Comment submitted by Leslye Krutko, Director of Housing, City of San Jose, Department of Housing

To Whom It May Concern: I am writing in response to the public notice that was issued on December 16, 2005, regarding the proposed metropolitan area definitions for Fiscal Year 2006 Income Limits and Median Family Income Estimates. The City of San Jos? has strong concerns with the proposed metropolitan area definitions. As currently proposed, the new Metropolitan Statistical Area (MSA) for our region would include San Benito County. Although we understand that, according to the Office of Management & Budget, the new MSAs are meant to ?better reflect metropolitan area commuting and economic patterns,? it is not appropriate or fair to include San Benito County as part of the San Jos?-Sunnyvale-Santa Clara MSA. There is little connection between these two areas. Census 2000 information shows that only .8% (3,105 persons) of all San Jos?'s workers commute from San Benito County. There is a much larger number of commuters from the Counties of Alameda at 6.7% (25,035 persons), and San Mateo at 2.9% (10,845 persons). In addition, there is a significant disparity between the incomes and rents in San Jos? and San Benito County that will likely never be altered. Census 2000 data indicates that San Jos??s median family income is $74,813, compared to that of $60,665 for San Benito County ? a 23% difference. The Census data also indicates that the median rent in San Jos? is $1,123, compared to that of $765 in San Benito County ? a 47% difference. These numbers illustrate the stark difference in the economic and housing characteristics of both of these communities. By holding us ?harmless,? the median family income for San Jos? will remain static, as we wait for the median family income in San Benito County to come to par with that of San Jos?. This may take many years, and in the meantime it will impose significant problems for the residents of San Jos? and the City?s affordable housing programs. The impact to San Jos? will be especially great given that the leading industries in San Jos? and San Benito County are vastly different. San Jos? is home to leading high-tech companies, whereas San Benito County is more of an agricultural community. The difference is also apparent when we compare the major employers in Santa Clara and San Benito counties. Seventeen percent of San Benito County residents are employed in the farm industry, compared to .5% of Santa Clara County residents. In addition, 13% of Santa Clara County residents are employed in the computer and electronic product manufacturing industry, compared to 0% of San Benito County residents. Lastly, 6% of Santa Clara county residents are employed in the semiconductor industry, compared to only .6% of San Benito County residents. The public notice acknowledges that, by including San Benito County as part of our MSA, and to make up for the discrepancy in calculating median family incomes from past years, our median family income and income limits will drop by 11%. I sincerely hope that you take these comments into consideration as you finalize the proposed metropolitan area definitions and median family income estimates for 2006. If you have any questions, please do not hesitate to contact me at 408- 535-3851. Sincerely, Leslye Krutko Director of Housing cc: HUD San Francisco Regional Office