Office-to-Housing Conversion in Downtown San Jose

Of 47 commercial buildings at least 60 feet tall in Downtown San Jose, 12 pencil for residential conversion with no subsidy, and 10 more — 1,182 homes — pencil only with a grant from the RESIDE Act.

The highest-scoring office buildings in Downtown San Jose are 1 Almaden Blvd (an estimated 149 homes), 111 W St John St (an estimated 168 homes), 99 Almaden Blvd (an estimated 117 homes), 55 Almaden Blvd (an estimated 125 homes), and 12 S 1st St (an estimated 99 homes). The scores come from a screen of public data, not a feasibility study.

CA-18 · Downtown San Jose, California · Screened from City of San Jose open GIS data and © OpenStreetMap contributors · Last updated 2026-10-20 · Cite or download the data

Buildings screened

≥ 60 ft, commercial zoning

Pencil unsubsidized

no grant required

Pencil with a grant

at market rents, if they qualified

Homes in them

1,182

in those buildings

Never pencil

at default assumptions

Grant requested

$68.8M

under the modeled formula

Loading building data…

Every assumption in the model is a slider. Change conversion cost, unit size, circulation efficiency or completed value in the Assumptions tab and all 47 buildings re-score and re-rank live. Every building also has a page of its own: see all 93 by address. The full analysis continues below.

San Jose says 1,500 homes. This model finds 1,182 that turn on a federal grant — if their buildings qualify.

In February 2026 San Jose city staff reviewed downtown’s underused office stock and estimated roughly 1,500 homes’ worth of potentially viable conversion projects, of which they projected 611 would actually be built. This model screens the same submarket building by building and finds 10 buildings — 1,182 homes — that fail on financing alone and would pencil with a RESIDE Act grant, if they qualified for one.

The interesting number is not the homes. It is the money. Under the award formula modeled here — 30% of eligible conversion cost, capped at $60K per home and $10.0M per award — those 10 buildings would request $68.8M. Congress has appropriated nothing for the program yet, and the law ties its $1 million to $10 million grant range to years with at least $100 million available for the whole country.

Downtown San Jose alone would ask for 69% of that $100 million — one neighborhood of one city, against a funding level set for every eligible state and locality in the country.

But that is an artifact of the formula, not of the buildings. The actual financing gap across those same 10 buildings is only $47.0M. A formula award gives them 1.5× what they need to close — $58K per home where $40K would do. Sized to the gap instead, the same 1,182 homes would need less than $100 million, leaving room for other cities.

That is the most consequential finding on this page, and it is a design question HUD still has open: the statute sets each award at $1 million to $10 million in a year with at least $100 million available, but does not say how to size it. A gap-based funding notice would unlock roughly twice the housing per federal dollar as a percentage-of-cost one. HUD has not published a Notice of Funding Opportunity, so both remain possible.

One caveat cuts the other way. These figures value every home at market rate, but RESIDE homes must mostly be affordable at 60% of area median income, which makes every gap larger. Priced in, the formula pays too little rather than too much. How RESIDE grants should be sized works through both.

Why most office buildings can never become apartments

The binding constraint on office-to-residential conversion is floor-plate geometry, not financing. Apartments need light and air; office floors were built deep on purpose.

333 W San Carlos St — 77% of each floor sits within daylight reach of a facade. The shading is daylight, darkest at the windows and gone 35 ft in. The hatched area is windowless core: 4,551 sq ft per floor that must be renovated but can never be rented as an apartment. The dimension marks the deepest interior point, 71 ft from the nearest window.

Building codes limit how far a habitable room can sit from a window — roughly 25 to 35 feet. This model erodes each real building footprint inward by 35 feet, the generous end of that range. What survives the erosion is windowless dead core. What remains is the daylit band where apartments can legally go.

Across the 47 buildings screened here, the median has 79% of its floor area within daylight reach and a deepest interior point 59 feet from the nearest window. 9 of them are past the 80-foot threshold where conversion requires carving a light well through the building — at which point it effectively never pencils.

Conversion cost is charged on gross floor area while revenue is earned only on the daylit band. That is not an accounting trick — it is the real economics. You must gut, seismically brace and sprinkler the windowless core, but you can never rent an apartment in it. Deep floor plates are penalized twice, which is precisely why they fail in practice.

This is why a subsidy program alone does not produce conversions, and why a list of vacant buildings is not a pipeline. Information was never the bottleneck — cities have published vacancy reports for years. The bottleneck is that establishing which specific buildings are physically convertible is expensive expert work, and most of them are not.

The 10 buildings a RESIDE grant would unlock, if they qualify

Each of these fails on financing rather than geometry: the floor plate works, the pro-forma does not, and a grant closes the difference. None has been checked against the law’s vacant-and-abandoned test, which public GIS data cannot show. Buildings are ranked by conversion suitability score.

Buildings in Downtown San Jose that pencil for residential conversion only with a RESIDE Act grant, modeled 2026-10-20.
Address	Score	Stories	Homes	Daylit	Depth	Gap	Grant
111 N Market St	85	10	151	81%	51 ft	$6.8M	$9.1M
121 S Market St	84	9	84	89%	52 ft	$365K	$5.0M
152 N 3rd St	81	9	177	79%	55 ft	$9.5M	$10.0M
233 W Santa Clara St	81	10	126	84%	58 ft	$3.4M	$7.6M
150 Almaden Blvd	81	15	177	83%	60 ft	$6.6M	$10.0M
75 E Santa Clara St	78	14	182	79%	60 ft	$9.7M	$10.0M
96 N 3rd St	78	6	57	86%	55 ft	$1.3M	$3.4M
210 N 4th St	77	6	60	85%	55 ft	$1.8M	$3.6M
111 Almaden Blvd	77	8	111	82%	59 ft	$4.5M	$6.7M
Building 649605	69	5	57	79%	59 ft	$3.0M	$3.4M

Also profiled in detail — the highest-scoring buildings in the survey: 1 Almaden Blvd, 111 W St John St, 99 Almaden Blvd, 55 Almaden Blvd, 12 S 1st St, 350 W Santa Clara St, 84 W Santa Clara St, 5 S 1st St, 255 W Julian St, 81 Post St, 83 S 2nd St, 630 S 1st St, 601 E Santa Clara St, 60 S Market St and 125 S Market St.

“Gap” is conversion cost minus completed value before any subsidy. “Grant” is the modeled RESIDE award. Where the grant exceeds the gap, the formula is over-funding the project — see the finding above. All 47 screened buildings, including those that do not pencil, are in the survey above and in the full list by address, each linked to its own analysis.

What a RESIDE appropriation would buy in Downtown San Jose

Congress has not funded the program. If it does, how HUD sizes each award matters as much as the amount.

For each funding level, the table shows the most of the 10 buildings above that the money could close, taking the lowest cost per home first: once with awards at the modeled formula, and once with each award sized to the building’s actual financing gap. Funding all 10 would take $68.8M under the formula and $47.0M sized to the gap.

Most buildings and homes each amount could fund in Downtown San Jose, modeled 2026-10-20.
Appropriation	Formula: buildings	Formula: homes	Gap-sized: buildings	Gap-sized: homes
$10.0M	1	182	5	384
$25.0M	3	416	7	766
$50.0M	6	828	10	1,182
$100.0M	10	1,182	10	1,182

These are upper bounds for one study area, not forecasts. Any appropriation is national and competitive across every eligible state and city, and HUD’s priorities are not modeled. The law’s $1 million minimum award, which applies in a year with at least $100 million, is not applied here. Every building would still have to meet the law’s vacant-and-abandoned test, and homes are valued at market rate although RESIDE housing must be mostly affordable, which would widen every gap.

What San Jose is already doing

The city has moved ahead of the federal program, with an incentive capped at the first 1,500 converted homes.

On January 27, 2026 the San Jose City Council voted unanimously to extend its downtown residential high-rise incentive program to office-to-residential conversion projects creating at least 20 homes. The first 500 homes receive a full waiver of construction taxes, elimination of inclusionary housing fees, and a 50% reduction in parkland in-lieu fees. A second phase covering another 1,000 homes halves construction taxes and cuts park fees by 30%. City staff estimated the package would waive roughly $16 million in fees and taxes.

To qualify, a project must sit in the Downtown Planned Growth Area and occupy a building constructed before 2021 that is not Class A office space. The incentive covers only the first 1,500 converted homes, and the federal program this page models cannot begin before fiscal year 2027 and has no money yet. A project waiting on a RESIDE grant may find the city incentive already taken.

State law now points the same way. Since July 1, 2026, California’s Office to Housing Conversion Act (AB 507) has made converting an existing building to housing a use by right, reviewed on fixed 60- or 90-day clocks without CEQA review, in exchange for on-site affordable homes and prevailing wages. It speeds the approval; it does not change a floor plate.

The context for all of it is an office market that has not recovered. Downtown San Jose’s office vacancy rate was 30.8% in the first quarter of 2026, the lowest of the three major Bay Area downtowns but still trending upward. The pipeline is not correcting on its own: Google demolished roughly 80 acres of downtown for its Downtown West campus and then paused the project, leaving the site largely vacant and its planned 7 million square feet of offices and about 4,000 homes unbuilt. Meanwhile San Jose’s state housing obligation for the 2023–2031 cycle is 62,200 homes.

Every building screened here lies in California's 18th Congressional District, represented by Zoe Lofgren. The RESIDE Act's House author, Sam Liccardo, represents the neighboring 16th District, which takes in other parts of San Jose, and was Mayor of San Jose from 2015 through 2022.

What the RESIDE Act, Section 210 of the ROAD to Housing Act, funds

The RESIDE Act is law, but it has no money yet, its grants go to cities rather than developers, and only vacant and abandoned buildings qualify. All three facts are widely misreported.

The Revitalizing Empty Structures Into Desirable Environments Act was introduced as H.R. 5591 in the 119th Congress and enacted as Section 210 of the 21st Century ROAD to Housing Act, which became law without the President’s signature on July 11, 2026. It authorizes HUD to run a pilot program, in fiscal years 2027 through 2031, of competitive grants to convert vacant and abandoned buildings into attainable housing, with priority for economically distressed communities, Opportunity Zones, needs in a city’s consolidated plan, and cities that have passed ordinances easing conversion.

The program has no money yet. The law authorizes it only “subject to the availability of funds appropriated,” and as of October 28, 2026, Congress had appropriated nothing (funding status). In a year Congress provides at least $100 million, each grant is $1 million to $10 million; with less, HUD must seek to maximize the number of grants awarded. The widely quoted $100 million a year from HOME funding above $1.35 billion comes from the introduced bill, not the law.

Most empty offices would not qualify. The law covers only a vacant and abandoned building: one built for commercial or industrial use that code enforcement has found unsafe, where at least 90 days have passed since the owner was notified and the owner has taken no corrective action, or that is in court-ordered receivership or nuisance abatement related to abandonment, or meets state law’s definition of abandoned property. This survey cannot see code enforcement or court records, so a building shown as shown here as penciling with a grant is one that would pencil with a modeled grant, at market rents, if it qualified. The homes must also be attainable, serving households up to 120% of area median income with most units affordable at 60%, while this model values every home at market completed value, so its grant results are optimistic.

Individual awards are capped at $10.0M, and eligible applicants are HOME participating jurisdictions — states and local governments — not private developers or building owners. That changes what this tool is for. It is not a developer’s capital stack; it is a worksheet for the grant application a city would file, and for the question of which buildings would justify the ask.

Because HUD has not published a Notice of Funding Opportunity, the award formula used here — 30% of eligible conversion cost, capped at $60K per home and $10.0M per award — is modeled on how comparable HUD gap-financing programs are structured. The $10.0M per-award cap is statutory. The rest is an assumption, and 24 of the 47 buildings here hit that statutory ceiling.

More on the law: The ROAD to Housing Act explained · Environmental review changes · CDBG and HOME changes · Opportunity Zones · The Innovation Fund · Innovation Fund reforms, city by city · The Build Now Act · Manufactured housing and the chassis rule · Chassis-free manufactured homes by state · RESIDE Act funding status · How RESIDE grants should be sized · The ban on large investors buying homes

State law for San Jose: Office to Housing Conversion Act (AB 507) · New California housing laws for 2027 · California’s new housing laws and Ro Khanna

How this was computed, and what it cannot tell you

Every figure on this page is reproducible from public data. Stating the limits is part of the method, not a disclaimer attached to it.

Building footprints, LiDAR-derived heights and zoning come from the City of San Jose’s open GIS service. Where the city’s map draws several buildings as one outline with one height, the buildings are separated using OpenStreetMap’s outlines, heights and floor counts (© OpenStreetMap contributors), and OpenStreetMap’s building types count as a second record of which buildings are already homes. Footprints are projected to a local tangent plane in feet, eroded inward by 35 feet to separate daylit band from dead core, and the largest circle that fits inside each footprint gives the distance from the deepest interior point to the nearest facade. Unit yield is the daylit band times a 80% circulation factor divided by a 750 sq ft average home, across every floor above the ground floor. Cost is a base of $260/sq ft plus itemized change-of-occupancy triggers — plumbing risers, seismic retrofit, operable windows, egress stairs, sprinklers — weighed against completed value, then against the modeled grant.

Two further figures appear on each building’s own page. Window line is the building’s exterior wall summed across its residential floors and divided by the homes estimated in it: daylight efficiency says how much of a floor is near glass, and window line says whether there is enough glass to go round, since every bedroom needs one. Plate shape is the isoperimetric quotient — 1.00 for a circle, about 0.79 for a square, lower for anything longer or more articulated. The direction that favours housing is the opposite of the one that favours offices: a compact plan is the cheapest envelope per square foot to build and heat, while apartments are sold by the window, so the notched outline an office would call wasteful is the one that converts.

The geometry math is validated against shapes with known analytic answers, and computed floor areas agree with the city’s own recorded areas to within 0.01%, which confirms the coordinate projection. The browser model that powers the interactive survey above is checked against the Python engine on every build; both must agree on units, cost, grant, gap, tier and score for all 47 buildings.

What this tool does not know

It screens geometry from footprints. It cannot see interior cores, columns, ceiling heights, post-tension slabs or mechanical systems.
It does not know which buildings are vacant. It screens the commercial stock of a submarket with 30.8% office vacancy; it does not assert that any specific building is empty.
Story count is derived from LiDAR height ÷ floor-to-floor, not read from plans.
It does not model the statute’s four priorities — economically distressed communities, Opportunity Zones, needs in the city’s consolidated plan and local ordinances that ease conversion — nor San Jose’s own pre-2021 and non-Class-A eligibility conditions.
It cannot tell whether a building would qualify for a RESIDE grant, which requires a code-enforcement finding, receivership or abandonment, and it values every home at market rate although RESIDE-funded housing must be mostly affordable.
HUD has not published an award formula, so every per-project grant here is modeled rather than known.
A high score means worth a professional feasibility study — never “convertible.”
Downtown zoning permits offices and homes alike, so each building is also checked against the city’s Multiple Housing roster of rental buildings and its condominium records. 31 turn out to be homes already: the records hold at least half as many homes as this model estimates the building could. They stay on the map and keep their pages, marked as housing, but are left out of every count on this page. Another 0 hold fewer homes than that; they are counted, and flagged as part residential. Hotels are on the roster too and are treated as conversion candidates, not homes.

Questions

Can empty office buildings in downtown San Jose be converted into housing?

Some can. Of 47 commercial buildings at least 60 feet tall in Downtown San Jose, this model finds 12 whose conversion pencils with no subsidy at all, and 10 more — 1,182 homes — that would pencil only with a RESIDE Act grant, if they met the law's vacant-and-abandoned test. The remaining 25 do not pencil at default assumptions, almost always because the floor plate is too deep for apartments rather than because the money is short.

Why do most office-to-residential conversions fail?

Floor-plate geometry, not financing. Apartments need light and air, and building codes limit how far a habitable room can sit from a window — roughly 25 to 35 feet. Office floors were built deep on purpose, so the middle of the plate is windowless core that can never legally become a bedroom. In this survey the median building has 79% of its floor area within daylight reach and a deepest interior point 59 feet from the nearest window. 9 of the 47 buildings are past the 80-foot threshold where conversion requires carving a light well, at which point it effectively never pencils. No subsidy fixes bad geometry.

What is the RESIDE Act and is it law?

Yes, it is law. The RESIDE Act — Revitalizing Empty Structures Into Desirable Environments — was introduced as H.R. 5591 and enacted as Section 210 of the 21st Century ROAD to Housing Act (Public Law 119-101), which became law without the President's signature on July 11, 2026. It authorizes HUD to run a pilot program, in fiscal years 2027 through 2031, of competitive grants to states and local governments to convert vacant and abandoned commercial and industrial buildings into attainable housing.

Which buildings qualify for a RESIDE Act grant?

Far fewer than "empty offices" suggests. The law covers only a vacant and abandoned building: one built as a warehouse, factory, mall, strip mall or hotel, or for another commercial or industrial use such as offices, that code enforcement has found unsafe, where at least 90 days have passed since the owner was notified and the owner has taken no corrective action, or that is in court-ordered receivership or nuisance abatement related to abandonment, or meets state law's definition of abandoned property. A building that is merely empty does not qualify. The homes it creates must be attainable housing, serving households earning up to 120% of area median income, with most units affordable at 60%.

What does the ROAD to Housing Act mean for office conversions in Downtown San Jose?

Several parts of the 21st Century ROAD to Housing Act apply. The RESIDE Act (Section 210) would fund conversions of vacant and abandoned buildings, if Congress appropriates money and a building meets that test. Section 206 gives HUD-funded conversions of existing office buildings a lighter environmental review once HUD writes its rules. Section 204 lets a city spend up to 20% of its Community Development Block Grant on new affordable housing construction. Section 201 lets HUD favor housing grants in Opportunity Zones, and 42 of the 47 buildings screened here sit in a 2018 Opportunity Zone tract.

How much money does the RESIDE Act actually provide?

None yet. The law authorizes the pilot only "subject to the availability of funds appropriated," authorizes no new funding, and as of October 28, 2026, Congress had appropriated nothing for it. In a year Congress provides at least $100 million, each grant is between $1 million and $10 million; with less, HUD must seek to maximize the number of grants awarded. The often quoted $100 million a year from HOME funding above $1.35 billion comes from the introduced bill and is not in the law.

Who applies for a RESIDE Act grant — the developer or the city?

The city. Eligible applicants are HOME participating jurisdictions — states and local governments — not private developers or building owners. That makes this tool a municipal grant-application worksheet rather than a developer's pro-forma: it estimates what San Jose could credibly ask HUD for, and which buildings would justify the ask.

How many homes could office conversions add in downtown San Jose?

This model estimates 1,182 homes across the 10 buildings that would pencil only with a RESIDE grant, and 3,407 homes across all 27 buildings it rates strong candidates. For comparison, San Jose city staff reviewing the same downtown stock in February 2026 identified roughly 1,500 homes of potentially viable conversion projects and projected 611 would actually be built. San Jose's state housing obligation for 2023–2031 is 62,200 homes.

What incentives does San Jose already offer for office-to-housing conversion?

On January 27, 2026 the City Council extended its downtown high-rise incentive program to conversion projects creating at least 20 homes. The first 500 homes receive a full waiver of construction taxes, elimination of inclusionary housing fees, and a 50% reduction in parkland in-lieu fees; a second phase covering another 1,000 homes halves construction taxes and cuts park fees 30%. Projects must sit in the Downtown Planned Growth Area and occupy a building constructed before 2021 that is not Class A office space. Staff estimated the package would waive about $16 million in fees and taxes.

Does this tool know which buildings are actually vacant?

No, and that limit matters. It screens the commercial building stock of a submarket whose office vacancy rate was 30.8% in the first quarter of 2026; it does not assert that any specific building is empty. Ownership, lease status, and tenancy are outside what public footprint and zoning data can show.

How accurate is this analysis?

It is a screen, not a feasibility study. The geometry is computed from real city footprints and LiDAR-derived heights, and the floor-plate math is validated against shapes with known analytic answers; computed floor areas agree with the city's own recorded areas to within 0.01%. But the model cannot see interior columns, existing cores, ceiling heights, post-tension slabs, or mechanical systems, though story counts here are the San Jose Office of Property Assessment's own figures rather than a number inferred from height. A high score means a building is worth a professional feasibility study — never that it is convertible.

Can this analysis be run for other cities?

Only where the city publishes the right data. The model depends on open GIS building footprints carrying a height attribute, which is what makes story counts and floor-plate geometry computable without commercial real estate data. San Jose publishes LiDAR-derived heights; Denver publishes heights from an aerial survey of roof outlines. Many cities publish footprints without heights, and for those this method does not work as written.

Cite or reuse this analysis

Everything on this page is free to quote, republish and build on, with credit. The scored dataset behind it is one download.

Suggested citation

RESIDE Act Feasibility Engine, “Office-to-Housing Conversion in Downtown San Jose,” resideact.org/san-jose, updated 2026-10-20.

Download the scored dataset (GeoJSON)Read the method

The text is licensed under CC BY 4.0: copy, adapt and republish it, commercially or not, with credit and a link back. The dataset is licensed under the ODbL 1.0. It is built partly from OpenStreetMap data (© OpenStreetMap contributors), so it carries OpenStreetMap’s Open Database License: share it under the same license, with credit to resideact.org and OpenStreetMap. Footprints, heights and zoning come from the City of San Jose, whose own terms still apply to that source data. See the terms of use.

Sources

Downtown San Jose's office vacancy rate was 30.8% in the first quarter of 2026. Cushman & Wakefield, reported by The Press Democrat, “Sky-high office vacancy levels haunt Bay Area's three major downtowns” — verified 2026-09-12.
On January 27, 2026 the San Jose City Council extended its downtown high-rise incentive program to office-to-residential conversions of at least 20 homes. San Jose Spotlight, “San Jose boosts incentives to convert offices to housing” — verified 2026-09-12.
Under Resolution No. RES2026-20, adopted January 27, 2026, conversion projects get a 100% construction tax reduction and 50% parkland in-lieu fee reduction for the first 500 units, 50% and 30% for the next 1,000, and a $0 inclusionary housing in-lieu fee. City of San José, Housing Department, “Downtown Residential Incentive Program Tax and Fee Waiver for the Gateway Tower and Bank of Italy Developments (memorandum, February 19, 2026)” — verified 2026-10-26.
The program waives construction taxes and inclusionary housing fees for the first 500 converted homes, and city staff estimated roughly 1,500 homes of potentially viable conversion stock while projecting 611 homes would actually be built, at a cost of about $16M in waived fees. Propmodo, “San Jose Is Betting $16 Million in Fee Waivers Can Turn Empty Offices Into Apartments” — verified 2026-09-12.
The RESIDE Act is Section 210 of the 21st Century ROAD to Housing Act (Public Law 119-101), which became law without the President's signature on July 11, 2026. Section 210 authorizes a HUD pilot program, in fiscal years 2027 through 2031 and subject to appropriations, of competitive grants to HOME participating jurisdictions to convert vacant and abandoned buildings into attainable housing; in a year at least $100M is available, each grant is $1M to $10M. U.S. Government Publishing Office, “Public Law 119-101, 21st Century ROAD to Housing Act” — verified 2026-09-14.
As of October 28, 2026, HUD had issued no Notice of Funding Opportunity, guidance or rule for the RESIDE pilot, and no funds had been appropriated for it. Federal Register, “Documents from the Department of Housing and Urban Development since July 11, 2026” — verified 2026-10-28.
The RESIDE Act was introduced as H.R. 5591 in the 119th Congress. As introduced, it would have funded the program with up to $100M a year of HOME appropriations above $1.35B; the enacted law does not. Congress.gov, “H.R.5591 — RESIDE Act” — verified 2026-09-14.
All 99 buildings on the Downtown San Jose map, homes already included, lie in California's 18th Congressional District, checked building by building against the 119th Congress district boundaries. U.S. Census Bureau, “TIGERweb Legislative Map Service: 119th Congressional Districts” — verified 2026-09-14.
Google demolished roughly 80 acres of downtown San Jose for its Downtown West campus, then paused the project; the site remains largely vacant and the planned 7M sq ft of offices and about 4,000 homes have not been built. Planetizen, “Google Razed 80 Acres in Downtown San Jose. Then… Nothing Happened.” — verified 2026-09-12.
San Jose's Regional Housing Needs Allocation for the 2023–2031 cycle is 62,200 homes. San Jose Spotlight, “Staedler: San Jose's 62,200 housing unit question” — verified 2026-09-12.
Building footprints, LiDAR-derived heights and zoning come from the City of San Jose's open GIS service. City of San Jose, “DPW Basemap MapServer (layers 21 and 33)” — verified 2026-09-12.

The scored dataset behind this page is available as GeoJSON. Findings generated 2026-10-20 from City of San Jose GIS Open Data (DPW_BasemapServiceWGS layers 21/33).