In response to a request for information (RFI), the National Trust offered comments to the Department of Housing and Urban Development (HUD) and the White House Council on Eliminating Regulatory Barriers to Affordable Housing, regarding Federal, State, local and Tribal laws, regulations, and administrative practices that raise the costs of affordable housing and contribute to shortages in housing supply. Executive Order 13878 establishing the White House Council on Eliminating Regulatory Barriers to Affordable Housing states that historic preservation requirements are a regulatory barrier to the development of affordable housing.

The National Trust is very concerned with the lack of affordable housing, but we believe that older and historic buildings are community assets with significant reuse potential that can make an important contribution to solving the affordable housing crisis. We strongly disagree with the broad characterization of the relationship between affordable housing and historic preservation. Our research shows that historic preservation is not a significant barrier to the creation of affordable housing; and in fact, preservation regulations and administrative practices help retain valuable existing affordable housing and create new units through rehabilitation of vacant and underused structures.

Key Messages:

Strengthen Historic Preservation Incentives to Create More Affordable Housing 

Historic Preservation is Not a Significant Barrier to Affordable Housing 

Demolishing Historic Buildings Does Not Create Affordable Housing