The urgent need for an agenda to preserve ‘naturally occurring’ affordable housing   (2025)

THERE IS considerable talk about the housing crisis in Massachusetts and increasingly throughout the country, but there is not universal agreement on the nature of the crisis and what government should do about it. The simple understanding is that an enormous number of households cannot afford their rent and young adults cannot afford to buy their first home. The widely accepted solution? We must “build, build, build” so that the supply of homes can catch up with the demand.

This is an incomplete and two-dimensional characterization of the problem and solution. It neglects the fact that the very expensive inputs to housing – land, labor, and building materials — put a rather high floor on rent or purchase price of newly built housing. More importantly, the term “affordable” has been used very loosely.

High rents and home purchase prices are unquestionably a serious problem for middle-income families. But it is lower-income, working-class people that are facing a true crisis. The supply of rental housing affordable to the state’s low-income families – rents below $1,400 per month — is rapidly shrinking. Census analysis by the Joint Center for Housing Studies shows a decline of over 115,000 affordable rental units in Massachusetts between 2012 and 2022. Soaring rent are undoubtedly one of the causes of the surge of homelessness, the most tragic manifestation of the housing crisis.

A big driver of the housing crisis is the disappearance of what has recently been dubbed “naturally occurring affordable housing, or NOAH. NOAH is older rental housing, with rents low enough to be affordable to lower-income households, but generally no public subsidy.

Typically, the housing is in only fair condition. It is often owned by small landlords who have owned the property for a decade or longer. Most owners of NOAH are middle aged or older small businesspeople, not real estate investors.

As shown in a recent MassINC Policy Center report, the bulk of the naturally occurring affordable housing in Massachusetts is in the state’s Gateway Cities, but this inventory is dwindling.

When NOAH properties are put on the market they are quickly snapped up, often in all-cash transactions, by investors who renovate the properties as high-end market rentals or condominiums. The low- and moderate-income tenants living there are generally hit with a whopping rent increase shortly before or after the sale to the speculator investors.

Some tenants wind up being evicted for non-payment of the rent increase or as a “no-fault eviction” with no cause given. Many tenants, unaware of their legal rights, simply move upon being told that the building has been sold and their tenancies will not continue.

It is very likely that in the past decade more naturally occurring affordable housing has been lost through investor “flipping” than government-funded affordable housing has been built. Our state housing policies of focusing almost exclusively on the production of new housing is akin to attempting to fill a bathtub with an open drain.

Last summer Gov. Healey signed the Affordable Homes Act, a historic housing bond bill that authorized over $5.1 billion of borrowing that includes production and preservation of thousands of units of affordable housing over the next five years. The measure included more than 40 housing policy provisions that do not have specific spending authorizations attached.

In tandem with the housing bond bill, the new Executive Office of Housing and Livable Communities launched a process and appointed a blue-ribbon advisory body to develop a five-year housing strategy that is intended to address a range of housing challenges in a flexible, location-sensitive approach. The five-year plan was released in early February 2025

There is almost nothing, however, in this major investment plan, the overhaul of state housing policies, or the elevation of the state’s housing agency to cabinet level stature or the state’s strategic housing plan that addresses the loss of naturally occurring affordable housing and the annual displacement of hundreds of lower-income households living in such housing.

In fact, over the past 10 to 15 years the Commonwealth’s affordable housing bureaucracy has been noticeably absent from efforts to preserve naturally occurring affordable housing and re-house those households that have been displaced by private marketaction.Even where communities have initiated programs to preserve NOAH with local resources, the state has been absent from both the design and funding of these programs.

It is time for Massachusetts to develop polices, programs, and, most importantly, a long-term capital investment goal for preserving NOAH and integrating it into a comprehensive affordable housing strategy for the state.

Here are some immediate steps to be taken:

• A task force focused exclusively on NOAH should be established within the statewide housing planning effort. Its members should be housing professionals, officials, attorneys, tenant organizers, and academics that have worked directly on the preservation of NOAH. The task force final report should state a specific dollar investment goal of state housing resources that should be established for NOAH preservation through the state’s 2029 fiscal year.

• The Executive Office of Housing and Livable Communities should provide matching state funding to every municipality that is using local resources to preserve NOAH.

• The Legislature should send a FY 2026 budget to the governor that mandates that a modest 5 percent of all funds managed by the Executive Office of Housing and Livable Communities, including rental subsidies, be committed to NOAH preservation projects.

• The Legislature should enact and the governor sign the Tenant Opportunity to Purchase Act (TOPA), which could preserve thousands of units of NOAH by giving tenants the right to form an association, or work with nonprofits or local housing authorities to match third-party offers when multi-family buildings are being sold.

There is also a need for more research on NOAH: How much NOAH remains in the state and where is it, where is it most threatened, how is the disappearance of NOAH fueling homelessness, what are the resources and fiscal benefits of housing investment that balance new production with preservation of viable occupied housing.

Of course,morehousingmust be createdfor allincome levels.However, strong and deliberatepublic action is criticalfor halting the erosion ofnaturally occurring affordable housing — the largestinventoryofaffordable housing in the Commonwealth. Wemust be much morethoughtful about balancingstill scarce housingdollars betweenbuildingneeded new units and preservingand improving the old, but viable affordable housing in the State.

Mathew Thall is a Boston-based affordable housing and community development consultant. He is president of the Massachusetts Association of Housing Cooperatives and a member of the steering committee of the Tenant Opportunity to Purchase Act Coalition.

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