This post is still in draft — released for vetting.
As noted previously, the Subsidized Housing Inventory is not a good metric of the affordable housing units in Massachusetts. Fortunately, over the past few years, Jennifer Gilbert and her team at the Housing Navigator have done the hard work to rigorously assemble a database of affordable housing units in Massachusetts. Their goal was to create a friendly search tool for people seeking affordable housing. but the foundation for that tool is a complete database of affordable housing units. They have published the high level counts from that database as of January 2024 and those counts are reproduced below.
Affordable Housing Units in Massachusetts, January 2024
| Affordable Units | Rent based on income | Fixed below market | Total |
|---|---|---|---|
| Non-age restricted | 78035 | 50903 | 128938 |
| Age restricted | 70201 | 10445 | 80646 |
| Total | 148236 | 61348 | 209584 |
The conclusion of this post is that these counts are credible. They give us the best idea we have as to the total count of affordable units. The numbers were rigorously prepared, they reconcile adequately with available data from state and federal administrative agencies, and they reconcile adequately with Census data.
The Navigator Data
The Navigator covers income-restricted rental housing units available to the public. For short, we’ll refer to “affordable housing” in this post, but to be clear, that term is being used to refer the Navigator’s selection of housing units.
- It includes rental housing not ownership housing.
- It includes income-restricted housing, housing that by law may only be rented by households with limited income, not “naturally occurring” affordable housing — unregulated housing which happens to be inexpensive. Income restrictions are usually defined with reference to Section 8 standards.
- It excludes group homes and other specialized housing that is not available to households for rental.
- It excludes mobile housing vouchers, although people with mobile vouchers might use the database to find units and use their vouchers in income restricted units.
The term “rent based on income” means that the rent will be set at 30% of the eligible household’s actual income. “Fixed below market” means that the unit’s rent is set at a fixed low level, usually 30% of the unit’s income eligibility threshold, but will not vary by the actual income of the household and so could exceed 30% of the household’s income if the household’s income is materially below the unit’s income eligibility threshold. The legal income eligibility threshold is a household income maximum, not a minimum, although owners of “fixed below market” units may also impose a minimum income as well, because like any landlord, they want tenants who can pay the rent.
The Navigator team collected, analyzed, and deduped every available agency list of affordable housing units, including the following:
- State public housing database underlying the CHAMP system.
- Federal public housing and other HUD assisted properties
- Grant making databases of properties receiving federal LIHTC, state LIHTC, tax-exempt financing, and other subsidies from the state’s lead housing agency (Housing and Livable Communities) and its affiliated quasi-public agencies (MassHousing, Massachusetts Housing Partnership)
- Properties receiving federal low income housing tax credits as reported by HUD
- CEDAC’s affordability preservation database
- The state’s subsidized housing inventory
- Major city housing agencies
Where available property data was incomplete as to income-restrictions or rent levels, the team sought information from property managers and/or researched the recorded deed restrictions governing the properties. For more information, see the Navigator’s FAQ sheet. In interviewing CEO Jennifer Gilbert I came away fully convinced of the integrity and completeness of the Navigator unit count.
Comparing Navigator Totals to Agency Totals
The numbers in the analysis below add up affordable units based on published agency counts. These numbers are reassuringly consistent with the Navigator count and they help give additional sense of the components of the count.
Agency counts of Affordable Units in 2024
| Program or category | Units — Rent Based on Income | Units — Fixed below market |
|---|---|---|
| (1) State Public Housing — Elderly and Disabled | 28,700 | |
| (2) State Public Housing — Families | 12,800 | |
| (3) Federal Public Housing | 29,957 | |
| (4) Federal Moderate Rehabilitation | 1,662 | |
| (5) Federal Section 8 Project Based Rental Assistance (PBRA) | 59,394 | |
| (6) 202/PRAC (Federal Supportive Housing for the Elderly ) | 3,752 | |
| (7) 811/PRAC (Federal Supportive Housing for Persons with Disabilities) | 967 | |
| (8) Federal low income housing tax credit units from HUD LIHTC property database | 68,899 | |
| (9) Total units from administrative program counts | 137,232 | 68,899 |
| (10) Adjustment 1: Tax credit projects that are preservation of Section 8 Project-Based Rental Assistance projects (duplicate PBRA count) | (21,121) | |
| (11) Adjustment 2: Tax credit units that carry modern project based vouchers (should be classified as “Rent based on income”) | 12,752 | (12,752) |
| (12) Adjustment 3: 40B projects not HLC Subsidized | ~20,000 | |
| (13) Adjustment 4: Units affordable pursuant to inclusionary by-laws and other local agreements. | ~4,000 | |
| (14) Adjustment 5: HLC subsidized units without federal tax credits | ~5,771 | |
| (15) Adjusted total administrative program counts | 149,984 | ~64,796 |
| (16) Navigator Total | 148,236 | 61,348 |
| (17) % Difference between Navigator and Administrative | 1% | 6% |
Line Notes to Table Above
- Recent count supplied by Housing and Livable Communities, Undersecretary of Public Housing & Rental Assistance at Massachusetts Executive Office of Housing & Livable Communities.
- Same source as 1.
- Using count supplied from HUD Program Data as of December 31, 2023; direct download here. See also Federal Public Housing Dashboard.
- Same source as 3. See Mod Rehab program description here.
- Same source as 3. See PBRA program description here.
- Same source as 3. See Section 202 program description here.
- Same source as 3. See Section 811 program description here.
- Source: Federal Low Income Housing Tax Credit database. See program description here. Affordable unit count derivation explained in attached spreadsheet.
- Sum of lines (1) through (8)
- Data on tenants of tax federal credit properties shows that 72.3% received some form of federal rental assistance. Among these in turn, 42.4% were receiving project based rental assistance. These are likely older PBRA properties that were rehabilitated and preserved as affordable using tax credits. Thus, they are already counted under line 5. 72.3% * 31% * Line 8 yields Line 9. Note that the tenant database only matches information for 47.9% of Massachusetts tax credit properties; we are extrapolating the same ratios to the unmatched properties. See tables 9, 11 and 12 from the tenant data.
- The adjustment in this line is based on the same sources as line 9. 25.6% of tax credit properties receiving federal rental assistance have HUD project based vouchers. 72.3% * 25.6% * Line 8 yields Line 10.
- This approximate adjustment was supplied by the Housing Navigator and is currently being further vetted.
- This approximate adjustment was supplied by the Housing Navigator and is currently being further vetted.
- This adjustment likely double counts to some extent Line 11. It is based on applying 8.4% to line 8. 8.4% is derived as the ratio of total affordable units without federal tax credits to total affordable units with federal tax credits within the HLC Intelligrants database for projects with apparently complete data (those placed in service after 2015).
- Line (9) with additions/(subtractions) in lines (10) through (14). The “~” symbol denotes approximation.
- The Housing Navigator totals for comparison — from the first table in the post.
- Line (15) – Line (16) — as percent of Line (16).
Comparing Navigator Totals to Census Data
The American Community Survey (ACS) is the primary Census data product offering details about households at a regional level. The ACS does not differentiate affordable units in our strict sense — that is, it does not track whether units are legally reserved for people of low income. But it turns out that we can make a rough identification of income restricted units in the ACS data which provides another confirmation point for both the Navigator and administrative data above.
The first observation to make is that there is essentially no market rate housing in Massachusetts that is affordable at the 30% of AMI level (i.e., for which rent is less than the 30% AMI level). In recent Zillo searches, we found essentially no units affordable at the 30% ELI level or even twice that level. The table below shows results for 3 bedroom searches in low/moderate income communities in the Boston area. Similar tables in the attached spreadsheet show the results of single bedroom searches and searches in the Springfield area.
3 Bedroom Search results from Zillo on 10/31/2024 at HUD Income Levels for 4 Person Households
| 2024 HUD Income Level | Maximum Affordable Rent | Brighton Results | Roxbury Results | Everett Results | Malden Results | Lynn Results | |
|---|---|---|---|---|---|---|---|
| Extremely Low Income Limit | $48,950 | $1,224 | 0 | 0 | 0 | 0 | 0 |
| Very Low (50%) Income Limit | $81,600 | $2,040 | 0 | 1 | 0 | 0 | 0 |
| 2x ELIL | $97,900 | $2,448 | 0 | 1 | 0 | 0 | 0 |
| Low (80%) Income Limit | $130,250 | $3,256 | 133 | 20 | 13 | 18 | 12 |
| Median Family Income | $148,900 | $3,723 | 337 | 42 | 21 | 27 | 17 |
| All rent levels | All | 951 | 172 | 29 | 34 | 21 |
We did another set of statewide searches to facilitate a comparison to the 2022 ACS data. The ACS tabulates Massachusetts units according to tenant reported rent in $500 ranges. We inflated these ranges to 2024 levels by 15%. This 27 month inflation percentage is a rough estimate based on Zillow’s Observed Rent Index. Zillow does not provide statewide inflation rates, but ZORI showed inflation of 12% in the Boston area and 18% in the Springfield and Worcester areas, comparing September 30, 2024 to the average for 2022.
The graphic below shows that the American Community Survey for 2022 reports a total of over 1/3 of the rental units in the state as renting in ranges below $1,500 in 2022. By contrast, Zillo in November 2024 only showed 3.7% of the offered units of any size in the state renting below $1725 ($1500 inflated 15%) and only 0.3% renting below $1,150 ($1000 inflated 15%). Households at the 2022 HUD Extremely Low Income levels constituted approximately 1/3 of renters. For most of them, affordable rent would be below the $1000 rent level. The chart shows that despite the large number of apparently low rent units appearing in the Census, ELIL households actually faced a complete lack of affordable market rate housing. See attached spreadsheet.
Percent of all units in 2022 rent ranges vs Zillow percentages for same rent ranges
(27 months later, inflation adjusted)
We can make an important inference from the graphic above. We know that the ACS record rents paid in units according to the tenant. We also know that tenants usually report the rent payments that they actually make themselves (as opposed to the true total rent that being subsidized by government programs). The exception is for tenants with mobile vouchers — they are split as to what they report, with approximately 60% reporting the full rent and 40% reporting their own payment. We can infer that in the low rent ranges, the low reported rents are almost all subsidized.
We can therefore take the ACS count of units that are affordable to and occupied by people below HUD’s 30%-AMI (“Extremely Low Income Level”) as a count of ELI-occupied subsidized housing. The National Low Income Housing Coalition developed such an affordable/occupied-by count from the 2022 ACS data, finding a total of 145,391 of ELIL Massachusetts households that are in homes that affordable at the ELIL level (possibly also including some vacant units). How does this count compare to the Navigator and administrative data?
We can use ELIL occupancy rates from the administrative data to develop an alternative count of ELIL-occupied subsidized units renting at ELIL levels as shown in the table below:
Prediction of Census Count of Units Affordable to and Available to ELIL Households
from Agency Data
| Units | %ELIL Occupied at ELIL Affordable Rent | Count Occupied at ELIL Affordable Rent | |
|---|---|---|---|
| (1) State public housing | 41,500 | 78% | 32,370 |
| (2) Federal Public Housing | 29,957 | 78% | 23,366 |
| (3) Federal Mod Rehab | 1,662 | 87% | 1,446 |
| (4) Federal Project Based Section 8 Rental Assistance | 59,394 | 79% | 46,921 |
| (5) 202/PRAC (Federal Supportive Housing for the Elderly ) | 3,752 | 80% | 3,002 |
| (6) 811/PRAC (Federal Supportive Housing for Persons with Disabilities) | 967 | 94% | 909 |
| (7) Tax Credit Units w/ federal project based vouchers | 12,752 | 79% | 10,074 |
| (8) Tax credit units w/ federal tenant based vouchers | 9,166 | 31% | 2,860 |
| (9) Other Fixed Below Market Unit | 55,630 | 0% | – |
| (10) Federal Mobile vouchers in unsubsidized units | 77,612 | 31% | 24,215 |
| (11) State vouchers MRVP/AHVP | 11,000 | 55% | 6,061 |
| (12) Total Agency Predicted Count (2023-4) | 151,224 | ||
| (13) National Low Income Housing Coalition Count From Census (2022) | 145,391 |
Line Notes to Table Above
For the first column in most lines, see the first comparison table. These notes explain the second column.
- We do not have an ELIL occupancy rate for state public housing. We are assuming the same ELIL occupancy as for federal housing. This is reasonable as they have similar median/average income levels.
- Using rates supplied from HUD Program Data as of December 31, 2023.
- Same source as 2.
- Same source as 2.
- Same source as 2.
- Same source as 2.
- Assuming same rate as federal project based rental assistance, line 4.
- Based on data for tenants of tax federal credit properties as discussed in note to line 10 in previous table. 18.4% * 72.3% * 68,899= 9,166 tax credit units have are occupied by tenants with mobile vouchers. Assuming 40% of the these units report their tenant payment (see text discussion) and that 78% are ELIL. 78% is the Housing Choice average ELIL rate from HUD Program Data.
- For other units in the Fixed Below Income category, some (perhaps 10 or 15%) may be occupied by ELIL households, but since most ELIL households have incomes well below the ELIL threshold, they will not show in the Census data as paying affordable rent.
- Voucher count from HUD Program Data with previously counted vouchers removed. For ELIL rate, see 8.
- State voucher count from HLC. Assuming (for lack of better data) an even blend between project-based and mobile deployment of these vouchers and using federal ELIL rates.
- This is the total count of units that we expect would show to the ACS as occupied by ELIL households at ELIL affordable rent levels. These counts are ambiguous as to vacancy rates, but there are long waiting lists for all of these programs, so vacancy rates are very low.
- This is the total count of units that show in the ACS as available to ELIL households at ELIL affordable rent levels, based on analysis from the National Low Income Housing Coalition. These counts include units occupied by ELIL households at affordable rents and vacant units with rents that would be affordable to ELIL households.
Conclusion
The robustly developed affordable housing counts from the Housing Navigator are reassuringly consistent with both agency data and census data.
Resource spreadsheet here.