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Turlock council approves draft housing element for state review after identifying 5,802-unit RHNA
Summary
The City Council voted 3-2 to submit the draft 2023–31 housing element to the California Department of Housing and Community Development for a statutory 90-day review. Consultants and staff said the city’s zoning currently shows capacity for about 4,250 units, leaving a shortage that the plan addresses with overlays, SB 9 sites and other tools.
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Turlock City Council on Jan. 28 approved sending the city’s draft housing element for the 2023–31 cycle to the California Department of Housing and Community Development (HCD) for its required 90‑day review.
The vote, 3 in favor and 2 opposed, directs staff to start HCD’s review. The draft documents the Regional Housing Needs Allocation (RHNA) of 5,802 units that the state assigned to Turlock for this planning cycle and proposes zoning changes and programs to demonstrate the city’s capacity to accommodate that total.
Consultant Andrew Hill told the council the state requirement is to show the zoning capacity exists rather than to promise the city will build every unit. "The requirement is not that the city build those 5,802 units, but rather that the zoning map has the capacity to accommodate those new units," Hill said. The draft inventory counts nearly 4,250 units from currently approved projects, vacant residentially zoned land, master-planned areas and accessory dwelling-unit (ADU) trends.
Because that figure leaves a shortfall—particularly for lower‑income units—the draft proposes a workforce housing overlay covering identified underused commercial parcels in four areas of the city; consultants estimate the overlay could add roughly 2,410 units to the city’s zoned capacity. The plan also calls for use of SB 9 parcel splits and a "congregational overlay" to enable interested religious institutions to develop housing on underused church land as a fair‑housing strategy. A city-conducted survey that drew about 1,500 responses showed majority support for higher‑density options in the targeted areas, Hill said.
The council emphasized the regulatory and financial context. Hill said HCD must certify the element as complete before the city can finalize and adopt it, and that certification affects eligibility for some state grants. Council member Phillips, who voted no, said she hears frequent staff warnings about time constraints on housing items and remains concerned about infrastructure and readiness: "We need to do better," she said.
Council members Abra, Bixill and Vice Mayor Monette voted to submit the draft to HCD; Council member Phillips and Mayor Bublak voted no. With submission, staff and the consultant will meet with HCD during the 90‑day review period, pursue follow‑up meetings with the planning commission on the proposed overlay, and return the revised draft to the planning commission and council for adoption hearings after HCD’s review, staff said. Adoption hearings are tentatively scheduled for May–June of 2025.
What the council approved was submittal for review only; the element must still receive HCD certification and then come back to the planning commission and council for final adoption. The draft’s implementing program lists 43 actions, each with timing, responsible departments and funding notes intended to guide the city through the eight‑year cycle.
The council’s action comes after the city missed the December 2023 deadline for this element; consultants said the delay was substantially affected by the city’s choice to distribute a mailed paper survey and the time required to process about 1,500 paper responses.
Looking ahead, staff said they will work with HCD to resolve questions during the review period and will return to the council with any required revisions before final adoption.

