment noted. (RDHE, p. C-7.) This is not sufficient. The City must revise the Housing Element to commit to adopt objective development standards applicable to all residential development, as required by law. (Gov.

Code §§ 65589.5(j), 66300(b)(1)(C).)
May 29, 2025
Revised Draft
Housing Element
(published on
April 16, 2025)
YIMBY Law
Dear Housing Accountability Unit,
YIMBY Law is a 501(c)3 non-profit corporation, whose mission is to increase the accessibility and affordability of housing in California. YIMBY Law sues municipalities when they fail to comply with state housing laws, including the Housing Element Law.

I write to express concerns with the City of Patterson’s April 16, 2025 Housing Element Draft, submitted to the Department of Housing & Community Development on May 5, 2025. Its actions and commitments are irreconcilable, indicating a clear lack of candor with the Department that, if left unchanged, cannot support a finding of substantial compliance with state law.

The City’s recent April draft update stands in glaring contrast with the City’s many previous public representations about its ability to provide more housing without constraints based on water supply or groundwater. The City of Patterson would have HCD believe that between February 2025 – when the City submitted its first (overdue) draft Housing Element Update, which stated that the City had no water supply or infrastructure constraints on providing new housing – and April 2025 when the City submitted the current draft, Patterson abruptly suffered a drought of disastrous proportions, but not one that will affect housing in any The City prepared the Draft Housing Element in good faith and has since updated it to more accurately reflect the current status of water availability for future development. To address water supply constraints, the City is actively implementing a range of strategies outlined in Programs 1.14 and 1.15. These include aggressively pursuing funding opportunities to construct essential infrastructure, providing flexibility in permit timing and infrastructure phasing, requiring developers to contribute fair share payment toward necessary infrastructure improvements, and coordinating annually with property owners and developers to accelerate residential development. These efforts are designed to address water supply challenges while prioritizing and facilitating the development of new housing. The Public Works Department has recently secured substantial funding to help resolve water supply challenges, and the Community Development/Planning Division remains committed to pursuing additional funding opportunities and supporting developers in securing project-specific resources.

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way – other than the large Zacharias & Baldwin Master Plan area that the City is relying on to meet most of its current RHNA obligations.

Local governments are required to identify and mitigate constraints to development via their Housing Elements. Patterson’s February 2025 draft Housing Element Update identified no inadequacies from water supply. This was further attested to in the 2022 Zacharias & Baldwin Ranch Master Plan Environmental Impact Report, which found no significant impacts to water supply from development in the area. Indeed, in seeking LAFCO approval for the annexation of the Master Plan area in July 2023, the City affirmatively refuted any questions about possible adverse impacts of new housing development on water supply and groundwater.

What changed between February 2025 and April 2025 was the project sponsors refusing to pay $20 million for a new City water supply project. The Keystone Ranch proposal would bring 719 units of single and multi-family housing to the City, and was denied by the City Council on April 1st for declining to fund a $20 million project that previous city documents stated was unnecessary. On April 1, 2025, Patterson’s City Council denied the development, stating the City needs at least a 5 year moratorium on new housing development (but not apparently on commercial or industrial development) in order for the private housing proponents to construct new City recharge facilities to address a suddenlyclaimed “water shortage.” Remarkably, the City Staff and Planning Commission had just unanimously recommended conditional approval of the Keystone Ranch housing development in February 2025.

Therefore, the vast majority of sites identified in the April draft are now unbuildable until at least 2030. As cities are obligated to identify constraints to housing, they are also obligated to identify adequate sites to accommodate their RHNA. Patterson is either unable to properly identify constraints to development, or unable to identify sites that are adequate for housing. In either reality, its efforts are not substantially compliant with state housing law.

The City of Patterson is placing its compliance on inherently contradictory principles: it has adequate water for sites that cannot be developed without a $20 million facility. Its officials have identified all significant constraints to development, other than ones that would prevent anything from moving forward until at least 2030. Without seriously reconsidering its draft Housing Element or its practices towards development proposals, I respectfully submit to your staff that Patterson’s Housing Element cannot be found in compliance with state law, substantial or otherwise.

May 29, 2025 YIMBY Law These comments have been noted.

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Appendix C Public Participation and Outreach C-25 EMC Planning Group City of Patterson 6th Cycle Housing Element HCD Revised Draft October 2025 2 See CA Gov. Code § 65943(a)-(b) and § 65589.5(h)(6)(F). 3 CA. Gov Code § 65589.5(h)(6)(D).
4 Patterson City Council Staff Report, April 1, 2025, Item 8.1.a [the “Staff Report”], p. 176 [“The City will require developers of the Master Plan Area to fully fund and construct the [City Perc Pond Project] . . . before building permits are issued for the Master Plan Project.”]; Staff Report, p. 177 [City Perc Pond Project “must be funded and constructed prior to the issuance of building permits”]; VTM Application Condition No. 4 at Staff Report, p. 208 [“Prior to issuance of the first building permit in the Master Plan areas, the [City Perc Pond Project] shall be sufficiently completed for the delivery of water for recharge at the Del Puerto Creek Project location.”]; Staff Report, pp. 223-224 [listing impact fees that are approximately $20,000 to $30,000 more per unit than those fees in place when the SB 330 Preliminary Application was submitted.]
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Revised Draft
Housing Element
(published on
April 16, 2025)
Dear Patterson City Council,
We are pleased to submit this letter of support of the proposed Keystone Ranch project. YIMBY Law is a 501(c)(3) non-profit corporation, whose mission is to increase the accessibility and affordability of housing in California. YIMBY Law closely monitors projects to ensure that all relevant state laws are properly applied, including the Housing Accountability Act and AB 1633. Should the City fail to follow these laws, YIMBY Law will not hesitate to file suit to ensure state housing policies are enforced.

The Keystone project will consist of 719 units of housing, comprising 506 singlefamily and 213 multi-family units. California Government Code § 65589.5, the Housing Accountability Act, prohibits localities from denying housing development projects that are compliant with the locality’s zoning ordinance or general plan at the time the application was deemed complete, unless the locality can make findings that the proposed housing development would be a threat to public health and safety.

Fully aware that Patterson could make no such findings, Patterson’s officials have resorted to lying and breaking the law to prevent this project from moving forward. It was only after a lawsuit that the City accepted the vesting application at all. That application was met with three incompleteness determinations, based upon items not included in the submission checklist, new information that was not mentioned in prior incompleteness letters, and subjective design standards that are not applicable. All such denials were illegal under California law.2 Explicitly, a city denies a project when it “fails to cease a course of conduct undertaken for an improper purpose, such as to harass or to cause unnecessary delay or needless increase in the cost of the proposed housing development project, that effectively disapproves the proposed housing development project.”3
After an appeal, the application was deemed complete, only to be met with $40 million in fees and 159 conditions of approval as a measure to illegally make the project unbuildable.4 Conditioning a project so that it is infeasible amounts to a denial under the HAA. Many of these fees and conditions apply to water Packet Pg. 1598
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7 Pub. Res. Code § 21166; CEQA Guidelines § 15162.

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infrastructure that, curiously, City documents stated would be unnecessary until this project came before the Council. The governing Zacharias & Baldwin Ranch Master Plan Environmental Impact Report (EIR) stated that there would be no significant impacts to groundwater supplies. The draft Housing Element staked a substantial portion of the RHNA on this site, and raised no issues with water supply. A July 2024 report stated Patterson would construct its separate City Perc Pond Project via other state and local funding sources for only $7.8 million.5 Many of these new conditions were not in place at the time of the project’s preliminary application, in further violation of SB 330’s protection of vesting rights.6
The contradictions between these statements and those to HCD threatens Patterson’s compliance with state law, which will subject it to the Builder’s Remedy until it reconciles its statements with its actions. Greater consequences come the longer Patterson uses illegal means to forestall this project. The City could face severe penalties from a finding of bad faith, on top of being found responsible for attorney’s fees and court costs for an improper denial.

Among the new conditions applied to this project is the request for a supplemental EIR, despite a finalized EIR for the Master Plan. CEQA only allows revisions to completed EIRs where there are substantial changes to the project or new information is discovered which was not, and could not, have been known originally.7 Deciding that individual public officials don’t like a specific proposal is not a legal reason to call for a new EIR. This project has been in process for many years before, during, and after the prior EIR was completed and certified.

Faced with an application that complies with local zoning and state land use laws, and has its own funding, materials, land, and project proponent willing to bring much needed housing to the city of Patterson, city officials waste innumerable staff resources and tax dollars to break the law and stop it from being built. Under California law, you must approve the application, or else make findings to the effect that the proposed project would have an adverse impact on public health and safety based on written standards in effect when the application was deemed complete. Should Patterson and its officials fail to Packet Pg. 1599
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comply with the law, YIMBY Law will not hesitate to take legal action to ensure that the law is enforced. I am signing this letter both in my capacity as the Executive Director of YIMBY Law, and as a resident of California who is affected by the shortage of housing in our state.

August 13, 2025
Revised Draft
Housing Element
(published on
August 6, 2025)
Public Participation Rutan & Tucker, LLP

1. Failure to comply with statutorily-required public participation procedures.

As a preliminary matter, the City has failed to comply with the public noticing procedures associated with the public review of Draft Housing Elements.

Government Code Section 65585(b) (1) plainly requires that for any subsequent revisions to a draft Housing Element, “the local government shall post the draft revision on its internet and shall email a link to the draft revision to all individuals and organizations that have previously requested notices relating to the local government’s housing element at least seven days before submitting the draft revision to the department.” HCD further informed the City of this requirement in its May 2, 2025 comment letter to Bryan Stice on the City’s previous draft Housing Elements (“HCD Letter”). (HCD Letter, p. 2 [further noting that “[p]ublic participation in the development, adoption and implementation of the housing element is essential to effective housing planning.”])
In my April 23, 2025 comment letter to you, I specifically asked to be included “on the notification list for any correspondence to and from HCD regarding the Patterson 6th Cycle Housing Element and for any subsequent drafts of the Housing Element. Despite this request, the City failed to email me the August 6th RDHE. I found it by happenstance when reviewing the City’s website. At minimum, the City cannot proceed with providing the RDHE to HCD without first providing the proper notice to me and other interested parties that requested it.

Moreover, the City’s response to our April 23, 2025 letter is woefully inadequate.

In response to my 12-page letter with detailed comments on the deficiencies in the April DHE, the City’s primary response is: “Comment Noted.” It claims in a conclusory fashion that the sites on the inventory are “suitable and available” and that it is “working collaboratively to address water supply constraints.” There is no evidence, let alone substantial evidence, to support that claim. It notes that the RDHE clarifies that the GSP “applies to the entire Master Plan area.” The GSP applies to the entire City. Indeed, at the April 1, 2025 City Council hearing, Gage Marchini, an attorney with the City Attorney’s office, admitted that the GSP (and associated regulations) apply to “any new development.” In reality, as evidenced by its approval of non-residential projects and its denial of the The City has extended the public review period by seven days— from August 15 through August 22—and updated the Housing Element webpage to reflect this change. In addition, the City has issued email notices to all interested parties to address the earlier oversight.

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Keystone Ranch housing Project, the City is selectively enforcing the GSP on just one housing developer—Keystone Ranch.

Constraints 2. Comments on Chapter 2-Housing Constraints Analysis In added text on pages 2-44 to 2-45, the RDHE states that projects located in areas with limited or no existing infrastructure “require extensive improvements to support new development. These projects face longer timelines, higher costs, and necessitate financing from developers due to the need to construct major infrastructure components such as water, sewer, electrical, and roadway systems.” In contrast, it states that a project like Villages of Patterson (“VOP”) is situated near existing infrastructure allowing it to connect to existing systems. As far we know, VOP is not connected to or situated near any existing recharge basin.

In denying the Project, the City cited to and relied on the GSP. It stated that under the GSP, it was under a mandated pumping reduction program such that it could not authorize additional pumping for any project unless and until that project offset its groundwater use, such as by purchasing surface water and recharging that water. If the City’s position is that these new water measures apply because of the GSP, then all new developments must adhere to these requirements, not just some. As noted above, Mr. Marchini acknowledged this point at the April 1st hearing on the Keystone Ranch Project.

The RDHE states that the Del Puerto Creek Project (also known as the City Perc Pond Project) was included as part of the Master Plan. (RDHE, pp. 2-54, 3-23, 4-14.) This is not true. There is no reference whatsoever to the Del Puerto Creek Project in the Master Plan. Instead, the Master Plan describes the Zacharias Recharge Basin, a single basin proposed to capture stormwater from Zacharias development only. (Master Plan, p. 98 [further noting that the Keystone Ranch Project can proceed in advance of that recharge facility].) By comparison, the GSP describes the City Perc Pond Project as a Tier 3 project (not needed until 2040), to be supplied by stormwater runoff from Del Puerto Creek, and to be funded by the City and State grant funds. (GSP, Chapter 15, Table PMA-1, p. 9 and Table PMA-2, p. 5.)
It is evident the City is attempting to coopt and convert the proposed Zacharias Recharge Basin—a single basin proposed to capture and recharge stormwater from Zacharias developments only—and expand it into the four-basin Del Puerto Creek Project to recharge surface water from all new development, while trying to get Master Plan developers to pay for it. (See, RDHE, p. 2-54 [require “water demand from future developments to be offset by the purchase of surface water which will be diverted for recharge in the Del Puerto Creek Project basins” and The Groundwater Sustainability Plan (GSP) for the Northern & Central Delta-Mendota Region is available here -
https://deltamendota.org/final-gsp-documents/
The Northern Delta-Mendota Region Pumping Reduction Plan (PRP) is available here -
https://www.stancounty.com/er/groundwater/pdf/Northern-DeltaMendota-Region-Pumping-Reduction-Plan.pdf The City is subject to the requirements of the GSP and PRP, which require reductions to groundwater pumping. The City is in the process of developing clear policies for how new
development can meet the requirements of the GSP and
identifying alternative water supply options.

Housing Element Program 1.15 Water Supply to Development addresses the Groundwater Sustainability Plan.

City master plans and corresponding environmental impact reports (for example, the Zacharias/Baldwin Ranch Master Plan) identify specific projects and mitigation measures required for new development, including the specific projects mentioned by the commenter. Developers are always required to construct or contribute their fair share toward the water and stormwater infrastructure required for new development.

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“[u]pon completion of the Del Puerto Creek Project, the City will recharge the total amount of purchased and delivered surface water to meet the increase in water demand as a result of development projects.”].) Because all development is subject to the GSP, those other developers must pay their fair share for the expansion of the recharge facility. To date, the City has only attempted to condition Keystone to fully front the costs of the Del Puerto Creek Project. And it continues to approve other developments without imposing any conditions requiring contribution of fair share costs towards the Del Puerto Creek Project.

Programmatic Actions 3. Comments on Chapter 3-Housing Action Plan The RDHE includes certain new programs, including Program 1.14 (Facilitating Development of the Zacharias & Baldwin Ranch Master Plan Areas), Program

1.15 (Water Supply to Support Development), and Program 1.17 (Diversify and Expand the Housing Stock). In short, the “programs” added to the RDHE appears to just “parrot” the language of HCD’s May 2025 comment letter with no meaningful analysis or detailed plan of action. These programs fail to reflect that any water issue is a citywide one that applies to all developments residential and non-residential alike, whether located inside or outside the Master Plan area.

The GSP and associated PRP contain significant limitations for groundwater pumping. The City is in the process of developing clear policies for how new development can meet the
requirements of the GSP and identifying alternative water supply options. The City is required to comply with the GSP and PRP, and further ensure new development is subject to appropriate conditions and mitigation for any new groundwater demand.

Housing Element Program 1.15 Water Supply to Development addresses the Groundwater Sustainability Plan.

Programmatic Actions 3a. Program 1.14-Facilitating Development of the Zacharias & Baldwin Ranch Master Plan Area
The City denied the Keystone Ranch Project, identified in the Master Plan as the very first phase of development, because Keystone would not agree to fully fund construction of the estimated $20 million Del Puerto Creek Project. Under Program 1.14, the City states it is committed to “facilitate the phasing of infrastructure to enable timely residential development to meet the City’s RHNA.” (RDHE, p. 3-21; see also RDHE, p. 3-23 [Program 1.15 likewise states the City “will provide flexibility in permit timing relative to needed infrastructure improvements and facilitate the phasing of infrastructure to enable timely residential development to meet the City’s RHNA”].) While this appears to a be a positive statement in terms of allowing housing development to proceed, it is entirely unclear what it means or how it will be implemented.

For instance, what infrastructure will be phased and how will it impact the 3,200 Master Plan units relied on by the Housing Element to meet the City’s RHNA figure? How can the City allow other non-Master Plan development to proceed absent payment of its fair share towards the Del Puerto Creek Project? What There is no moratorium on housing in the City. The City is subject to the requirements of the GSP and PRP, which require reductions to groundwater pumping.

For the Zacharias / Baldwin Ranch Master Plan (Master Plan), the Environmental Impact Report (EIR) was subject to a lawsuit and a settlement agreement. This commenter is not the only developer of the Master Plan, and all developers of the Master Plan are subject to the same mitigation requirements and conditions.

Per Housing Element Program 1.15, the City has initiated studies to determine scopes of work, feasibility, and
development timelines for its identified water supply projects.

The study results will further inform the specifics for what new development will be required to build or contribute to these projects. City funding is limited, however. It was always the Packet Pg. 1602
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does “timely residential development” mean especially given that the City is nearly two years delinquent in having its 2023-2031 Housing Element certified and Keystone has tried for over 10 years to get a residential housing project approved. Underscoring this point, elsewhere, the City admits it is only committing to ensuring the timely construction of infrastructure to facilitate housing for occupancy “within the eight-year planning cycle.” (RDHE, p. 3-22.) Highlighting our concerns with the RDHE’s loose and ill-defined concept of infrastructure phasing, the RDHE states the City will conduct a mid-cycle review in December 2027 and if “infrastructure improvements are not funded or underway” by January 2028, it will “consider” alternative land use strategies such as identifying alternative sites and amending zoning or other land use documents to make suitable land available for development to meet its RHNA. (RDHE, p. 3-22; see also RDHE, p. 3-24.) Elsewhere, the City says it is targeting “completion” of the infrastructure improvements by December 2027 and that it will monitor Project approvals in obtaining 3,503 residential building permits by June 2027. (RDHE, p. 3-23.) So far the City has zero permits issued with less than two years to go. It denied the 719-unit Keystone Ranch Project in April after postponing a decision on it for several years.

It is unclear what infrastructure improvements are being referred to here. Is it just stormwater? The Master Plan detailed the stormwater phasing as proceeding in early stages from local retention basin to middle stages consisting of the Lakeside Hills lake features to later phases comprised of a flood control basin and the Zacharias Recharge Basin. Indeed, the Master Plan included a phasing schedule to ensure that the early-phased development was not saddled with substantial infrastructure costs not needed until future phases are proposed. It specifically identified Keystone Ranch as the very first Master Plan project to be developed “prior to the installation of the major storm drain facilities (lakes, FEMA basin, and recharge basin . . ..” (Master Plan, p. 98.).

To the extent the City is referring to the Del Puerto Creek Project when it refers to infrastructure improvements, as we believe to be the case, the City seems to be perpetuating the moratorium on housing that begin with its denial of the Keystone Ranch Project. In other words, the City is saying that no Master Plan development will be issued building permits until the Del Puerto Creek Project is funded, designed, approved, and constructed. (Cf. RDHE, pp. 4-21 to 4-22 [“To secure potable water supplies for the project, [Zacharias] developers will need to contribute their fair shares to finance the Del Puerto Creek Recharge Project and the project will need to be constructed.”].)
Moreover, any GSP obligations would apply citywide. So how will identifying and changing the land use designation of other sites meaningfully change anything intent and requirement that new water and storm drainage projects required for new development will be paid for by developers.

While advancing buildout of the General Plan and meeting the RHNA, the City must still ensure compliance with the GSP and reduce its groundwater pumping. The City is highly supportive of new development and is actively working to address and clarify infrastructure challenges.

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when those sites would also not be able to go forward absent the Del Puerto Creek Project? From a practical standpoint, where and how would the City find an additional 3,200 units to replace the Master Plan units currently included in its Housing Sites Inventory?
The City must revise this language to allow early phased Master Plan development counted on by the City to meet its RHNA (such as Keystone Ranch) to proceed pending future development of the regional-serving Del Puerto Creek Project. The City has approved major warehouse projects pending such future development so certainly it can allow much-needed housing projects to proceed as well.

Similarly, Program 1.14 states that the City “commits to charg[ing] developers their respective fair share payments as part of the larger needed improvements to the infrastructure required for development of Master Plan Area including water, sewer, and stormwater.” (RDHE, p. 3-21.) What does fair share payment mean? The cost of the Del Puerto Creek Project has been described by the City as anywhere between $7.8 (in the July 2024 GSP) to $17.9 million (in a March 2025 Settlement Agreement) plus land cost. If the Del Puerto Creek Project will recharge surface water purchased by other non-Master Plan developers, how will they be assessed their fair share? Clarify that this stormwater infrastructure is not “required” solely for Master Plan development nor solely to facilitate development of the Master Plan as implied on pages 3-21 and 4-14 of the RDHE. (See also RDHE, p. C-16 [City states revisions were made to Chapters 3 and 4 of the RDHE “to clarify that the Groundwater Sustainability Program applies (sic) to the entire Master Plan area.”].)
The City states that it will make its “best efforts” to begin design and environmental review of the Del Puerto Creek Project no later than December 2026. (RDHE, p. 3-21.) Why will it take the City nearly 18 months to begin the design and environmental review process for this project when it has been considered by the City since at least 2018? Why has the City not made any substantial progress on that project since that time? What housing projects will be allowed to proceed pending completion of the Del Puerto Creek Project and why? Conversely, which housing projects will not be allowed to proceed pending completion of the Del Puerto Creek Project and why not? The RDHE acknowledges that “potable water supply is a challenge for new development city-wide.” (RDHE, p. 4-6; see also RDHE, p. 4-41 [noting that the GSP applies city-wide].) As such, if retained in the Housing Element, the reference to the GSP and Sustainable Groundwater Management Act (“SGMA”) should be placed in a separate program that applies citywide, not just to Master Plan development. For instance, the RDHE states that the City is required to Packet Pg. 1604
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monitor and enforce compliance with the GSP pursuant to State law and that Program 1.14 “is a necessary component of the City’s accountability and compliance with the GSP.”
The RDHE also states that the City will work with other agencies to develop a regional recharge solution for stormwater per the SGMA. If the City is required to reduce groundwater pumping and not allow any net new pumping to occur per the GSP, as it claims, then the program of requiring new developments to purchase surface water and recharge it to the groundwater basin has to apply citywide to all new development, whether inside or outside the Master Plan, and whether the development is residential or non-residential in nature. Similarly, the reference to regional recharge solutions applies to all developments citywide, not just those in the Master Plan.

The City also claims that it will continue to “review potable water supply portfolios to ensure adequate water availability.” (RDHE, p. 3-22.) Groundwater levels in Patterson have remained constant and unchanged for the last 20 years, including recent drought years. (Department of Water Resources [“DWR”], 20-Year Groundwater Level Trends, May 2025.) Moreover, most monitoring wells in Patterson show normal or above normal groundwater levels with some wells showing all-time high levels. (DWR, Groundwater Level Conditions, May 2025.)
Further evidence of adequate water supplies is contained in the City’s Master Plan EIR. The Master Plan EIR finds that the Master Plan will decrease water demand by 3,225 afy compared to the existing agricultural uses and concludes that the Master Plan will not have a significant impact to groundwater supplies. (Draft EIR, pp. 3.15-5 to 3.15-22 [finding Impact US-1 to be less than significant with no mitigation required]; Draft EIR, pp. 3.9-23 to 3.9-26 [finding Impact HYD2 to be less than significant with no mitigation required]; Draft EIR, pp. 3.9-33 to

3.9-34 [finding Impact HYD-5 to be less than significant with no mitigation required; see also Final EIR, p. 3-70].) By comparison, the Project’s estimated potable water demand is 138 afy.

The Master Plan EIR cites the City’s Urban Water Management Plan and the Master Plan’s Water Supply Assessment, both of which find that Patterson has sufficient water supplies to meet the Master Plan’s water demand over the next 20 to 30 years during normal, dry, and multiple dry years. (Draft EIR, pp. 3.15-20 to 3.15-21, 4-13 to 4-14; Final EIR, pp. 3-39 to 3-40; see also Master Plan, p. 97 [Table 8 shows sufficient supplies for Project water demand currently and in future years].)
Programmatic Actions 3b. Program 1.15-Water Supply to Support New Development Packet Pg. 1605
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On page 3-23, the RDHE states the GSP “establishes a pumping reduction plan which requires the City to reduce its groundwater pumping to 2,626 [afy] by 2030.” Please indicate where in the GSP it imposes this obligation. We have searched the document and see no such reference. We do see a reference to a 460 afy pumping reduction by 2030 in the Pumping Reduction Plan (“PRP”).

That is indicated to be a “target” that “may be adjusted and adapted based on model updates and the availability of additional data and measurements.” (PRP, p. 3.) Explain how this is a requirement and, if so, what has the City done to achieve its 92 afy reduction by 2025? What other groundwater sustainability agencies subject to the PRP have required new development to purchase offsetting surface water and pay for recharge basins?
The text goes on to state that the City can still continue to support additional development through the construction and implementation of the Del Puerto Creek Project. (RDHE, p. 3-23.) The GSP identifies the Del Puerto Creek Project (also known as the City Perc Pond Project) as a Tier 3 water supply project (not needed until 2040). It also indicates that pumping reduction objectives by 2030 are to be achieved through specified Tier 1 and Tier 2 pumping reduction projects. Explain how and why this Tier 3 project is needed to meet the Tier 1 and Tier 2 pumping reduction objectives.

Program 1.15 is supposed be about water supply citywide, but purports to require only Master Plan developers to make fair share payments for the City’s Del Puerto Creek Project.
(RDHE, p. 3-24 [“The City commits to charge developers their respective fair share payments as part of the larger needed improvements to the infrastructure required for development of the Master Plan Area including water, sewer, and stormwater.”].) If the GSP requires no net new pumping, as the City contends, then all developments (including those outside the Master Plan and including non-residential development) must pay for surface water and for their fair share of the Del Puerto Creek Project.

The City also purports to require all development projects with potable water demand to fund an evaluation of the redesign of the existing storm water infrastructure associated with the Black Gulch Drainage Area. (RDHE, pp. 2-54, 3-24.) Explain the nexus between this requirement and new development not located in this drainage area.

The GSP requires reducing extraction of groundwater in the Delta-Mendota Subbasin by approximately 42,000 acre-feet per year (AFY) by 2030 (GSP, Chapter 15, p. 291). The City’s share of that reduction requires that the City reduce its groundwater pumping by 460 AFY by 2030 (Pumping Reduction Plan, page 3, Table 2). This figure is based on modeling of the City’s total aquifer pumping during the years 2019-2023 (Pumping
Reduction Plan, page 3). Pumping reductions may be adjusted based on model updates and availability of additional data.

All new development is subject to the City’s enforcement and implementation of the GSP and PRP requirements.

In support of the City’s implementation of the GSP and PRP requirements, the City is evaluating alternatives for the capture of stormwater for recharge. The City is considering alternatives such as participation in cooperative recharge programs with other partnering groundwater sustainability agencies in the Northern Delta-Mendota Subbasin and the study of regional stormwater management to provide recharge, including capture of stormwater from the Blach Gulch Drainage Area.

Housing Element Program 1.15 Water Supply to Support
Development and Program 3.1 Water and Energy Conservation Opportunities identify actions to support groundwater
sustainability.

Programmatic Actions 3c. Program 1.17-Diversify and Expand the Housing Stock Explain why this program to diversify and expand the City’s housing stock is focused solely on the Zacharias area. (RDHE, p. 3-26.) How does promoting “missing middle” housing in just one geographic part of the City advance the Program 1.17 targets areas identified as High Resource by HCD’s AFFH Data Viewer. Specifically, it states: “This effort will focus on areas south of Zacharias Road, west of State Route 33, north of Elfers Road, and east of Baldwin Road, including Packet Pg. 1606
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goals of affirmatively furthering fair housing? Explain the basis for determining that the vacant, undeveloped Zacharias area is a high resource and high opportunity area. Per the State’s 2025 AFFH Mapping Tool, the Zacharias area is located in a Moderate Resource area and is located adjacent to Low and Moderate Resource areas.

Similarly, explain the basis for determining that all affordable housing for special needs and disabled persons should be accommodated in the Master Plan area.

Where are the support services, commercial services, and transit facilities to support such populations?
Further explain why the existing Master Plan land use plan with a mixture of low, medium, and high density residential housing density housing, and objectives, including neighborhood and housing diversity, do not already accomplish the goal of providing diverse housing types. (Master Plan, pp. 11, 13, 14.) On April 1, 2025, the Patterson City Council denied the 719-unit Keystone Ranch Project with its 213 high-density residential units. Will this be acknowledged as a barrier to housing production, increasing housing capacity, and providing a variety of housing types?
the City’s master planned areas.” See Figure A-11 in the Revised Draft Housing Element for an illustration of TCAC Opportunity Areas in Patterson.

N/A 4. Comments on Chapter 4-Housing Resources and Sites Inventory The City denied the Keystone Ranch Project on April 1, 2025 after delaying it for years. The RDHE should be updated to reflect the City’s denial of the Keystone Ranch Project. For instance, the RDHE continues to say the area is slated for infrastructure improvements beginning in Summer 2025 and development in Fall 2025. (RDHE, p. 4-9.) The statement that the City “is continuing to work with the developer on the vesting tentative maps” is false. (Id.) The City denied the Keystone Ranch Project on April 1st.

Keystone Ranch is proposed for a diversity of housing units, including both single-family and multi-family residences. On page 4-10, the RDHE refers to the affordability assumptions for the Keystone Ranch Project. It accurately portrays the multi-family portion of the Project as being proposed at densities that are deemed appropriate to accommodate housing for lower-income households, i.e. at least 20 units per acre. (Gov. Code § 65583.2(c)(3)(B)(iii).) We appreciate the RDHE’s acknowledgement that temporary sewer connections are necessary to support new housing development and the City’s fulfillment of its RHNA. (RDHE, p. 4-13.) RDHE page 4-42 likewise acknowledges that temporary sewer and water connections “will support the initial phases of development in the Zacharias and Baldwin Ranch Master Plan area.” Zacharias and Baldwin Ranch were approved as one Master Plan under the same Master Plan EIR. Yet, under the potential limitations to development, the At the April 1, 2025 City Council meeting, the City Council denied the Vesting Tentative Map because Keystone Ranch LLC would not agree to the required mitigation measures to address the changed circumstances created by the GSP and PRP. Without adherence to such mitigation, a further
supplemental EIR would be required before the City could legally approve the Vesting Tentative Map in accordance with CEQA.

The City’s denial of a single project application is not a permanent denial. Keystone Ranch LLC may resubmit its project application at any time. Further, Keystone Ranch LLC is not the only developer of the Zacharias / Baldwin Ranch Master Plan (Master Plan), and all developers of the Master Plan are subject to the same mitigation requirements.

The City disagrees with claims of arbitrary application of infrastructure requirements to this commenter. All new
development is subject to the requirements of applicable Master Packet Pg. 1607
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RDHE only discusses Zacharias development. (RDHE, pp. 4-21 to 4-22.) The recharge basin is not being used for stormwater for Zacharias only. Instead, now the City is proposing a larger basin to recharge surface-water purchased by all new development. There is no logical reason why Baldwin Ranch South and all other new developments citywide (including the recently approved Patterson Logistics Center and Project Zach) should not be subject to the same fair share obligation.

On page 4-24, the RDHE states the developers of Baldwin Ranch “will be required to contribute their fair share of financing for improvement projects to meet the state-imposed timeline to mitigate water shortages.” Explain whether the Baldwin Ranch South developers and others will need to contribute their fair share to finance the Del Puerto Creek Project and that project will need to be constructed in order for them to secure potable water supplies for their project. (RDHE, p. 4-21.) If that is not the case, please explain the City’s position and cite to and support it with substantial evidence.

On page 4-43, the RDHE states that all other sites in the inventory (except Zacharias) have adequate existing infrastructure and do not require the construction of new or expanded facilities. But the RDHE also inconsistently states that the Del Puerto Creek Project is needed to recharge the surface water purchased by all new developments to offset their groundwater usage.

Patterson City CouncilMay 19, 2026

Patterson City Council
May 19, 2026