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                                                                    Exhibit 23.1



                        CONSENT OF ROSEN CONSULTING GROUP
                        ---------------------------------

We consent to the incorporation by reference in the Registration Statement of
Bay Apartment Communities, Inc. (the "Company") on Form S-3 (File No. 333-15875)
(the "Registration Statement") of our report dated June 28, 1996, entitled the
Apartment Markets in Orange, Santa Clara, Alameda, San Francisco and San Mateo
counties, and any addendum thereto, which report and addendum are included in
the Company's report on Form 8-K dated July 5, 1996 and in the Company's report
on Form 8-K to which this consent is an exhibit. We also consent to being named
as an expert in any Prospectus Supplement to the Registration Statement with
respect to demographics and market information.

                                       ROSEN CONSULTING GROUP



                                       By: /s/ Kenneth T. Rosen
                                          ----------------------------
                                          Kenneth T. Rosen