Tracy | Growth management
Tracy, California Growth Management Ordinance: Residential Growth Allotments, Yearly Limits, Exemptions and State Law
Tracy limits the number of new homes it approves each year. The rule is Chapter 10.12 of the Municipal Code, the Growth Management Ordinance, and two of its sections carry the words "as set forth in Measure A adopted by voters November 2000" in their titles. A builder needs one residential growth allotment for each home before the building permit is issued. Small projects are exempt: an accessory dwelling unit, and up to four homes on a single existing lot. This page explains the yearly limits, the exemptions, and how state law treats a voter-approved cap. The Tracy overview has the summary.
The Tracy growth limit in six facts
- Chapter 10.12 of the Tracy Municipal Code is the Growth Management Ordinance, called the GMO. Source: TMC 10.12.010
- One residential growth allotment, or RGA, is required for each dwelling unit before the City issues its building permit, unless the project is exempt. Source: TMC 10.12.030
- The City may not allocate more than an average of 600 RGAs a year, or more than 750 in any one calendar year. Source: TMC 10.12.100
- A fourplex or a smaller number of homes on a single existing lot is exempt, up to four such homes per subdivider per calendar year. Source: TMC 10.12.060
- An accessory dwelling unit needs no RGA. Source: TMC 10.12.060(e)
- The state housing department lists Tracy as an affected city under the Housing Crisis Act, which limits when a city may enforce a cap on housing permits. Source: HCD, Affected Cities
What the Ordinance Is
Section 10.12.010 says "This chapter 10.12 of the Tracy Municipal Code may be referred to as the 'Growth Management Ordinance' or 'GMO', and is adopted pursuant to article XI, sections 7 and 9 of the California Constitution." The history note under each section cites Ordinance No. 1136 of 2009, with later changes by Ordinance No. 1184 of April 2, 2013, Ordinance No. 1201 of November 3, 2015 and Ordinance No. 1254 of May 1, 2018. The two sections that set the yearly numbers, 10.12.100 and 10.12.110, name Measure A of November 2000 in their titles.
Section 10.12.020 lists six purposes. The first is to "Achieve a steady and orderly rate of annual residential growth in the City." The second is to "Regulate the timing and annual amount of new development projects, so that necessary and sufficient public facilities and services are provided." The fifth is to "Encourage a balance of housing types in the City," including affordable housing projects.
- Residential growth allotment (RGA). Section 10.12.030 defines it as an allotment "which must be obtained by a developer (by allocation or conveyance) before each residential building permit is issued by the City, unless the subdivider obtains an exemption in accordance with this chapter. One RGA is required for each dwelling unit to be constructed."
- Development project. The term "shall specifically include any tentative parcel map, tentative subdivision map, final parcel map, final subdivision map, preliminary development plan, final development plan or building permit."
- Growth Management Board. Section 10.12.040 creates it "to manage and enforce the requirements of this chapter." The Board is staff: "All decisions of the Board shall be made by the City Manager in consultation with appropriate department heads."
- GMO guidelines. Section 10.12.050 says "The City Council shall adopt GMO guidelines, in order to implement the requirements of this chapter," and that the chapter controls if the two conflict.
- Which rule controls. Section 10.12.030 says that if the zoning, subdivision or impact fee rules conflict with the chapter, "this chapter shall control to the extent necessary to administer and effectuate the purpose of this chapter."
The Yearly Limits
The chapter sets two kinds of limit, one on allotments and one on building permits, and each has a yearly average and a yearly maximum. Section 10.12.100 says "The City shall not allocate RGAs in any calendar year in excess of either of the following: (1) an average of 600 RGAs per year calculated pursuant to subsection 10.12.100(b); and (2) a maximum of 750 RGAs per year." Section 10.12.110 repeats the two numbers for residential building permits.
| Limit | Number | How it is counted |
|---|---|---|
| RGAs, yearly average | 600 | All RGAs allocated since January 1, 2000, less invalid RGAs and RGAs for affordable housing project exceptions, divided by the number of years |
| RGAs, yearly maximum | 750 | All RGAs allocated in the calendar year, counting the affordable and development agreement RGAs |
| RGAs for affordable housing project exceptions | 150 a year | Counted inside the 750; left out of the 600 average; reserved until the first Friday in July |
| RGAs for projects with a development agreement | 225 a year | The total for all development agreements in one calendar year; counted inside the 750 |
| Residential building permits, yearly average | 600 | Permits since January 1, 2000, less expired permits, affordable exceptions and exempt permits, divided by the number of years |
| Residential building permits, yearly maximum | 750 | Permits in the calendar year, less permits exempt from the chapter |
| Active adult permits, Tracy Village Specific Plan | 200 a year | A separate limit in Chapter 10.18 for 600 allotments given by ballot measure; outside the GMO |
Sources: Tracy Municipal Code 10.12.100, 10.12.110, 10.12.090 and 10.18.070 (Supplement 69).
- The average runs from 2000. The average number of RGAs is "the total sum of RGAs allocated by the City from January 1, 2000, through the calendar year of the allocation," less invalid RGAs and RGAs for affordable housing project exceptions, "divided by the number of years which have passed from January 1, 2000, to the year of the allocation, inclusive." A slow year lowers the average and allows a later year above 600.
- The maximum is a fixed yearly number. "The City shall not allocate more than 750 RGAs in any calendar year."
- Affordable homes. "The City shall not allocate more than 150 RGAs in any calendar year for affordable housing project exceptions." The City reserves "150 RGAs for affordable housing projects" until "the first Friday in July of each year."
- Development agreements. "The City shall not allocate more than 225 RGAs in any calendar year to development projects with which the City has entered into a development agreement providing for an allocation of RGAs."
- Permits are issued in order. Section 10.12.110(d): "Applications for residential building permits will be evaluated (and, for each approved application, will be issued) by the City in the order they are received."
- Exempt permits are left out. The permit average subtracts "the sum of residential building permits exempt from this chapter," and so does the yearly maximum.
Projects That Need No Allotment
Section 10.12.060 exempts five kinds of project. The developer gives the Development and Engineering Services Director documents showing that the project fits one of them. A homeowner or a small builder should read this section first, because it covers common small projects on one existing lot.
- Remodel, minor addition, conversion. "The development project is a rehabilitation or remodeling of, or a minor addition to, an existing structure, or a conversion of apartments to condominiums."
- Replacement. "The development is replacing legally established dwelling units that have been demolished and do not exceed the number of legally established dwelling units demolished." Where the new homes exceed the old ones, "an allocation of RGAs must be obtained for the additional dwelling units."
- Model homes. Model homes need no RGA while they are used to advertise homes for sale. Their number is "the lesser of twenty (20) percent of the total dwelling units identified in the application, or seven dwelling units per project," and they "may be converted and occupied as dwellings only after RGAs are allocated for each dwelling unit."
- Four units or fewer on a single lot. "The development project is either a four-plex or lesser number of dwelling units on a single existing lot." Three conditions follow. "The dwellings are not part of a larger eligible parcel that will result in more than four dwelling units at build-out of the project." "The exemption is limited to no more than a total of four such dwelling units per subdivider per calendar year." And before each building permit "the subdivider shall pay all required fees, including impact fees required by title 13 of this Code."
- Accessory dwelling unit. The heading of subsection (e) is "Accessory dwelling unit," and its text reads "The development is a secondary residential unit." Section 10.08.052 says "Any reference in this Code to 'second unit' means 'accessory dwelling unit.'"
| Project | RGA needed? | Where the code says so |
|---|---|---|
| Accessory dwelling unit | No | Section 10.12.060(e) |
| Remodel, minor addition, or apartments converted to condominiums | No | Section 10.12.060(a) |
| New homes that replace legally established homes that were demolished | No, up to the number demolished | Section 10.12.060(b); extra homes need RGAs |
| Two, three or four homes on a single existing lot | No, if the three conditions are met | Section 10.12.060(d) |
| Model homes | No, until they are occupied as homes | Section 10.12.060(c); the lesser of 20 percent of the homes or seven per project |
| Five or more homes on one lot | Yes, one per home | Section 10.12.030 |
| Lots in a new subdivision | Yes, one per home | Section 10.12.030 |
| Homes in a recognized affordable housing program | Yes, from the 150 set aside each year | Sections 10.12.080 and 10.12.100 |
| Homes needed to reach the regional housing goal for an income group | No | Section 10.12.065(c) |
| Active adult homes with allotments under Chapter 10.18 | No | Section 10.12.021 |
Sources: Tracy Municipal Code 10.12.021, 10.12.030, 10.12.060, 10.12.065 and 10.12.080 (Supplement 69).
The code has no section on SB 9, the state law that allows two homes on a single-family lot and a split into two lots. Two homes on one existing lot fit the words of the four-unit exemption. A lot split creates a second lot, and the exemption speaks of "a single existing lot" and of four homes "per subdivider per calendar year." Ask the Planning Division how it counts homes on the two lots of an urban lot split. The ADUs and SB 9 page has the state rules.
Affordable Homes and the Regional Housing Goal
Two parts of the chapter work in favor of housing that the state asks the City to plan for. Section 10.12.080 creates the affordable housing project exception. The home must meet "the income level requirements for low, very low, or moderate income levels," be "formally dedicated to provide affordable dwelling units in accordance with a locally recognized program," and the applicant must show that these requirements "will be met and maintained for a minimum of ten years." Section 10.12.030 sets the income levels against the San Joaquin County area median income: not more than 50 percent for very low income, more than 50 and not more than 80 percent for low income, and more than 80 and not more than 120 percent for moderate income.
Section 10.12.065 deals with the Regional Housing Needs Allocation (RHNA), the number of homes the state assigns each city to plan for in each housing plan period. It says "in any calendar year, once RGAs have been allocated or building permits have been issued for the number of residential units permitted by this chapter, the City shall continue to issue building permits for residential dwelling units if they are necessary to achieve the RHNA goals in a particular income category." Two limits follow: "The number of building permits may not exceed the RHNA goals in each income category," and "Any building permits issued in accordance with this provision shall not require an RGA." For the averages, such a permit is treated "as if an RGA and a building permit were issued under the GMO."
The City's Draft EIR for its rezone program gives the current goal: "8,830 total housing units that were included in the City's Regional Housing Needs Allocation (RHNA) for 2023-2031." Its table divides that into 2,994 very low income, 1,879 low income, 1,175 moderate income and 2,782 above moderate income homes. Spread evenly over the eight years from 2023 to 2031, the total is 1,104 homes a year (VanPlex arithmetic: 8,830 divided by 8, rounded up from 1,103.75). The ordinance's yearly average is 600. Section 10.12.065 is the part of the code that lets permits go past the yearly numbers to reach the goal for an income group.
Applications, Development Agreements and Appeals
- Application. Section 10.12.070: "No RGA shall be allocated by the City unless the developer submits an application in accordance with the requirements of this chapter and the requirements of the GMO guidelines."
- How many per application. Under Section 10.12.090 an application may receive no more than the number requested and no more than "the number which can be reasonably anticipated to be used by the applicant based on development project approvals (such as general plan, specific plan, tentative map, final map or development plan)."
- The Board's choice. "The Board has the discretion to award all of the RGAs that are available in that allocation cycle, or fewer, based on the applications received and the criteria as established in the GMO guidelines."
- Reasonable certainty. Section 10.12.030 defines it as proof "that the financing necessary for the public facilities and services required to serve the development project is secured." The Board looks at capacity in public facilities, financing, and the expected completion date of the permanent facilities.
- Development agreements. An agreement that gives RGAs must state the timing and amount, "not to exceed a maximum of 225 RGAs per calendar year," and the remedies for default. It "may only modify the requirements of the GMO related to: (1) the timing requirements for applications for RGAs; and (2) the time after which RGAs will be deemed invalid."
- Annual report. "Notice shall be given to each applicant of the availability of the annual report."
- Appeals. Section 10.12.120: an applicant "may submit a written appeal to the City Clerk in accordance with chapter 1.12 of this Code. All decisions of the City Council are final." Section 1.12.020 gives ten working days from the written notice of a decision to file.
Active Adult Allotments Under Chapter 10.18
Chapter 10.18, the Active Adult Residential Allotments Ordinance, is a second allotment system, separate from the GMO. It was added by Resolution No. 2015-162 of September 15, 2015. Its purpose is to let allotments for communities of older adults "be allocated to specific properties within the City of Tracy through the initiative process, separate from the City's Growth Management Ordinance." Section 10.18.070 gives one property its allotments: "Six hundred (600) active adult residential allotments are allocated to the property/area formerly known as Urban Reserve 9, now referenced as the Tracy Village Specific Plan property, located at the southeast corner of Corral Hollow and Valpico Roads." The same section adds "No more than 200 residential building permits may be issued by City for the Tracy Village Specific Plan property in any given calendar year."
Section 10.12.021 states how the two chapters relate. Homes built with these allotments "are not subject to this GMO or the GMO Guidelines and shall not require any residential growth allotment under the GMO," and they "shall not be counted against the annual residential growth allotment allotments under this chapter." The allotments cannot be moved to another property and do not expire.
State Law and a Voter-Approved Cap
The Housing Crisis Act is a 2019 state law that limits what cities may do to slow housing. Its main section, Government Code 66300, applies to an "affected city," which the state Department of Housing and Community Development (HCD) lists. HCD's Affected Cities list, updated in 2023, includes "Tracy city" in the "Tracy--Mountain House" urban area. The section says an affected city includes "the electorate of an affected county or city exercising its local initiative or referendum power."
Section 66300(b)(1)(D) bars an affected city from "establishing or implementing any provision that" does any of three things: "Limits the number of land use approvals or permits necessary for the approval and construction of housing that will be issued or allocated," "Acts as a cap on the number of housing units that can be approved or constructed either annually or for some other time period," or "Limits the population." HCD's fact sheet of April 2026 states the same rule in one line.
The next paragraph, 66300(b)(1)(E), is an exception. An affected city "may enforce a limit on the number of approvals or permits or a cap on the number of housing units that can be approved or constructed if the provision of law imposing the limit was approved by voters prior to January 1, 2005, and the affected county or affected city is located in a predominantly agricultural county." A predominantly agricultural county is one that, in "the most recent California Farmland Conversion Report produced by the Department of Conservation," "Has more than 550,000 acres of agricultural land" and where "At least one-half of the county area is agricultural land."
The titles of Sections 10.12.100 and 10.12.110 date Measure A to November 2000, which is before January 1, 2005. The second half of the test depends on the Department of Conservation report for San Joaquin County. That report was not read for this guide, so this page does not say whether the exception applies to Tracy. The City's own 2026 Draft EIR says growth in the City's water service area "has slowed as a result of the GMO." Ask the Planning Division how many allotments are available this year and whether any part of the chapter is not being enforced.
Where the Code Text Does Not Line Up
- ADU heading and text. Section 10.12.060(e) is headed "Accessory dwelling unit" and its text says "secondary residential unit." Section 10.08.052 ties the two terms together.
- Old planning period. Section 10.12.065 says "The planning period in effect at the time this code amendment was adopted is July 1, 2009 through December 31, 2015." The current housing plan covers 2023 to 2031. The rule in subsection (c) is written for "each planning period," so it also applies to the current one.
- Two formulas for permits. Section 10.12.110(a) says the permit average and maximum are "calculated pursuant to subsection 10.12.100(b)" and "10.12.100(c)," which are the RGA formulas. Subsections (b) and (c) of Section 10.12.110 then give separate formulas for permits. The permit formulas subtract exempt permits and the RGA formulas have no such line.
- Department names. Chapter 10.12 names the "Development and Engineering Services Director." Ordinance No. 1394 of July 2026 names the "Director of Community and Economic Development." Ask the City which office takes GMO filings.
- Junior ADUs. The exemption names the accessory dwelling unit. The chapter does not name the junior ADU, a unit of up to 500 square feet inside a house, which Ordinance No. 1394 added to the zoning rules in 2026.
Limits of This Page
The chapter text comes from Municode's Supplement 69, whose Supplement History Table lists ordinances through No. 1390 as included. The Municode ordinance bank lists Ordinance Nos. 1391 to 1404 as pending codification, the last of them adopted September 15, 2026, and none of their titles names Chapter 10.12. The City's website answered a script with an access denied page, so three things were not read: the GMO Guidelines the Council adopted under Section 10.12.050, the yearly reports that show how many RGAs were allocated, and the text of Measure A. The number of RGAs available in 2026 is therefore not on this page. The Farmland Conversion Report was not read. Ask the Planning Division at 333 Civic Center Plaza, Tracy, for the current guidelines and allocation schedule.
Best For
- ✓ An ADU, a duplex, a triplex or a fourplex on one existing lot, which needs no RGA under Section 10.12.060.
- ✓ Homes that replace demolished homes one for one.
- ✓ Affordable projects that can use the 150 RGAs set aside each year.
Usually Fails When
- ✕ A project of five or more homes is planned with no RGA application.
- ✕ One subdivider plans more than four exempt homes in one calendar year.
- ✕ A small lot is part of a larger parcel that will hold more than four homes at build-out.
What To Verify Before Spending Money
- → How many RGAs are available this year and when applications are due under the GMO Guidelines.
- → How the City counts the homes on the two lots of an SB 9 lot split.
- → Whether the City applies Section 10.12.065 to your income category.
Where to Go Next
Related on VanPlex: the Tracy overview, the zoning districts page and the CEQA and permit streamlining page.
Frequently Asked Questions
What is the Tracy Growth Management Ordinance?
What is a residential growth allotment in Tracy?
How many homes can be built in Tracy each year?
Does a duplex or fourplex in Tracy need a growth allotment?
Does an ADU count against the Tracy growth limit?
Who decides Tracy growth allotment applications?
Are affordable homes treated differently under the Tracy GMO?
Can Tracy stop issuing building permits when the yearly limit is reached?
Does state law allow the Tracy growth cap?
How do development agreements work with the Tracy growth limit?
Official sources (checked October 2026)
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