Unsubsidized Affordable Housing
Definition
Unsubsidized affordable housing – housing units with rents that are relatively low compared to other market rate rents for the applicable region, commonly referred to as “Naturally Occurring” Affordable Housing (NOAH). These properties are typically Class B and C rental buildings or complexes, often constructed between 1940 and 1990, that can range from small (100 hundred units), each with unique financial and physical needs. They are typically not part of any government-subsidized housing program and therefore do not have enforceable affordability covenants, excepting for local rent control laws where applicable. In addition, some public funding programs may include short-term affordability requirements.
Scale
This affordable housing type comprises the majority of affordable rental housing units in California, with an estimated 864,000 units as of 2022.
Most Common Owner Type
Private owners and investors, including the “mom and pop” variety.
TYPOLOGY ANALYSIS FOR EQUITABLE DECARBONIZATION
Decarbonizing Unsubsidized Affordable Housing
CHALLENGES UNIQUE TO THIS TYPOLOGY | WE MUST SOLVE FOR… | INTERVENTIONS RECOMMENDED TO RESOLVE THIS CHALLENGE | DESIRED OUTCOMES | PARTNERSHIPS NECESSARY TO ACHIEVE THESE OUTCOMES |
RENT INCREASES + TENANT DISPLACEMENTDecarb upgrades add cost which can lead to permanently displacing tenants and loss of affordability |
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| Near-term: Pilot programs to market test incentives that place new affordability covenants or tenant protections and outcomes for tenants and owners. Long-term: Decarbonization funding programs that effectively incentivize owners and maintain affordability. | Collaboration between foundations, state and local agencies, people with lived experience, landlord and affordable housing associations, trusted community organizations, TA providers, and other institutions to support the statewide commission. Engagement with owners and residents in unsubsidized properties. Housing departments for tenant protection enforcements |
PHYSICAL NEEDSHousing stock is older with site and other constraints | Existing building systems and envelope:
CA State Tenant Protection Act allows for eviction for "substantial remodel" like the major capital improvements necessary for electrification. | Comprehensive capital programs that provide both energy and capital upgrades:
| Statewide pipeline of unsubsidized affordable housing undergoing full decarbonization | Technical assistance providers and owners or buyers of unsubsidized affordable housing. |
FINANCE STRUCTUREVaried owner types, size of properties, and access to existing programs (isn't scalable to meet housing stock need) | Varied owner types result in owners of smaller properties unable to access existing programs
Restricted rent income prevents the ability to take on debt.
| Market-tested products to preserve affordability through:
Provide targeted technical assistance from trusted providers
| Market-tested programs that successfully incentivize all owner types and include financial restructuring, decarb retrofits, and preservation of affordability simultaneously. |
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CAPACITY & AWARNESSOwner types vary and require deep technical assistance to integrate decarb retrofits into existing properties | Capacity challenges to implement decarbonization
| Increased public awareness
| Implementation and operational proficiency by property owners and their partners, including property and asset management, and general contractors | Collaboration between technical assistance providers (including consultants, designers, and engineering professionals), trade associations, and funding program administrators |
Typology Specific Recommendations
Equitable Decarbonization of Unsubsidized Affordable Housing
Typology Specific Funding Pathways And Solutions
The IRA includes $9 billion in consumer home energy rebate programs, focused on low-income consumers, for energy efficiency and electrification. This funding could be used to enhance the State’s Weatherization Assistance Program (WAP) and Low-Income Home Energy Assistance Program (LIHEAP) Weatherization Assistance Program, and additional funding could be used to enable more extensive capital upgrades as part of this program.
For small unsubsidized multifamily, structure products as:
Grant funds structured as debt
Public subsidies with low or no-cost debt that can function as "gap" funding
Below-market subordinate loans or equity investment products that can leverage owner's borrowing power
For large unsubsidized multifamily, structure products as:
Subordinate revolving debt pool that generates return on investment through realized operational savings and creates the potential for a sustainable loan pool by recycling funds.
Oversight And Governance Structures To Reach More Equitable Outcomes
Establish an Oversight Committee comprised of tenants, community organizations, owners, state agencies, TA providers, and financing partners
For small unsubsidized multifamily:
Lead Administrator to manage grants, soft loans, and technical assistance (TA)
Select a well-established mission-aligned state housing agency with both:
Proven capacity to lend or provide grants and TA to developers and/or owners of unsubsidized properties of all sizes.
A well-established network of regional and community-based financing institutions.
For large unsubsidized multifamily:
Lead Administrator
Select a well-established mission-aligned state housing agency with:
Proven capacity to manage soft loans
Strong network of regional and community-based financing institutions and can also fill technical assistance roles
Mission-aligned lenders to administer subordinate debt such as community development financial institutions (CDFIs)
Subsidized Affordable Housing [Existing Buildings]
Definition
Existing subsidized affordable housing refers to housing units that have legally enforceable restrictions on their rents which ensures they remain affordable to low-income households. Typically, these affordability restrictions are enforced via affordability covenants recorded against the property and which accompany a source of public financing used in the purchase or development of the units.
Scale
Currently in California there are approximately 527,500 regulated housing units. All affordable housing projects developed utilizing the low-income housing tax credit (LIHTC) are examples of regulated affordable housing.
Most Common Owner Type
For-profit and nonprofit entities of varying size, from small community- based organizations to institutional real estate investments firms. Public housing authorities.
TYPOLOGY ANALYSIS FOR EQUITABLE DECARBONIZATION
Decarbonizing Existing Subsidized Affordable Housing
CHALLENGES UNIQUE TO THIS TYPOLOGY | WE MUST SOLVE FOR… | INTERVENTIONS RECOMMENDED TO RESOLVE THIS CHALLENGE | DESIRED OUTCOMES | PARTNERSHIPS NECESSARY TO ACHIEVE THESE OUTCOMES |
RESOURCE ALLOCATIONPreservation funding and energy resources for existing affordable housing is extremely limited and is not currently prioritized. | Housing resources for affordable housing preservation are limited in CA, regardless of decarbonization goals. This includes:
Energy resources for existing properties are limited and do not cover capital upgrades. |
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| Use private sector resources to lower the cost of capital, offering lower interest rates for properties that decarbonize. |
PHYSICAL NEEDSHousing stock is older with site and other constraints | Existing building systems and envelope:
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| Statewide pipeline of existing regulated affordable housing undergoing full decarbonization with newly placed / renewed affordability covenants. | Deep relationships between Technical Assistance providers and owners or buyers of regulated affordable housing. |
FINANCE STRUCTURERegulated properties have complicated financial stacks, investor partnerships, and intricate regulations. | Existing regulated affordable properties usually have five or more funding sources that each require approval to accept new decarb dollars. Many financing programs for affordable housing have varying requirements for accepting additional debt for decarbonization upgrades:
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| Pilot funding program of projects undergoing decarbonization retrofits between recapitalization cycles. | Private or public sector investment products administered by housing agencies and mission-aligned CDFIs
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CAPACITYOwners require deep technical assistance to integrate decarb retrofits into existing properties. | Capacity challenges are at the development and operational levels of decarbonization implementation. Technical assistance must be freely available to ensure newly introduced features maximize performance and efficiency. |
| Implementation and operational proficiency of decarbonization retrofits by property owners and their partners (property and asset management). | Collaboration between administrators, contractors, and technical assistance providers, such as: consultants, designers, and engineering professionals. |
Typology Specific Recommendations
Equitable Decarbonization of Unsubsidized Affordable Housing
Typology Specific Funding Pathways And Solutions
Reimagining how preservation activity is resourced, and how green building and decarbonization programs can be layered into preservation financing structures, will be key to achieving the state's housing sustainability goals.
To help achieve this, state energy agencies can grant funds to the housing agencies to fund decarbonization and preservation programs, creating new financing solutions.
Energy money can be utilized to fund decarbonization retrofits with housing finance structured as:
Grants or forgivable loans
Below market subordinate loans layered into housing stack
Bridge financing for energy incentives
Below market mezzanine debt on top of existing debt
Ensure compatible terms that can be used with existing financing products like mortgage debt (subordinate participation loan alongside existing financing terms)
Cover both decarbonization, Major Capital Improvements (MCI’s), and critical replacement and repairs
Oversight And Governance Structures To Reach More Equitable Outcomes
Oversight:
Governor’s office, Treasury, and State Public Service Commission
Lead Administrator
State housing agency that is well established in managing syndications and preservations of affordable housing.
Capital to flow through housing agency and/or mission- aligned Community Development Finance Institutions with local relationships.
Community partners to assist with outreach to ensure funds flow into the communities in the right ways.
Subsidized Affordable Housing [New Construction]
Definition
New construction subsidized affordable housing refers to residential properties built from the ground up, or through adaptive reuse of an existing non-residential property, for the purpose of providing affordable rental housing units for low-income households. Most new construction affordable housing is financed using low-income housing tax credits (LIHTC) and a combination of public subsidies, grants, and conventional debt. Affordability is regulated through placement of affordability covenants recorded against the property which ensure rents are maintained at levels affordable to low-income households.
Scale
Between 2020-22 California produced an average of 22,869 new affordable units per year, 96,418 units below the state’s annual goal.
Most Common Owner Type
For-profit and nonprofit entities of varying size, from small community- based organizations to large real estate developers.
TYPOLOGY ANALYSIS FOR EQUITABLE DECARBONIZATION
Decarbonizing New Construction Affordable Housing
CHALLENGES UNIQUE TO THIS TYPOLOGY | WE MUST SOLVE FOR… | INTERVENTIONS RECOMMENDED TO RESOLVE THIS CHALLENGE | DESIRED OUTCOMES | PARTNERSHIPS NECESSARY TO ACHIEVE THESE OUTCOMES |
RESOURCE ALLOCATIONCurrent housing programs don’t receive or provide enough support to fund the full cost of decarbonization. | Title 24 (the section of CA building code that regulates sustainability) effectively incentivizes developers to construct all-electric buildings, though many developers don't choose to take the incentives because:
Rural and disaster-vulnerable prone areas of the state face common funding gaps: Infrastructure investments: gaps for fire resilience, utility/sewer connectivity, flood mitigation, as well as electrification.
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| All new construction projects utilizing state funding will feature all electric construction Uptake of energy scopes and decarbonization due to meaningful benefits to both developers and tenants through ample resource allocations to soft costs, technical assistance, and robust funds per unit. |
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FINANCE STRUCTUREThere are too many small energy programs that are not reasonable for meaningful developer uptake. | Existing programs are small, hard to access, and do not yield a worthy return on investment for developers to access them. Programs require specialized expertise and staff time, often for limited resources and returns. This results in relatively low uptake. |
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CAPACITYAll-electric high- performance buildings require additional time and knowledge. | Increased soft costs (time and education) for operators and tenants to learn how to use the new equipment and manage the associated risks with high performance buildings. |
| Implementation and operational proficiency of decarb features by property owners and their partners, including property and asset management | Collaboration between developers/owners, TA providers (including consultants, designers and engineering professionals) and funding program administrators |