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NAA Barriers Data to Reach White House

The National Apartment Association (NAA) is pleased to provide comments to the White House Council on Eliminating Regulatory Barriers to Affordable Housing, and we encourage members and affiliates to submit comments on the unique, local challenges faced by developers and other industry professionals. 

The Council was established with the purpose of identifying federal, state, tribal and local land use policies and administrative practices that restrict the development of affordable housing. In November 2019, the Council published a request for information (RFI) regarding the factors that contribute to reduced levels of housing development. Once collected, the information will be used to generate the federal government’s strategy towards increasing housing affordability.  The RFI poses several questions that can be roughly grouped into three specific asks:

  1. Which federal, state, tribal and local barriers (physical and artificial) contribute to the lack of affordable housing development and/or raise the cost of housing?
  2. What solutions are available to counter their detrimental impact?
  3. What research is available to support these claims?


As part of its comments, NAA plans to highlight its Barriers to Apartments Construction Index. Our barriers data was previously presented to the White House during a listening session in which NAA participated in November. The session brought together leaders in the housing industry for a solutions-driven conversation chaired by United States Department of Housing and Urban Development (HUD) Secretary Dr. Ben Carson. The survey measured development complexity including the impact of community involvement, construction costs, affordability issues, infrastructure, density and growth restrictions, land supply, environmental restrictions, approval process complexity, political structure complexity and the time to develop a new property. Both affiliates and members have supported our response by submitting feedback on the local land use policy and administrative practices that inhibit housing growth and limit affordability in their communities. For instance, the public hearing requirement under the California Environmental Quality Act has allowed Not-In-My-Backyard (NIMBY) activists to vocally demonstrate opposition to high density development in cities like Los Angeles and San Francisco, thus harming a project’s potential for approval. Limited available land, layered with restrictions as to the type and density of what can be developed on it, has significantly increased the cost of construction for developers in Dallas. We thank those for their contributions.

The deadline for submission has been extended to January 31. NAA encourages its members and affiliates to reach out with their own experiences facing barriers to development. For more information on the RFI, contact Sam Gilboard, Manager of Public Policy.