Turlock City Council
August 11, 2026

Appendix B: Housing Needs Assessment
B-46 Hearing Draft | August 6, 2026
B.7 Assisted Housing at Risk of Conversion
State Housing Element law requires that communities identify the status of assisted low-income rental units that are “at risk” of conversion to market rent status within ten years of the statutory mandated update of the Housing Element (from January 2023 to January 2031). The California Housing Partnership (CHP) estimates that there are 4,254 low-income rental units in Stanislaus County. Table B41 shows that while most units in the county are at low risk of conversion, there are 87 units (2.0 percent) at moderate risk and 179 units (4.0 percent) at high risk. In addition, Stanislaus County has experienced the loss of 170 affordable units (3.8 percent) between 1999 and 2023. There are currently 104 units at risk of conversion by 2031 in the City of Turlock. As such, Program 4-J, Expiring Covenants, would pursue a program to purchase affordability covenants on existing multi-family units, subject to restrictions that the affordability covenants would be in effect for not less than 30 years, and that at least 20 percent of the units would be affordable to extremely low- and very low-income households.

More information is available in Chapter 4: Housing Action Plan. While California Housing Partnership’s Preservation Database is the state’s most comprehensive source of information on subsidized affordable housing at risk of losing its affordable status and converting to market-rate housing, this database does not include all deed-restricted affordable units in the state. Consequently, there may be at-risk assisted units in a jurisdiction that are not captured in this data table.

Table B-41: Assisted Units at Risk of Conversion
Turlock Stanislaus County
Risk Level1 Number Percent Number Percent
Moderate 0 0.00% 87 2.00%
High 0 0.00% 179 4.04%
Very High 0 0.00% 0 0.00%
Lost Affordable Homes 0 0.00% 170 3.84%

1. California Housing Partnership uses the following categories for assisted housing developments in its database:
• Low Risk: affordable homes that are at-risk of converting to market rate in 10+ years and/or are owned by a large/stable non-profit, mission-driven developer.
• Moderate Risk: affordable homes that are at-risk of converting to market rate in the next 5-10 years that do not have a known overlapping subsidy that would extend affordability and are not owned by a large/stable non-profit, mission-driven developer.
• High Risk: affordable homes that are at-risk of converting to market rate in the next 1-5 years that do not have a known overlapping subsidy that would extend affordability and are not owned by a large/stable non-profit, missiondriven developer. • Very-High Risk: affordable homes that are at-risk of converting to market rate within the next year that do not have a known overlapping subsidy that would extend affordability and are not owned by a large/stable non-profit, mission-driven developer.

Source: California Housing Partnership, Preservation Database, 2024 Per HCD guidance, local jurisdictions must also list the specific affordable housing developments at risk of converting to market rate uses to supplement the aggregate numbers provided in Table B-41. The assisted housing inventory is available in Table B-42 below.

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Table B-42: Turlock Assisted Housing Inventory
Project Name Project Address Project Type
Total
Units
Affordable
Units
Date
Constructed
Affordability End
Date
Avena Bella 500 W
Linwood Ave
Family 80 79 2013 2067
Avena Bella, Phase
2 500 W
Linwood Ave
Family 61 60 1/21/2077
Denair Manor 550 Wayside
Dr
Seniors 62+ 70 70 1979 2074
Crane Terrace
Apartments
1318 E Canal
Drive
Seniors 62+ 44 44 2006 2060
Cherry Tree
Village
139 W
Minnesota Ave
Family &
Seniors
194 104 2003 2056
Turlock
Silvercrest
895 Lander
Ave
Seniors 62+ 80 80 2002 11/30/2041
Parkwood
Apartments
3800 Crowell
Road
Family 180 180 1978 2053
Villas Parkside
Apartments
381 W
Hawkeye Ave
Family &
Seniors
104 104 1973 2029
Total 813 721
Source: California Housing Partnership, 2024

COST ANALYSIS
State law requires the analysis of at-risk housing to identify “the total cost of producing new rental housing that is comparable in size and rent levels, to replace the units that could change from lowincome use, and an estimated cost of preserving the assisted housing developments.” The typical development cost of affordable housing projects in Turlock is about $393,799 per unit. Estimates are derived from the average projected development costs per unit provided in recent California Tax Credit Allocation Committee (TCAC) project tax credit applications, see Table B-43. If the 141 units identified by the CHP as facing some level of risk converted to market rate housing during the 10-year period, the total replacement cost would be about $55,525,612.

Table B-43: Typical Development Costs of Affordable Housing Project Name TCAC Application Year Per Unit Cost1
Church Lane 2017 $418,536
Montevista Senior Apartments 2018 $292,056
Hilltop Commons 2020 $470,804
Average $393,799

1. Derived from stated “true cash per unit cost” or “effective per unit costs”, where applicable, in TCAC project applications.

Source: California Tax Credit Allocation Committee, Project Staff Reports 2017-2020 The cost of preservation for the typical affordable housing project can be estimated by finding the difference between fair market rent and affordable rent. As shown in Table B-36 the affordable monthly rental payment for a very-low-income, four-person household in Turlock is $1,713. In fiscal year 2021 the HUD Fair Market Rent (FMR), or gross rent estimate, in the Oakland-Fremont, CA HUD Metro FMR

Appendix B: Housing Needs Assessment
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area for a three-bedroom unit was $3,196. The difference between these two prices is the “affordability gap,” which is about $1,483 in Turlock. Given this affordability gap, the total cost of preserving all 141 at-risk units would be approximately $209,103 per month or $2,509,236 per year. This translates to a cost of $25,092,360 over the 10-year period, or $177,960 per unit. This is likely an overestimation of cost, since the FMR area that Turlock is part of includes Bay Area jurisdictions with much higher rental costs. Even so, preservation costs are lower than replacement costs.

RESOURCES FOR PRESERVATION
There are two primary resources available for preserving at-risk units – public agencies, nonprofit housing corporations, and tenant groups; and public financing or subsidy programs. HCD maintains a current list of all “qualified entities” across the state, which are nonprofit or for-profit organizations or individuals that agree to maintain the long-term affordability of affordable housing developments. Table B-44 provides the list of all qualified entities for Stanislaus County. The City would work with these organizations to preserve the housing units in danger of conversion. Additional housing resources, including funding sources, that the City utilizes are discussed further in Chapter 3.

Table B-44: Qualified Entities in Stanislaus County
Qualified Entity City Contact
ACLC, Inc Stockton (209) 466-6811
Self-Help Enterprises Visalia (559) 802-1620
Modesto Redevelopment Agency Modesto (209) 577-5247
Housing Authority of the County of Stanislaus Modesto (209) 523-0705 ROEM Development Corporation Santa Clara (408) 984-5600 Ext 17 Volunteers of America National Services Sacramento (916) 917-6848 Source: HCD, May 2021
B.8 Energy Conservation
Conservation of energy is an important issue in housing development today not only due to the cost of energy, which can be a substantial portion of monthly housing costs for both owners and renters, but also due to an emerging interest in sustainable development, energy independence, and reduction of greenhouse gas emissions in line with new legislation such as the Global Warming Solutions Act of 2006 (AB 32).

Conservation can be accomplished by reducing the use of energy-consuming items, or by physically modifying existing structures and land uses, and by designing buildings to be more energy efficient. The California Energy Commission first adopted energy conservation standards for new construction in 1978. These standards, contained in Title 24 of the California Administrative Code, contain specifications relating to insulation, glazing, heating and cooling systems, water heaters, swimming pool heaters, and several other items. Specific design provisions differ throughout the State depending upon local temperature conditions. Title 24 energy requirements are consistently reviewed in all building applications processed in the City.

Although the energy regulations establish a uniform standard of energy efficiency, they do not ensure that all available conservation features are incorporated into building design. Additional measures may further reduce heating, cooling, and lighting loads, and overall energy consumption. While it is not

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suggested that all possible conservation features be included in every development, there are often a number of economically feasible measures that may result in savings in excess of the minimum required by Title 24.

While construction of energy efficient buildings does not lower the purchase price of housing, housing with energy conservation features should result in reduced monthly occupancy costs as consumption of water and energy is decreased. Similarly, retrofitting existing structures with energy-conserving features can result in a reduction in utility costs. Examples of energy conservation opportunities include weatherization programs and home energy audits; installation of insulation; installation or retrofitting of more efficient appliances, and mechanical or solar energy systems; and building design and orientation that incorporates energy conservation considerations. Rebate programs run by the local and State utilities are described below.

The City of Turlock has updated its General Plan. In order to comply with AB 32 and SB 375, the City has incorporated numerous policies and programs into the updated General Plan, aimed at reducing energy consumption and greenhouse gas emissions in buildings and through sustainable land use and transportation planning. New residential development that takes place in Turlock will have to comply with these new policies as well.

INTEGRATING LAND USE AND TRANSPORTATION PLANNING
The City of Turlock seeks to minimize energy consumption through integrating land use and transportation planning in its General Plan policies. Infill development, mixed uses, and higher density development enable residents to access goods and services without a car, or in shorter and fewer car trips; dense, pedestrian-oriented areas encourage walking and cycling. High density residential projects also use less energy per unit for heating and cooling than single family homes. Policies in the Land Use, Transportation, and City Design Elements of the current General Plan encourage development that, by nature of its design, reduces energy consumption.

By virtue of its location, compact development pattern, and by the presence of several large local employers, residents of Turlock tend to work locally as compared with many other Central Valley cities.

Approximately 45 percent of the city’s employed residents work in Turlock, and over 80 percent work in Stanislaus County. Additionally, approximately 75 percent of residents commute less than 30 minutes to work.

BUILDING DESIGN AND CONSTRUCTION
Many modern design methods used to reduce residential energy consumption are based on proven techniques that have been known to humans since the earliest of days of collective settlement. These methods can be categorized in three ways:

First: building design that keeps natural heat in during the winter and keeps natural heat out during the summer. Such design reduces air conditioning and heating demands. Proven building techniques in this category include:
• Locating windows and openings in relation to the path of the sun to minimize solar gain in the summer and maximize solar gain in the winter;
• Use of “thermal mass,” earthen materials such as stone, brick, concrete, and tiles that absorb heat during the day and release heat at night;
• “Burying” part of the home in a hillside or berm to reduce solar exposure or to insulate the home against extremes of temperature;

Appendix B: Housing Needs Assessment
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• Use of window coverings, insulation, and other materials to reduce heat exchange between the interior of a home and the exterior;
• Locating openings and using ventilating devices to take advantage of natural air flow; and • Use of eaves and overhangs that block direct solar gain through window openings during the summer but allow solar gain during the winter.

Second: building orientation that uses natural forces to maintain a comfortable interior temperature.

Examples include:
• North-south orientation of the long axis of a dwelling; • Minimizing the southern and western exposure of exterior surfaces in hot climates; and • Location of dwellings to take advantage of natural air circulation and evening breezes.

Third: Use of landscaping features to moderate interior temperatures. Such techniques include:
• Use of deciduous shade trees and other plants to protect the home; • Use of natural or artificial flowing water; and
• Use of trees and hedges as windbreaks.

In addition to natural techniques that have been used for millennia, a number of modern methods of energy conservation have been developed or advanced during the present century. These include:
• Use of solar energy to heat water;
• Window glazing to repel summer heat and trap winter warmth; • Weather-stripping and other insulation to reduce heat gain and loss; and • Use of energy-efficient home appliances.

Turlock’s abundant sunshine provides an opportunity to use solar energy techniques to generate electricity, heat water, and provide space heating during colder months, as well. Natural space heating can be substantially increased through the proper location of windows and thermal mass.

City Policies
Within the Open Space and Conservation Element of the City of Turlock’s current General Plan, the City outlines several goals and policies pertaining to Energy Conservation. As part of the residential design review process, all developments must be evaluated against the Energy Conservation Guidelines. These guidelines include that all residential developments should be oriented to be within 22.5 degrees of the east-west axis to maximize south-wall and minimize west-wall exposure, roof overhangs, wood trellises and other sunshade devices should be provided to shape the east and west building surfaces and windows, deciduous tree cover should be provided to shade streets and parking areas and to reduce summer heat radiation, use of solar collectors of water, space and swimming pool heating should be encouraged, and construction material conservation is to be encouraged.

REBATE PROGRAMS
The City also has a policy to support Turlock Irrigation District (TID) and Pacific Gas and Electric (PG&E) programs to encourage retrofit measures such as weather-stripping and insulation. PG&E provides gas, and TID provides electric service to Turlock residents. These companies offer company a variety of energy conservation programs and information services that are available to residents.

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PG&E Rebates
PG&E offers rebates on the purchase of Smart Thermostats, electric heat pump storage water heater, backup power generator, and portable batteries. Customers of PG&E are eligible for rebates on thermostats of $50-$120, depending on the needed appliance, electric heat pump storage water heater rebates of $300, backup power generator rebates of $300-$500, and portable battery rebates of $300- $500.

Turlock Irrigation District Rebates
Turlock receives its electricity supply from TID. TID has developed numerous energy efficiency and demand reduction programs for its customers, both residential and commercial. The residential customer programs are as follows:
• LED Lights Rebate for replacing incandescent bulbs
• Residential Rebate Programs: Rebates for purchasing and installing energy-efficient appliances including Energy Star refrigerators, Energy Star clothes washers, Energy Star room air conditioner or mini split A/C, induction stove tops, heat pump or electric water heater, Energy Star windows and sun screens.
• Shade Tree Rebate: Rebates for the purchase of up to three trees plants for shade purposes

ALTERNATIVE ENERGY DEVELOPMENT
Solar energy is a viable alternate energy source for the City of Turlock. There are two basic types of solar systems: active and passive.

Active Solar Systems
Active solar systems typically collect and store energy in panels attached to the exterior of a house. This type of system utilizes mechanical fans or pumps to circulate the warm/cool air, while heated water can flow directly into a home’s hot water system. Solar cells absorb the sun’s rays to generate electricity and can substantially reduce electric bills. Technological improvements have made the cells increasingly efficient and reduced their cost.

Passive Solar Systems
In passive solar systems, the structure itself is designed to collect the sun’s energy, then store and circulate the resulting heat similar to a greenhouse. Passive buildings are typically designed with a southerly orientation to maximize solar exposure, and are constructed with dense material such as concrete or adobe to better absorb heat. Properly placed windows, overhanging eaves, and landscaping can all be designed to keep a house cool. Although passive solar systems generally maximize use of the sun’s energy and are less costly to install, active systems have greater potential application to cool and heat a house and to provide it with hot water and electricity. This may mean lower energy costs for Turlock residents.

SUMMARY OF KEY FINDINGS
Findings Regarding Statutorily Defined Special Needs Groups. - Extremely-Low Income Residents: American Indian or Alaska Native non-Hispanic residents are most likely to fall below 30 percent AMI and experienced the second highest rates of poverty, while only representing 0.21 percent of the City’s population. They are

Appendix B: Housing Needs Assessment
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followed by Black or African American residents who experience the highest rates of poverty. Overall, Turlock has a slightly lower poverty rate (13.1 percent) than the County (15.1 percent)
- Older Adult Residents: Approximately one-third of older adults are renters and nearly 33 percent qualify as low income, while nearly 20 percent qualify as very low income. Overall, around 50 percent of older adult households in Turlock are considered cost burdened, whether renter or owner. Notably, 10 percent of the population is aged between 55 and 64 years, which means a relatively large number of residents will become seniors during the 2023-31 planning period.
- Persons with Disabilities: In the city, there is almost equivalent proportion of persons with disabilities to the City and the County (12.3 percent and 12.7 percent). Over 90 percent of residents with a developmental disability lived at the home of a parent/family/guardian. - Large Families: There is a smaller share of larger households (5 or more people) in Turlock at 12.6% compared to Stanislaus County at 17.8%. Turlock also holds a larger share of single-person households at 22% compared to 20.3% for the County. However, these households tends to be less cost burdened and are less likely to be extremely low-income. - Female-Headed Households: Female-headed households make up about 15.2 percent of the total households in Turlock. These households are more likely to rent than to own.

Nearly 30 percent of all female-headed households with children in Turlock live below the federal poverty level. The special needs of these households should be addressed in the Housing Element Update.
- Persons Experiencing Homelessness: As a share of the total population of Stanislaus County, the number of people experiencing homelessness is not large; however, the rate of homelessness in the county has nearly doubled since 2018. Additionally, more than 40 percent of people experiencing homelessness in Stanislaus County are unsheltered, which represents an urgent need that should be addressed through a coordinated effort with the County and other Stanislaus jurisdictions. Further, people of color are disproportionately represented among those experiencing homelessness: Hispanic, African American, and American Indian or Alaska Native homeless persons make up 35.6 percent, 12.5 percent, and

5.3 percent of homeless Stanislaus residents respectively, but account for only 0.13 percent,

0.05 percent, and 0.01 percent of the overall population. - Farmworkers: Overall, the farmworker population in Stanislaus County has decreased dramatically since 2000 among seasonal farmworkers as the mechanization of agriculture has proceeded. However, the number of permanent farmworkers has increased approximately 2 percent. Still, farmworkers represent about 4 percent of the total population in Turlock, and number of student migrant workers has decreased only slightly since 2016-2017. Given the seasonal nature of this work for at least a portion of this group, the special. needs of this segment of the population should be considered in the Housing Element Update.
- Demographics: Turlock is a fast-growing community. The city has grown at a much faster rate than Stanislaus County since 2000 and is projected to add another 20,000 residents by 2050, which represents a nearly 29 percent increase over the period. Since 2000, the population has aged slightly. The share of residents aged over 65 has grown by 2 percent

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while share of residents aged less than 24 has decreased by 5.2 percent. Ethnically, the older adult population in Turlock is overwhelmingly White. However, Turlock is becoming more diverse. Since 2000, the share of residents who identify as Hispanic has increased dramatically from 29.42 percent to 40.06 percent, while the share who identify as White has decreased from 60.41 percent to 48 percent. Other races make up a relatively small and stable share of the population.
- Income. Household income levels are generally on par with the county; however, over 42 percent of households in Turlock make less than 80 percent of the area median income, meaning a very large share qualifies as lower income by HUD standards. Notably, people of color are disproportionately lower income in Turlock. Strikingly, more than 23 percent of African American residents and nearly 14 percent of Native Americans live below the federal poverty level. These two groups in particular have special needs that should be considered in the Housing Element Update.
- Cost Burden: A substantial portion of the local population in Turlock experiences housing cost burden: 20 percent of households devote more than 30 percent of their income to housing costs while nearly 17 percent devote more than 50 percent. Almost half of all renters in Turlock experience cost burden. This indicates a strong need for rental assistance and stabilization programs to help keep people in their homes proactively and prevent homelessness.
- Overcrowding: Overall, the rate of overcrowding is equivalent in Turlock (7.6 percent) and Stanislaus County (7.6 percent). However, although they represent a relatively small share of the total population, Native Hawaiians and Other Pacific Islanders are three times more likely to experience overcrowding than other races and ethnicities. - Housing Quality: In Turlock, just under 50 percent of the housing stock was constructed prior to 1980, making it more than 40 years old. As such, programs to assist with maintenance and repair should be a focus in the Housing Action Plan. However, the percentage of households living in substandard conditions in Turlock is very low, indicating that, overall, housing is generally in good condition. A review of code enforcement actions in Turlock in recent years indicates that vehicle and weed abatement are the primary issues addressed and that there is no clear pattern of housing related code violations in any one neighborhood.
- Housing Tenure: Renters represent a robust share of the total number of households in Turlock at 45 percent. This is a slight increase over 2000, but still a sizable share of the overall population in comparison to other communities. As such, an emphasis on rental assistance, rent stabilization, and homeownership assistance may be warranted in the Action Plan of the Housing Element Update. Renters tend to be people who have arrived in the community more recently than homeowners and they are more likely to be African American, Hispanic, or Native American.
- Vacancy: Vacancy rates in the community are very low for both rental (1.63 percent) and for sale units (0.47 percent).
- Production and Need at Various Income Levels. Housing production has not kept pace with population growth: the total number of housing units in the community increased by only 2.78 percent between 2000 and 2020, even as population increased by approximately

Appendix B: Housing Needs Assessment
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35 percent. Correspondingly, home values in Turlock have more than doubled since 2012.

The local housing stock in Turlock is predominantly composed of single-family homes (approximately 70 percent). About 25 percent of homes are multifamily units and these are almost exclusively rental units (98.0 percent). Mobile homes account for 2.2 percent of the total housing stock, primarily concentrated in 2 mobile home parks located in east central Turlock. Approximately 0 assisted units are at risk of conversion in Turlock compared to 170 units in the County.
- Housing Affordability: Home values in Turlock have doubled since 2014, with the value of smaller units (1 and 2-bedrooms) seeing the steepest increases. This indicates a mismatch of supply and demand. The Housing Action Plan should include strategies to promote and incentivize the production of smaller units to meet this demand. At $476,933 in 2024, however, the average home value in Turlock was well beyond reach for Moderate- and lower-income households. Contract rents (exclusive of utilities) in Turlock increased by nearly 5 percent between 2012 and 2017 and by about 40 percent between 2017 and 2022.

While substantial, this rate of increase is markedly lower than that seen on the ownership market and overall rental housing is relatively more affordable. - Energy Conservation. While energy conservation remains an important goal for the City, affordability of various upgrades may be out of reach for a larger proportion of citizens, as many energy efficiency related rebates have expired since 2015. Notably, TID’s solar rebates program has come to an end.

Appendix C
Constraints Analysis

Table of Contents
C Housing Constraints Analysis.......................................................................................... C-1 C.1 Governmental Constraints.............................................................................................................................. C-1 C.2 Housing For Persons with Special Needs.................................................................................................. C-14 C.3 Development Review Process, Fees, and Exactions............................................................................... C-24 C.4 Off-Site Improvements................................................................................................................................... C-37 C.5 Non-Governmental Constraints.................................................................................................................. C-39 C.6 Environmental Constraints............................................................................................................................ C-43 C.7 Infrastructure.................................................................................................................................................... C-47 List of Maps
Map C-1: Emergency Shelter Overlay ...................................................................................................................C-23 List of Tables and Charts
Table C-1: General Plan Land Use Classifications and Residential Density.................................................... C-3 Table C-2: Permitted Housing Types by Residential Zoning District.............................................................. C-6 Table C-3: Permitted Housing Types by Non-Residential Zoning District.................................................... C-7 Table C-4: Development Standards for Residential Zones................................................................................ C-9 Table C-5: Development Standards for Residential Uses in Mixed-Use and Overlay Zones.................... C-9 Table C-6: Off-Street Parking Requirements for Residential Units................................................................ C-10 Table C-7: Height and Bulk Restrictions for Residential Units in Downtown Overlay Districts........... C-10 Table C-8a: Stanislaus County Point-in-Time (PIT) Count (2022-2025)....................................................... C-19 Table C-8b: Parcel Characteristics of Vacant Sites in the Emergency Shelter Overlay............................. C-22 Table C-9: Development Review and Approval Procedures – Turlock........................................................ C-27 Table C-10: Planning Application Fees – Turlock and Surrounding Jurisdictions....................................... C-29 Table C-11: Development Impact Fees (Effective 1 January 2023) ................................................................ C-30 Table C-12: Total Development Cost and Fee Percentage for One Typical Single-Family Home......... C-31 Figure C-1 CEQA Overview Flowchart................................................................................................................ C-36 Table C-13: Findings and Corrective Actions, HUD ......................................................................................... C-39 Chart C-1: National Mortgage Rates..................................................................................................................... C-41 Table C-14: Monthly Housing Cost and Income Required ............................................................................. C-41 Table C-15: Local Hazards Likely to Affect Housing ......................................................................................... C-44 Table C-16 Hazardous Sites in 6th Cycle Housing Element.............................................................................. C-46

Table C-17: Five Consecutive Dry Years Supply and Demand Comparison – (Potable DWR Table 7-4) ......................................................................................................................................................................................... C-48

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C Housing Constraints Analysis
State law requires housing elements to identify and evaluate potential and actual governmental and nongovernmental constraints that affect a jurisdiction’s ability to maintain and improve existing housing and develop housing to meet its housing needs. Governmental constraints can include land use regulations, fees and exactions, and processing and permitting times, among others. Non-governmental constraints can be infrastructural, environmental, or market based. This Chapter evaluates these constraints to help identify any approaches Turlock could use to reduce or overcome them and improve its ability to meet its housing needs.

C.1 Governmental Constraints
Actions or policies of governmental agencies, whether involved directly or indirectly in the housing market, can impact the ability of the development community to provide adequate housing to meet consumer demands. For example, the impact of federal monetary policies and the budgeting and funding policies of a variety of departments can either stimulate or depress various aspects of the housing industry. Local or state government compliance or the enactment of sanctions (sewer connection or growth moratoriums) for noncompliance with the federal Clean Air and Water Pollution Control Acts can also affect all types of development.

State agencies and local government compliance with state statutes can complicate the development of housing. Statutes such as the California Environmental Quality Act and sections of the Government Code relating to rezoning and General Plan amendment procedures can also act to prolong the review and approval of development proposals by local governments. In many instances, compliance with these mandates establishes time constraints that cannot be altered by local governments.

LAND USE AND DEVELOPMENT REGULATIONS
Turlock regulates the type, location, density, and scale of residential development through the General Plan, Zoning Ordinance, Subdivision Ordinance, Specific Plans, and a variety of building and site development standards, all of which must be consistent with the General Plan. These requirements are intended to protect the health, safety, and general welfare of the community but such regulations, associated procedures and processing fees can also reduce the City’s ability to meet its housing objectives by decreasing the feasibility and increasing the cost of developing housing. This part of the Housing Element discusses existing governmental constraints as well as policies and programs Turlock could enact to overcome obstacles and promote needed housing development.

GENERAL PLAN
The Turlock General Plan, which the City Council adopted in September 2012, is the primary land use control document. The Plan’s elements and policies reflect eight themes intended to realize an overarching vision for Turlock to “grow sensibly and compacting, maintaining its small-town feel, while enhancing quality of life, meeting housing needs, and providing high quality jobs and recreation opportunities for its diverse population.” Six of the themes are particularly relevant to this analysis:

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• Establish limits to urban growth that will maintain Turlock as a freestanding city surrounded by productive agricultural land.
• Maintain an economically and socially diverse population by promoting a greater variety of housing types citywide and a localized mix of housing types in some areas. • Attract new businesses to Turlock to create well-paying jobs and maintain a good jobs/housing balance. • Implement sustainable development and green building principles in municipal projects and new private development projects and foster development that encourages alternatives to auto use, especially for non-commute trips.
• Revitalize and enhance older areas of Turlock. Create an economic and social balance among different city sectors. Enhance the County islands within the City limits, and annex them into the City if feasible. • Manage growth using the Master Planning process to implement General Plan policies and enhance Turlock's quality of life.1
Consistent with State law requires, General Plan establishes the location and amount of land that will be allocated to residential development and specifies the intensity of development (in terms of unit densities and total number of units) that will be permitted. While nearly all components or elements of the General Plan contain goals and policies that influence residential development, it is the Land Use Element that has the most direct influence.

The current General Plan Land Use Element defines four land use classifications that are exclusively residential (Very Low Density, Low Density, Medium Density, and High Density Residential), as well as a Downtown Mixed-Use classification that allows freestanding residential and residential mixed-use projects.

The General Plan also identifies several areas where residential and non-residential uses may be combined.

These designations allow properties to be developed at the highest density or FAR allowed by each classification and are mapped as Medium Density Residential/Office, High Density Residential/Office, and Community Commercial/High Density Residential. The residential classifications allow densities ranging from 0.2 units per acre to 30 units per acre, exclusive of second units and density bonuses for affordable housing. As discussed in Chapter 4, there are currently adequate sites for new housing in each of the land use categories. Therefore, the residential land use regulations in the General Plan are not to be viewed as a constraint. As the General Plan undergoes its comprehensive update, this range of permissible densities is expected to be maintained or increased; policies that would allow for a greater variety of residential development types are also under consideration.

SPECIFIC PLANS AND MASTER PLANS
Turlock has adopted several Specific Plans and Master Plans to guide growth in specified areas in accord with the City’s Residential Annexation Policy. The Policy was adopted in 1998 to implement its 1992 General Plan. The Annexation Policy (City Council Resolution No. 98-036) was intended to focus annexations and growth to one quadrant of the city at a time to allow timely and efficient construction of infrastructure. The Specific and Master Plans implement General Plan policies based on analysis of land use, circulation, public facilities, infrastructure, and financing issues affecting their development potential, often prior to annexation by the City. Master Plan areas primarily unincorporated land within planning area. These include (SE 2 and 3) primarily north of East Linwood, SE1 designated Medium Density 1 Turlock General Plan, Adopted September 2012, pp. 1-2 to 1-4.

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Residential between Highway 99 and low-density residential neighborhood to north, and Montana West from 99 to Sander Avenue.

Table C-1: General Plan Land Use Classifications and Residential Density Designation Classification Maximum/Minimum Density
VLDR Very Low Density Residential 0.2 – 3.0
LDR Low Density Residential 3.0 – 7.0
LDR-MDR Low and Medium Density Residential 5.0 – 10.0
MDR Medium Density Residential 7.0 – 15.0
HDR High Density Residential 15.0 – 40.0
DT Downtown Mixed Use 7.0 – 40.0
O Office NA
CC Community Commercial NA
HC Heavy Commercial NA
HWC Highway Commercial NA
RC Regional Commercial NA
I Industrial NA
BP Business Park NA
PUB Public/Semi-Public NA
P Park NA
UR Reserve NA
Northwest Triangle Specific Plan (1995, amended 2004)
New residential development was proposed to occur first in Turlock’s northwest quadrant and the Northwest Triangle Specific Plan was adopted in 1995 to allow development in that area. The Northwest Triangle Specific Plan (NWTSP) covers an area of approximately 800 acres in the triangle created by Golden State Boulevard to the east, Highway 99 to the west, and Fulkerth Road to the south. Its four goals are to implement the General Plan; allow development to proceed without unnecessary delay (by facilitating the approval of subsequent development projects consistent with the Specific Plan policies); provide for efficient extension of services; and establish funding mechanisms for the improvements.

Much of the NWTSP area has been built out. Low density residential and community commercial development dominates the southern part of the plan area. Highway-oriented commercial uses occupy the northern part of the plan area along Monte Vista Avenue. Some agricultural land remains in the southwest area, along West Tuolumne Road. The Pedretti Park community ball fields are also in the plan area.

Additionally, there are several other parcels adjacent to the plan area that were not included in the plan or annexed that could be included in the Specific Plan area, but this would require an update to the Specific Plan and associated environmental documentation.

North Turlock Master Plan (2001)
The North Turlock Master Plan (NTMP), completed in 2001, guided development in the Northwest quadrant of the City. The NTMP plan area is just east of the NWTSP, bounded by Tegner Road to the west, Christofferson Parkway to the south, Crowell Road to the east, and Taylor Road and the Turlock Irrigation District Lateral 3 to the north. The plan area encompasses approximately 370 acres. At the time of the plan’s creation, the land under study was not yet annexed to the city.

Appendix C: Housing Constraints Analysis
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The primary objective of the NTMP was to incorporate “smart growth” planning and design principles into the development of cohesive neighborhoods. The plan established a wide range of land uses, including low, medium, and high density residential, commercial, office, schools, and park sites. Furthermore, the residential, school, and open space areas were to be linked by a network of pedestrian and bike trails. As built, the neighborhoods in the NTMP include other “neo-traditional” design elements such as narrower streets, a diversity of housing types, homes oriented towards the street, and several streets with wide landscaped medians. The NTMP plan area also includes Turlock’s second high school, John H. Pitman (the first high school to be built in Turlock since 1904), and the new Regional Sports Complex.

Northeast Turlock Master Plan (2004)
The Northeast Turlock Master Plan (NETMP), focused on an area at the northeast corner of the City.

Covering approximately 255 acres, the plan area is bounded on the north by Taylor Road and the Turlock Irrigation District Lateral 3; on the east by the rear parcel lines of the lots that front the east side of Berkeley Avenue; on the south by the midpoint between Christofferson Parkway and Monte Vista Avenue; and on the west by Colorado Avenue, with a rectangular “finger” that stretches along Christoffersen Parkway to Olive Avenue. At the time of the plan’s creation, the subject area was not yet annexed to the city.

The NETMP pursued the goal of expanding carefully guided primarily residential development to the northeastern edge of Turlock and integrating it into the rest of the city. At the same time, the NETMP endeavored to create a well-defined “edge,” maintaining a clear separation between Turlock and the neighboring community of Denair. Nearly all the land in the plan area prior to development was productive agriculture, but the area was designated for growth in the 1992 General Plan. As built, the NETMP area consists primarily of low-density residential development, transitioning into very low-density residential development toward the plan area’s eastern edge. A greenbelt buffer, creating a transition zone from urban to rural uses between Turlock and Denair, includes detention areas and a community trail.

East Tuolumne Master Plan (2005)
The East Tuolumne Master Plan (ETMP) was adopted in 2005. The plan area covers approximately 100 acres along East Tuolumne Road between North Quincy and North Waring Roads. The purpose of the ETMP is like the Northeast Turlock Master Plan—to create a smooth transition from urban to rural land uses along the City’s eastern border, while creating a distinct boundary between Turlock and Denair. The plan calls for the development of very low density (generally less than three dwelling units per acre) single family homes, with some open space and trails. However, since the plan’s adoption, the market conditions in Turlock have not supported developing the land in this manner. The planning area remains largely agricultural with a few existing estate homes.

COUNTY ISLAND STRATEGY
The Turlock Planning Area includes several “County Islands,” areas of unincorporated county land that are surrounded by incorporated Turlock on all sides. The islands are a result of piecemeal annexation over the years and property owners’ interests and preferences. Generally, the county islands are not served by City infrastructure or services; some have no curb and gutter improvements, and their roads are not maintained to City standards. Similarly, Stanislaus County is technically responsible for their public safety services.

Annexing the county islands and bringing their public infrastructure up to City standards would help ameliorate public health and safety concerns in these areas several of which include older residential development. However, willingness on the part of landowners and Stanislaus County is necessary for incorporation, as is funding for infrastructure upgrades. Turlock is in the process of negotiating a costsharing strategy with the County that would split the cost burden between the two jurisdictions. For the largest of the islands (the “Montana-West” area), incorporation would likely take place through a master planning process like that for other unincorporated areas outlined later in this chapter. The Montana-West

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master plan area is not subject to the phasing policy that restricts when master plan development may proceed and could proceed at any time.

While a formal master planning process may not take place for incorporation of the smaller county islands, property owners seeking annexation must still demonstrate that they have a plan to finance the needed improvements to bring their properties up to City infrastructure standards. At the time that annexation is being considered, the City and property owners may also reexamine the General Plan land uses designated on the properties and determine whether higher density/intensity uses are warranted or desirable, especially if increasing the intensity of development would improve the financial feasibility of incorporation. Turlock has initiated the annexation of the 16-acre Kenwood-Starr unincorporated “island”, which Staff anticipates will be completed within the eight-year planning period. This area includes 52 residential parcels developed with older single-family homes, many of which are not well-maintained. Stanislaus County has already begun upgrading the infrastructure in the area including storm drain facilities, water lines, sanitary sewer facilities, sidewalks, and streetlights. Much of the estimated $5,270,000 cost of the improvements is being funded by the American Rescue Plan Act of 2021 (ARPA).2

GROWTH MANAGEMENT PROGRAM
Following the City’s rapid growth in the 1980s, the City of Turlock implemented several strategies for controlling the type, pace, and location of urban development. A growth management program was adopted in the early 1990s, which was later replaced in 1998 with a Residential Annexation Policy that focuses annexations and growth to one quadrant of the city at a time. Residential development in the northwest and northeast quadrants has proceeded since the 1990s via several Master and Specific Plan processes. This is in accordance with policies put in place in the current General Plan (adopted in 1993 and updated in 2002), which require that unincorporated areas for new development be pre-zoned prior to city annexation, that adequacy of public facilities be established, and that new development be contiguous to existing development. The current General Plan continues the policies (2.5-f and 3.1-g) requiring that 70 percent of one master plan area be complete (ie building permits issued) before development of the next master plan area proceeds, which allows for timely and efficient use of infrastructure and resources.

Some commenters on the Draft Housing Element have expressed the view that these policies, which have been in place since the General Plan was adopted in 2012, represent a constraint on housing development.

Staff notes that at the time the General Plan was adopted there were three existing master plan areas that were less than 70 percent complete: Northeast Turlock (approximately 50 percent complete in 2012), East Tuolumne (0 percent complete in 2012), and Morgan Ranch (0 percent complete in 2012). In the intervening years, development has proceeded in the master plan areas, and the Northeast Turlock Master Plan is now 100 percent complete, while the East Tuolumne Master Plan is nearing completion (building permits have not yet been issued for a small area of approximately 20 lots). Additionally, as noted in the Draft Housing Element, the City has funded the construction of a sewer lift station to assist with infrastructure feasibility for the Morgan Ranch Master Plan area and is in discussions with developers about modifications to minimum lots sizes to facilitate redevelopment in Morgan Ranch. Further, staff notes that, anecdotally, there is evidence that the master plan requirements have supported infill growth within the City limit, pushing developers to think more creatively about the design of projects as opposed to building formulaic subdivisions on agricultural land outside the City limit. As examples, staff points to two projects constructed or proposed by Florsheim Homes. With the Crowell Subdivision/Atrium project, Florsheim purchased underutilized land from a church within the City limit and developed it with single-family housing and Florsheim is currently pursuing a small lot subdivision on three adjacent parcels on Fifth Street. 2 Stanislaus County, Board Action Summary, September 20, 2022. https://www.stancounty.com/bos/agenda/2022/20220920/DIS01.pdf

Appendix C: Housing Constraints Analysis
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Overall, the City does not have a limit on the number of building permits that can be issued each year.

Research informing the General Plan update shows that ample vacant land exists for residential development within the City’s study area boundary to accommodate projected future population and employment growth over the next 20 years (see details in Chapter 4, and Appendix D: Growth Capacity Analysis of Planning Area Boundary). Therefore, growth controls do not pose constraints on housing development in Turlock. Additionally, the City has adhered to the provisions of AB 2292, which prevent the downzoning of a residential property without the concomitant up-zoning of a comparable property.

The City has not engaged in any systematic down-zoning of residential property, and keeps a record of all rezones, including some that were approved prior to the legislation. Down-zoning has not been permitted without documentation that the loss of dwelling units can be recaptured elsewhere in the city. Updates on the City’s “no net loss” efforts are reported in the Housing Element Annual Reports. Nevertheless, a new program has been added to the Action Plan in Chapter 4 calling for the City to review the growth management strategy and policies 2.5-f and 3.1-g with the next update to the General Plan, anticipated to begin in 2027.

ZONING CODE
The Turlock Zoning Ordinance (Turlock Municipal Code, Title 9) establishes five residential districts and allow residential uses in most other districts subject to specific requirements. Tables C-2 and C-3 list the housing types the Turlock Zoning Code allows in each district where residential uses are permitted with the required entitlement. Table C-6 summarizes the density, size, and parking requirements of the residential zoning districts.

Table C-2: Permitted Housing Types by Residential Zoning District Use Type
Zoning District
R-E R-L R-4.5 R-M R-H
Single Family P P P P P
Second
Dwellings1

P P P P P
Housing2 P1 P1 P1 P1 P1
Multi-Family X X X MDP MDP
Condominiums PD PD PD PD PD
Group Homes
13 or more X X X CUP MDP
7 to 12 X CUP CUP MDP MDP
6 or fewer P P P P P
Group Quarters
13 or more X X X CUP CUP
7 to 12 X CUP CUP MDP MDP
6 or fewer P P P P P
Emergency
Shelters

X CUP CUP CUP CUP
Manufactured
Housing3

P P P MDP CUP
Mobile Home
Park4

X CUP CUP CUP CUP

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Table C-2: Permitted Housing Types by Residential Zoning District Use Type
Zoning District
R-E R-L R-4.5 R-M R-H
Supportive and
Transitional
Housing1
P1 P1 P1 P1 P1
Notes:

P Permitted
X Not Permitted
PD Planned Development
CUP Conditional Use Permit
MDP Minor Discretionary Permit
MAA Minor Administrative Approval

1. Subject to TMC 9-2-119.

2. Employee, supportive and transitional housing serving 6 or fewer permitted as single-family unit, projects serving 7 or more subject to restrictions applicable to residential development of same type in same zone.

3. Subject to architectural review to ensure compatibility with adjacent residential buildings in terms of scale, height, and exterior design and treatment as provided in the design guidelines, including but not limited to roof pitch and style, window and door detailing, exterior materials, textures, colors, and finishes.

4. Subject to requirements for TMC 9-2-111, Mobile home development Table C-3: Permitted Housing Types by Non-Residential Zoning District Use Type Zoning District

A C-O C-C C-H C-T DC DCT TC IR OR
Single-Family P X X X X P P P P P
Employee
Housing1

P P -- -- -- -- -- -- -- --
Caretaker Unit2 X X X CUP X X X X -- --
Second
Dwellings P -- -- -- X -- -- X -- --
Multi-Family X X X X X P P X P P
Group Homes3
13 or more X MDP X X X X X CUP CUP CUP
7 to 12 P MDP X X X MAA MAA MDP CUP MDP
6 or less P P X X P
Artists’ studio
w. residential4 X MDP P P MDP MDP P MDP -- --
Group Quarters
13 or more X MDP X X X X X CUP CUP CUP
7 to 12 MDP MDP MDP MDP X MAA MAA MDP CUP MDP
6 or fewer P P P P P P P P P P
Emergency
Shelters5

X CUP CUP CUP X X X CUP CUP CUP

Appendix C: Housing Constraints Analysis
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Table C-3: Permitted Housing Types by Non-Residential Zoning District Use Type Zoning District

A C-O C-C C-H C-T DC DCT TC IR OR
Manufactured
Housing
MAA2 -- -- -- -- P2 P2 P2 P2 P2
Mobile Home
Parks

X X X X X X X X X X
Notes:

P Permitted
X Not Permitted
PD Planned Development
CUP Conditional Use Permit
MDP Minor Discretionary Permit
MAA Minor Administrative Approval

1. Any employee housing consisting of no more than 36 beds in group quarters or 12 units or spaces designed for use by a single family or household shall be deemed an agricultural use and subject to the same permitting requirements.

2. Subject to architectural review to ensure compatibility with adjacent residential buildings in terms of scale, height, and exterior design and treatment as provided in the design guidelines, including but not limited to roof pitch and style, window and door detailing, exterior materials, textures, colors, and finishes.

3. Subject to requirements of Article 2, Emergency Shelters, if site is in emergency shelter overlay district.

4. Artists’ studios in the downtown area may also be a place of residence for the artist as a secondary use. Artists’ studios must be compatible with adjacent uses and shall not be a nuisance regarding noise and dust.

5. Subject to requirements of Article 2, Emergency Shelter Regulations when located in Emergency Shelter Overlay District.

The Zoning Code includes provisions for home-based work in all residential units and for artist’ studios in the downtown area that allow a place of residence for the artist as a secondary use subject to a Minor Discretionary Permit. The Code does not, however, provide for work-live units for workers other than artists. The Zoning Code should be revised to establish provisions for work-live units as an alternative approach to accommodating those engaged in other professions and vocations who want to live and work in the same space. These provisions would treat work-live development as a commercial use with incidental residential subject to conditions intended to protect other uses both within and adjacent to the work-live occupancy. Many cities have found work-live development as a good way to provide affordable housing and workspaces while reducing the pollutants generated by commuting. Work-live occupancies can also help to generate support for retail commercial and service uses in the areas where they locate.

Compliance with numerous governmental laws or regulations can also add to the cost of housing.

Requirements for site coverage, parking, and open space can indirectly increase costs by limiting the number of dwelling units which can occupy a given piece of land. This is especially true with larger units when the bulk of the buildings and increased parking requirements occupy an increasing share of the site.

In some instances, developers must decide whether to build smaller units at the maximum allowable density or fewer larger units at a density less than the maximum. Either solution can have different impacts on the housing market. Building a higher number of smaller units can reduce costs and provide additional housing opportunities for smaller households but does not necessarily accommodate the needs of larger families.

Larger units can be made available to families, but because of their size and lower density, the cost of these units is higher.

LANDSCAPING
Landscaping is required for all zoning districts. Residential districts require 30 percent of the site to be landscaped. Such landscaping would include, but not be limited to, shrubbery, trees, grass, and decorative

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masonry walls. Landscaping contributes to a cooler and more aesthetic environment in the city by providing relief from developed and paved areas. It also improves water quality by filtering surface water runoff. All landscaping is installed by the developer and must be approved prior to occupancy of any building.

Additionally, subdivisions must, to the extent possible, promote energy conservation through passive/natural heating and cooling. Landscaping that provides shade helps achieve that design consideration.

Table C-4: Development Standards for Residential Zones
Zoning District
Bldg
Height
(ft.)
Yard Setback (ft.)
Minimum Lot
Area (sq. ft.)
Lot Area/
Dwelling
Unit
(sq.ft.),or
max density1
Open Space Front Side Rear
Residential
Estate (RE)
35 30 10 20 14,500 14,500 NA
Low Density
Residential (RL)
35 15 5 10 5,000 5,000 NA
Low Density
Residential 4.5
(RL 4.5)
35 15 0-10 10 4,500 4,500 900 sf
Medium Density
Residential (RM)
35 20 10-
20 10/
story
6,000 NA 500 sf
High Density
Residential (RH)
40 20 10-
20 10/
story
7,500 NA 500 sf
Source: City of Turlock Zoning Ordinance https://www.codepublishing.com/CA/Turlock/#!/Turlock09/Turlock093.html#9-3-203 Table C-5: Development Standards for Residential Uses in Mixed-Use and Overlay Zones
Zoning District Bldg Height
(ft.)
Yard Setback (ft.) Maximum
coverage Typical FAR Landscaping Front Side Rear
Downtown Core
(DC)
60 01 0 0 NA 3.0 for
mixed use

1.0 for
retail
commercial
None
Downtown Core
Transitional
(DCT)
45 10 5 10 60% 1.0 15% of lot
area 3
Transitional
Commercial (TC)
45 10 5 10 45% 1.5 10% of lot
area3
Industrial/
Residential (IR)
35 15 5 10 NA 10 du/ac 25% of lot
area
Office/Residential
(OR)
35 15 5 10 NA 10 du/ac 10% of lot
area

Appendix C: Housing Constraints Analysis
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Parking
Turlock requires two off-street parking spaces per unit for single-family units in low density residential districts and up to 1.5 spaces per unit in medium- and high-density residential districts. Residential development in the Downtown Core and transition areas is facilitated by reduced parking requirements. In the DC zone, no off-street parking provision is required; in the DCT zone, parking requirements are half of what the base residential zones require.

Table C-6: Off-Street Parking Requirements for Residential Units Use Type Required Spaces per Unit Additional Regulations Single-Family 2.0
Multi-Family 1.5 plus 1 guest space per 4 units No parking required in Downtown Core (DC); 50% of
parking required per Chapter 9-2
for uses located in in Downtown
Core Transition (DCT)
Second Dwelling Unit 1.0 May be tandem
Group Home1 1.0 per 400 sq. ft. of gross floor area No parking required in Downtown Core (DC); 50% of
parking required per Chapter 9-2
for uses located in in Downtown
Core Transition (DCT)
Emergency Shelter 1.0 per employee by shift plus 1.0 for every 10 beds
Mobile Home Parks Same as required for district in which park is located.

Notes:

1. Includes community care facilities, residential care facilities for the elderly, intermediate care facilities, nursing homes, assisted living facilities, alcohol and drug recovery, and other similar facilities that provide twenty-four (24) hour nonmedical services, supervision.

2. 1.0 space per unit designed for people with disabilities.

AB 2097 (Friedman), signed into September 2022, prohibits cities from imposing minimum parking requirements on residential, commercial, or other development if the project is within one-half mile of a major transit stop unless it makes certain findings supported by evidence in the record. Major transit stops, as defined by Public Resources Code Section 21064.3, means an existing rail transit station, a ferry terminal served by either a bus or rail transit service, or the intersection of two or more major bus routes with a service interval of 15 minutes or less during the morning and evening peak periods. There are no transit facilities in Turlock which meet this definition.

Height and Bulk Restrictions
Turlock allows building heights up to 35 feet (usually three stories) in all residential districts. As shown in Table C-7, Turlock has established more liberal standards for building height, coverage, and bulk in the overlay districts to encourage infill development while maintaining the traditional character of the areas where these regulations apply.

Table C-7: Height and Bulk Restrictions for Residential Units in Downtown Overlay Districts
Zoning District Height (ft.) Lot Coverage (%) Floor Area Ratio (FAR)

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Downtown Core (DC) 60 100 3.0
Downtown Core Transition
(DCT)
45 60 1.0
Transitional Commercial (TC) 45 45 1.5
Industrial Residential (IR) 50 100 1.5
Office Residential (OR) 40 60 0.8

ZONING FOR VARIETY OF HOUSING TYPES
Multi-Family Housing
The current Zoning Ordinance allows multi-family development in the Medium Density Residential (RM) and High Density Residential (RH) districts and in five Downtown Overlay Districts. In the residential districts multi-family projects require approval of a Minor Discretionary Permit and are also subject to Design Review; in the Downtown Overlay Districts multi-family development that complies with the applicable standards of the district where it is located is permitted by right. (See Tables 5.1-2-B and -C) During the 2014 to 2024 planning period, the City saw construction of 1,014 new homes; the majority of new homes built were detached single-family houses, with 277 multifamily units constructed. Even though most of Turlock’s housing is in single-family detached units, the proportion of multi-family units has increased more rapidly comprising 27 percent in 2021 compared with 32 percent statewide and 14 percent in the Modesto SMSA.

Accessory Dwelling Units (ADUs)
From the end of 2018 to the end of 2024, Turlock processed 27 applications for accessory dwelling units (ADUs); 11 projects were completed including four garage conversions and four new detached units. The project costs ranged from $2,000 to $200,000 with a median value of $27,500. During 2023, the city issued permits for 8 ADUs and 5 projects were completed while in 2024 16 ADUs were permitted. 3 The City Council adopted revisions to Section 9-2-119 Second Units of the Zoning Ordinance in May 2024 to comply with the most current State requirements. The Action Plan includes Program 1-E for updating the handout summarizing the ADU requirements and the discussion of “second dwelling” units on the City website. Program 1-G commits the City to submitting the ADU regulations to HCD for review to ensure compliance with recent State law.

Turlock received funding under the SB-2 program to pay for preparation of seven fully engineered plan sets that will be made available to the public at no charge. The plans, which are being prepared by an architectural firm working for Stanislaus County, Turlock, and the other cities in the County, will provide three options for ADUs smaller than 750 square feet, three larger ADUs, and a seventh option that consists of an ADU built above a garage.

Affordable Housing Density Bonus
Section 9-2-103 of the Zoning Ordinance includes a short summary of the purpose and requirements for affordable housing density bonuses with a cross-reference to the requirements codified in California Government Code Section 65915. The ordinance is structured to always reference the most current codified requirements so that it remains current and there is no need for frequent amendments to track changes in 3 City of Turlock, Annual Progress Report, 2023 and 2024.

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State law. Density bonus applicants make use of the City's uniform development application form, which includes a section used for determining the applicable density bonus under State law. Application and submittal requirements, review parameters, approval authority and processing timelines are specified in Section 9-5 of the Zoning Ordinance. Turlock has not established any additional bonuses or incentives for affordable housing or childcare facilities. During the eight-year period from December 31, 2015, to December 31, 2023, Turlock did not receive any applications for housing projects eligible for a density bonus under Government Code Section 65915.

Employee Housing
The State Employee Housing Act (Health and Safety Code Section 17000 et seq.) and associated regulations govern the requirements for construction, maintenance, use, and occupancy of privately-operated housing for five or more employees including living quarters provided in connection with any work, whether rent is involved or not, and housing in rural areas provided for agricultural workers. State law generally requires employee housing for six or fewer persons to be treated as a single-family structure and residential use. This provision applies not only to farmworkers but also to non-agricultural household employees, including those working for religious, educational, and other establishments.

Employee housing is defined pursuant to Section 17008 of the California Health and Safety Code and includes farm worker housing. In non-agricultural residential zones, accommodations for six or fewer employees are deemed a single-family structure pursuant to Section 17021.5 of the California Health and Safety Code. It is important to note the City of Turlock does not contain any land within city limits zoned for agriculture. Chapter 9-3, Article 1, of the Municipal Code outlines regulations to preserve and protect agricultural land from urban development if land were zoned for agriculture in the future. Further, within Chapter 9-1, Definitions, the Turlock zoning code specifies that employee housing “shall be as defined in Section 17008 of the California Health and Safety Code and shall include farm worker housing. In nonagricultural residential zones, accommodations for six (6) or fewer employees shall be deemed a singlefamily structure pursuant to Section 17021.5 of the California Health and Safety Code. In agricultural zones, accommodations of no more than thirty-six (36) beds in a group quarter or twelve (12) units or spaces designed for use by a single family or households shall be deemed a permitted agricultural land use pursuant to Section 17021.6 of the California Health and Safety Code.” Further, in Chapter 9-3, Base District Regulations, both Agricultural and Residential use classifications specify that “Employee, supportive, and transitional housing serving six (6) or fewer people is permitted by right. Transitional housing and supportive housing shall be considered a residential use of property, and shall be subject only to those restrictions that apply to other residential dwellings of the same type in the same zone.”, and the Agricultural use classifications specify that “Any employee housing consisting of no more than thirty-six (36) beds in a group quarters or twelve (12) units or spaces designed for use by a single family or household shall be deemed an agricultural use and subject to the same permitting requirements.” The Turlock zoning code is in compliance with the Employee Housing Act and no amendment is needed. Additionally, Turlock’s zoning and permitting processes comply with Health & Safety Code Section 17021.8 by providing a streamlined, ministerial approval process for eligible agricultural employee housing developments, and do not subject such developments to a conditional use permit, design review, or other discretionary approvals. The City will continue to monitor its zoning ordinance to ensure compliance.

The most recent US Census Bureau American Community Survey (ACS) five-year estimates reported that there were 1,405 Turlock residents employed in the “agriculture, forestry, fishing and hunting” industry in 2020 representing about 4.5 percent of the labor force. This is slightly below Stanislaus County (5.2 percent) but considerably higher than the 2.1 percent of jobs in this category statewide. Although agriculture remains important to Turlock’s economy and the economy of Stanislaus Count, jobs in this sector are not limited to workers involved in agricultural production and include a variety of titles such as engineers, technicians, heavy machine operators, and managerial positions with Foster Farms, California Dairies, and other larger agricultural processing companies based in Turlock as well as a wide variety of smaller crop farmers,

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orchard growers, egg producers, honey farms, wineries, and agricultural support companies with fewer than five employees.

Determining the breakdown by seasonal and permanent workers can be even more difficult. Based on the California Department of Education tracking of the student population of migrant workers, there were 3,849 reported student migrant workers in Stanislaus County in the 2016-2017 school year and 4,335 in 2020-2021, the most recent reported school year. According to County data, less than half of the 12,713 agricultural workers reported in 2020 worked 150 or more days a year. These temporary workers are probably have a greater need for affordable housing than workers with permanent positions.

The City of Turlock doesn’t qualify for U.S. Department of Agriculture funding for agricultural worker housing because its population exceeds 50,000. Instead, the City works with Stanislaus County, agricultural stakeholders, and developers/builders of farmworker housing in Stanislaus County and greater Turlock to identify available and suitable sites for farmworker housing. Turlock also uses the State density bonus provisions under Government Code Section 65915 to approve additional density and grant incentives and concessions for qualifying farmworker housing projects.

Because of the small size of Turlock’s farm worker population, the housing needs of this group are addressed through its standard affordable housing strategies. There is no housing designated for farm workers in Turlock, but both seasonal and permanent farm worker housing can be found in the nearby unincorporated communities of Westley and Empire and in other communities in Stanislaus County.

Mobile Homes and Manufactured Housing
State law requires that mobile homes (or manufactured homes) on permanent foundations be permitted by right in residential zones, subject to the same development standards and processes as single-family homes but does not require municipalities to permit mobile home parks.

The Turlock Zoning Ordinance defines “manufactured housing” as single-family detached housing built to the National Manufactured Housing Construction and Safety Standards Act of 1974 including structures known as manufactured homes, which do not have a permanent hitch for relocation. (Section 9-1-202 Definitions). Section 9-3-202, Use Classifications, allows manufactured housing in all districts where residential uses are permitted but requires a Minor Discretionary Permit in the R-M district and a CUP in the R-H district where single-family dwellings are permitted by right. Manufactured housing is also subject to architectural review “to ensure compatibility with adjacent residential buildings in terms of scale, height, and exterior design and treatment as provided in the design guidelines, including but not limited to roof pitch and style, window and door detailing, exterior materials, textures, colors, and finishes.” Requiring a CUP or other discretionary review to allow installation of a manufactured housing unit on a lot where stick-built units are permitted by right conflicts with State law. Government Code Section 65852.3 also states that architectural requirements imposed on a manufactured home structure shall be limited to its roof overhang, roofing material, and siding material. The cost and time required to obtain a CUP or other discretionary approval including design approval is a constraint to using manufactured housing.

Moreover, this requirement also conflicts with Section 9-5-1002 Applicability of the Zoning Ordinance, which states that design guidelines are advisory for permitted uses.

Section 9-2-111 Mobile Home Development of the Zoning Ordinance allows mobile home parks on any site at least an acre in size where residential use is permitted subject to approval of a conditional use permit.

Parks must meet all standards applicable to other development in the zoning district but allows modification to allow for the “unique site design requirements” of this use.

Appendix C: Housing Constraints Analysis
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The Action Plan proposes to revise the zoning ordinance to make manufactured housing subject to the same requirements applicable to stick-built units in the same district. The Plan also proposes to amend the Code and other regulations to allow small residential structures on a mobile base (“tiny homes”) to be treated as a type of ADU.

Single Room Occupancy (SRO)
Single-room occupancy (SRO) units are small, one-room units occupied by a single individual or couple that may have either shared or private bathroom and kitchen facilities. This type of housing is an alternative housing that is affordable to extremely-low-income households. The Fairfax Zoning Code does not define or establish any requirements specific to SRO housing although, as mentioned above, other chapters of the Municipal Code recognize these establishments as a type of multi-unit rental housing. As such, SRO housing would be allowed in the CL (Limited Commercial), CH (Highway Commercial), and CC (Central Commercial) zones subject to approval of a use permit. In the CH and CC zones, residential uses are only allowed above the ground floor.

Because of the potential SROs offer as an accommodation for very low-income individuals or couples, this Housing Action Plan includes a program to amend the Zoning Code to include a definition and standards for developing SRO housing, especially to meet the Town’s need to accommodate homeless and very lowincome persons and households.

C.2 Housing For Persons with Special Needs

PERSONS WITH DISABILITIES
The Federal Fair Housing Act, the Americans with Disabilities Act, and the California Fair Employment and Housing Act all require municipalities to enact regulations allowing modifications to development regulations to ensure that people with disabilities have equal access to housing. Many cities have met these mandates by adopting specific regulations allowing eligible applicants to request a modification or exception to any provision in the zoning or subdivision laws that create an obstacle to providing such access.

These federal and State statutes and the State housing element requirements also require municipalities to analyze and remove constraints to providing housing for persons with disabilities. These requirements limit the extent to which agencies can regulate housing to accommodate persons with disabilities including residential care facilities, housing for recovering alcoholics and drug users, sober living homes, and supportive and transitional housing.

The 2016 Housing Element included a program to revise its ordinances to meet the requirement for reasonable accommodation. In response, the City amended the Turlock Municipal Code to add the following language before each Municipal Code Section under property development regulations for each zoning district, which includes Article 2 Residential Districts (R-E, R-L, R-L4.5, R-M, R-H):
“The following schedule prescribes the development regulations for each residential district.

Deviations from the setback and height requirements for the purpose of providing accommodation for disabled access to an existing structure may be permitted upon approval of a minor administrative approval pursuant to Article 3 of Chapter 9-5 TMC.” Minor administrative approvals are those which are routine in nature and do not require a public hearing.

The purpose of minor administrative approvals is to provide speedy approval over the counter or within a time period of approximately five (5) to ten (10) working days, depending on the complexity of the specific proposal. The City of Turlock has approved requests for deviations from development standards for reasonable accommodations through building permits when the improvements require a building permit.

Exceeding the allowable hardscaped area of a front yard is one example of a development standard that was

City of Turlock – Housing Element Update 2023-31
Hearing Draft | August 6, 2026 C-15
allowed to be deviated from to accommodate an accessible ramp in the front yard of a home. There have been no requests for reasonable accommodation have been denied in Turlock.

FEMALE-HEADED HOUSEHOLDS
More than a quarter (27.9 percent) of Turlock households are headed by women without a spouse or partner. This proportion is slightly higher than the percentage of female-headed households countywide and statewide (25.3 and 26.2 percent respectively). Although single women comprise close to half of all female-headed households, 24.1 percent include children under 18, which is slightly higher than the County as a whole (23.0 percent) and significantly higher than Statewide (17.9 percent). More importantly, 27.8 percent of all households headed by women have incomes below the poverty line.4 There are no special constraints that regulations pose to female-headed households but problems that lower-income households in general are exacerbated by the lower wages women earn and the availability of affordable childcare.

Elderly women living alone have higher rates of poverty and even though some may be in owner-occupied housing, their lower incomes make it particularly difficult to maintain their homes.

TRANSITIONAL AND SUPPORTIVE HOUSING
Supportive Housing
Supportive housing is generally defined as permanent, affordable housing with on-site or off-site services that help residents who fall within the “target population” under state law improve their health status, and maximize their ability to live and, when possible, work in the community. Services may include case management, medical and mental health care, substance abuse treatment, employment services, and benefits advocacy. Supportive housing is further defined as “housing with no limit on length of stay and that is occupied by a target population as defined in the Government Code and subdivision (d) of Section 53260 of the California Health and Safety Code, that provides, directly or indirectly, a significant level of on-site or off-site services to help residents retain housing, improve their health status, and maximize their ability to live and, when possible, work in the residents’ community. (California Health and Safety Code Section 50675.14 (b))
“Target population” means persons with low incomes who have one or more disabilities, including mental illness, HIV or AIDS, substance abuse, or other chronic health condition, or individuals eligible for services provided pursuant to the Lanterman Developmental Disabilities Services Act (Division 4.5 (commencing with Section 4500) of the Welfare and Institutions Code) and may include, among other populations, adults, emancipated minors, families with children, elderly persons, young adults aging out of the foster care system, individuals exiting from institutional settings, veterans, and homeless people.

Transitional Housing
Transitional housing is a type of supportive housing used to facilitate the movement of people experiencing homelessness into permanent housing. A person experiencing homelessness may live in a transitional apartment for a predetermined period of time, however not less than six months while receiving supportive services that enable independent living. Transitional housing units are “residential units operated under program requirements that call for (1) the termination of any assistance to an existing program recipient and (2) the subsequent recirculation of the assisted residential unit to another eligible program recipient at some predetermined future point in time, which point in time shall be no less than six months into the future.” “Transitional housing” (California Health and Safety Code Section 50675.2 (h)) means buildings configured as rental housing but operated under program requirements that require the termination of 4 U.S. Census Bureau, ACS16-20 (5-year Estimates), Table B11012

Appendix C: Housing Constraints Analysis
C-16 Hearing Draft | August 6, 2026
assistance and recirculating of the assisted unit to another eligible program recipient at a predetermined future point in time that shall be no less than six months from the beginning of the assistance.

Regulations Regarding Transitional and Supportive Housing State law requires that transitional and supportive housing be treated as a residential use and be subject only to those restrictions that apply to other residential uses of the same development type in the same zone.

This housing can take several forms, including group housing or multi-family units, and typically includes a supportive services component to allow individuals to gain necessary life skills in support of independent living. For example, if the transitional housing is a multi-family use proposed in a multi-family zone, then zoning should treat the transitional housing the same as other multifamily uses in the proposed zone.

The State has enacted additional requirements that jurisdictions must address in their regulation of supportive housing. These include:
• Allowing supportive housing as a use by-right in all zones where multi-family and mixed-uses are permitted, including non-residential zones permitting multi-family uses, if the proposed development meets specified criteria in State law;
• Approval of an application for supportive housing that meets these criteria within specified periods; and,
• Eliminating parking requirements for supportive housing located within ½ mile of public transit.

SB 2, which amended the State housing law effective January 1, 2008, clarified that transitional and supportive housing types must be treated as residential uses and subject only to those restrictions that apply to other residential uses of the same type in the same zone. The Turlock Zoning Ordinance defines Group homes as any licensed or unlicensed “congregate housing arrangement for a group of unrelated individuals that share a condition, characteristic, or status not typical of the general population. This classification includes community care facilities, residential care facilities for the elderly, intermediate care facilities, nursing homes, assisted living facilities, alcohol and drug recovery, and other similar facilities that provide twenty-four (24) hour nonmedical services, supervision, or assistance for sustaining the activities of daily living, treatment, or for the protection of the individual. “(Section 9-1-202 Definitions) As noted in Table C-2, in Turlock, multifamily dwelling units are permitted by Minor Discretionary Permit in R-M and R-H zones. Multifamily dwelling units are also permitted by-right in all Downtown overlay districts, which include DC, DCT, TC, IR, and OR zones. Mixed-use development is permitted by-right in the DC zone, and conditionally permitted in DCT, IR, OR zones within Downtown.

Currently, transitional housing serving six (6) or fewer is permitted by-right in the R-M and R-H zones without any discretionary action. It is not clear whether transitional housing is permitted by-right or conditionally permitted in the Downtown overlay districts. To comply with State law, the Zoning Ordinance needs to be revised to remove the limits on number of people in transitional housing and permit transitional housing by right in the DC, DCT, TC, IR, and OR zones.

Similarly, while the Turlock Zoning Code permits supportive housing serving six (6) or fewer by-right in the R-M and R-H zones, the same limit in the number of residents is not imposed on other housing types in the R-M and R-H zones, and supportive housing is not clearly permitted by right in the DC, DCT, TC, IR, and OR zones, unlike other multifamily housing types. Additionally, the Code does not clearly establish timeframes for approval of applications as specified in State law or provide exemptions from parking requirements for proposed supportive housing projects located within one 1/2 mile of transit.

Accordingly, Programs 2-J and 2-P have been added to the Housing Action Plan to bring the Zoning Ordinance into fully compliance with applicable State law.

City of Turlock – Housing Element Update 2023-31
Hearing Draft | August 6, 2026 C-17
Residential Care Facilities
Since the passage of SB 520 in 2001, cities and counties have been required to permit supportive multifamily or single-family housing for the disabled in any residential zone that permits non-designated single or multifamily housing. In December 2022, HCD published a technical advisory on group homes which provides guidance for local jurisdictions in identifying and removing constraints on and discrimination against group homes. The technical advisory notes that "although the Group Home [Technical Advisory] focuses on group homes operating as single-family residences, the same principles apply to those operating, for example, as multifamily residences in multifamily zones." Specifically, HCD guidance on the treatment of group homes in local zoning states that:

Group homes that operate as single-family residences and that do not provide licensable services should be allowed in single-family neighborhoods, subject only to the generally applicable, nondiscriminatory health, safety, and zoning laws that apply to all singlefamily residences. This is true even if these homes have more than six residents. Because these homes are not providing licensable services, they should be treated the same as other residences.

Group homes that operate as single-family residences and that provide licensable services to six or fewer residents should be allowed in single-family neighborhoods, subject only to the generally applicable, nondiscriminatory health, safety, and zoning laws that apply to all single-family residences. This complies with, among other things, the Health and Safety Code protections for these smaller, licensed group homes.

Group homes operating as single-family residences that provide licensable services to more than six residents may be subject to conditional use or other discretionary approval processes. Local governments must still provide flexible and efficient reasonable accommodations in these permitting processes. This means that some requests for exceptions to permitting processes should be resolved through reasonable accommodation procedures instead of conditional use procedures. In addition, any substantive requirements for these group homes must still comply with the local government’s obligations to remove constraints on housing for persons with disabilities, affirmatively support it, and prevent discrimination against it.

The Turlock Municipal Code permits group homes with six or fewer persons in any residential zone, as well as the agricultural and commercial office districts, without restriction or additional permits. This allows proponents to locate these facilities in any area they can afford without additional development or permit costs. The development of group homes is therefore a market issue, not a regulatory issue. As of August 2024, Turlock had seven adult residential facilities with an approved capacity of 36 persons and 13 residential facilities for seniors with a capacity of 527 persons. Two adult residential facilities with a capacity for 10 persons and five senior residential facilities approved to accommodate 278 persons closed between 2014 and 2021. According to data from the State Department of Social Services Licensing Division, it appears that some of the closed facilities reopened under different management. 5 As noted above, HCD guidance states that, regardless of the number of residents, group homes that do not provide licensable services should be permitted in all residential zones in the same manner and subject to the same provisions as other single-family and multi-family uses. However, group homes providing licensable services to more than six residents may be conditionally permitted or subject to other 5 California Department of Social Services
https://www.ccld.dss.ca.gov/carefacilitysearch/FacList?facType=740&facility=&Street=&city=Turlock&zip=&coun ty=&facnum=

Appendix C: Housing Constraints Analysis
C-18 Hearing Draft | August 6, 2026
discretionary processes to the extent that such requirements and processes do not represent a discriminatory constraint. Per Section 9-3-202 of the Turlock Municipal Code, Unlimited Group Homes (13 or more residents) are not permitted in the R-E, R-L, or R-L4.5 zones and are permitted with a CUP in the R-M zone and with an MDP in the R-H zone. Large Group Homes (between 7 and 12 residents) are not permitted in the R-E zone but are permitted with a CUP in the R-L and R-L4.5 zones, and with an MDP in the R-M and R-H zones. No distinction between facilities that offer licensable services and those that do not is made. Therefore, to comply with State law, Program 2-P has been added to the Action Plan, pursuant to which the City will amend the zoning code to permit Unlimited and Large Group Homes that do not provide licensable services by right in the R-E, R-L, R-L4.5, R-M, and R-H zones subject to the same conditions and standards as apply to other permitted residential uses in the same zones, including parking standards. The Turlock Municipal Code requires one parking space per 400 square feet of gross floor area in group homes. While, this requirement is waived in the Downtown Core (DC) zone and reduced by 50 percent in the Downtown Core Transition (DCT) zone, in other zones it could result more required spaces for group homes than for other residential uses in the same zone. Additionally, AB 2162 (Government Code 65654) prohibits a local jurisdiction from establishing minimum parking requirements for supportive housing located within a half mile of a public transit stop.

There are no regulations relating to the siting of special needs housing in relationship to distance or location to one another. There are no special conditions for group homes that also provide services, such as counseling, if there will be six persons or fewer in residence, or if the larger facility is in a commercial zone or civic center. Unlimited and Large Group Homes providing licensable services to more than six residents would continue to require a CUP or MDP in zones where they are permitted. Similar facilities providing licensable services in Turlock, such as convalescent hospitals and day care centers, are subject to similar requirements. As such, these requirements do not represent a discriminatory constraint. Additionally, project proponents proposing group homes that provide licensable services to more than six disabled residents would be able to request exceptions to permitting processes through the City's reasonable accommodation procedures instead of conditional use procedures, consistent with federal and State law.

Turlock Municipal Code 9-5-604 establishes the following findings that must be made for granting of any CUP. There are no special requirements for group homes:
a. That the site for the proposed use is adequate in size and shape to accommodate such uses, all yards, open spaces, wall, fences, parking, loading, landscaping, and other features required by the Municipal Code or the Planning Commission to make sure such use is compatible with the land and uses in the vicinity;
b. That the site for the proposed use is related properly to streets and highways to carry the quantity and kind of traffic generated by the proposed use;
c. That the proposed use will not adversely affect the abutting property or the permitted use thereof with the provisions of conditions; and
d. That the site for the proposed use is in conformance with the General Plan.

Findings (b) and (d) include objective standards based on measurable requirements that can be externally verified. Findings (a) and (c), however, rely on interpretation or judgment by public officials, rather than uniformly verifiable, quantifiable criteria. Therefore, to ensure that conditional use permits for unlicensed facilities of 7 or more residents are issued on the basis of objective standards and that the required findings so that they are limited to objective standards that do not constrain these residential uses. Specifically, through Program 2-P in the Action Plan, finding (a) will be revised to remove the word “adequate,” which is subjective, and instead state that the proposed use will meet the applicable objective standards established in the Code for size and shape; finding (c) will be revised to state only that the proposed use will not exceed applicable objective standards for noise, odors, or other environmental considerations established in the Turlock Municipal Code to ensure land use compatibility.

City of Turlock – Housing Element Update 2023-31
Hearing Draft | August 6, 2026 C-19

INDIVIDUALS EXPERIENCING HOMELESSNESS
The 2025 homeless Point-In-Time (PIT) count tallied 2,086 persons countywide as displayed in Table C8a, including 241 in Turlock and 1,603 in Modesto.6 The number of people experiencing homelessness in
Turlock has increased slightly from 9.8 percent in 2024 to 11.55 percent in 2025; however, the share of people experiencing homelessness in Turlock has stayed relatively the same the past four years, though overall Stanislaus County PIT Count has increased. The Turlock homeless PIT count in 2025 tallied 241 individuals (11.55 percent), which was almost the same as the share counted in 203 (233 individuals, 11.14 percent) and 2022 (211 individuals, 11.36 percent).
7 Table C-8a Stanislaus County Point-in-Time (PIT) Count (2022-2025) Year 2022 2023 2024 2025
Count Percent Count Percent Count Percent Count Percent Turlock 211 11.36% 233 11.14% 201 9.80% 241 11.55%
Stanislaus
County
1,857 100.00% 2,091 100.00% 2,052 100.00% 2,086 100.00% Source: Stanislaus County Community Services Agency Homeless Management Information System (HMIS) Team Interim housing, which includes (but is not limited to) short term emergency shelters, women’s shelters and other emergency shelters, transitional shelters, and halfway houses, is currently permitted in all residential zones with a CUP but not by right. State law (SB 2 (Cedillo)) requires all jurisdictions to have at least one zone (where residential uses are allowed) in which at least one year-round emergency shelter is permitted by right. In order to address State law requirements, the City has adopted an Emergency Shelter Zoning Overlay in 2011 in Chapter 9-4 which applies in the downtown area and permits the development of such facilities without discretionary review subject to compliance with applicable objective standards.

The overlay, shown in Map C-1, applies to about 14.93 acres of Downtown and includes sites with base zoning of Heavy Commercial (CH), Community Commercial (CC), Industrial (I), Industrial Residential (IR), or Transitional Commercial (TC) zoning districts, all of which permit residential uses. The updated zoning establishes objective development and management standards as allowed by the State. These standards include:
• A maximum number of beds depending on the zone;
• A district-wide cap on the number of beds, to be reviewed annually by the Turlock City Council at a formal public meeting;
• Outdoor screening requirements if in proximity to residential zones; • Lighting requirements for outdoor areas;
• Off-street parking at a rate of one space per employee by shift plus one place for every 10 beds; however, parking available on street along the street frontage of the property on which the shelter is located may also be counted toward satisfying the off-street parking requirement.;
• Security plan and personnel requirements;
6 Executive Summary, 2025 Stanislaus County Homeless Point-in-Time Count, /https://csocstan.com/wpcontent/uploads/2025/06/2025-Final-PIT-Report-English-.pdf 7 Executive Summary, 2023 Stanislaus County Homeless Point-in-Time Count, https://www.stancounty.com/newsfeed/pdf/executive-summary-english.pdf

Appendix C: Housing Constraints Analysis
C-20 Hearing Draft | August 6, 2026
• No outdoor activity between 10pm and 8am; and
• Requirements for keeping pets on site.

In 2011, the Turlock City Council established a cap of 200 beds within the Emergency Shelter Overlay and referencing that cap, the Turlock Municipal Code Section 9-4-205 establishes a limit on the number of beds in any single shelter broken down as follows within downtown zoning districts:
• Forty (40) beds in the community commercial (C-C) and downtown transitional commercial (TC) districts;
• Seventy-five (75) beds in the heavy commercial (C-H) zoning district; and • One hundred (100) beds in the industrial (I) and downtown industrial residential (IR) zoning districts.

The cap and the related objective standards for non-discretionary permit approval were originally established based on shelter bed occupancy trends and input from homeless service providers. Specifically, the cap was developed based on a study of the usage statistics gathered during the operation of the Turlock cold-weather shelter from 2004 to 2008 and by reviewing the demand for homeless shelter provided by nonprofit organizations at the time that the ordinance was developed. The current ordinance allows for exceptions to the cap by CUP. Per Section 9-4-203, the cap is reviewed annually by the Turlock City Council at a formal public hearing. There have not been applications for shelters that would result in approaching or exceeding the cap in any year since it was enacted; however, as shown on Table C-8a, PIT data shows the number of homeless individuals has generally increased year-on-year since 2022 and the need has consistently exceeded 200 beds. Therefore, to ensure that the cap does not preclude the provision of shelter beds needed to meet the need as calculated on the basis of the latest available annual PIT data, through Program 2-R the City will increase the cap to 245 beds in Q2 2026 and annually each year thereafter will evaluate the need to raise the cap if needed to accommodate the need as calculated on the basis of the latest available annual PIT data. Further, as discussed in greater detail below, the projected need for shelter beds based on the most recent PIT count data can easily be accommodated on vacant sites within the emergency shelter overlay. The provision for an annual review of the cap in the Municipal Code and Program 2-R will allow for considerations of increased need for shelter beds on an ongoing basis throughout the Sixth Cycle and beyond. Linking the annual review to the latest available PIT count data will also ensure that the cap will not deter future emergency shelters that may be needed to accommodate unmet need. As such the cap does not represent a constraint on emergency shelters. The other approval standards established in the Code are all objective and consistent with the provisions for emergency shelter standards established in Gov Code 65583.(a)(4)(B). The standards have been used in the approval of facilities within the overlay, including existing facilities, since adoption in 2008 and do not represent a constraint on the establishment of shelters in Turlock.

Recent amendments to the requirements in Government Code Section 65583(a)(4) require local governments with zoning that only allows shelters by-right on sites zoned for nonresidential uses to demonstrate these sites are located near amenities and services that serve people experiencing homelessness, such as health care, transportation, retail, employment, and social services, or that the local government provides free transportation to these services or offers them on site. Downtown Turlock meets the requirements of Government Code Section 65583(a)(4) due to its proximity to local transit lines, including Turlock Transit and Stanislaus Regional Transit Authority bus service. In Turlock, emergency shelters are permitted in Downtown within the IR Industrial Residential and TC Transitional Commercial districts.

This location features easy access to amenities, jobs, retail, and healthcare. This area sits just south of the Turlock Town Center shopping center, which is home to grocery stores, pharmacies, banks, and medical offices, and is served by local bus routes, including service to Emanuel Medical Center, a full-service hospital in the city.

City of Turlock – Housing Element Update 2023-31
Hearing Draft | August 6, 2026 C-21
As noted above, the 2025 Point-in-Time Count found 241 persons experiencing homelessness in the City of Turlock. At about 200 square feet per bed per State requirements,8 approximately 48,200 square feet of building area would be required to accommodate this need. There are currently two shelters run by nonprofit groups in Turlock that provide shelter for homeless individuals, including Turlock Gospel Mission, who operate an 80-bed shelter and WeCare Program, who operate a 49-bed shelter that serves chronically homeless men over age of 18. Together these facilities offer a total of 129 beds. As such, this leaves a gap of 112 beds or 22,400 square feet of building area (at the 200 square feet per bed standard) to accommodate the unmet need of unsheltered people in Turlock. Accounting for the 129 existing beds within the emergency shelter overlay, the additional 112 beds would be accommodated by increasing the area-wide 200-bed cap as proposed through Program 2-R.

The sites inventory identifies 10 vacant sites within the Emergency Shelter Overlay with a total site area of 650,280 square feet, as shown in Table C-8b. The vacant parcels range in size from 0.15 acres (6,447 square feet) to 1.87 acres (81,388 square feet) and have an average size of 0.65 acres (28,249 square feet). As shown on Map C-1, the vacant parcels are all regularly shaped and dimensions or access to the street network would not present a challenge for development. One of the parcels (APN 043-049-002-000) is currently owned by Turlock Gospel Mission, an organization that currently operates an emergency shelter elsewhere in Turlock. As discussed in greater detail in Section C.6 of this Constraints Analysis, there are no environmental constraints that would preclude or complicate development of these vacant sites.

Specifically, these vacant sites are not located within a FEMA-delineated flood hazard area or within areas of geological or seismic hazards identified by the U.S. Geological Survey. Further, there are no humanmade hazards that would preclude development: no known cases of unremediated hazardous materials; no Williamson Act contracts; no airport and use regulations that would constrain development. Assuming the emergency shelters are single-story shelters, building area would be about 85 percent of the site area to account for circulation. As such, there is about 552,738 square feet of building area within the inventory to accommodate the unsheltered need. This square footage is well in excess of the 22,400 square feet of building area required to accommodate the 2025 Point-in-Time Count unmet need of 112 beds.

In addition to other revisions necessary to bring the Zoning Code into compliance with State law through Program 2-R, the City will amend the code to revise the definition of emergency shelter in Section 9-1-202 to expand the definition of “emergency shelters” to include other interim interventions consistent with Government Code section 65583, subdivision (a)(4), and through Program 2-I to include provisions applicable to Low Barrier Navigation Centers (LBNC), a type of emergency shelter. LBCNs focus on helping homeless individuals and families to more quickly obtain permanent housing. Government Code Section 65583.2 (i) stipulates that LBNCs shall be permitted by right in any mixed-use or non-residential district where multi-family housing is permitted subject to certain conditions. The Action Plan also commits the city to pursuing financial assistance and partnering with nonprofit agencies in support of housing development. Program 4-H, Pursue State and Federal Funds in Support of Housing Development, aims to increase the availability of housing and supportive services to the most vulnerable population groups and those with the greatest unmet needs, including people experiencing homelessness, by pursuing available State and federal funding sources to support efforts to construct housing. Furthermore, Program 2-J, Transitional Housing, and Program 2-P, Supportive Housing, plans to facilitate production of affordable housing by amending the zoning code to comply with State law regarding the treatment of transitional and supportive housing facilities, respectively. The City maintains a web page called Homelessness in Turlock that includes a resource guide and a list of service providers in the Turlock area including addresses, hours of operation and links to provider websites. See Appendix B, Housing Needs Assessment, of this Housing Element for more information about homelessness in Turlock and available resources. 8 California Government Code Section 65583 (I)

Appendix C: Housing Constraints Analysis
C-22 Hearing Draft | August 6, 2026
Table C-8b Parcel Characteristics of Vacant Sites in the Emergency Shelter Overlay APN Address Owner Existing
Use
Current
Zoning
Acres Square Feet
043-007-006-000 129 E

LINWOOD
AVE
RAJPUT KIRTI ET AL Vacant C-H 0.33 14,386
043-006-008-000 1500 LANDER
AVE
IMTIAZ IQRA Vacant C-H 1.55 67,555
043-003-002-000 1082 LANDER
AVE
RJ COMPANY LLC Vacant C-H 0.29 12,796
043-001-002-000 614 8TH ST PADILLA MIGUEL Vacant C-H 0.28 12,335 043-047-010-000 LANDER AVE FOSTER POULTRY
FARMS
Vacant C-C 0.15 6,447
043-036-017-000 S 1ST ST TURLOCK UNIFIED

SCHOOL DISTRICT
Vacant I 1.87 81,388
043-051-015-000 650 S 99 HWY YOKOI YAE Vacant I 0.96 41,899 043-048-017-000 B ST SJCA 3 LLC Vacant IR 0.19 8,439
043-048-007-000 B ST SJCA 3 LLC Vacant IR 0.50 21,988
043-048-040-000 3RD ST HARVEST CHURCH

OF TURLOCK INC
Vacant IR 0.44 19,012
043-050-004-000 475 S
GOLDEN

STATE BLVD

GUARANTY

HOLDINGS OF

CALIFORNIA INC
Vacant TC 0.66 28,846
043-049-002-000 1ST & D ST TURLOCK GOSPEL

MISSION
Vacant IR 0.47 20,475
043-049-075-000 0 3RD ST HACKLER RENTALS
LLC
Vacant IR 0.73 31,670
Average 0.65 28,249
Source: City of Turlock, 2021; Dyett & Bhatia, 2025

F St
Fifth St
C St
S Lander Ave
B St
A St
D St
East Ave
Ninth St
S Center St
E Linwood Ave
Third St
S Golden State Blvd
S Rose St
S Minaret Ave
Serr Dr
S Broadway

MYRTLE ST
English Ave
Locust St
High St
S Laurel St

MERRITT ST
Emily St
Mill St
Bethany Ave
Sixth St
Alpha Rd
Jessica St
Rockwood Ave
Castor St
South Ave
E Main St
OAK ST
BoxwoodWay
S Thor St
Angelus St
Marshall St
Bernell Ave
N First St
Amberwood Ln
Columbia St
LacyWay
W Olive Ave
Vermont Ave
West Main St
Lewis St
BirchwoodWay
Fouth St
N Center St

N ROSE ST
S Minerva St
Clark St
N Broadway
Ironwood Dr
N Laurel St
Seventh St
Pinewood St
Market St
N Minaret Ave
Race St
Crane Ave
Wagner Dr
Picard Ct
VillaWoods Dr
Blossom Dr
Lukas St
Eureka Dr
Fernwood Dr
Hartley Ln
Teakwood St
Fearlane Ave
N Lander Ave
Fifth St
D St
Locust St
W Olive Ave
S First St
Map C-1
Emergency Shelter
Overlay District
0 0.125 0.25 0.5
Miles
Source: City of Turlock, 2025; Dyett & Bhatia, 2025
Vacant Sites
Emergency Shelter Zoning Overlay
City Limit
Freeway
Major Road
Railroad

Appendix C: Housing Constraints Analysis
C-24 Hearing Draft | August 6, 2026
C.3 Development Review Process, Fees, and Exactions
The cost associated with developing residential units is related to the fees or other exactions required of developers but also the length of time needed to conduct project review and issue land use entitlements.

Lengthy review periods increase financial and carrying costs and fees and exactions add to expenses. These costs are in part passed onto the prospective homebuyer in the form of higher purchase prices or rents, and can, therefore, affect affordability. In addition to charging applicants for the cost of reviewing their applications, Turlock has established a system of impact fees to pay for constructing the public facilities needed to support new development including water and sewer transportation and treatment, storm drainage, streetlights, traffic signals, parks and other capital facility development costs. The City has also enacted fees to pay for the cost of developing master plans.

The time allowed for project review and approval is consistent with that provided by State law. Depending on the conformity of a project application with the General Plan and the Zoning Ordinance, and magnitude and complexity of a development proposal, the time required to process a project varies greatly from one project to another. Factors which can affect the length of development review on a proposed project include a rezoning or General Plan amendment requirement, public meetings required for Planning Commission or City Council review, or a required Negative Declaration or Environmental Impact Report (EIR). Table C-9 identifies the most common steps in the entitlement process. It should be noted that each project does not necessarily have to complete every step in the process (i.e., small scale projects consistent with General Plan and zoning designations do not generally require Environmental Impact Reports, General Plan Amendments, Rezones, or Variances). A residential project on an appropriately zoned parcel would only require a Minor Discretionary Permit (staff-level review) and Design Review.

A single-family subdivision that is consistent with the zoning of the parcel is processed as a Vesting Tentative Subdivision Map or Tentative Subdivision Map depending upon how the applicant chooses to submit the map. The Subdivision Map is taken to the Planning Commission for review for one public hearing. A map that is exempt from CEQA is taken to Planning Commission within 60-70 days from receiving a complete application. A map that requires a Negative Declaration or Mitigated Negative Declaration is taken to Planning Commission within 90-100 days of receiving a completed application.

Turlock Municipal Code 11-5-303 contains the findings for review of the tentative map. These findings are the same findings in Section 66474 of the Subdivision Map Act. A single-family home being built on an existing lot which is not being subdivided and is consistent with zoning is only subject to a building permit, no land use entitlements or discretionary actions are required.

Property owners within a 500’ radius of the project are mailed public notices, and a public notice sign is required to be installed on the project site. At the beginning of the year a Planning Commission submittal calendar is published by the Planning Department so applicants know based upon their submittal date, the date of the Planning Commission meeting their item will be heard. This creates certainty for applicants on land use entitlement processing times.

For multifamily development that is consistent with zoning a Minor Discretionary Permit (MDP) is required. This is a staff level approval and is issued within 8 to 10 weeks for project Exempt from CEQA and within 10 to 12 weeks for projects which require a Negative Declaration or Mitigated Negative Declaration. The findings for Minor Discretionary Permits are in Section 9-5-312 of the Turlock Municipal Code and are as follows:
9-5-312 Minor discretionary permit: Approval:

Findings: Conditions.

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(a) The Development Services Director or his/her designee may approve, conditionally approve, or disapprove an application for a minor discretionary permit. In approving a minor discretionary permit application, the Development Services Director or his/her designee shall find that the following are fulfilled or shall impose reasonable conditions to ensure that they are fulfilled:
(1) The proposal is consistent with the Turlock General Plan, the zoning ordinance and all other adopted plans for the site;
(2) The proposal is in harmony with the existing or proposed development in the general area or neighborhood and will be compatible with adjacent structures and uses, including those on adjoining properties; (3) The proposal is consistent with the development plan, terms, conditions, and/or intent of any planned development or conditional use permit currently in effect on the property;
(4) Any structural elements contained within the proposal are of high quality design consistent with the intent of the City Design Element of the Turlock General Plan and the exterior design, appearance, materials, and colors will not cause the nature of the neighborhood to materially depreciate; (5) The proposal will not otherwise constitute a nuisance or be detrimental to the public safety, health, and welfare of the neighborhood and community. (b) An approved or conditionally approved minor discretionary permit shall become effective on the date that it is acted upon by the City.

Adjacent property owners are mailed a public notice, and the project is routed to all interested agencies for review and comment. No public hearing is conducted, MDPs are issued at staff level unless appealed to Planning Commission. Turlock staff say that the City’s typical processing procedures and time frames do not pose undue constraints to the ability of project applicants to develop multi-family and lower-income housing projects. However, minor discretionary permit approval findings 2 and 4 require personal or subjective judgment and as such do not represent objective standards as required under State housing law.

Therefore, as part of Program 2-C in the Action Plan, the City will amend minor discretionary permit approval findings 2 and 4 to remove subjective findings and replace with objective standards that are based on measurable criteria and verifiable external benchmarks. Specifically, the revised findings should reference applicable objective standards related to exterior design, appearance, materials, and colors in the Zoning Ordinance.

Turlock received various housing applications in recent years, ranging from single-family, multifamily, and ADUs. Specifically for multifamily, an application for Tegner Townhomes, a 31-unit multifamily residential project, was received in February 2022 and approved in May 2022. The project required approval of a Minor Discretionary Permit and a design review. The project was categorically exempt from provisions of CEQA under Section 15332 In-Fill Development Projects. Another application for a 261-unit multifamily residential project at 4121 Geer Road was received in April 2022 and approved in January 2023. The project also required approval of a Minor Discretionary Permit and design review. The project was approved with an initial study and negative declaration. Lastly, an application for a 348-unit family residential project at 1525 W. Monte Vista Avenue was received in May 2021 and approved in August 2021. Similar to other multifamily applications, this project required approval of a Minor Discretionary Permit and a design review. The project was approved with an initial study and negative declaration.

Appendix C: Housing Constraints Analysis
C-26 Hearing Draft | August 6, 2026
Use Permits
The Turlock Zoning Ordinance establishes several different types of approval for projects subject to discretionary review--Minor Discretionary Permits (MDP) are reviewed and may be approved by the Development Services Director unless the applicant or other affected person requests a hearing or submits a statement opposing the project; Conditional Use Permits (CUP) require review and approval by the Planning Commission. The findings the existing ordinance requires for action on both MDPs and CUPs are subjective and, therefore, inconsistent with the requirements of State law, which mandate objective standards for review of residential projects.

Certain review and approval procedures may run concurrently, and the City encourages joint processing of related applications for a single project. For example, a rezone petition may be reviewed in conjunction with the required site plan, a tentative tract map, and any necessary variances. Such procedures save time, money, and effort for both the public and private sector. Processing timelines comply with the Permit Streamlining Act (Government Code Section 65920 et seq. and could not be made much shorter, if at all, without violating State laws, particularly as they relate to public noticing, compliance with the California Environmental Quality Act, etc. The City received a grant under the SB 2 program to prepare objective standards to meet the requirements of SB 35, which will also bring the ordinance into compliance with other provisions of the Housing Accountability Act.

The City also offers an optional Planned Development process that may be used by property owners and developers proposing residential projects that do not conform to the standards for established zoning districts. The procedures are established in Section 9-2-113 of the Turlock Municipal Code with the intent of encouraging variety in developments by allowing greater freedom and flexibility with the use of alternative development standards and providing a mechanism whereby the City may authorize desirable developments consistent with the Turlock General Plan. Deviations from setback requirements, minimum lot size and lot dimension requirements are an example of the types of standards an applicant may ask for through a Planned Development. Planned Developments require two public hearings. The Planned Development application is first heard by the Planning Commission and the Planning Commission makes a recommendation on the application to the City Council. The City Council hears the Planned Development request and if approved the item then goes back to the next Council meeting for a second reading and is enacted 30 days after the second reading. The PD Zone is applied to a property after approval to codify the standards established through the process. Planned Development is not a barrier to housing production in Turlock; rather it is a flexible tool that permits a wider variety of creative and innovative designs tailored to site-specific conditions.

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Table C-9: Development Review and Approval Procedures – Turlock Action/Request and Fee Processing Time* Fee
Conditional Use Permit
Minor
Medium
Major
8 to 12 weeks Including Planning Commission hearing.
$4,338
$7,409
$10,821
Minor Discretionary Permit
Minor
Medium
Major
5 to 6 weeks Staff Level Review
$2,879
$5,628
$8,111
Design Review (no fee) Concurrent with other
permits
Staff Level Review
Environmental Impact Report Per CEQA requirements 17 % of EIR consultant Negative Declaration Per CEQA requirements
plus time for document
preparation
$2,250 to $6,231 if additional studies are
required
General Plan Amendment 4 to 6 months
(applications processed
once per quarter)
$13,836 including Planning Commision
and City Council hearings
Rezone
Minor (< 5 acres)
Major ( > 5acres)
4 to 6 months Including City Council and Planning
Commission hearings
$8,300
$9,468
Planned Development Application
Review
Minor (< 5 acres)
Major ( > 5acres)
Amendment
4 to 6 months
Minor $10,944
Major $14,356
Minor Amend. $5,491 (Planning
Commission)
Major Amend. $7,198 (City Council)
Parcel Map 3 months $2,198
Extension $1,196
Tentative Subdivision Map
0-10 acres
11-20 acres
21-50 acres
> 50 acres
50 days Including Planning Commission hearing.
$ 7,283
10,126
12,970
15,472
Variance 3 months $3,104
Development Agreement $15,125 plus fees for additional actions Notes:
* From date application is deemed complete.

Source: City of Turlock Planning Fees, Eff. Janury 1, 2023; Application Instructions, p. 3

Appendix C: Housing Constraints Analysis
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Design Review
Turlock requires design review for projects that are subject to a minor administrative permit, minor discretionary permit, conditional use permit or other discretionary approval (Turlock Zoning Ordinance, Section 9-5-1002) including multi-family rental units in the R-M and R-H districts and all condominium development. As noted above, the current ordinance also requires design review for manufactured units on lots where single-family homes are permitted by right, which appears to conflict with State law. The Ordinance states that design guidelines are advisory for permitted uses but doesn’t explain how the City conducts this advisory review.

The citywide design guidelines are advisory for permitted uses and explicitly intended to provide examples of potential design solutions and help to explain the Zoning Ordinance’s mandatory regulations (p. iv). 9

The Downtown Design Guidelines are more detailed but, like the citywide design guidelines, are out of date.10 Both documents include a combination of prescriptive and advisory provisions that Turlock could use as a basis for developing objective standards that meet State requirements for review of residential development.

Pre-Application Review
When developers have a project proposal, Turlock invites them to a Predevelopment Meeting. These meetings, held each week free of charge, provide developers with an opportunity to meet with various City staff representing numerous City departments (e.g. planning, building, housing, redevelopment, engineering, fire, etc.) to strategize about project design, City standards, necessary public improvements, and funding opportunities (where appropriate).

Application Fees
A brief survey shows that the City of Turlock charges somewhat above-average planning application fees when compared to its neighboring jurisdictions. For example, Turlock requires a deposit of $8,275 for a General Plan amendment, while Modesto, Stanislaus County, Ceres, and Patterson fees are all less. In Turlock, the average cost for a 20-lot subdivision would be between $5,070 and $7,230, while in Patterson, Ceres, and Stanislaus County, the total cost is several thousand dollars less. However, Turlock’s fees are designed to recover costs for all City departments, not just the Planning Division’s costs of reviewing the application. Table 5.1-3 details the planning application fees of Turlock and its neighboring jurisdictions.

Turlock has enough vacant residentially zoned land to accommodate its housing needs for Above Moderate Income housing, making it unlikely that a General Plan amendment or a zoning change would be necessary for new single-family housing development built in the city. Residential projects that meet all applicable development and design standards and in which 20 percent or more of the units are affordable to lower income households may be developed by right on properties included in in the Sites Inventory. Projects that are located on a site in any Downtown Overlay District are also permitted by right. 9 City of Turlock Design Guidelines, Undated https://www.cityofturlock.org/_pdf/files/DesignGuidelines.pdf 10 City of Turlock Downtown Design Guidelines & Zoning Districts, Adopted September 23, 2003 https://www.cityofturlock.org/_pdf/files/DowntownDesignGuidelines.pdf

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Table C-10: Planning Application Fees – Turlock and Surrounding Jurisdictions Jurisdiction Conditional Use Permit Rezone Tentative Subdivision Map Variance
Turlock $4,338 to $10,821 $8,300 to
$9,468
$7,823 to $15,472 $3,104
Modesto $6,041 ($1,584 for SF
dwelling)
$4,323 $6,195 $2,877 ($1,584
for SF dwelling)
Stanislaus
County
$5,549 (non-agricultural
zone)
$12,162 $8,954 + $30/lot $4,913
Source: Turlock Planning Fees, eff. 1/1/23; Modesto Planning Division Fee Schedule, eff. 9/1/23; Stanislaus County Planning Services Fee Schedule, eff. 7/22/23
Impact Fees
Impact fees, land dedications, or improvements are required for most new residential development to ensure public parkland is sufficient to meet City standards and to provide other necessary infrastructure (streets, sewers, and storm drains) to support new development. While such costs are charged to the developer, most, if not all, additional costs are passed to the ultimate product consumer in the form of higher home prices or rents.

The significance of the necessary infrastructure improvements in determining final costs varies greatly from project to project. The improvements are dependent on the extent and adequacy of existing improvements and nature of the project. A Capital Facility Development Fee to offset the cost of transportation, police, general government, and fire protection is assessed to each new housing unit constructed in the city. The amount of the fee is determined by the land use type and the quadrant in which the project is located. On average, the per-unit fee cost is $8,993 for low density residential and $6,472 for high density residential.

This fee can be deferred for projects with affordable units if it can be clearly demonstrated that the fee (alone) will increase the cost of the housing so that it is no longer affordable to low-income households.

Table C-11 lists the development impact fees charged for a representative single-family unit (at 6 dwelling units per acre and with a unit size of 2,000 square feet) and multifamily unit (at 20 dwelling units per acre and with a unit size of 1,000 square feet). Due to some efficiencies associated with developing multifamily housing, the total fee amount for the multifamily unit is nearly $9,000 lower than the single-family unit ($21,812 versus $30,582).

Development impact fee schedules are updated quarterly to account for increases in construction costs. In 2015, Turlock established a fee deferral program for residential development similar to its existing program for commercial and industrial development. The program allows Development Impact Fees to be deferred until close of escrow. The City also participates in the Statewide Community Infrastructure Program (SCIP), which allows property owners to have selected fees for public capital improvements and development impact fees to be financed by the issuance of tax-exempt bonds by the California Statewide Communities Development Authority (CSCDA), a joint powers authority sponsored by the League of California Cities and the California State Association of Counties.

Appendix C: Housing Constraints Analysis
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Table C-11: Development Impact Fees (Effective 1 January 2023) Fee
Single Family
(assumes 6
du/ac and a
2,000 SF unit)
Multifamily
(assumes 20
du/ac and a
1,000 SF unit) When Due
Water Grid $2,457 $2,457 Building Permit
Water Frontage $48 $48 Map Recording or Building Permit Water Connection $2,250 $2,250 Building Permit or Water Permit Waste Water Plant Capacity $3,719 $3,719 Building Permit Sewer Frontage $2023 $25 Building Permit or Sewer Permit Sewer Connection $1,800 $1,800 Sewer Permit
Sewer Trunk Capacity $3032 $2399 Building Permit
Master Storm Development $8642 $15,136 Final Map
Capital Facility Development1 Building Permit
SE Quadrant $8,638 $6,252 Building Permit
SW Quadrant $9,394 $6,721 Building Permit
NE Quadrant $8,966 $6,455 Building Permit
NW Quadrant $9,590 $6,842 Building Permit
Northwest Triangle SP Area $8,378 $6,091 Building Permit Average $8,993 $6,472 Building Permit
School2 $9,120 $4,560 Building Permit
Building Permit Tax3 $125 $100 Building Permit
Park Improvement $1,268 $1,268 Building Permit
Street Light Development Building Permit
Total Fees per Unit4 $30,582 $21,812

1. Community Facilities Development fee includes transportation, police, fire, and general government.

2. School fees based on Turlock Unified School District rate of $4.56 per square foot. Some land within Turlock city limits lies in the Denair Unified School District, where fees are $2.97 per square foot.

3. Covers water well, transportation, traffic signal, public safety, and park development. Fee is based on number of bedrooms; calculation assumes 3 bedrooms for single family and 2 bedrooms for multifamily.

4. Total includes the average Capital Facility Development fee.

5. Assumes 40 feet of frontage/unit ($11.67/foot on non-arterial for SF and 60 feet of frontage for MF on arterial ($23.33 /foot)
Source: City of Turlock Development Services, Development Impact Fees, Effective 1 July 2023 to 30 September 2023 https://www.cityofturlock.org/_pdf/devimpactfee.asp?id=64 Additionally, there are development impact fees associated with the Master and Specific Plan areas in which much new residential development occurs. These fees generally cover additional sewer, storm drainage, transportation, and water infrastructure above the standard development impact fees levied by the City, to reflect the cost of extending services to newly developed residential areas. In the past, these fees have ranged from $3,000 per unit for the Northwest Triangle Specific Plan Area to over $55,000 per unit in the East Tuolumne Master Plan Area. New development occurring on vacant parcels in these areas would be subject to these additional fees; however, the housing sites identified in this document for affordable housing are located outside of the existing Master and Specific Plan Areas in the northwest and northeast.

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The Turlock Unified School District (TUSD) and the Denair Unified School District (DUSD) serve the City of Turlock. TUSD and DUSD have school impact fees on new development of $4.56 and $2.97 per square foot, respectively. These fees can add significantly to the cost of development, but they are consistent with the amount established by California Government Code Section 65995 et seq. Senior housing is exempt from school fees because it does not impact the demand for schools.

Fees as a Percentage of Development Costs
The following Table C-12 illustrates the total development costs for a typical single-family home in Turlock, taking the sample unit used in Table C-11 above as an example: a 2,000 square foot home built at a density of six units per acre. The analysis assumes the unit is part of a 50-lot subdivision in a master plan area with average impact fees. As the table shows, total fees make up approximately 11 percent of the total development cost for a typical single-family unit in Turlock.

Table C-12: Total Development Cost and Fee Percentage for One Typical Single-Family Home Development Component Fee or Cost Percent of Total Development Costs Construction1 $156,000 55.8%
Land2 $77,167 27.6%
Impact Fees3 $30,580 10.9%
Permitting Fees4 $277 0.1%
Subtotal: Fees $30,857 11.0%
Other Soft Costs5 $15,600 5.6%
Total $279,624 100.0%

1. Assumes construction costs of $78 per square foot.

2. Assumes average residential land price of $463,000 developed at six units per acre.

3. Assumes the average impact fee for a single family home.

4. Assumes fees for parcel map, subdivision map, and Minor Discretionary Permit for a 50-unit subdivision.

5. Assumes that other soft costs (besides fees), including architecture, administrative, etc. are approximately 10 percent of construction costs.

Source: Dyett & Bhatia
SB 35 Streamlining
Government Code section 65913.4 allows qualifying development projects with a specified proportion of affordable housing units to move more quickly through the local government review process and restricts the ability of local governments to reject these proposals. The bill creates a streamlined approval process for qualifying infill developments in localities that have failed to meet their RHNA, requiring a ministerial approval process, removing the requirement for CEQA analysis, and removing the requirement for discretionary entitlements. The City did not make sufficient progress toward its Above Moderate RHNA for the 5th cycle planning period (2015 – 2023) and is therefore subject to SB 35. The Action Plan proposes to amend the Zoning Code to establish regulations consistent with State law to review and make decisions on projects eligible for processing under SB 35 including applicable objective development standards.

Associated programs include preparation of application forms that Staff can use to quickly determine whether projects are eligible for expedited processing. The City has not received any SB35 applications to date.

Appendix C: Housing Constraints Analysis
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SB9 California Housing Opportunity and More Efficiency (HOME) Act SB9, also known as the California Housing Opportunity and More Efficiency (HOME) Act, requires cities to allow one additional residential unit onto parcels zoned for single-dwelling units. Turlock has not amended its regulations to permit duplexes in qualifying single family zoning districts or to allow subdivision of qualifying lots ministerially pursuant to SB9. The Action Plan includes a program to provide information to familiarize owners with the SB 9 program and revise the Zoning and Subdivision Ordinances to implement the State law.

Building Codes and Enforcement
Turlock has adopted the 1997 Uniform Housing Code and the Uniform Code for the Abatement of Dangerous Buildings and all the State’s 2022 building and construction codes including Residential, Existing Buildings, Green Building, and the Fire Code. 11 The Uniform Code for the Abatement of Dangerous Buildings applies to all buildings, old or new. These building codes ensure structural integrity and facilitate the City’s efforts to maintain a safe housing supply. The City has engaged two consulting firms, Bureau Veritas-North America Inc., and CSG Consultants, to provide plan review services. All applications for significant residential projects, including substantial improvements, are submitted electronically and the Building in Turlock website provides extensive information about the plan review process, submission requirements, predevelopment meetings and other procedural issues. The website also includes a fee estimating tool.12 The City of Turlock has not adopted any local amendments to the building code that impact the cost or supply of housing, as noted by City planning staff. The City of Turlock Building Regulations can be found in Title 8 of the Turlock Municipal Code13 and at Turlock City Hall.

Responsibility for code enforcement is shared between City departments. For cases involving illegal storage of property, parking violations, and weed abatement, the Code Enforcement Unit, a division within the Police Department, takes the lead. The Code Enforcement Unit is dedicated to improving the quality of life in the City of Turlock for its residents. The Unit accomplishes this through public education regarding and enforcement of local and State regulations. The Development Services Department is responsible for code enforcement on other matters. Planning Division staff takes the lead on complaints for issues such as fences constructed in the wrong location, structures constructed within the required setback areas, and unpermitted uses of structures. Building Division staff takes the lead on complaints regarding construction done without required permits.

The City of Turlock works with property owners to bring their properties into compliance by giving them time needed to make the required corrections. The goal of code enforcement is compliance and is not punitive. Turlock Municipal Code Title 2 establishes the Administrative Citation process that can be used for code enforcement cases. Property owners with limited incomes may be unable to afford the repairs required to meet code standards. To help address this, Turlock dedicates Community Development Block (CDBG) funding to provide loans and grants to rehabilitate single- and multi-family affordable housing. In FY-2022-23 the City allocated $900,000 for this purpose. Additionally, the City provides$5,000 for families 11 Building in Turlock, Current Code and Design Criteria https://www.cityofturlock.org/buildinginturlock/buildingsafety/currentcodedesigncriteria.asp 12 City of Turlock, 2025. Building in Turlock, Development Fee Estimate. Available:
https://www.cityofturlock.org/buildinginturlock/developmentfeeestimate/ 13 City of Turlock, 2025. Turlock Municipal Code, Title 8 Building Regulations. Available:
https://www.codepublishing.com/CA/Turlock/#!/Turlock08/Turlock081.html#8-1.

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who need to be temporarily relocated during construction, but these funds are only sufficient to pay for about 10 units.14
Length of Time Between Planning Approval and Permits
The time between planning application approval and building permit issuance is influenced by multiple factors, many of which are out of the city’s control. These factors include the time it takes the design professionals to prepare the construction drawings for the buildings and the civil improvement plans for the site work, secure financing and select contractors. It is also common for applicants to get properties entitled for development and then market to see the property with the approved land use entitlement to prospective builders which can also add time between approval and permits as the property owners try to find and negotiate with prospective builders. It can sometimes also lead to amendments being needed to the original entitlements if the builder is interested in the project but wants to make significant enough changes from the previous approval which requires amendment.

Planning approvals are good for one year but if plans have been submitted to the Building or Engineering Division for building, grading or encroachment permits the land use entitlement remains in effect unless the Building or Engineering applications or permits expire. Applicants can also apply for time extensions for their Planning approvals if needed.

On average it takes 4 to 8 months from planning approval to building permit plan submittal and on average it takes 3 to 12 months from building permit plan submittal to building permit issuance. The time from building permit submittal to issuance is largely affected by the time it takes for the design professionals to make the necessary revisions to respond to plan check comments.

The City does allow for concurrent review of construction drawings with the land use entitlement processing. This is at the risk of the applicant as any changes required through the entitlement process would have to be updated in the construction drawings. The City is actively looking at ways to reduce the time it takes to obtain permits. The City has hired Rafetalis Group to evaluate the processes in the Development Services Division to make recommendations for improvements. As part of this process the consultant has interviewed staff, interviewed contractors, applicants and design professionals who have worked in Turlock as well as are in the process of reviewing all department processes and documents. The report generated from this review will help guide improvements the department can make to help expedite the permit process. The City is also in the process of purchasing new permitting software which will automate the plan review routing process and will track time spent in review while alerting staff to upcoming deadlines to ensure projects stay on track. The software is budgeted for in the FY2025-6 Annual Budget and a vendor has been selected. Once the software is in place, applicants will also be able to sign in and see in real time where their projects are in the review process. This will also help improve plan check turn around times and will add transparency to the process.

Requests to Develop at Densities Below Inventory Assumptions State Housing Element law requires the non-governmental constraints analysis to evaluate developer requests to build at densities below that assumed in the Housing Element sites inventory. The projected densities used for the realistic capacity of sites on the inventory in Appendix A were developed based on a survey of recent residential development projects in Turlock and other peer jurisdictions. Several recent projects in the City of Turlock have been built at or above the densities assumed in the inventory. For example, 1525 West Monte Vista currently under construction in the R-H zone has an as built density of 14 City of Turlock, Annual Action Plan for CDBG Funds & Turlock/Stanislaus Urban County HOME Consortium Funds, Fiscal Year 2022-2023

Appendix C: Housing Constraints Analysis
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29 units per acre, whereas the inventory assumes that sites in the R-H zone will be constructed at 24 units per acre, representing 80 percent of the maximum permitted density of 30 units per acre. The Avena Bella project at 500 West Linwood has an as built density of 33 units per acre, which exceeds the assumption of 28 units per acre used for sites in the Workforce Housing Overlay.

Nevertheless, it is possible that projects may be permitted at densities that are within the permitted range established in the Turlock Zoning Code but that are lower than those assumed in the inventory. The inventory includes a buffer of 15 percent to help ensure the "no-net loss" provisions of State law will be observed if some sites do not develop at the densities projected. Additionally, through Program 6-B the City will annually monitor progress and ensure adequate capacity is available to meet RHNA obligations at all times or to take corrective action as needed.

ENVIRONMENTAL REVIEW
Environmental review, in compliance with State and federal requirements, runs concurrent with the land use entitlement process. The City of Turlock follows applicable requirements, and the process is detailed in the City of Turlock CEQA Implementation Procedures, which outline the steps described below and depicted in Figure C-1 CEQA Overview flowchart, excerpted from the CEQA Implementation Procedures document.

Preliminary Review
The first step in the CEQA process is a preliminary review by City Staff. During this review, all preapplication information or formal development applications submitted to the City are evaluated to determine if CEQA applies and if they can be classified as projects under CEQA. If a development proposal is deemed a project, it is subject to further environmental review unless it is found to be exempt from the requirements of CEQA. Determination as to whether a development application is a proposed activity that is subject to CEQA (§21080, §15060) is made on the basis of criteria established in State law which stipulate that a “project” is subject to CEQA if:
• The activity involves a discretionary approval by the City; • The activity will result in a direct or reasonably foreseeable indirect physical change in the environment;
• The activity is a project as defined by CEQA (§15378); • A project is an activity undertaken by the City, or is financed by the City in part or whole, or is a private activity requiring City approval and has the potential for resulting in a direct or indirect physical change in the environment.

If a development application is deemed not a project, then it is exempt from CEQA requirements. If a development proposal is deemed a project, it may require formal environmental review starting with an Initial Study), or it may be exempt from the requirements of CEQA.

Environmental Analysis
For projects that are not exempt, City Staff must perform an environmental analysis or Initial Study. The Initial Study aids City Staff in determining the environmental effects of the project and the corresponding course of action required under CEQA. Based upon the results of the Initial Study, City Staff makes a determination of the project’s potential environmental impacts. Depending upon the significance of the project’s environmental impacts, either a Negative Declaration or Mitigated Negative Declaration or an Environmental Impact Report (EIR) is prepared.

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Public Disclosure
After deciding which environmental determination is required for the project, staff informs the applicant and the public of the environmental determination and prepares the appropriate documentation. City Staff normally prepares Negative Declarations and Mitigated Negative Declarations, while Environmental Impact Reports (EIRs) are typically prepared by an environmental consulting firm under contract with the City of Turlock.

Agency Approval and Notice of Determination
Once the environmental documents have been prepared and approved by the appropriate decision-making body, a Notice of Determination is filed within five working days of approval with the County Clerk. The County Clerk and/or the Office of Planning and Research are required to post this notice for a 30-day period. During that period, a writ of mandate may be filed challenging the adequacy of the environmental document and/or the procedures followed to adopt the environmental document. Filing of the Notice of Determination begins a 30-day statute of limitation period for court challenges based on the California Environmental Quality Act. If a NOD is not filed, then the statute of limitation period on court challenges is 180 days. During the 180-day period, the NOD may be filed at any time to establish a 30-day statute of limitation period from date of filing.

Pre-Application Discussion
Upon the request of a potential applicant, the City of Turlock CEQA Implementation Procedures require that staff provide consultation prior to the filing of an application. This gives the applicant an opportunity to discuss with staff the type of discretionary action, potential alternatives, mitigation measures, and any potential and significant effects on the environment of a given project. If the pre-application review is not requested, City staff should ideally determine whether CEQA applies prior to the filing of a project application so that the applicant can submit the Environmental Questionnaire with application submittal and save processing time. If City staff is unable to determine if CEQA applies prior to application submittal, then the determination must be made within 30 days of application submittal in conjunction of determining application completeness.

CEQA and Permit Streamlining Act Compliance
The City complies with the Permit Streamlining Act through the procedures established in the City of Turlock CEQA Implementation Procedures. Additionally, as noted above, the City is also in the process of purchasing new permitting software which will automate the plan review routing process and will track time spent in review while alerting staff to upcoming deadlines to ensure projects stay on track. Once in place, every permit (e.g., Architectural Review Permit, Use Permit, Environmental Permit) application received in the Development Services Department will be entered into the system and a due date of within 30-days will be set for the initial application review and any subsequent resubmittals. If a project is exempt from CEQA, the Notice of Exemption findings will be made through the permit approval letter. If an Initial Study or EIR is required, an Environmental Review application will be submitted by the applicant and the required CEQA timing requirements will be tracked through the system to further ensure the City complies with CEQA streamlining provisions.

Appendix C: Housing Constraints Analysis
C-36 Hearing Draft | August 6, 2026
Figure C-1 CEQA Overview Flowchart
CEQA Does Not Apply – Not a Project
• No Discretionary Action (Is a ministerial action)
• No Physical Change
• Not a Project as defined in 15378
CEQA Overview
CEQA Applies – Is a Project
Project results in:
• A Discretionary Action
• A Physical Change
• A Project as defined in 15378
Preliminary Review (§15060)
Determine completion of
application within 30 days of
submittal. Acceptance starts time
periods for environmental
review.

Prepare Initial Study (§15063)
To determine Neg. Dec. or EIR?
Prepare EIR (§15080-15097)
EIR required for Potential
unavoidable significant effects
Notice of Preparation sent to
other agencies for scope and
content response within 30 days.

Draft EIR prepared by agency
Notice of Completion filed with
specified agencies.

Notice of Availability Post, mail
and publish
Public Review/Agency
Consultation for min. 30 days
Comments and Responses in
final EIR.

Findings/Overriding
Consideration Statement for
approvals with significant effect.

Final EIR Certification within 1
year of completed application.
90-day extension
Notice of Determination filed
and posted within 5 days.

Project Decision – If EIR Certified, agency
must approve or deny within 180 days (90
days if low-income housing). Project deemed
approved if no action within time limits.

Exemptions (§15061)
• Categorical Exemption
• Statutory Exemption
• No Possible Significant Effect (not often applied)
Notice of Exemption is optional but limits
challenges to 35 day period
Prepare Negative Declaration (§15070)
• Negative Declaration required when there is no
significant effects
• A Mitigated Negative Declaration required
when significant effects can be mitigated
Notice of Intent to Adopt ND with sufficient time
to allow review. Post, mail and publish.

Review and Consultation Period at least 20 days.

Adoption of ND within 180 days of completer
application.

Notice of Determination of ND files and posted
within 5 days of project approval.

Project Decision – If Exempt or ND Adopted,
agency must approve/disapprove within 60 days.

Deemed approved if no action within time limits.

No
Further
Action
Required
Under
CEQA

City of Turlock – Housing Element Update 2023-31
Hearing Draft | August 6, 2026 C-37
C.4 Off-Site Improvements
Per Chapter 11-5 of the Turlock Municipal Code,15 developers of residential subdivisions are required to provide each lot with connections to the City sanitary sewer system, the City domestic water supply, and gas, electric, telephone, and cable television services. Subdivisions must also be provided with storm drainage facilities, or pay a fee, in accordance with the City’s adopted Storm Drain Master Plan.

Subdivisions must also include sidewalks (in most cases, except where very low-density zoning permits their exclusion), paved streets, and street trees. Such improvements are required as a condition of the subdivision map, or if there is no required map, improvements are required as part of the building permit. These onand off-site improvements promote the health, safety, and general welfare of the public.

Chapter 7-2 of the Municipal Code addresses regulations related to off-street improvements 16. Curbs, gutters, and sidewalks are the off-site improvements the City most frequently required for new residential development that are not on infill sites. Curbs, gutters, and drainage facilities direct storm and runoff water out of residential developments. City roadways are required to be paved. Pavement creates an all-weather roadway, facilitates roadway drainage, and reduces dust. It also produces a high-speed circulation system and facilitates relatively safe traffic movement. Roadways are classified by the City according to traffic needs as follows:
• Arterial - Six lanes, 100 to 110 foot right-of-way, with left turn median • Major Collector- Four lanes, 94 foot right-of-way, with two bicycle lanes • Collector – Two lanes with 60-foot right-of-way
• Local - Two lanes with 50 to 54-foot right-of-way
Arterials and collectors are designated on the General Plan according to existing and projected needs.

Developers are responsible for the development of roadways associated with the residential project and participate in regional transportation system improvements through payment of the Capital Facility Development fee (see Table C-10 above).

Comparing to other Stanislaus County jurisdictions, the City of Turlock imposes standard on and off-site improvements. The City of Modesto requires a variety of improvements for new developments. Typical onand off-site improvements for new development include improvements to the adjacent traffic signals and sidewalks and sanitary sewer and stormwater connections. Other off-site improvements include the installation of sewer, water, and storm drain lines. The installation of streetlights, street signage, fire hydrants, and street trees is also required for single-family subdivisions and certificate of occupancy for multifamily development. Neighboring City of Ceres also imposes on- and off-site improvement standards to support new residential development similar to the City of Modesto and Turlock, such as streets, sidewalks, water and sewer, drainage, curbs and gutters, street signs, utility easements, and landscaping.

Lastly, the City of Riverbank requires land improvements, such as off-site improvements that include curbs, gutters, sidewalks of at least four feet in width, pavement, adequate drainage, and street lighting, that are comparable to other jurisdictions.
15 City of Turlock, 2025. Chapter 11-5 Subdivision Maps. Available:
https://www.codepublishing.com/CA/Turlock/#!/Turlock11/Turlock115.html%2311-5 16 City of Turlock, 2025. Chapter 7-2 Street Improvements. Available:
https://www.codepublishing.com/CA/Turlock/#!/Turlock07/Turlock072.html%237-2

Appendix C: Housing Constraints Analysis
C-38 Hearing Draft | August 6, 2026
The City of Turlock does not impose any additional or unusual constraints beyond the standard improvements comparable to surrounding jurisdictions. As residential development cannot take place without the addition of adequate infrastructure, site improvement requirements are considered a regular component of housing development and do not represent a constraint to development. According to City staff, on- and off-site improvements cost about 2.7 percent on average per unit, per subdivision, based on recent single family subdivisions developments.

Although requirements for on- and off-site improvements do add to the overall cost of development, they are necessary to ensure provision of vital infrastructure services to residents. Based on the recent pipeline projects submitted and entitled citywide for a range of housing types (Table 3-2 Pipeline Projects), the City’s site improvement requirements do not create an undue constraint on development.

Transparency in Development Regulations
State Government Code Section 65940.1 requires cities and counties to provide transparency in publicizing land use controls and fees. Turlock provides links to a variety of resources on the planning and construction process from a web portal for the Planning, Building & Safety, and Engineering Departments called Building in Turlock.17 Users can use this page to navigate to pages providing a wide variety of information about planning and building requirements, procedures, and fees along with contact information for each Division with a role in the development process. Division pages make it easy to estimate and pay for permit fees schedule meetings and inspections and download information sheets. There is also a link for providing customer feedback. The Planning & Land Use Permitting page provides links to the General Plan, Zoning Code, and other adopted plans and design guidelines as well as information, schedules, and submittal deadlines for the Planning and Building staff and links to websites for related Boards and Commissions.

In 2022, The Department of Housing and Urban Development (HUD) conducted remote monitoring of the Turlock’s Community Development Block Grant (CDBG) and HOME Investment Partnerships Program (HOME) to ensure compliance with applicable federal requirements. HUD made six findings and one concern in addition to identifying several unresolved issues from previous audits in 2010, 2014, and 2019. Even though the HUD monitor reportedly indicated that the findings and concerns were “normal”, some of them should be considered as obstacles that affect Turlock’s ability to meet its housing needs.

See Table C-13 for a list of the recent findings and corrections. The HUD monitor also expressed concern that Turlock appeared to be overlooking a requirement that recipients of HUD funding must direct employment, training and contracting opportunities to low-income individuals and the businesses that employ these persons within their community. (The definition of “Finding” is a deficiency in a program performance based on a violation of statutory or regulatory requirement. A “Concern” is defined as a deficiency in program performance that is not based on a statutory or regulatory requirement but is brought to the grantee’s attention.)18
17 Building in Turlock https://www.turlock.ca.us/buildinginturlock/ 18 Turlock Journal, October 3, 2022 https://www.turlockjournal.com/news/government/housing-funding-audithighlights-city-council-discord/

City of Turlock – Housing Element Update 2023-31
Hearing Draft | August 6, 2026 C-39
Table C-13: Findings and Corrective Actions, HUD
Finding Corrective Action
The City of Turlock incorrectly classified a $1,000
grant to allow a homeowner to rent a portable
storage unit to store their furniture and other
personal items while their home was being
rehabilitated.

Return the $1,000 and then reapply for the funds
under the correct CDBG activity.

The City of Turlock lacks a current Residential Antidisplacement and Relocation Assistance Plan.City of Turlock must update its current Displacement Plan to reflect new requirements and submit it to
HUD.

There is an absence of dated signatures of all parties
on the beneficiary written agreement for a Ceres
First-Time Homebuyer project as well as Turlock’s
Avena Bella Phase II project.

Submit a revised HOME policies and procedures to
include specific requirements that written agreements
include dated signatures of all parties.

There is an absence of many federally required
provisions in the City of Turlock’s loan agreement
with Avena Bella.

Submit an amended loan agreement to include the
requirements.

The amount of HOME funds invested in the Avena
Bella Phase II project was not at or below the
applicable maximum per-unit subsidy limit. The limit
was exceeded by $133,625.

City of Turlock must repay the $133,615 to the
HOME Investment Trust Fund account.

The City of Turlock does not have comprehensive
written policies and procedures as required under
HOME regulation.

The City must submit a revised HOME policies and
procedures to meet all requirements.

In March 2023, the City engaged CohnReznick LLP to conduct a review of Housing Department records regarding use of funds from the HUD CBG and HOME Investment Partnership Programs for the purchase, rehabilitation, and sale of real estate to support the City’s Neighborhood Stabilization Program. The consultant’s findings identified several issues similar to those identified in the August 2022 HUD Monitoring Report but focused on the Housing Rehabilitation Program. The CohnReznick report also attributed some of the problems to the fact that the City experienced a significant amount of turnover in recent year including a number of key positions in the Housing Department.17 On July 31, 2024 the Department of Housing and Urban Development San Francisco Regional Office officially informed the City that sufficient information had been provided to close all of the prior findings. Additionally, from May 20th to May 24th, 2024, HUD conducted remote monitoring of the City’s CDBG-CV program in order to assess the City’s performance and compliance with applicable Federal program requirements. HUD’s review of the City’s program performance resulted in the identification of zero findings and zero concerns, as communicated in the FY2024 Monitoring Report.

C.5 Non-Governmental Constraints
Non-governmental constraints range from environmental factors such as flooding, wildfire, and seismic hazards to economic conditions including the cost and availability of financing, labor supply, the cost of materials and, more recently, supply chain problems. These conditions can hamper residential development and are, for the most part, beyond the ability of local government to control. Nevertheless, there are approaches cities might use to help offset the impacts of these constraints through their planning and regulation of land use and development.

Appendix C: Housing Constraints Analysis
C-40 Hearing Draft | August 6, 2026
In Turlock as throughout California, the major non-governmental constraints to residential development are the cost of land, construction costs, and the availability and cost of financing. Although many constraints are driven by market conditions, jurisdictions have some leverage in instituting policies and programs to address such constraints. The ability to address the underserved needs of the citizens of the City of Turlock is challenging, especially since so many of the impediments to providing services are beyond the scope of municipal governments. The responsibility for identifying, responding to, and mitigating these needs rests with the variety of agencies providing services. Funding limitations exist at all levels. The private market influences the selling and rental prices of all types of housing, which includes existing and new dwelling units. While actions within the public sector play important parts in determining the cost of housing, the private sector affects the residential markets through such mechanisms as supply costs (i.e., land, construction, financing) and value of consumer preference.

Current Housing Market
Like other communities in California’s Central Valley and beyond, Turlock has experienced a decline in new housing production during the past decade. From 2000 to 2009, the housing stock increased by 4,962 units. Since then, construction rates have sharply declined with only 1,014 of Turlock’s housing units added between 2014 and 2024, according to California Department of Finance and City of Turlock. 19 Another
constraint affecting housing costs is the cyclical nature of the housing industry. Housing production can vary widely from year to year with periods of above-average production followed by periods of belowaverage production. Fluctuations are common in most industries but appear to be more dramatic in the homebuilding sector because of the susceptibility of the industry to changes in federal fiscal and monetary policies. There is little that cities can do to affect this major constraint.

Availability of Financing
One of the significant components to overall housing cost is financing. After decades of slight fluctuations in the prime rate, the 1980s saw a rise in interest rates, which peaked at approximately 18.8 percent in 1982.

As the decade closed and the economy weakened, the prevailing interest rate was around 10 percent. The decade of the 1990s has seen interest rates drop dramatically, fluctuating between six and eight percent.

Through 2008, the rates on a 30-year fixed rate mortgage have varied between just below six percent and eight percent. For the first time since the 1960s, some mortgage rates have fallen below six percent. Between 2004 and 2006, many Americans were able to utilize very low and adjustable interest rates to purchase homes otherwise out of their price range.

Through mid-2008, home mortgage financing was readily available to residents of Turlock and California at large. Now, with interest rates are currently in the range of six to almost eight percent, it can be significantly more difficult to obtain a home purchase loan. In response to the contribution of mortgagebacked securities to the current financial crisis, people with short credit history, lower incomes, selfemployment incomes, or other unusual circumstances have had trouble qualifying for loans or are charged higher rates. Due to a decline in supply as well as the increased cost of new housing units, the median value of owner-occupied homes in Turlock increased by 12.1 percent between 2010 and 2020 to $329,900. This is a 65.4 percent increase above the median in 2000 but still only 38.7 percent of the median value of housing statewide. 20 During the same period, the proportion of owner-occupied housing in Turlock dropped from

55.8 to 53.7 percent, due not only to the cost of home-ownership but also to the creation of additional rental housing.21 Since October 2020, mortgage rates have more than doubled — rising to 8.022 percent as of this 19 City of Turlock Housing Element Update 2023-2031 Chapter 2: Community Profile. 20 U.S. Census Bureau, Census 1980(ORG STF1), 1990(STF3), 2000(SF3); ACS 06-10, 16-20 (5-year Estimates), Table B25077
21 U.S. Census Bureau, Census 1980(SF1), 1990(SF1), 2000(SF1); ACS 16-20 (5-year Estimates), Table B25042

City of Turlock – Housing Element Update 2023-31
Hearing Draft | August 6, 2026 C-41
writing, the highest they’ve been since 2000— in response to moves by the Federal Reserve to control inflation. In January 2022, a buyer would have paid around $2,100 a month in principal and interest for a $500,000 home loan. 12 months later, that same loan would cost about $2,900 a month.

Chart C-1: National Mortgage Rates
Source: Freddie Mac, Mortgage Rates https://www.freddiemac.com/pmms Assuming a 10 percent down payment, and a 30-year fixed rate mortgage, the Principal-Interest-TaxesInsurance (PITI) payment as of this writing would be $2,401. 22 This means a household would need an
annual income of $96,040 to be able to afford to buy a home in Turlock in today’s market, which is 58 percent more than the $60,700 median income of Turlock households according to the U.S. Census ACS estimates.
23 As Table C-14 shows, even if mortgage rates dropped to 5.0 percent, more than half of Turlock’s households couldn’t afford to buy a home in the city today.

Table C-14: Monthly Housing Cost and Income Required
Interest Rate Selling Price Net Monthly Payment1 Income Required2

5.0% $329,900 $1,876 $75,040

6.0% $329,900 $2,063 $82,520

7.0% $329,900 $2,258 $90,320

8.0% $329,900 $2,461 $98,440

9.0% $329,900 $2,672 $106,880

1. Assumes a 10 percent down payment and Taxes and Insurance at $283 per month.

2. Assumes 30 percent of income towards net monthly payment.

First Time Homebuyers Program
The need to assist low-income entry-level homebuyers has always been an aspect of a comprehensive housing program, and the City of Turlock has established a First Time Homebuyers Program (FTHB) for this purpose. The FTHB program helps eligible applicants purchase a home with down payment assistance 22 Bankrate Mortgage Calculator https://www.bankrate.com/mortgages/mortgage-calculator/ 23 U.S. Census Bureau, ACS16-20 (5-year Estimates), Table B19013.

Appendix C: Housing Constraints Analysis
C-42 Hearing Draft | August 6, 2026
of up to $50,000 or 40percent (whichever is less) of the sales price of a home. Households must have incomes at or below 80 percent of the Stanislaus County AMI. For a typical four-person household this income limit is $67,500. Given the current economic conditions and the increasing difficulty of obtaining home purchase financing for lower income households, continuation of the FTHB program is a high priority for the City.

The Housing Action Plan continues the program.

Cost of Construction
The costs of labor and materials have a direct impact on the price of housing and are the main components of housing cost. Residential construction costs in Stanislaus County vary depending upon the quality, size, and the materials being used. Construction costs for a two-story, stucco on wood frame single family unit range from $150 to $340 per square foot or $300,000 to $680,000 for a 2,000 square foot home. These “hard” construction costs do not include costs associated with permits and fees, land acquisition, site work and lot improvement, design, marketing, or administrative overhead (“soft” costs). Soft costs generally account for approximately 33 percent of overall construction costs.24A random sample of newly constructed homes available for sale in Turlock ranged from 1,718 to 2,344 square feet and had a median listing price of $579,995 and an average cost per square foot of $296. 25 Residential construction costs have fluctuated over the last seven years in the northern San Joaquin Valley.

While costs increase over the years to some extent, market factors dictate the extent to which prices change beyond inflation. From 2000 to 2004, construction costs increased annually at an average of less than three percent per year; from 2004 to 2005, costs increased 11 percent. Since 2005, the rate of cost increase has varied from three percent to seven percent as the housing market heated up. The current economic downturn has not spelled relief from cost increases, as from 2008 to 2009, construction costs are estimated to increase by over seven percent. Other regions of California have seen similar price jumps, so the current construction cost conditions are not unique to Turlock.26 Construction Financing
Like loans for home purchases, construction loans for new housing are also now increasingly difficult to obtain. In previous years, lenders would provide up to 80 percent of the cost of new construction (loan to value ratio). Recently, due to market conditions and government regulations, banks have started to require larger investments by the builder. Complicated projects such as mixed-use developments are among the more difficult to finance. Nonprofit developers may also find it difficult to secure funding from the private sector. Limited construction financing is therefore also a likely contributor to the recent decline in new construction; while conditions may improve over the course of the planning period, it will remain a constraint in the short term.

Cost of Land
The cost of raw, developable land has a direct impact on the cost of a new home and is therefore a potential non-governmental constraint. The higher the raw land costs, the higher the price of a new home. Normally, developers will seek to obtain city approvals for the largest number of lots possible on a given parcel of raw land. This allows the developer to spread the costs for off-site improvements (i.e., streets, water lines, etc.) over the maximum number of units.
24 RSMeans. “Square Foot Construction Costs, 30th ed.” R. S. Means Company, Inc., 2008. 25 Realtor.com https://www.realtor.com/realestateandhomes-search/Turlock_CA/type-single-family-home/shwnc 26 Ibid.

City of Turlock – Housing Element Update 2023-31
Hearing Draft | August 6, 2026 C-43
Land costs are often difficult to estimate, and there is no single publicly available database that records urban land prices. A study conducted by researchers from the Federal Housing Finance Agency (FHFA) has estimated the price of residential land based on appraisals of single-family parcels conducted between 2012 and 2019. No data are available for Turlock specifically but the median value for a quarter-acre singlefamily parcel in Stanislaus County was estimated at $77,500. 27 Recent sales information for the Turlock
from Realtor.com show that the land costs for a large, relatively level site ranged from $63,710 to $90,000 per acre. On the other end, small infill sites were on the market for as much as 1.38 million per acre.28 As the availability of vacant residential land becomes scarcer over time, the cost of vacant land in Turlock will increase. As a rule, if the land cost component remains within 35 percent of development costs, then the availability of land should not pose a significant constraint on the development of housing for all income groups. A 1,500 square foot home with hard construction costs of $300 per square foot, plus an additional 33 percent for soft costs, would have total construction costs of $598,500. With residential land prices in Turlock of $63,710 to $90,000 per acre, and assuming that the home is built on property zoned for seven units per acre, the land cost for each home would be less than $13,000 and well within the percentage typically allowed for land costs indicating that land costs are within a reasonable range and should not pose a constraint.

C.6 Environmental Constraints
While many cities in California confront significant environmental constraints on housing development, Turlock is located such that many of the environmental hazards that other communities face are virtually nonexistent. The City is not near any active faults; its flat terrain precludes the danger of landslides; and its agricultural soils are not subject to shrink-swell or subsidence. The topography and nature of urban and agricultural development makes the risk of wildfires very low. There are no areas within the City limits located in floodplains (including special flood hazard areas delineated by the Federal Emergency Management Agency) and virtually no wetlands aside from those in existing parks or on farms or pastures outside the City limits. While the flat terrain may occasionally lead to minor flooding on impervious areas during large storm events, this is not considered to be a constraint to housing development as City infrastructure can handle the stormwater runoff.

Further, Turlock and other communities in Stanislaus County do, however, face risks from incidents associated with the County’s nine largest dams. Even though the probability of a major dam break is unlikely the effects of such a disaster would be catastrophic, which is why the County’s Hazard Mitigation Plan identifies Dam Incidents as a Priority Hazard. The New Exchequer and Don Pedro Dams are of particular concern and are rated as Extremely High hazards by the California Department of Water Resources, Division of Safety of Dams.29 A major breach in the Don Pedro Dam, an earthen embankment dam across the Tuolumne River, about 35 miles northeast of Turlock, would inundate the entire city; the New Exchequer Dam on the Merced River would primarily affect the southeastern part of the City.

The local hazards posing a more critical concern to Turlock and most of California’s Great Valley are all related to climate change including extreme heat, drought, and severe weather effects such as high winds, 27 William Larson et al., Working Paper 19-01: The Price of Residential Land for Counties, ZIP codes, and Census Tracts in the United States, 1/2/2019, updated 11/9/2020. https://www.fhfa.gov/PolicyProgramsResearch/Research/Pages/wp1901.aspx 28 Realtor.com https://www.realtor.com/realestateandhomes-search/Turlock_CA/type-land/nc-hide 29 Stanislaus County Multi-Jurisdictional Hazard Mitigation Plan: 2022-2027 Update, Annex H. City of Turlock, pp. 13-15.

Appendix C: Housing Constraints Analysis
C-44 Hearing Draft | August 6, 2026
tornadoes, and heavy rain. Extreme heat makes air conditioning essential, which contributes to the cost of housing. The frequency with which higher temperatures occur has had an impact on the provision of electricity and is likely to make auxiliary generators essential for housing in those areas, like the Valley, that are particularly prone to high temperatures.

Table C-15: Local Hazards Likely to Affect Housing
Hazard Type Geographic
Extent1
Probability of
Future
Occurrence2
Magnitude/
Severity3
Overall
Significance 4 Priority Hazard
Dam Incidents Extensive Unlikely Catastrophic High Yes
Extreme Heat Significant Highly likely Critical High Yes Drought Extensive Likely Critical High Yes
High Wind/Tornado Extensive Highly likely Critical High No Severe Weather: Hail,
Heavy Rain,
Thunderstorms, Lightning
Extensive Highly likely Critical High No
Dense Fog Extensive Likely Critical Medium No
Earthquake Extensive Occasional Critical Medium No
Flood Limited Likely Negligible Low No
Wildfire Limited Occasional Negligible Low No
Notes:

1. Limited: Less than 10% of planning area; Significant: 10-50% of planning area; Extensive: 50-100% of planning area

2. Highly Likely: Near 100% chance of occurrence in next year or happens every year.

Likely: Between 10 and 100% chance of occurrence in next year or has a recurrence interval of 10 years or less.

Occasional: Between 1 and 10% chance of occurrence in the next year or has a recurrence interval of 11 to 100 years.

Unlikely: Less than 1% chance of occurrence in next 100 years or has a recurrence interval of greater than every 100 years.

3. Catastrophic—More than 50 percent of property severely damaged; shutdown of facilities for more than 30 days; and/or multiple deaths
Critical—25-50 percent of property severely damaged; shutdown of facilities for at least two weeks; and/or injuries and/or illnesses result in permanent disability Limited—10-25 percent of property severely damaged; shutdown of facilities for more than a week; and/or injuries/illnesses treatable do not result in permanent disability Negligible—Less than 10 percent of property severely damaged, shutdown of facilities and services for less than 24 hours; and/or injuries/illnesses treatable with first aid.

4. Low: minimal potential impact Medium: moderate potential impact High: widespread potential impact Source: Stanislaus County Multi-Jurisdictional Hazard Mitigation Plan: 2022-2027 Update, Annex H. City of Turlock, p. 10 Considering humanmade hazards in Turlock, there are none that would preclude development of housing.

There are no sites that contain a Williamson Act land contracts or conservation easements that would deter housing development of the proposed RHNA units. The Housing Element sites inventory supports the first General Plan theme that set out to “establish limits to urban growth that will maintain Turlock a freestanding city surrounded by productive agricultural land.” Sites on the inventory promote infill development and mixed-use neighborhoods within City limits, and the Housing Element does not anticipate any conversion of prime agricultural land. Additionally, the closest airport to the City of Turlock

City of Turlock – Housing Element Update 2023-31
Hearing Draft | August 6, 2026 C-45
is located approximately 8 miles east of the city. The airport is not only outside the incorporated City limits, but is also situated in the adjoining Merced County, meaning none of the housing sites in the inventory are located within the Airport Influence Area nor airport land use compatibility zones. As such, the airport compatibility does not serve as a constraint to housing development. Further, the physical development pattern of the city features uniform, rectangular lots organized around a grid network. As such, parcel shape and access do not represent significant development constraints in Turlock.

State law stipulates for the adequacy of sites identified for lower income RHNA on the housing sites inventory, including that they be of appropriate size, be free from environmental constraints, be zoned to accommodate housing, have appropriate development standards, and be served by public facilities. All sites were screened for consistency with these criteria. No lower income sites on the inventory are in areas of natural hazard risk; however, as shown on Table C-16, there are 15 sites that contain hazardous materials based on a search of State databases. All sites are closed leaking underground storage Tank (LUST) cleanup sites where hazardous conditions have been remediated and do not pose a risk to human safety As such, hazardous materials do not represent a development constraint for the implementation of the Housing Element inventory.

Appendix C: Housing Constraints Analysis
C-46 Hearing Draft | August 6, 2026
Table C-16 Hazardous Sites in 6th Cycle Housing Element Site Address Existing Land
Use
Site Size
(acres)
Opportunity
Area
Capacity
Projected
(units)
Hazard Site
Type
Site
237 S 99 HWY Commercial 0.20 Downtown 6 Closed LUST
Cleanup Site

TOWN SERVICE
CASE /

GOODRICH OIL
CASE #1&2
325 S CENTER
ST
Commercial 0.68 Downtown 13 Closed LUST
Cleanup Site
Center Car Wash
214 S CENTER
ST
Vacant 0.20 Downtown 4 Closed LUST
Cleanup Site

FERNANDES

SPEED SHOP
141 N GOLDEN

STATE BLVD
Commercial 0.17 Downtown 6 Closed LUST
Cleanup Site
CHEVRON # 90678
210 N GOLDEN

STATE BLVD
Service
Station

0.58 Downtown 19 Closed LUST
Cleanup Site
ARCO #6161
216 N GOLDEN

STATE BLVD
Commercial 0.58 Downtown 13 Closed LUST
Cleanup Site
BEACON
STATION CASE #
01/BEACON
STATION #54
CASE # 02
997 N GOLDEN

STATE BLVD
Industrial 0.85 North Golden
State
17 Closed LUST
Cleanup Site

KIRKES ELECTRIC
INC
1000 N FRONT
ST
Industrial 0.95 North Golden
State
25 Closed LUST
Cleanup Site

UNOCAL BULK
PLANT NO. 0796
(FMR)
2032 DIVANIAN
DR
Industrial 0.74 North Golden
State
20 Closed LUST
Cleanup Site
MILLER

MANUFACTURING
2500 GEER RD Commercial 0.39 Geer Road 9 Closed LUST
Cleanup Site
SEVEN 11 # 16185
2590 GEER RD Commercial 0.45 Geer Road 10 Closed LUST
Cleanup Site

SHELL SERVICE

STATION
2901 GEER RD Service
Station

0.40 Geer Road 10 Closed LUST
Cleanup Site
CHEVRON # 91760
1202 GEER RD Service
Station

0.33 Geer Road 8 Closed LUST
Cleanup Site

WAYSIDE EXXON
1398 GEER RD Vacant 1.92 Geer Road 53 Closed LUST
Cleanup Site

REFLECTIONS CAR
WASH
1318 GOLDEN

STATE BLVD
Commercial 1.56 North Golden
State
41 Closed LUST
Cleanup Site

MANUEL BOKIDES
TEXACO
Source: Geotracker, State Water Resources Control Board (SWRCB), 2024 and Envirostor, Department of Toxic Substances Control (DTSC), 2024, Dyett and Bhatia, 2025

City of Turlock – Housing Element Update 2023-31
Hearing Draft | August 6, 2026 C-47
C.7 Infrastructure
The availability of infrastructure and services to meet new demands created by new residential development is another potential constraint to housing development.

WATER AND WASTEWATER
Water supply in Turlock originates from groundwater pumped from City-owned and operated wells from the underlying Turlock Groundwater Subbasin. City-owned wells extract groundwater and treat it as necessary to potable standards throughout the water service areas. To reliably meet future water demands, the City now receives wholesale surface water from Turlock Irrigation District (TID) supplied by the Stanislaus Regional Water Authority (SRWA) Regional Surface Water Supply Project (RSWSP). The City of Turlock and Ceres formed the SRWA as a Joint Powers Authority (JPA) in 2011 to provide a diversified and sustainable water supply portfolio for both Cities. As of 2023, both Cities relied solely on groundwater from the Turlock Subbasin, which had become less reliable due to both the decline in water quality and the increasing number of regulated contaminants. SRWA evaluated various water supply options and identified the Tuolumne River as a surface water supply that could be used in conjunction with the Cities’ groundwater supplies to provide a long-term, reliable drinking water supply for both Cities. The City plans to continue using groundwater as a source of potable water supply in the future and plans to maintain and replace groundwater wells as needed to provide a minimum emergency supply capacity in the future.

According to the City’s 2020 Urban Water Management Plan, the City has adequate projected supply to meet demand in normal, single dry year, and five-year drought scenarios between 2025 and 2045. Table C16 displays the five consecutive dry years supply and demand comparison as noted in the Urban Water Management Plan. The City’s drought risk was specifically assessed between 2021 and 2025, assuming that the next five years are dry years. In each case, water supplies comfortably exceed water demands. This remains true whether the drought occurs in 2021, 2045, or any year between. The Draft Housing Element would result in up to 6,671 units. Assuming an average flow or use of 47 gpd (gallons per year) for residential projects30, buildout of the Housing Element inventory would generate an additional 2,809 AF of water by 2031, well within the existing capacity of the 3,650 AF as shown on Table C-16. Therefore, there will be sufficient water for the Draft Housing Element and accommodation of RHNA. 30 California Water Efficiency Partnership, 2024. Indoor Residential Water Use Standard. Available:
https://calwep.org/indoor-residential-water-use-standard/

Appendix C: Housing Constraints Analysis
C-48 Hearing Draft | August 6, 2026
Table C-17: Five Consecutive Dry Years Supply and Demand Comparison – (Potable DWR Table 7-4) 2025 2030 2035 2040 2045* (Opt)
First year Supply totals 11,091 11,826 12,632 13,519 14,493 Demand
totals
7,441 8,176 8,982 9,869 10,843
Difference 3,650 3,650 3,650 3,650 3,650
Second year Supply totals 11,091 11,826 12,632 13,519 14,493 Demand
totals
7,441 8,176 8,982 9,869 10,843
Difference 3,650 3,650 3,650 3,650 3,650
Third year Supply totals 11,091 11,826 12,632 13,519 14,493 Demand
totals
7,441 8,176 8,982 9,869 10,843
Difference 3,650 3,650 3,650 3,650 3,650
Fourth year Supply totals 11,091 11,826 12,632 13,519 14,493 Demand
totals
7,441 8,176 8,982 9,869 10,843
Difference 3,650 3,650 3,650 3,650 3,650
Fifth year Supply totals 11,091 11,826 12,632 13,519 14,493 Demand
totals
7,441 8,176 8,982 9,869 10,843
Difference 3,650 3,650 3,650 3,650 3,650
* Units of measure (AF, CCF, MG) must remain consistent throughout the UWMP as reported in Table 2-3.

Notes: Volumes are in MG. In all year types, if potable demand cannot be met from Surface Water alone, it is assumed that groundwater will supply all remaining demand.

Wastewater service within the City of Turlock is provided by the City’s Municipal Services Department, which oversees the treatment of domestic and industrial wastewater through its Water Quality Control Division. The City of Turlock owns, maintains, and operates its own sanitary sewer collection system and associated facilities, including 225 miles of gravity sewer pipelines, 24 lift stations, force mains, and the Turlock Regional Water Quality Control Facility (RWQCF). The Turlock RWQCF has a design capacity of 20 million gallons of wastewater per day (mgd). The facility currently treats an average flow of 8.5 mgd. All wastewater generated within the sewer service area is conveyed to the Turlock RWQCF, which provides tertiary treatment of wastewater from the City of Turlock, Ceres and the community service districts of Keyes and Denair. The facility employs advanced tertiary treatment methods, including coagulation/flocculation, filtration, and efficient disinfection techniques. In 2022, the City initiated a Chemical System Upgrades Project, replacing the existing chlorine gas disinfection system with a new sodium hypochlorite system, and upgrading coagulant and dichlorination systems. The City of Turlock 2013 Sewer System Master Plan outlines a Capital Improvement Plan for the pipeline system and improvements to the pump stations.

The Turlock General Plan and associated EIR identify adequate water and sewer conveyance infrastructure to serve a projected total of 37,120 homes, 31,920,900 square feet of employment uses, and 104,480 residents in 2030. With 25,777 existing homes in 2024 and an additional capacity for 6,816 new units through 2031 as identified in the sites inventory, the City's Sixth Cycle RHNA allocation falls well within General Plan growth projections. Development of the Housing Element sites inventory would take place primarily as

City of Turlock – Housing Element Update 2023-31
Hearing Draft | August 6, 2026 C-49
infill development in established areas of Turlock that are well-served by water, sewer, and electrical infrastructure. As such, adequate conveyance infrastructure exists to serve projected housing development in these areas. New development in these infill areas would be required to connect to existing water and sewer systems. A portion of the sites inventory (1,325 new homes) would be constructed in the Morgan Ranch Master Plan area, located in the southern part of Turlock. The sites inventory assumes full buildout of the master plan's residential development program by 2030. The Master Plan identifies water, sewer, and electrical infrastructure needed to support planned residential and non-residential development along with funding and financing mechanisms to facilitate its provision. Additionally, Program 2-D, Morgan Ranch Sewer Lift Station, commits the City to constructing a sewer lift station to assist with the financial feasibility of master plan development. The sewer lift station will consist of two pumps with capacity of 1.2 million gallons per day at the Gold Road/Glenwood Avenue intersection in the eastern part of the master plan area addressing the cost of sewer infrastructure that has been a key constraint on development. Therefore, planned infrastructure is adequate to serve projected residential development in the Morgan Ranch Master Plan Area.

Accordingly, existing and planned infrastructure identified in the Turlock General Plan and Morgan Ranch Master Plan is both accessible and available to serve buildout of the sites inventory, and there is sufficient total water and sewer capacity to accommodate the RHNA through 2031.

WATER AND SEWER FOR AFFORDABLE HOUSING
Government Code 65589.7 and SB 1087 that public agencies providing water or sewer services adopt written policies and procedures that grant a priority for the provision of these services to proposed developments that include housing units affordable to lower income households. As described above, there is adequate water supply and sewer capacity to serve existing and projected development under the 2023-31 Housing Element and there has not historically been a need to ration or prioritize supply. Nevertheless, to comply with Government Code Section 65589.7, Program 2-L has been added to the Housing Action Plan to ensure that proposed developments that include units affordable to lower-income households are granted priority for water and sewer service allocations and hookups to the City’s conveyance system.

ENERGY CONSERVATION
Conservation of energy is an important issue in housing development today not only due to the cost of energy, which can be a substantial portion of monthly housing costs for both owners and renters, but also due to an emerging interest in sustainable development, energy independence, and reduction of greenhouse gas emissions in line with new legislation such as the Global Warming Solutions Act of 2006 (AB 32).

Conservation can be accomplished by reducing the use of energy-consuming items, or by physically modifying existing structures and land uses, and by designing buildings to be more energy efficient. The California Energy Commission first adopted energy conservation standards for new construction in 1978.

These standards, contained in Title 24 of the California Administrative Code, contain specifications relating to insulation, glazing, heating and cooling systems, water heaters, swimming pool heaters, and several other items. Specific design provisions differ throughout the State depending upon local temperature conditions.

Title 24 energy requirements are consistently reviewed in all building applications processed in the City.

Although the energy regulations establish a uniform standard of energy efficiency, they do not ensure that all available conservation features are incorporated into building design. Additional measures may further reduce heating, cooling, and lighting loads, and overall energy consumption. While it is not suggested that all possible conservation features be included in every development, there are often a number of economically feasible measures that may result in savings in excess of the minimum required by Title 24.

While construction of energy efficient buildings does not lower the purchase price of housing, housing with energy conservation features should result in reduced monthly occupancy costs as consumption of water

Appendix C: Housing Constraints Analysis
C-50 Hearing Draft | August 6, 2026
and energy is decreased. Similarly, retrofitting existing structures with energy-conserving features can result in a reduction in utility costs. Examples of energy conservation opportunities include weatherization programs and home energy audits; installation of insulation; installation or retrofitting of more efficient appliances, and mechanical or solar energy systems; and building design and orientation that incorporates energy conservation considerations.

Turlock Irrigation District (TID) offers numerous energy efficiency and demand reduction programs for its customers. TID operates a weatherization program available to all lower-income TID CARES customers who own or rent their homes, apartments, or mobile homes, and use electricity from TID. The program provides energy efficient measures such as electric water heater replacement, outlet and switch gaskets, wall air conditioner replacement, replacement of broken windows, refrigerator, microwave, swamp coolers and the installation of insulation, sunscreens, weatherstripping, and some repairs. TID also offers residential rebate programs, where customers can receive rebates for purchasing and installing energy-efficient appliances including Energy Star refrigerators, Energy Start clothes washers, Energy Star room air conditioner or mini split A/C, induction stove tops, heat pump or electric water heater, Energy star widows and sun screens.

Program 3-F, Home Energy and Water Conservation, ensures the City will continue to promote energy and water conservation in new and existing homes by publicizing the availability of State and Turlock Irrigation District energy conservation and renewable energy programs for housing construction and rehabilitation by providing information on the City website and in City newsletters and mailers; periodically updating the "pre-development tip sheet" with information on available energy and water conservation programs; and including a discussion of available programs in predevelopment meetings with developers of housing. This program, along with strategies and programs the City of Turlock is promoting and implementing as part of the Housing Element, will further local and statewide energy conservation goals.

Appendix D
Assessment of Fair Housing

Table of Contents
D Fair Housing Assessment ............................................................................................. D-1 D.1 Fair Housing Resources ................................................................................................................................ D-3 D.2 Segregation and Integration ....................................................................................................................... D-13 D.3 Racially/Ethnically Concentrated Areas of Poverty and Affluence ................................................... D-35 D.4 Disparities in Access to Opportunity ..................................................................................................... D-62 D.5 Disproportionate Housing Needs & Displacement Risk .................................................................... D-88 D.6 Sites Inventory .......................................................................................................................................... D-107 D.7 Summary and Conclusions ...................................................................................................................... D-113 List of Maps
Map D-1: Turlock Neighborhood Segregation .................................................................................................... D-15 Map D-2: Persons with Disabilities ......................................................................................................................... D-22 Map D-3: Residential Care Facilities in Turlock .................................................................................................. D-23 Map D-4: Percent of Children in Female Headed Households ....................................................................... D-25 Map D-5: Percent of Children in Married-Couple Households ...................................................................... D-26 Map D-6: Childcare Facilities in Turlock ............................................................................................................... D-27 Map D-7: Low- to Moderate-Income Population, Block Group ..................................................................... D-28 Map D-8: Poverty Status (2019), Turlock ............................................................................................................. D-29 Map D-9: Housing Vouchers (2019), Turlock...................................................................................................... D-31 Map D-10: Location of Publicly Subsidized Housing in Turlock ...................................................................... D-34 Map D-11: Segregation and Income, R/ECAP and RCAA Locations, Turlock ............................................. D-36 Map D-11b: DAC Census Tracts ............................................................................................................................ D-39 Map D-12: TCAC Opportunity Areas, Composite Score, Turlock ............................................................... D-64 Map D-13: TCAC Opportunity Areas, Economic Score, Turlock ................................................................. D-66 Map D-14 Lack of Internet Access ......................................................................................................................... D-71 Map D-15: TCAC Opportunity Areas, Education Score, Turlock ................................................................. D-74 Map D-16: TCAC Opportunity Areas, Environmental Score, Turlock ......................................................... D-78 Map D-17: Threats of Groundwater Contamination ......................................................................................... D-79 Map D-18: Concentration of Hazardous Waste Facilities ................................................................................ D-80 Map D-19: Concentration of Solid Waste Facilities ........................................................................................... D-81 Map D-20: Parks and Community Facilities .......................................................................................................... D-82 Map D-21: Existing and Proposed Bicycle Network from Turlock’s Active Transportation Plan .......... D-85 Map D-22: Turlock Transit Performance Score .................................................................................................. D-87

Map D-23: Renter Cost Burden, 2019 .................................................................................................................. D-91 Map D-24: Homeowner Cost Burden, 2019 ....................................................................................................... D-92 Map D-25: Overcrowded Households, Turlock ................................................................................................. D-95 Map D-26: Gentrification and Displacement Typologies, Turlock ................................................................. D-96 Map D-27: Substandard Housing, Owner Occupied Turlock ........................................................................ D-105 Map D-28: Substandard Housing, Renter Occupied Turlock ........................................................................ D-106 Map D-29: Sites Inventory and TCAC Composite Score by Tract, 2023 .................................................. D-108 List of Tables and Charts
Chart D-1: HMDA Loan Denial Rates by Race/Ethnicity, Turlock ................................................................. D-10 Chart D-2: HMDA Loan Denial Rates by Race/Ethnicity, Stanislaus County .............................................. D-10 Chart D-3: HMDA Home Improvement Loan Applications, 2021 ................................................................. D-11 Chart D-4: HMDA Home Purchase Loan Applications, 2021 ......................................................................... D-11 Chart D-5: Timeline of Segregation Policies in the United States .................................................................. D-14 Table D-1: Population Change by Race/Ethnicity within Turlock Census Tracts, 2010-2020 ................. D-19 Table D-2: Children Under 18 Years in Turlock Households, 2022 ............................................................. D-21 Table D-3: Poverty Status in the Past 12 Months by Race/Ethnicity, 2020 .................................................. D-30 Table D-3b Neighborhood Indicators ................................................................................................................... D-40 Table D-4: Units In Structures by TCAC and Census Tract, 2020 ................................................................ D-61 Table D-5: Opportunity Indicators and Measures for HCD/TCAC Opportunity Maps ........................... D-62 Chart D-6: Opportunity Indices, Population Living Above the Poverty Level ............................................ D-67 Chart D-7: Opportunity Indices, Population Living Below the Poverty Level ............................................. D-68 Table D-6: CAASP Scores ........................................................................................................................................ D-72 Chart D-8: Cost Burden for Renter Occupied Housing by Race/Ethnicity in Turlock ............................. D-90 Chart D-9: Cost Burden for Owner Occupied Housing by Race/Ethnicity in Turlock ............................. D-90 Chart D-10: Year Structure Built-Turlock and Stanislaus Urban County .................................................... D-99 Table D-7 Substandard Housing Issues, 2022 .................................................................................................... D-100 Table D-8: AFFH Housing Element Sites Analysis ............................................................................................ D-112 Table D-9: Fair Housing Issues, Contributing Factors, and Meaningful Actions ........................................ D-114

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Hearing Draft | August 6, 2026 D-1
D Assessment of Fair Housing
California Government Code Section 65583 (c)(5) requires cities to affirmatively further fair housing opportunities and promote housing throughout the community for all persons regardless of race, religion, sex, marital status, ancestry, national origin, color, familial status, or disability, and other characteristics protected by state and federal fair housing ad planning law. AB 686 (2019) defined “affirmatively further fair housing” to mean “taking meaningful actions, in addition to combat discrimination, that overcome patterns of segregation and foster inclusive communities free from barriers that restrict access to opportunity” for persons of color, persons with disabilities, and other protected classes. Section 65583 (c)(10) (A) requires the Housing Element to include an assessment of fair housing which includes the following components:
• A summary of fair housing issues and assessment of the City’s fair housing enforcement and outreach capacity,
• An analysis of available data and knowledge to identify integration and segregation patterns, disparities in access to opportunities, and disproportionate needs, and displacement, • An assessment of contributing factors, including local and regional historical origins and current policies and practices,
• Identification of fair housing goals and actions, giving highest priority to factors that limit or deny fair housing choice or access to opportunity; and
• Strategies and actions to implement priorities and goals.

CITY OVERVIEW
Turlock is in the San Joaquin Valley, comprised of Stanislaus, Merced, and Fresno counties, and is part of the Central Valley Region encompassing 19 counties from Redding to Bakersfield. The Valley is predominantly rural with a few more densely populated urban centers including Turlock, Modesto to the northwest and Merced to the southeast of Turlock. Turlock is the second-largest city in Stanislaus County with an estimated population of 71,924 as of this writing compared with 217,484 for Modesto.1 The population in both cities has declined since the 2020 Census, a reduction of 1.06 percent in Turlock and

0.54 percent in Modesto. The U.S. Department of Housing & Urban Development (HUD) requires a regional analysis as a part of assessing fair housing to help identify fair housing issues in a broader context, which allows jurisdictions to address regional issues with scale-appropriate solutions. To that end, this assessment contextualizes its analysis of Turlock with an analysis of the county and the broader Central Valley regions’ fair housing patterns and trends when applicable. 1 World Population Review https://worldpopulationreview.com/us-cities/turlock-ca-population

Appendix D: Assessment of Fair Housing
D-2 Hearing Draft | August 6, 2026

PUBLIC OUTREACH
This assessment considers feedback from the public received during the development of the Regional Analysis of Impediments to Fair Housing Choice, Fiscal Year 2020-2025, prepared by Stanislaus County for the Stanislaus Urban County and the Cities of Turlock and Modesto in conjunction with the preparation of their HUD-mandated Consolidated Plan. The outreach process in Turlock included a meeting with the Turlock Community Collaborative on February 18, 2020, and a public hearing before the Turlock City Council on May 12, 2020. The Community Collaborative is a group of local nonprofit organizations, government agencies, businesses, and cities founded in 2002 to provide information and support to nonprofit agencies working in the community. The Collaborative’s members include several organizations active in fair housing issues such as California Rural Legal Assistance, Community Housing and Shelter Services, Housing and Economic Rights Advocates, Project Sentinel, and the Stanislaus County Mediation Center.2
As required by HUD, the Turlock/Stanislaus County HOME Consortium consulted with organizations that address fair housing, civil rights, and the needs of persons with disabilities during preparation of the 2023 HOME-ARP Allocation Plan including Project Sentinel, California Rural Legal Assistance, Community Housing and Shelter Services, The Consortium held two facilitated virtual consultation sessions in December 2022 including one that focused on fair housing with the Disability Resources Agency for Independent Living and the LGBTQ Collaborative. The Consortium also reached out to other stakeholders at a meeting held by the Stanislaus Community System of Care governance body in January 2023 and encouraged all consultation session participants to complete an on-line survey. Participants included a variety of organizations serving persons experiencing homelessness and at risk of homelessness, persons fleeing or attempting to flee violence, and other populations at risk if housing instability.3

DATA/RESOURCES CONSULTED
Many of the data sources used to prepare Turlock’s housing needs assessment (Appendix B) also provided information to support this evaluation of fair housing in the city. Primary data sources include AFFH Mapping and Data Resources provided by the State Department of Housing and Community Development (HCD), the 2020 United States Census, the 2016-2020 American Community Survey, the Stanislaus Urban County and City of Turlock Consortium Consolidated Plan, Fiscal Year 2020-2025, and the following:
• Taking Stock: A Comprehensive Housing Report for the San Joaquin Valley in 2022, Regional Early Action Planning (REAP), Data Profile
• City of Turlock 2015-2023 Housing Element
• Stanislaus County Regional Analysis of Impediments to Fair Housing Choice (AI) • California Tax Credit Allocation Committee TCAC/HCD Opportunity Area Maps • Home Mortgage Disclosure Act Data, 2007-2017
• American Communities Project: Diversity and Disparities, Brown University4 • Urban Displacement Project, UC Berkeley5
2 Turlock Community Collaborative, 2023 Member Directory, 2023. 3 Turlock/Stanislaus County HOME Consortium, HOME-ARP Allocation Plan, submitted to HUD March 2023. 4 Brown University, American Communities Project, 2022. Available: https://www.brown.edu/academics/spatialstructures-in-social-sciences/diversity-and-disparities 5 Chapple, K., & Thomas, T., and Zuk, M, 2021. Urban Displacement Project, Berkeley, CA: Urban Displacement Project.

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D.1 Fair Housing Resources
Fair housing services are an essential component of proactive efforts to further fair housing. They help to ensure that a variety of housing options are accessible to State and federally protected groups, including those based on race, color, gender, religion, national origin, familial status, disability, age, marital status, ancestry, source of income, sexual orientation, genetic information, or other arbitrary factors. Fair housing services also help Turlock residents understand and protect their right to access housing. In addition to the HUD Office of Fair Housing and Equal Opportunity, California Department of Fair Employment and Housing (DFEH), and the California Department of Consumer Affairs, local agencies and organizations providing services to Turlock residents and those seeking housing in the community include:
• Community Housing and Shelter Services (CHHS)
• City of Turlock Housing Services
• California Rural Legal Assistance
• Project Sentinel and Stanislaus County Mediation Center • Families de la Raza Unida de Turlock
• Stanislaus County Bar Association Lawyers Referral Service • Stanislaus County Regional Housing Authority
• Stanislaus County Family Justice Center

FAIR HOUSING SERVICES, ENFORCEMENT AND OUTREACH CAPACITY Fair housing enforcement and outreach capacity refers to the ability of a city and the fair housing agencies and organizations serving the community to provide information about fair housing rights and responsibilities to community members including residents and housing providers. Outreach capacity includes the ability to address compliance with fair housing laws, such as investigating complaints, obtaining remedies, and engaging in fair housing testing. The US Department of Housing and Urban Development (HUD) has several programs that fund State and local agencies to conduct fair housing services and activities, including the Fair Housing Assistance Program (FHAP) and the Fair Housing Initiatives Program (FHIP). These groups communicate with housing providers, conduct investigations, perform testing to help determine if someone has experienced discrimination, and provide information and assistance. The FHAP funds the California Department of Fair Employment and Housing (DFEH) to enforce Federal fair housing laws in California. The closest FHIP to Turlock is Project Sentinel, a nongovernmental organization (NGO) based in Modesto that HUD funds to provide education, outreach, and enforcement. Housing discrimination complaints can be filed directly with HUD, with the State Department of Fair Employment and Housing, or with Fair Project Sentinel.

Housing discrimination complaints are one method to evaluate the extent of fair housing issues in a community. Turlock contracts with Project Sentinel to provide fair housing and tenant-landlord counseling services. Project Sentinel, a nonprofit organization offering a variety of fair housing resources and services in much of Northern California, is the primary organization providing individuals in Turlock and the rest of Stanislaus County with assistance for filing complaints about violations of fair housing law with state and national agencies. The organization also provides outreach and education to housing providers, property managers, and service providers, dispute resolution, and housing counseling. Resources are offered in English, Spanish, Vietnamese, and Chinese. Project Sentinel has an office in Modesto where Turlock

Appendix D: Assessment of Fair Housing
D-4 Hearing Draft | August 6, 2026
residents can obtain assistance with housing problems such as discrimination, mortgage foreclosure and delinquency, rental issues including repairs, deposits, privacy, dispute resolution, home buyer education, post purchase education and reverse mortgages. The city also provides information about Project Sentinel’s programs on a page at the Housing Programs website
(https://www.cityofturlock.org/housingprograms/fairhousing/) with downloadable copies of some informational materials including materials produced by HUD and State agencies.

Annually, Project Sentinel processes over 10,000 initial contacts; handles over 400 housing discrimination complaints and over 1,700 landlord tenant and community dispute cases; counsels over 750 homeowners; and provides monthly workshops on housing topics to its service area. During Fiscal Year 2019-2020, Project Sentinel received 545 calls for fair housing information within the Stanislaus Urban County area resulting in a total of 12 fair housing cases and 32 tenant/landlord cases handled by the agency.

Additionally, California Rural Legal Assistance (CRLA) has 17 offices statewide including headquarters in Modesto. CRLA operates a state-wide Fair Housing and Foreclosure Prevention Program under guidance of HUD that assists victims of housing discrimination. They focus on the needs of farmworker communities, those living in unincorporated areas, and other underserved areas of California that have been subject to segregation and historic patterns of discriminatory housing and lending practices.

Turlock collaborates with the Stanislaus County, the city of Modesto, and the Stanislaus Regional Housing Authority that receive entitlement funding from HUD. One of the requirements for maintaining eligibility for federally funded programs such as the Community Development Block Grant (CDBG), HOME Investment Partnership, and Emergency Solutions Grant programs, and other state and local programs is to “actively further fair housing choice” through:
• Completion of an Analysis of Impediments to Fair Housing Choice (AI), • Actions to eliminate identified impediments; and
• Maintenance of fair housing records
The 2024-2025 Annual Action Plan the City of Turlock submitted to HUD as the application for funding from the CDBG program and HOME Consortium funds, commits Turlock to funding organizations, including We Care Program, United Samaritans, Center for Human Services, Healthy Alternatives to Violent Environments (HAVEN) to provide supportive services to homeless and low-income populations, specifically to assist in fair housing education and counseling on housing discrimination.6 For the 2024- 2025 financial year, the City of Turlock committed to providing fair housing support services for 30 households with CDBG funds.

Fair housing complaints are not the only indication of fair housing conditions, but data from Stanislaus Regional Housing Authority, along with records published by the State Department of Fair Employment and Housing (DFEH), provide a basis for viewing Turlock in a broader context. The 2020-2025 Analysis of Impediments (AI) reports that between 2014 and 2019 complaints regarding housing in Turlock included 30 related to disability, five complaints related to race, and five related to familial status with fewer than five complaints filed in cases related to national origin, gender/sex, arbitrary reasons, and age. Relative to Stanislaus County, Modesto had a significant number of complaints (165) compared to other jurisdictions in the County. This may be because Project Sentinel has a physical office in Modesto but could also be due 6 City of Turlock Annual Action Plan For CDBG funds & Turlock/Stanislaus Urban County HOME Consortium funds Fiscal Year 2024-2025. Available: https://www.cityofturlock.org/_pdf/hppr.asp?id=45

City of Turlock – Housing Element Update 2023-31
Hearing Draft | August 6, 2026 D-5
to the amount of outreach or advertising to the public in Modesto, partnerships with other organizations, or the number of fair housing violations occurring. The larger number may therefore reflect successful community outreach as opposed to a greater prevalence of housing discrimination.

The 2020 AI reported that as of 2016, though many people who speak a language other than English at home are bilingual, there are also residents who report speaking English “less than very well” in all parts of the County. More than 20 percent of residents in Waterford, Newman, Ceres, and the Unincorporated County report speaking English less than “very well”. While Spanish is the predominant language of these residents, Turlock also has at least five percent of residents who speak another language and speak English less than “very well”. Linguistically isolated households are located in areas of Turlock west of SR99, southwest of downtown, both west and south of CSU Stanislaus. Communication regarding fair housing issues and solutions to closing any findings should consider there might be language barrier.

FAIR HOUSING COMPLIANCE
California Fair Employment and Housing Act (FEHA) (Part 2.8 (commencing with Section 12900) of Division 3 of Title 2) FEHA Regulations (California Code of Regulations (CCR), title 2, sections 12005- 12271) Government Code section 65008 covers actions a city, county, city and county, or other local government agency, and makes those actions null and void if the action denies an individual or group of individuals the enjoyment of residence, landownership, tenancy, or other land use in the state because of membership in a protected class, the method of financing, and/or the intended occupancy.

HCD guidance on Affirmatively Furthering Fair Housing requires an analysis of compliance with existing fair housing laws and regulations. Examples of State fair housing laws include the California Fair Employment and Housing Act (“FEHA,” Gov. Code, Section 12900 – 12996) and FEHA Regulations (CCR, Section 12005 – 12271). Government Code section 65008 covers actions of a city, county, city and county, or other local government agency, and makes those actions null and void if the action denies an individual or group of individuals the enjoyment of residence, landownership, tenancy, or other land use in the state because of membership in a protected class, the method of financing, and/or the intended occupancy.

HCD guidance on Affirmatively Furthering Fair Housing requires an analysis of compliance with existing fair housing laws and regulations. Examples of State fair housing laws include:
• California Fair Employment and Housing Act (FEHA) (Part 2.8 (commencing with section 12900) of Division 3 of Title 2)
• California Government Code section 8899.50, which requires all public agencies to administer programs and activities relating to housing and community development in a manner to affirmatively further fair housing and avoid any action that is materially inconsistent with its obligation to affirmatively further fair housing.
• Government Code section 11135 et seq., which requires full and equal access to all programs and activities operated, administered, or funded with financial assistance from the State, regardless of one’s membership or perceived membership in a protected class. • Density Bonus Law (Gov. Code, Section 65915.)
• Housing Accountability Act (Gov. Code, Section 65589.5.) • No-Net-Loss Law (Gov. Code, Section 65863)
• Least Cost Zoning Law (Gov. Code, Section 65913.1)
• Excessive subdivision standards (Gov. Code, Section 65913.2.)

Appendix D: Assessment of Fair Housing
D-6 Hearing Draft | August 6, 2026
• Limits on growth controls (Gov. Code, Section 65302.8.) • Housing Element Law (Gov. Code, Section 65583, esp. subds. (c)(5), (c)(10).) The City of Turlock complies with State fair housing laws, including but not limited to California Fair Employment and Housing Act (FEHA); FEHA Regulations; and Government Code sections 65008, 8899.50, and 11135 et seq. As a recipient of CDBG and HOME funds, the City is required to maintain Affirmatively Furthering Fair Housing (AFFH) certification and to demonstrate compliance through its Consolidated Plan and Annual Action Plans, which are submitted to HUD for approval prior to receipt of the CDBG and HOME funds. To the extent that funds are federal or State funds are directed to Turlock in the future, compliance will be demonstrated and maintained through that mechanism. From May 20th to May 24th, 2024, HUD conducted remote monitoring of the City’s CDBG-CV program in order to assess the City’s performance and compliance with applicable Federal program requirements. HUD’s review of the City’s program performance resulted in the identification of zero findings and zero concerns, as communicated in the FY2024 Monitoring Report. Additionally, the Federal Fiscal Year 2024 Turlock monitoring review provided an opportunity to address open findings from previous HUD monitoring reviews. The city provided its most recent responses to HUD open findings from prior years. All findings are now closed, and no further response is needed.

The City of Turlock complies with State Density Bonus Law (Gov. Code, Section 65915.), the Housing Accountability Act (Gov. Code, Section 65589.5.), and the No-Net-Loss Law (Gov. Code, Section 65863).

Section 9-2-103 of the Turlock Zoning Ordinance includes a short summary of the purpose and requirements for affordable housing density bonuses with a cross-reference to the most current State requirements in California Government Code Section 65915. Turlock has not established any additional bonuses or incentives for affordable housing or childcare facilities, nor has the City enacted any local ordinances, such as rent control or rent freezes, inclusionary regulations, or eviction protection ordinances.

Turlock has not denied any affordable housing project in its jurisdiction, and through this Housing Element, commits to implementing a plan to ensure adequate sites to accommodate its RHNA obligations during the planning period, and to comply with other legal requirements. In preparing this Housing Element, Turlock has reviewed its Zoning Code to identify regulations that create potential constraints to housing development some of which also interfere with efforts to further fair housing. The Action Plan in Chapter 4 of this Housing Element includes programs intended to reduce constraints to residential development that will also help Turlock further fair housing.

The City of Turlock received the Notice of Violation letter from the California Department of Housing and Community Development (HCD), dated June 19, 2025, regarding non-compliance with homelessness provisions and other housing element requirements. The City provided a response on July 2, 2025 clarifying the context for a recent City Council decision regarding support for County PLHA funding of an existing emergency shelter in Downtown Turlock and enumerating various efforts the City is undertaking to address homelessness citywide. The response letter also reiterated the City's commitment to achieving a compliant and certified Housing Element and provided a detailed schedule for achieving that objective.

The Notice of Violation cited a decision by the Turlock City Council on April 22, 2025 regarding support of an application for Stanislaus County Permanent Local Housing Allocation Program (PLHA) funding by We Care, a non-profit group that operates an emergency shelter for homeless men in Turlock. The Notice of Funding Availability (NOFA) issued by Stanislaus County required a letter of support and certified City Council resolution, which the City was prepared to provide in exchange for a commitment from We Care to help mitigate the health and safety impacts from its shelter operations in the surrounding downtown business area. In February 2025, the City suggested either 10 hours of additional street clean up or opening We Care restrooms during daytime hours after clients had to leave the shelter as potential mitigation. At a

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City Council meeting on April 8, 2025 when the letter of support and certified resolution were to be considered, the We Care Program Coordinator informed the City Council that she did not have the authority to agree to any mitigation efforts, and accordingly consideration of the item was continued until the next Council meeting to give the Program Coordinator the opportunity to talk with the We Care board.

Initially, in advance of the April 22 City Council meeting, the We Care Program Coordinator had indicated that shelter restrooms would be made available during the day; however, 5 minutes prior to the scheduled start of the meeting the We Care Program Coordinator informed the City Manager that the restrooms would not be available during the day. As a result, the City Council declined to provide the letter of support and resolution, as there was no partnership commitment by We Care. Subsequently, on April 25, 2025 the We Care Program Coordinator contacted the City Manager to commit to providing daytime bathrooms and the Mayor and City Clerk put a call for a special meeting on Monday May 5 to reconsider the We Care PLHA funding item; however, a quorum could not be convened. Consequently, the application deadline passed and the PLHA funds reverted to the County. As of November 2025, the County has not issued a new NOFA. Nevertheless, the We Care shelter continues to operate in Downtown Turlock. The facility closed temporarily during the summer as it does annually and reopened again in August 2025. Additionally, the Turlock Gospel Mission homeless shelter, which accepts men, women, and families, has operated continually in Turlock throughout 2025.

Although We Care's County PLHA application was not approved for this recent round of funding, the City of Turlock continues to take actions to prevent homelessness and provide for the needs of people experiencing homelessness in Turlock through various means:
• In October 2024, the City transferred a fourplex to We Care with a forgivable loan covering the acquisition costs. This project has housed 11 low-income tenants and provides We Care with approximately $4,000 in monthly rental income. Turlock has previously transferred another fourplex and a duplex to We Care with forgivable loans, which not only house low-income households but also provide the organization with monthly rental income that can be used to support We Care's shelter operations.
• Four units, comprising two single-family dwellings and one duplex, are being transferred to the United Samaritans Foundation (USF) with a forgivable loan to cover acquisition costs. These properties have created affordable housing for 14 individuals, helping prevent homelessness. USF will receive an approximate monthly rental amount of $4,000 from these properties, which can be used to support other programs administered by USF for the special needs population. • The City of Turlock has three other residential properties in the rehabilitation process. Two of these are proposed for transfer to non-profit agencies through a Request for Proposals (RFP) process, with forgivable loans. This will increase the supply of affordable housing while also providing capacity-building opportunities for non-profits that serve special needs populations.

Last fiscal year, several programs serving the homeless were also supported through the City's Public Services grants utilizing Community Development Block Grant (CDBG) funding, including:
• The United Samaritans Foundation's Emergency Food Box assisted 331 low-to moderate-income individuals and homeless families by providing monthly food support, and its Senior Congregate Lunch Program served 33 elderly residents with nutritious meals and social engagement opportunities.
• We Care's Emergency Shelter provided overnight accommodations to 28 homeless men. • The Center for Human Services reached two homeless or unsheltered youth with street outreach and case management.
• Healthy Alternatives to Violent Environment (HAVEN) aided 11 domestic violence survivors with housing-related support.

Appendix D: Assessment of Fair Housing
D-8 Hearing Draft | August 6, 2026
• Project Sentinel provided housing counseling and tenant-landlord dispute resolution services to 13 low-income individuals.

For the 2025-2026 fiscal year, the City of Turlock has allocated CDBG public service grant funding for several community support programs, including:
• The United Samaritans Foundation's Emergency Food Box Program is expected to serve approximately 300 homeless individuals and families.
• The Center for Human Services plans to support 20 homeless and unsheltered youth, ages 13-24, in the Turlock area.
• HAVEN expects to assist 50 individuals with essential housing-related services, focusing on low to moderate-income residents who are victims of domestic violence. • Project Sentinel estimates it will serve 30 individuals by providing comprehensive counseling, education, information, and referrals related to housing discrimination, tenant-landlord disputes, and home foreclosure.

Additionally, the City of Turlock actively participates in regional initiatives to address homelessness through partnerships with the Stanislaus Community System of Care (CSOC) and the Stanislaus Homeless Alliance (SHA). The City of Turlock Care Team collaborates with the Stanislaus County Care Team to offer resources to individuals experiencing homelessness in our community.

Building on this commitment to preventing homelessness and providing for the needs of people experiencing homelessness in Turlock, the City is working to complete the statutorily required analysis related to special needs populations and incorporate programs to address identified needs, including for people experiencing homelessness, into the Housing Element as needed to substantially comply with State Housing Element Law.

On September 5, 2025, a Turlock property owner informed the City that he has filed a housing discrimination complaint against the City with the Civil Rights Department. While the City has had no communications from the Civil Rights Department or any other agency regarding this complaint, the property owner informed City staff that a representative would be contacting him on December 16, 2025 to conduct a telephone intake interview. The property owner's complaint stems from City enforcement actions regarding a large shade structure erected in the backyard of 1842 Moonbeam Way without a building permit and within the setbacks. Based on complaints from neighbors, the City informed the property owner of 1842 Moonbeam Way of code violations and outlined three options available to bring the structure into compliance. City staff has met with the property owner on multiple occasions to outline the options available to him, but the property owner has not elected to pursue any of the remedies available to him. The code enforcement actions taken by the City in relation to this matter do not relate to nor have they prevented the permitting or construction of any housing units.

The City is not aware of any other any findings, lawsuits, consent decrees, judgments, and any other legal matters regarding fair housing.

LENDING PRACTICES
Discrimination in lending practices can be a major contributor to fair housing issues in a community because it limits the ability of individuals to live in a location of their choosing. The Home Mortgage Disclosure Act (HMDA) requires financial institutions, including banks, savings associations, credit unions, and other lenders, to annually disclose mortgage data to the public. HMDA financial data by itself

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is insufficient to conclusively identify instances of discrimination in lending but analysis of HMDA data is useful for exploring discrepancies in lending outcomes and identifying areas of concern.

Based on 2018 HMDA data, the 2020-2025 Regional AI for Stanislaus Urban County and the Cities of Turlock and Modesto found that out of 16,00 loans originated in Stanislaus County, 2,327 loans (14.5 percent) originated in Turlock. In 2018, Turlock experienced the highest approval rate in Stanislaus County at 59.5 percent which is higher than the national approval rate of 53.4 percent. Countywide in 2018, White applicants were approved for loans at a rate of 63.8 percent, compared with Hispanic applicants at a rate of

59.7 percent, Black applicants at a rate of 57.1 percent, and Asian applicants at a rate of 55.4 percent. In Turlock in 2018, White applicants were approved for loans at a rate of 65.5 percent, Asian applicants at a rate of 59.5 percent, Hispanic applicants at a rate of 58.7 percent, and Black applicants at a rate of 55.0 percent. Compared to the County, White and Asian applicants were approved at a higher rate in Turlock, while Black and Hispanic applicants were approved at a lower rate. The data does not indicate the grounds for the denial, and it cannot be proven on the basis of this data that the denials were not justified on the basis of standard financial criteria; however, the trend suggests both a potential for bias within the financial system and a need for financial literacy training among non-Whites to help those groups better understand how to improve their credit scores.

Charts D-1 and D-2 provide an overview of lending patterns in Turlock when compared to the county and over time. Chart D-1 confirms the findings of the 2020-2025 AI showing that potentially discriminatory lending patterns have continued at the county level up until the year 2021. Turlock has similarly seen uneven lending patterns, and as of 2021 (the most recent year that data is available) Black applicants had the highest loan denial rates, followed by Hispanic or Latino applicants. Further, since 2018, White applicants in Turlock have consistently experienced lower than average loan denial rates. The wider variation in loan denial rates for American Indian or Alaska Native and Native Hawaiian or Other Pacific Islander applicants is due to the low number of applicants during the period who identified as such. Chart D-3 and Chart D-4 show that in 2021, the City had higher loan approval rates for both home improvement and home purchase loans than the Stanislaus County.

Based on the identified disparities of lending patterns for residents of color and a history of discriminatory lending practices, the 2020-2025 AI recommended further fair lending investigations/testing into the disparities identified through the HMDA data analysis. More generally, it recommended that jurisdictions like Turlock may prefer lending institutions with a Community Reinvestment Act (CRA) rating of “Outstanding” and may exclude those with a rating of “Needs to Improve” or “Substantial Noncompliance” according to the most recent examination period published by the Federal Financial Institutions Examination Council (FFIEC). The AI also recommended Turlock and other jurisdictions to strengthen partnerships with lenders to discuss lenders’ community reinvestment goals, including home mortgages, home improvement loans, and community development investments to be made in low- and moderateincome neighborhoods in the Stanislaus Urban County and in the City of Turlock.

Appendix D: Assessment of Fair Housing
D-10 Hearing Draft | August 6, 2026
Chart D-1: HMDA Loan Denial Rates by Race/Ethnicity, Turlock Source: Home Mortgage Disclosure Act Data, 2018-2021
Chart D-2: HMDA Loan Denial Rates by Race/Ethnicity, Stanislaus County Source: Home Mortgage Disclosure Act Data, 2018-2021

0.00%

10.00%

20.00%

30.00%

40.00%

50.00%

60.00%
All American
Indian or
Alaska Native
Asian Black Hispanic or
Latino
Native
Hawaiian or
Other Pacific
Islander
White
Denial Rate
Turlock
2018 2019 2020 2021

0.00%

10.00%

20.00%

30.00%

40.00%

50.00%

60.00%
All American
Indian or
Alaska Native
Asian Black Hispanic or
Latino
Native
Hawaiian or
Other Pacific
Islander
White
Stanislaus County
2018 2019 2020 2021

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44.81 49.67

36.25 30.46

18.94 19.87
0 20
40 60
County Turlock
Percent of Loan Received
Home Improvement
Approved Denied Other
Source: Home Mortgage Disclosure Act Data, 2021
Source: Home Mortgage Disclosure Act Data, 2021

BROKERAGE SERVICES
Real estate brokers or salespersons whose business is in Turlock may belong to one of several associations but most likely the Central Valley Association of Realtors (CVAR). Like all associations, CVAR has a Multiple Listing Service (MLS)—Paragon MLS—and is part of the NORCAL MLS Alliance, an MLS data integration project across the seven leading MLSs in Northern California. CCAR is bound by the Code of Ethics and Standards of Practice of the National Association of Realtors (NAR), which explicitly states in Article 10 that members shall not discriminate against any person based on race, color, religion, sex, handicap, familial status, national origin, sexual orientation, or gender identity. In addition to adopting the ethics standards set by the NAR, the state branch promotes its own diversity and inclusion programs, such as the Latino Initiative Voices in Action program, which provide educational materials for members on homeownership opportunities and fraud prevention.

PROPERTY MANAGEMENT
Project Sentinel identified the largest rental companies in Stanislaus County as Liberty Property Management, Cornerstone Property Management, Matel Realtors, Marshall Perty, GreenGate Property Management, and Stanislaus Property Management. Half of these companies belong to California Apartment Association (CAA), the country’s largest trade association for rental property owners and managers. However, there are a substantial number of owners who rent out units without going through a Chart D-3: HMDA Home Improvement Loan Applications, 2021 Chart D-4: HMDA Home Purchase Loan Applications, 2021

62.49 65.6

7.03 5.73

30.48 28.17
0 20
40 60
80 Percent of Loans Received
County Turlock
Home Purchase
Approved Denied Other

Appendix D: Assessment of Fair Housing
D-12 Hearing Draft | August 6, 2026
property management company, generally referred to as “mom and pop” landlords, or small, independent landlords. CAA reports that the majority of these small, independent landlords are not CAA members due to the time and cost to join, even though the actual benefits of joining may outweigh the costs when they run into issues. CAA also finds that most landlords who call the helpline are these small, independent owners. CAA encourages them to attend training and to utilize services as members.

CAA supports the spirit and intent of all local, State, and Federal fair housing laws for all residents without regard to color, race, religion, sex, marital status, mental or physical disability, age, familial status, sexual orientation, or national origin. When signing up to become a member of the California Apartment Association, new members agree to abide by the following provisions of their Code of Ethics and Code of Equal Housing Opportunity. The Code of Equal Housing Opportunity reads as follows:
• We agree that in the rental, lease, sale, purchase, or exchange of real property, owners and their employees have the responsibility to offer housing accommodations to all persons on an equal basis; • We agree to set and implement fair and reasonable rental housing rules and guidelines and will provide equal and consistent services throughout our resident’s tenancy; • We agree that we have no right or responsibility to volunteer information regarding the racial, creed, or ethnic composition of any neighborhood, and we do not engage in any behavior or action that would result in steering; and
• We agree not to print, display, or circulate any statement or advertisement that indicates any preference, limitations, or discrimination in the rental or sale of housing.

CAA provides members with tenant screening services, application forms, and other types of landlord tenant forms, which if used by CAA members provide legal procedures for processing rental applications and resolving tenant issues. Further, should landlords stay within these guidelines, they will likely avoid committing housing violations. CAA offers a landlord helpline where landlords can call and speak to an attorney about their responsibilities. Lastly, all members receive a fair housing flyer to post on-site at their properties which states that it is illegal to discriminate based on the protected classes. When CAA receives complaints about potential fair housing violations, the association provides tenants with information on their rights and then refers them to the California Department of Fair Employment and Housing to file a claim. The Executive Director of CAA’s Central Valley branch stated that her experience has been that most tenant complaints are about non-CAA members. The director said that these non-CAA members are independent landlords with little training and are unaware of the laws. For this reason, CAA makes additional efforts to reach these smaller operations throughout outreach events and the landlord helpline.

Considering there is a large proportion of property owners who are not CAA members, Turlock and other Stanislaus County jurisdictions that contract with Project Sentinel can collaborate on outreach, education, and training to small, independent landlords about fair housing topics and regulations. Respondents to a Housing Element survey conducted by Stanislaus County identified landlord-tenant counseling and education/information on tenant rights as the two services needed most in their communities.7 Although recent declines in the population of Turlock and other Stanislaus County communities may relieve the shortage of affordable housing in the short-term, Stanislaus County and its communities are projected to grow over the next 40 years, which means that the shortage of affordable housing can be expected to continue. Landlords have little incentive to rent units to applicants with vouchers, disabilities, 7 Stanislaus County Draft 2023-2031 Housing Element, 2023. Available:
https://www.stancounty.com/planning/pl/pdf/draft-2023-2031-housing-element.pdf

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households with children, or other protected groups when they can find tenants able to afford to market rents. Programs that prioritize housing development for persons with disabilities, families with children, and those most at risk of homelessness, may be particularly effective.

D.2 Segregation and Integration
Patterns of segregation within a community can be a result of public or private actions, whether intentional or unintentional, that affect where different racial and ethnic groups and individuals in other protected classes live. Racial and ethnic characteristics are probably the most common and well-known basis for housing discrimination, but segregation may also be based on disability, familial status, and the level and source of household income. This section explores patterns and trends of segregation based on race and ethnicity, disability, familial status, and income level in the City of Turlock and the surrounding region.

These groups are not mutually exclusive, and there may be considerable overlap across each protected class.

Historically throughout the U.S., including in California and Stanislaus County, restrictive and exclusionary zoning practices have contributed to racial and economic segregation.

After the Civil War, John W. Mitchell, a wealthy land speculator, bought 100,000 acres where Turlock is now located, that were used for large herds of cattle and sheep as well as growing wheat. By the early part of the 20th century, Turlock had become the heart of a major agricultural area, which stands true today.

Japanese immigrants from rural farming and fishing areas arrived in California to fill a labor shortage created by the 1882 Chinese Exclusion Act, which prohibited Chinese immigration to the U.S. California lawmakers soon passed racist ordinances targeting issei (first-generation) farmers: the California Alien Land Law of 1913 barred Asian immigrants from owning agricultural land or signing leases longer than three years. Newly arrived Japanese had few employment opportunities, but they were able to find jobs as agricultural workers. See Chart D-5 for a more detailed timeline of segregation’s history in relation to fair housing practices.

Due to resentment toward Chinese and Japanese immigrants, especially from jobless White residents, many of whom had moved to California from the Dust Bowl, a series of severe dust storms swept across the midwest states of Oklahoma, Arkansas, Kansas, and Texas during the 1930s, growers began recruiting Blacks from the south. Blacks continued to move to the area after Japanese residents were moved into internment camps. Turlock was the site of one of several temporary detention camps established during the first phase of the mass incarceration of 97,785 Californians of Japanese ancestry during World War II. The so-called Turlock Assembly Center was located at the Stanislaus County Fairgrounds from April 30 to Aug. 12, 1942.8 At the height of its population, 3,692 people lived in barracks constructed on the fairgrounds.9 The Stanislaus County Fairgrounds is now located in central Turlock, in Tract 38.04 where it and surrounding tracts are deemed racially integrated, as shown on Map D-1. Due to a boom in population attributed to the expansion of State Route 99 in the 1970s, Turlock grew west to meet the freeway’s north-south path. This area is also where most of the city’s low-medium segregation tracts are located, as well as the City’s only High Segregation and Poverty tract (see discussion in Section D.3 and Map D-1 below). 8 California Historical Landmarks in Stanislaus County, Temporary Detention Camps for Japanese Americans – Turlock Assembly Center. Available: https://noehill.com/stanislaus/cal0934.asp 9 Turlock Journal, 2009. Turlock Japanese American assembly center to be memorialized. Available:
https://www.turlockjournal.com/news/local/turlock-japanese-american-assembly-center-to-be-memorialized/

Appendix D: Assessment of Fair Housing
D-14 Hearing Draft | August 6, 2026
Chart D-5: Timeline of Segregation Policies in the United States

STANISLAUS
COUNTY

W CHRISTOFFERSEN PKWY

WTAYLOR
RD

ETAYLOR RD

W MONTEVISTAAVE E MONTEVISTAAVE

WTUOLUMNE RD ETUOLUMNE RD

FULKERTH RD

WEST MAIN ST EASTAVE

W E LINWOOD AVE LINWOOD AVE

SWALNUT RD

S LANDERAVE

SOUTHAVE

W CANAL DR

E CANAL DR

NWALNUT RD

GEER RD

N OLIVEAVE

N BERKELEYAVE

E OLIVE ST

MARSHALL ST
D ST

FIFTH ST

N GOLDEN STATE BLVD

S GOLDEN STATE BLVD

S QUINCY RD

S JOHNSON RD

N DAUBENBERGER RD

N ROSE ST

DELS LN

CROWELL RD

N COLORADO AVE

E MINNESOTAAVE

NORTHAVE

N SODERQUIST RD

S KILROY RD

STEGNER RD

FRANSIL LN

DIANNE DR

GOLF RD

HARDING RD

BRIER RD
Census
Tract:

36.10 Census
Tract:

36.12 Census
Tract:

36.09 Census
Tract:

36.11 Census
Tract:

36.08 Census
Tract:
37 Census
Tract:

38.02 Census
Tract:

36.03 Census
Tract:

39.08 Census
Tract:

38.03 Census
Tract:

39.04 Census Tract:

39.09 Census
Tract:

39.05 Census
Tract:

39.06 Census
Tract:

39.07 Census
Tract:

38.05 Census
Tract:

38.04 Turlock Neighborhood
Segregation
0 ¼ ½ 1
Miles
SB 535 Disadvantaged Community
Racially Integrated
Low-Medium Segregation
HighWhite Segregation
No Data Applicable to
2021 Census Tract Boundary

MERCED COUNTY
J:\GISData\580_Turlock\GIS\Projects\HousingElement\AFFH\D-1 Turlock Neighborhood Segregation.mxd Map Date:
9/20/2024
Study Area Boundary
City Limit & County Island
County
Railroad
AÎ
AÎ Map D-1

STANISLAUS
COUNTY
Source: CalEPA, 2022; HCD, 2022; City ofTurlock, 2021;
Dyett & Bhatia, 2024

Appendix D: Assessment of Fair Housing
D-16 Hearing Draft | August 6, 2026
During World War II, many Black and White agricultural workers moved to California’s urban areas to fill jobs in the defense industry and other employment sectors. Additionally in this same timeframe the federal government initiated the Bracero program to attract workers from Mexico to help address a shortage of farmworkers. After the program ended in 1964, Mexican farmworkers continued to come to the Central Valley for agricultural work. Non-Hispanic Whites remain the largest racial group in Turlock and Stanislaus County, but Hispanics are now the second largest ethnic group comprising about 48 percent of the countywide population.

In addition to these ethnic groups, the southern part of Turlock has been known historically as “Little Urmia” because of the immigration of Assyrians in the early 20th century. Early Assyrian settlers began to arrive in the United States during the last part of the 19th century and came mainly from northwestern Iran (Urmia region) as early as 1910 but the migration increased due to the genocide committed against them before, during and after World War I by the Turks, Kurds, and Moslem Persians. By 1915, when the total population of Turlock was about 1,500, there were ten Assyrian families living in Turlock. By 1921, the Assyrian community had grown to become known as “little Urmia.” According to the 2020 US Census, 5.8 percent of Turlock residents reported that they had Assyrian ancestry, most located in southern Turlock in racially integrated Tract 37.

Historic segregation patterns in Turlock may be a factor that continues to affect the disparate characteristics of neighborhoods. Map D-1 shows neighborhood segregation in Turlock. The most racially integrated areas of Turlock today include Tract 38.04, where former internment camps were located, and Tract 37, where Assyrian settlers immigrated and settled. By contrast, Tract 39.05 in Turlock is classified as high White segregation, which can be traced back to the early immigration of White residents in central, east Turlock.

Turlock has one census tract that meets the criteria for designation as High Segregation and Poverty tract, Tract 38.02. As discussed in Section D.3 Racially/Ethnically Concentrated Areas of Poverty and Affluence, the population of this tract is predominantly Hispanic and has seen a decrease in non-Hispanic White residents that reflects Turlock’s overall demographic changes.

Additionally, the most racially integrated areas of Turlock today are Census tracts designated by the State as Disadvantaged Communities (DACs), or low-income areas disproportionately affected by environmental pollution and other hazards that can lead to negative health effects. According to City Housing Division staff, these areas are more integrated compared to other areas in Turlock due to the affordability, age of housing units, and mix of uses. As buildings age and initial construction costs are paid off, they may become less desirable due to wear and tear, which can contribute to lower prices, allowing all races opportunity to access housing. Additionally, City staff noted homeowners in these integrated areas may rent out their housing units or rooms at a lower price than market-rate, thus making housing more affordable in these areas compared to others. Lastly, integrated areas in Turlock are composed of a mix of residential, industrial, and commercial uses, making these areas less desirable than single-family neighborhood, thus allowing them to be more affordable for all races.

Racially/Ethnically Concentrated Areas of Affluence (RCAAs) census tracts are located along the very eastern edge of the city (Tract 39.05), while one RCAA is located outside the city to the east (Tract 36.08).

The RCAA tract in Turlock is 71.6 percent White (Hispanic or Latino) and has 79.6 percent of units occupied by owners, and 98.2 percent of homes are single family dwellings (the highest percent in all Turlock tracts). Further detail about these RCAA is included in Section D.3 Racially/Ethnically Concentrated Areas of Poverty and Affluence.

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CHANGE IN PATTERNS OVER TIME
Turlock’s racial and ethnic patterns of segregation need to be understood in the context of changing regional and local demographics. As shown in Table D-1, the population of Turlock increased by 2.7 percent between 2010 and 2020. Non-Hispanic White residents are still the largest population but have decreased by 12.8 percent and is only slightly larger than the Hispanic or Latino residents of any race, which grew by

15.4 percent between 2010 and 2020. The City’s non-Hispanic or Latino Asian and non-Hispanic or Latino Black populations each increased by around a third. The non-Hispanic or Latino Other Race or Multiple Races population had the largest increase, increasing by two-thirds. The non-Hispanic or Latino American Indian/Alaska Native and non-Hispanic or Latino Native Hawaiian/Pacific Islander populations changed marginally, increasing by 0.25 percent and decreasing by 2.1 percent, respectively. These patterns directionally resemble the County’s diversity, which saw increases in non-Hispanic or Latino Black, nonHispanic or Latino Asian, and non-Hispanic or Latino Other Race or Multiple Races populations and Hispanic or Latino populations; a decrease in non-Hispanic or Latino White population; and marginal changes in non-Hispanic or Latino American Indian/Alaska Native and non-Hispanic or Latino Native Hawaiian/Pacific Islander populations.10 However, the City saw greater change in magnitude among each racial and ethnic group. This growth in the Hispanic, non-Hispanic or Latino Black, and non-Hispanic or Latino Other Race or Multiple Races population could be reflecting the trend in the movement of Black and Latino households from the Bay Area to San Joaquin and Stanislaus Counties in search of more affordable housing.11
Despite the diversity of the County, the population is unevenly distributed geographically by race/ethnicity.

In Turlock, Salida, and Modesto, between 36 to 49 percent of the population is non-Hispanic White. The three CCDs with the highest concentrations of non-Hispanic White people are Hughson, Oakdale, and Waterford, which are adjacent to each other in the eastern end of the county. Westport, Newman, and Patterson, adjacent to one another in the western part of the county, have the lowest non-Hispanic White population percentages, and are adjacent to each other on the western side of the county.

In the Turlock (including Ceres), Salida, and Modesto CCDs, in the center of the county, the White population ranges from 36.60 percent to 48.90 in the Turlock subdivision. In 2020, Stanislaus County had the highest percent of non-Hispanic White residents among the eight counties in the greater San Joaquin Valley region and Merced County, just south of Stanislaus County, had the lowest percent among the eight counties in the greater San Joaquin Valley region.

The State approved legislation in 2021 that requires counties to establish a program to redact racial covenants that barred Black, Chinese, Japanese and other racial or ethnic groups from owning or occupying homes in certain areas of the county. Although such restrictions have been illegal and unenforceable for more than half a century, they remain in many property documents as a review of covenants in Modesto showed. Government Code Section 12956.2 requires counties to identify and redact such covenants that remain in records. Stanislaus County is hiring a vendor to meet this requirement, but has published a form 10 California Department of Finance, Table P-2D, County Population by Total Hispanic and Non-Hispanic Race (2010-2060). https://dof.ca.gov/forecasting/demographics/projections/ 11 Terner Center for Housing Innovation. 2018. “Disparity in Departure: Who Leaves the Bay Area and Where Do They Go?” https://ternercenter.berkeley.edu/wp-content/uploads/pdfs/Disparity_in_Departure.pdf

Appendix D: Assessment of Fair Housing
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that allows property owners and other parties to undertake the process for individual properties in the meantime.
12, 13
Table D-1 displays the population dynamics within census tracts by race and ethnicity between 2010 and 2020. Change in non-Hispanic or Latino American Indian/Alaska Native populations and non-Hispanic or Latino Native Hawaiian/Pacific Islander populations within census tracts did not have a predominant trend and are quite mixed. Non-Hispanic or Latino Asian populations increased within all but two tracts, with the highest increase (252.6 percent) in Tract 39.08, a Low Resource area by California Tax Credit Allocation Committee (TCAC) measures. Non-Hispanic or Latino Black populations increased within all but two tracts, with a larger decline in Tract 39.05, a tract considered to be High Resource and a Racially Concentrated Area of Affluence. The largest increase of Non-Hispanic or Latino Black residents within tracts were Tracts 36.03 and 38.03, both Moderate Resource areas designated as Disadvantaged Communities. Non-Hispanic or Latino Other Race or Multiple Races increased within every tract. The largest increases (between 134.4 and 137.2 percent) were in Tracts 39.04 and 39.05, both of which are High Resource. By contrast, Non-Hispanic or Latino White populations consistently decreased within each tract between 6.3 and 19.4 percent, with the exception of Tract 38.05, which saw no change. The Hispanic or Latino population of any race increased within all tracts between 2010 and 2020, except for Tract 36.08 and a small decrease in Tract 38.02. All tracts in Turlock saw population increases except for Tract 36.08 at a

19.3 percent decrease and Tract 38.02’s small decrease of 2.3 percent. Information on TCAC resource areas is explained further in Section D.4 Disparities in Access to Opportunity.

PERSONS WITH DISABILITIES
Persons with disabilities may face discriminatory housing practices based on their disability, including the lack of accessible dwellings and refusal by housing providers to offer reasonable accommodations. Data shows that from a housing perspective, there are several different housing needs of disabled persons. For those disabled with a developmental or mental disability, one of the most significant problems is securing affordable housing that meets their specialized needs. Housing needs can range from institutional care facilities to facilities that support partial or full independence (such as group care homes). Supportive services such as daily living skills and employment assistance need to be integrated into the housing situation also. A disabled person with a mobility limitation requires housing that is physically accessible. 12 The Modesto Bee, 2023. “Stanislaus County to search for records revealing white-only neighborhoods and racism.” Available: https://www.modbee.com/news/local/article273097685.html 13 Stanislaus County, 2022. “Stanislaus County Clerk-Recorder’s Office Restrictive Covenant Modification Program Implementation Plan”. Available: https://www.stancounty.com/clerkrecorder/pdf/restrictive-modificationprogram.pdf

City of Turlock – Housing Element Update 2023-31
Hearing Draft | August 6, 2026 D-19
Table D-1: Population Change by Race/Ethnicity within Turlock Census Tracts, 2010-2020 American Indian/Alaska Native
(NH)
Asian (NH) Black (NH) Native Hawaiian/Pacific Islander
(NH)
Other Race, Multiple Races (NH) White (NH) Hispanic or Latino (any race) Total Tract 2010 2020 Percent
change
2010 2020 Percent
change
2010 2020 Percent
change
2010 2020 Percent
change
2010 2020 Percent
change
2010 2020 Percent
change
2010 2020 Percent
change
2010 2020 Percent
change

36.03 13 13 0.0% 30 21 -30% 4 9 125.0% 1 3 200.0% 70 135 92.9% 2,188 2,050 -6.3% 1,646 1,781 8.2% 3,952 4,012 1.5%

36.04 in 2010,

36.08 in 2020)
48 27 -43.8% 234 328 40.2% 31 34 9.7% 6 7 16.7% 181 353 95.0% 5,274 3,883 -26.4% 2,318 1,898 -18.1% 8,092 6,530 -19.3%

36.09 (Part of
2010 Tract

36.05)
34 13

23.5%
647 372

25.8%
158 50
-1.3%
46 15
-21.7%
327 199

23.9%
4,744 2,026
-10.5%
2,051 1,018

37.5%
8,007 3,693

6.4% 36.10 (Part of
2010 Tract

36.05. See 36.09
for 2010 data)
- 29 - 442 - 106 - 21 - 206 - 2,219 - 1,803 - 4,826

36.11 (Part of
2010 Tract

36.06)
41 16
-12.2%
1,262 636

40.0%
183 76

35.0%
41 11
-7.3%
376 193

62.8%
6,019 2,140
-8.8%
2,916 1,100

12.8%
10,838 4,172

5.9%

36.12 (Part of
2010 Tract

36.06. See 36.11
for 2010 data)
- 20 - 1,131 - 171 - 27 - 419 - 3,347 - 2,188 - 7,303
37 33 35 6.1% 242 253 4.5% 37 64 73.0% 24 39 62.5% 119 138 16.0% 1,862 1,664 -10.6% 2,476 2,803 13.2% 4,796 4,996 4.2%

38.02 30 33 10.0% 96 158 64.6% 66 97 47.0% 8 6 -25.0% 79 127 60.8% 1,223 1,069 -12.6% 4,358 4,234 -2.8% 5,860 5,724 -2.3%

38.03 7 6 -14.3% 243 197 -18.9% 22 50 127.3% 21 10 -52.4% 58 69 19.0% 723 630 -12.9% 1,930 2,083 7.9% 3,004 3,045 1.4%

38.04 50 54 8.0% 215 210 -0.02% 85 114 34.1% 27 22 -18.5% 147 205 39.5% 2,577 2,076 -19.4% 3,349 4,145 23.8% 6,450 6,826 5.8%

38.05 14 10 -28.6% 218 441 102.3% 31 51 64.5% 19 20 5.3% 85 164 92.9% 1,194 1,194 0.0% 1,106 1,207 9.1% 2,667 3,087 15.7%

39.04 19 13 -31.6% 55 124 125.4% 44 61 38.6% 20 22 10.0% 94 223 137.2% 2,384 2,099 -12.0% 1,758 2,190 24.6% 4,374 4,732 8.2%

39.05 18 22 22.2% 53 60 13.2% 24 13 -45.8% 4 6 50.0% 93 218 134.4% 3,065 2,688 -12.3% 614 933 52.0% 3,871 3,940 17.8%

39.06 28 34 21.4% 124 251 102.4% 162 197 17.8% 28 15 -46.4% 151 249 64.9% 2,339 1,895 -19.0% 2,048 2,488 21.5% 4,880 5,129 5.1%

39.07 21 34 61.9% 251 307 22.3% 91 122 34.1% 15 7 -53.3% 224 362 61.6% 5,658 4,999 -11.6% 1,200 1,735 44.6% 7,460 7,566 1.4%

39.08 7 10 42.9% 57 201 252.6% 39 80 105.1% 3 14 366.7% 95 145 52.6% 1,133 955 -15.7% 892 1,044 17.0% 2,226 2,449 10.0%

39.09 34 29 -14.7% 164 269 64.0% 88 125 42.0% 27 39 44.4% 223 370 65.9% 3,573 3,414 -9.0% 1,691 2,379 40.7% 5,980 6,625 10.8% Total 397 398 0.25% 3,891 5,401 38.8% 1,065 1,420 33.3% 290 284 -2.1% 2,322 3,775 62.6% 43,956 38,348 -12.8% 30,353 35,029 15.4% 82,457 84,655 2.7% I. NH refers to non-Hispanic or Latino.

II. Percent change for tracts with boundary changes was calculated by combining the 2020 values of the singular 2010 tract, subtracting the combined values from the 2010 value, and dividing by the 2010 value.

Source: U.S. Census Bureau Decennial Census, Table P-9 Hispanic or Latino, and not Hispanic or Latino by Race (2010-2020)

Appendix D: Assessment of Fair Housing
D-20 Hearing Draft | August 6, 2026
During the last planning period, the City of Turlock approved two requests for deviations from development standards for reasonable accommodations through building permits when the improvements require a building permit. Exceeding the allowable hardscaped area of a front yard is one example of a development standard that was allowed to be deviated from to accommodate an accessible ramp in the front yard of a home. No requests for reasonable accommodation have been denied in Turlock during the last planning period. Housing staff at the City details Turlock city staff provides resources such as brochures and web materials to those in need. City staff also makes an effort to go to older adults and people with disabilities who cannot come to City Hall for information. City staff also mentioned Legacy Health Endowment, a nonprofit foundation serving in Stanislaus and Merced Counties, that is dedicated to improving residents’ health by funding and supporting healthcare services and wellness education.14 It makes its resources directly available to the community through patient-centered programs, such as affordable generic medicine via its $2 Medication Program, nursing scholarships, mental health initiatives, and online grant applications and resources. Staff noted that Legacy Health Endowment are actively involved within the Turlock community and have found older adults and people with disabilities greatly benefit from their services.

According to 2021 ACS five-year estimates, 7,576 persons (10.5 percent of the non-institutionalized population) in Turlock had a disability. This proportion is slightly lower than Stanislaus County (12.2 percent) and Modesto (13.7 percent). The most common disabilities in the city are ambulatory (28.0 percent of people with disabilities), independent living difficulty (21.6 percent) and hearing difficulty (12.4 percent).

As shown in Map D-2, the northern and eastern portions of the city fewer than ten percent of the population has disabilities while in the rest of Turlock, at least 10 to 20 percent of residents are disabled. There is one Turlock census tract, Tract 39.08 in the center of Turlock, in which persons with disabilities exceed 20 percent of the total tract’s population, which is the threshold HCD typically uses as an indicator of overconcentration. Further, group homes and licensed adult residential care facilities are located throughout the city, with concentrations in the northern and southern portions of Turlock as shown in Map D-3. There are 17 licensed residential care facilities within Turlock: two adult day programs and 15 adult residential facilities. There is a cluster of facilities in southern Turlock comprised of four separate structures operating as the Paulson Community for developmentally disabled ambulatory adults, intentionally designed to create a welcoming, neighborhood–like atmosphere. Other residential care facilities are found in central Turlock near the Emanuel Medical Center. People with disabilities have many different housing needs, depending on their age, level of income, current tenure status, cultural background, and health status. People with disabilities may need assistance with personal and financial affairs, networks of care to provide services and daily assistance, and, possibly, architectural services to design features to allow those with disabilities to live independently. During the consultation process conducted as part of the HOME-ARP Allocation Plan, the Turlock/Stanislaus HOME Consortium in 2022, service providers reported that individual with disabilities may find affordable housing in smaller cities or rural areas, but these areas are frequently not accessible for a person’s disability (e.g., wheelchair inaccessible) or are far from needed medical care, healthy food, or transportation.15

FAMILIAL STATUS
Familial status, and particularly discrimination against families with children, may be another basis for discriminatory housing practices. Such discrimination can limit the choices of where families can live and 14 Legacy Health Endowment, 2025. About LHE. Available: https://legacyhealthendowment.org/about-lhe/ 15 Turlock/Stanislaus County HOME Consortium, pp. 9-10.

City of Turlock – Housing Element Update 2023-31
Hearing Draft | August 6, 2026 D-21
lead to geographic concentrations within a community. Statistically, female-headed households with children are more likely to be targets of discrimination than other families with households because of their lower income or source of income. Within Turlock, as indicated in Table D-2, most children under 18 years live in married-couple households. About 23 percent of children live in female-headed households with no spouse present compared with 10 percent of children live in male householder, no spouse present households. Female-headed households represented about 10.3 percent of owner-occupied households and

19.3 percent of renter-occupied households. Female-headed households are as common in Turlock as they are in Stanislaus County, as the County has 22 percent female-headed households and 68 percent marriedcouple households. For female-headed households in Turlock, City staff shared they typically have two to three children and are a predominant group seeking housing assistance, though specific age demographics weren't collected. In Modesto, the other urban center in the County, households with children under 18 are

24.9 percent female-headed households and 65.4 percent married-couple households.

Housing Division staff directs female-headed households to resources from a couple of local organizations such as Healthy Alternatives to Violent Environments (HAVEN), United Samaritans, local churches, and school districts. HAVEN has a collaborative relationship with the City of Turlock to secure office space to bring services closer to home for residents living in the southern portion of Stanislaus County.16 HAVEN offers supportive services for survivors of domestic violence, sexual assault, and human trafficking. HAVEN provides an emergency shelter for survivors and children, with food, clothing, and a place to sleep, as well as case management/crisis intervention services, and support groups. United Samaritans Foundation offers emergency food boxes and mobile lunch programs for those in need. Turlock Gospel Mission Day Center offers clothing and hygiene supplies, while the Turlock Unified School District operates a Family Resource Center (FRC) where families can receive resources, programs, and services based on the needs and interests of our diverse families. Support at the FRC is specialized to support foster youth, students experiencing homelessness, and refugees/newcomers. City staff is versed in resources available in Turlock and can point special needs groups to a direction that suits their needs.

Household type Number Percent
Married couple 12,588 66%
Male Householder, No Spouse Present 1,920 10%
Female Householder, No Spouse Present 4,353 23%
Total 18,978 100.0%
Source: U.S. Census Bureau, 2022 ACS Five-Year Estimates (Table S0901) 16 HAVEN, 2025. Turlock Office. Available: https://www.havenstan.org/turlock-office Table D-2: Children Under 18 Years in Turlock Households, 2022

STANISLAUS
COUNTY

W CHRISTOFFERSEN PKWY

WTAYLOR
RD

ETAYLOR RD

W MONTEVISTAAVE E MONTEVISTAAVE

WTUOLUMNE RD ETUOLUMNE RD

FULKERTH RD

WEST MAIN ST EASTAVE

W E LINWOOD AVE LINWOOD AVE

SWALNUT RD

S LANDERAVE

SOUTHAVE

W CANAL DR

E CANAL DR

NWALNUT RD

GEER RD

N OLIVEAVE

N BERKELEYAVE

E OLIVE ST

MARSHALL ST
D ST

FIFTH ST

N GOLDEN STATE BLVD

S GOLDEN STATE BLVD

S QUINCY RD

S JOHNSON RD

N DAUBENBERGER RD

N ROSE ST

DELS LN

CROWELL RD

N COLORADO AVE

E MINNESOTAAVE

NORTHAVE

N SODERQUIST RD

S KILROY RD

STEGNER RD

FRANSIL LN

DIANNE DR

GOLF RD

HARDING RD

BRIER RD
Census
Tract:

36.10 Census
Tract:

36.12 Census
Tract:

36.09 Census
Tract:

36.11 Census
Tract:

36.08 Census
Tract:
37 Census
Tract:

38.02 Census
Tract:

36.03 Census
Tract:

39.08 Census
Tract:

38.03 Census
Tract:

39.04 Census Tract:

39.09 Census
Tract:

39.05 Census
Tract:

39.06 Census
Tract:

39.07 Census
Tract:

38.05 Census
Tract:

38.04 Persons with Disabilities
0 ¼ ½ 1
Miles
Percent of Population with a Disability
(ACS, 2017-2021) - Tract
< 10%
10% - 20%
20% - 30%

MERCED COUNTY
J:\GISData\580_Turlock\GIS\Projects\HousingElement\AFFH\D-2 Persons with Disabilities.mxd Map Date:
9/20/2024
Study Area Boundary
City Limit & County Island
County
Railroad
AÎ
AÎ Map D-2

STANISLAUS
COUNTY
Source: HCD, 2022;American Community Survey (ACS) (2017-2021); City ofTurlock, 2021; Dyett & Bhatia, 2024

N Colorado Ave
West Main St
S Washington Rd
N Soderquist Rd
Geer Rd
Fosberg Rd
N Tully Rd
NBerkeley Ave
State Blvd
E Monte Vista Ave
E Tuolumne Rd
E Main St
Ninth St
S Lander Ave
Roberts Rd
N Quincy Rd
S Tegner Rd
N Walnut Rd
W Tuolumne Rd
Montana Ave
Andre Ln
1525W
MonteVista
S Quincy Rd
E Minnesota Ave
S Golden State Blvd
Brier Rd
N Johnson Rd
W Christoffersen Pkwy
Pedras Rd
El Capitan Dr
E Hawkeye Ave
W Linwood Ave
Dels Ln
Fulkerth Rd
N Olive Ave
S Kilroy Rd
North Ave
E Taylor Rd
East Ave
F St
W Taylor Rd
S Soderquist Rd
N Washington Rd
A St
Fullerton Dr
Hedstrom Rd
Mountain View Rd
Georgetown Ave
S oJ hnson Rd
South Ave
W Springer Dr
E Canal Dr
Marshall St
N Denair Ave
E Glenwood Ave
N Berkeley Ave
Grant Ave
Park St
W Monte Vista Ave
Golf Rd
E Linwood Ave
W Glenwood Ave
Spengler Wy
S Walnut Rd
Countryside Dr
Harding Rd
Simmons Rd
E Zeering Rd
S Tully Rd
Dianne Dr
Ruble Rd
N
Tegner Rd
Fransil Ln
!(
!(
!(
!(!(!(
!(
!(
!(
!(

STANISLAUS
COUNTY
AÎ
Census
Tract:

36.12 Census
Tract:

36.11 Census
Tract:

36.10 Census
Tract:

36.09 Census
Tract:

36.08 Census
Tract:

39.07 Census Tract:

39.09 Census
Tract:

38.05 Census
Tract:

36.03 Census
Tract:
37 Census
Tract:

38.04 Census
Tract:

38.02 Census
Tract:

38.03 Census
Tract:

39.04 Census
Tract:

39.08 Census
Tract:

39.05 Census
Tract:

39.06 Census
Tract:
37 Tot Lot
Crane
Park
Summerfaire
Park
Donnelly
Park
Atch
Pedretti
Park
Markley
Park
Four
Seasons
Park
Turlock
Sports
Complex
Ferreira
Ranch Park
Montana
Park
Soderquist
Ballpark
Broadway
Park
Columbia
Park
0 ¼ ½ 1
Miles
Source: California Department of Social Services, 2025; City of Turlock, 2024; Dyett & Bhatia, 2024
City Limit
County
Freeway
Major Road
Railroad
MERCED
COUNTY
!( Adult Day Program
!( Adult Residential
Map D-3
Residential Care Facilities
inTurlock
Census Tracts

Appendix D: Assessment of Fair Housing
D-24 Hearing Draft | August 6, 2026
Map D-4 and Map D-5 show the percentage of children in each census tract that live in different types of family households and indicate there are some patterns of geographic concentration in Turlock based on familial status. For instance, Map D-4 shows a lower comparative share of children living in female-headed households outside of the city’s center and a higher concentration of female-headed households living in census tracts north and west of downtown (where more than 20 percent of households are femalehouseholds). Map D-5 shows a higher concentration of married-couple households having children in the northeast portions of Turlock, in Tracts 36.11, 36.09, and 36.08, while, married-couples with less percent of children and located in southern Turlock around tract 38.02. Higher concentrations of female-headed households living north and west of downtown is likely linked to housing affordability and proximity to resources, according to Housing Division staff. In tracts more removed from the center of the city, particularly those in east Turlock, 80 to 100 percent of households are married-couple households while 20 percent or less of households are female-headed. Childcare facilities are located throughout the city and are not drawn to a specific locational direction in Turlock as shown on Map D-6. However, there is a concentration of child care centers and day care centers in census tract 39.04, which is within close proximity to tract 39.06 that has the highest percentage of female-headed households. In Turlock, about

35.7 percent of female-headed households with children were under the poverty line, while only 13.1 percent of households without children were. This demonstrates that female-headed households with children are more likely to have greater housing needs and face difficulties in finding affordable housing due to their financial vulnerability. Affordable housing is not evenly distributed throughout Turlock and female-headed households are concentrated in lower resource areas. Greater access to affordable housing in areas outside the center of the city would aid in the integration of female-headed households. Outside of Turlock and Modesto, female-headed households are better integrated, but they are also less common, indicating that this may be a greater issue in the County’s urban centers.

INCOME LEVEL
Geographic concentration by income, including concentration of poverty, is another type of segregation that may exist within a jurisdiction. The concentration of low- or moderate-income (LMI) individuals provides one method to gauge the extent of such segregation. HUD defines an LMI area as a census tract or block group where over 51 percent of the population is LMI – based on the HUD income definition of up to 80 percent area median income (AMI). Map D-7 provides the distribution of LMI block groups across Turlock; the central area of the City along South Golden State Boulevard, south of Fulkerth Road, and north of West Linwood Avenue is an LMI area, as well as the southeastern portions of the City, extending to the City limits and Merced County boundary. Higher concentrations of LMI households are located near central areas of Turlock due to older, more affordable housing located near services and transit in these areas, according to City staff.

Poverty rates and the concentration of poverty over time can provide an insight into the economic wellbeing of households and individuals in the region and in Turlock. As of 2020, both Turlock (15 percent) and Stanislaus County (13.5 percent) had a higher overall rate of poverty than the State (12.6 percent). Further, as shown on Table D-3, no race or ethnicity is significantly impacted more than another, as all races/ethnicities hover around 11 to 15 percent poverty rate. Overall, the rate of poverty for most ethnic groups is lower in Turlock than the County, though Hispanic/Latino and Two or More Races experience slightly higher rates of poverty. As shown in Map D-8, areas with higher percentage of poverty are located in central Turlock and west of Golden State Road, with one census Tract 39.08 exceeding 30 percent of population below poverty line. In 2020, between renter-occupied units and owner-occupied units, 19.6 percent of people below the poverty line owned where they lived, while 80.4 percent of people below the poverty line rented. Knowing which groups locally and regionally face the greatest economic challenges can inform targeted programs for financial literacy training and other fair housing programs.

STANI S LAUS
COUNTY

W CHRISTOFFERSEN PKWY

WTAYLOR
RD

ETAYLOR RD

W MONTEVISTA AVE E MONTEVISTA AVE

WTUOLUMNE RD ETUOLUMNE RD

FULKERTH RD

WEST MAIN ST EAST AVE

W E LINWOOD AVE LINWOOD AVE

SWALNUT RD

S LANDER AVE

SOUTH AVE

W CANAL DR

E CANAL DR

NWALNUT RD

GEER RD

N OLIVE AVE

N BERKELEY AVE

E OLIVE ST

MARSHALL ST
D ST

FIFTH ST

N GOLDEN STATE BLVD

S GOLDEN STATE BLVD

S QUINCY RD

S JOHNSON RD

N DAUBENBERGER RD

N ROSE ST

DELS LN

CROWELL RD

N COLORADO AVE

E MINNESOTA AVE

NORTH AVE

N SODERQUIST RD

S KILROY RD

STEGNER RD

FRANSIL LN

DIANNE DR

GOLF RD

HARDING RD

BRIER RD
Census
Tract:

36.10 Census
Tract:

36.12 Census
Tract:

36.09 Census
Tract:

36.11 Census
Tract:

36.08 Census
Tract:
37 Census
Tract:

38.02 Census
Tract:

36.03 Census
Tract:

39.08 Census
Tract:

38.03 Census
Tract:

39.04 Census Tract:

39.09 Census
Tract:

39.05 Census
Tract:

39.06 Census
Tract:

39.07 Census
Tract:

38.05 Census
Tract:

38.04 Percent of Children in
Female Headed
Households
0 ¼ ½ 1
Miles
SB 535 Disadvantaged Community
Less than 20%
20% - 40%
40% - 60%

MERCED C OUNTY
J:\GISData\580_Turlock\GIS\Projects\HousingElement\AFFH\D-3 Percent of Children in Female Headed Households.mxd Map Date:
9/20/2024
Study Area Boundary
City Limit & County Island
County
Railroad
AÎ
AÎ Map D-4

STANI S LAUS
COUNTY
Source: CalEPA, 2022; HCD, 2022; City of Turlock, 2021; Dyett & Bhatia, 2024

STANI S LAUS
COUNTY

W CHRISTOFFERSEN PKWY

WTAYLOR
RD

ETAYLOR RD

W MONTEVISTA AVE E MONTEVISTA AVE

WTUOLUMNE RD ETUOLUMNE RD

FULKERTH RD

WEST MAIN ST EAST AVE

W E LINWOOD AVE LINWOOD AVE

SWALNUT RD

S LANDER AVE

SOUTH AVE

W CANAL DR

E CANAL DR

NWALNUT RD

GEER RD

N OLIVE AVE

N BERKELEY AVE

E OLIVE ST

MARSHALL ST
D ST

FIFTH ST

N GOLDEN STATE BLVD

S GOLDEN STATE BLVD

S QUINCY RD

S JOHNSON RD

N DAUBENBERGER RD

N ROSE ST

DELS LN

CROWELL RD

N COLORADO AVE

E MINNESOTA AVE

NORTH AVE

N SODERQUIST RD

S KILROY RD

STEGNER RD

FRANSIL LN

DIANNE DR

GOLF RD

HARDING RD

BRIER RD
Census
Tract:

36.10 Census
Tract:

36.12 Census
Tract:

36.09 Census
Tract:

36.11 Census
Tract:

36.08 Census
Tract:
37 Census
Tract:

38.02 Census
Tract:

36.03 Census
Tract:

39.08 Census
Tract:

38.03 Census
Tract:

39.04 Census Tract:

39.09 Census
Tract:

39.05 Census
Tract:

39.06 Census
Tract:

39.07 Census
Tract:

38.05 Census
Tract:

38.04 Percent of Children in
Married-Couple
Households
0 ¼ ½ 1
Miles
20% - 40%
40% - 60%
60% - 80%
80% - 100%

MERCED C OUNTY
J:\GISData\580_Turlock\GIS\Projects\HousingElement\AFFH\D-4 Percent of Children in Married-Couple Households.mxd Map Date:
9/20/2024
Study Area Boundary
City Limit & County Island
County
Railroad
AÎ
AÎ Map D-5

STANI S LAUS
COUNTY
Source: HCD, 2022;
City ofTurlock, 2021; Dyett & Bhatia, 2024

N Colorado Ave
West Main St
S Washington Rd
N Soderquist Rd
Geer Rd
Fosberg Rd
N Tully Rd
NBerkeley Ave
State Blvd
E Monte Vista Ave
E Tuolumne Rd
E Main St
Ninth St
S Lander Ave
Roberts Rd
N Quincy Rd
S Tegner Rd
N Walnut Rd
W Tuolumne Rd
Montana Ave
Andre Ln
1525W
MonteVista
S Quincy Rd
E Minnesota Ave
S Golden State Blvd
Brier Rd
N Johnson Rd
W Christoffersen Pkwy
Pedras Rd
El Capitan Dr
E Hawkeye Ave
W Linwood Ave
Dels Ln
Fulkerth Rd
N Olive Ave
S Kilroy Rd
North Ave
E Taylor Rd
East Ave
F St
W Taylor Rd
S Soderquist Rd
N Washington Rd
A St
Fullerton Dr
Hedstrom Rd
Mountain View Rd
Georgetown Ave
S oJ hnson Rd
South Ave
W Springer Dr
E Canal Dr
Marshall St
N Denair Ave
E Glenwood Ave
N Berkeley Ave
Grant Ave
Park St
W Monte Vista Ave
Golf Rd
E Linwood Ave
W Glenwood Ave
Spengler Wy
S Walnut Rd
Countryside Dr
Harding Rd
Simmons Rd
E Zeering Rd
S Tully Rd
Dianne Dr
Ruble Rd
N
Tegner Rd
Fransil Ln
!(
!(
!(
!(
!(
!(
!(
!(
!(
!(
!(
!(
!( !(
!(
!(
!(
!(
!(
!(
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!(

STANISLAUS
COUNTY
AÎ
Census
Tract:

36.12 Census
Tract:

36.11 Census
Tract:

36.10 Census
Tract:

36.09 Census
Tract:

36.08 Census
Tract:

39.07 Census Tract:

39.09 Census
Tract:

38.05 Census
Tract:

36.03 Census
Tract:
37 Census
Tract:

38.04 Census
Tract:

38.02 Census
Tract:

38.03 Census
Tract:

39.04 Census
Tract:

39.08 Census
Tract:

39.05 Census
Tract:

39.06 Census
Tract:
37 Tot Lot
Crane
Park
Summerfaire
Park
Donnelly
Park
Atch
Pedretti
Park
Markley
Park
Four
Seasons
Park
Ferreira
Ranch Park
Montana
Park
Soderquist
Ballpark
Broadway
Park
Columbia
Park
Turlock
Sports
Complex
0 ¼ ½ 1
Miles
Source: California Department of Social Services, 2025; City of Turlock, 2024; Dyett & Bhatia, 2024
City Limit
County
Freeway
Major Road
Railroad
MERCED
COUNTY
!( Day Care Center
!( Infant Center
!( Single Licensed Child Care Center
Map D-6
Childcare Facilities
inTurlock
Census Tracts