By Michael Anderson | Wed, August 5, 26
Across the Northeast and Mid-Atlantic, thousands of families live in older apartment buildings that maintain affordable rents not because of subsidies, but because of age, condition, or location. This is naturally occurring affordable housing, or NOAH, the quiet backbone of affordability in many cities.
When people think about affordable housing, they often picture properties supported by government programs like Section 8 or the Low-Income Housing Tax Credit (LIHTC). These programs are essential, but they represent only a slice of the region’s affordable rental stock. In gateway cities and dense urban neighborhoods, NOAH properties make up a much larger share of affordable homes for seniors on fixed incomes, individuals with disabilities, and working families.
However, “affordable” in the context of NOAH refers to rent alone, rather than total housing costs. Unfortunately, NOAH buildings are often inefficient, do not have the same utility cost protections for tenants as many subsidized housing programs, and rarely fit neatly into traditional energy efficiency programs. That mismatch is costing families money, straining owners, and leaving major energy saving opportunities on the table.
NEEP's new white paper, Energy Efficiency in Naturally Occurring Affordable Multifamily Housing: Barriers and Opportunities in the Northeast and Mid-Atlantic, explores why this segment is so difficult to serve and what approaches exist to address these challenges.
Why does NOAH Matter for Affordability
For the large numbers of low- and moderate-income residents living in inefficient NOAH buildings, high energy burdens strain already tight household budgets. For many NOAH tenants, energy efficiency is not about saving kilowatt hours, it is about keeping monthly costs manageable and preserving long-term affordability.
Yet, in terms of the ability to engage in an energy efficiency program, NOAH owners operate in a fundamentally different reality than subsidized housing providers. They often lack:
- Income documentation for conventional program eligibility
- Staff capacity to navigate complex program applications
- Access to low-cost, flexible financing
- Cash reserves to manage large, multi-measure retrofit projects
- The incentive to improve energy efficiency when tenants pay their own utility costs
In addition, because these buildings are older, even “simple” upgrades can quickly become complicated. Aging heating and cooling systems, outdated electrical panels, mold or asbestos, and deferred maintenance can turn basic efficiency upgrades into capital-intensive projects.
Unlike subsidized affordable housing, NOAH properties generally do not collect or maintain household income documentation, making it difficult to demonstrate program eligibility under conventional requirements. At the same time, many owners operate on thin margins and lack the financial resources or administrative capacity needed to pursue major building upgrades.
For tenants, the stakes are equally high. Efficiency upgrades can improve comfort and health, but they can also trigger rent increases, property sales, or changes to utility billing that increase tenant energy burden. Without careful program design, upgrades meant to help tenants can unintentionally destabilize the relative affordability that NOAH provides through lower rent.
Why NOAH is Hard to Serve
The core challenge is simple: NOAH is affordable, but not subsidized, and many energy efficiency programs are not designed to address this middle ground. In other words, NOAH sits in a gap that is too important to ignore, but too structurally different to fit into existing program models.
Emerging Regional Models
NEEP's white paper examines four regional states using innovative approaches to program design that can help address this gap:
New York
The Affordable Multifamily Energy Efficiency Program (AMEEP) allows properties to qualify for incentives if at least 25 percent of the building's units are affordable to households earning 80 percent or less than AMI. The program uses rent roll verification to verify affordability, requiring owners to submit rent and occupancy data that is applied to a standardized formula to determine if a building meets the affordability threshold, eliminating the need for direct tenant income verification while still grounding the program in verifiable data. AMEEP also structures incentives to meet the needs of property owners through program pathways for both limited scope projects and deep retrofits and staged payments to ease owner cash-flow constraints. AMEEP is a combined effort of the Joint Utilities of New York and the New York State Energy Research and Development Authority (NYSERDA).
Connecticut
The state legislature requires that energy and housing agencies cooperatively advance the state’s energy efficiency and affordable housing preservation goals. To meet this mandate, CT Department of Energy and Environmental Protection (DEEP) established a dedicated office for multifamily programs, the Office of Affordable Housing Energy Retrofits (AHER). The office conducted a targeted outreach and engagement campaign with affordable housing owners and other relevant stakeholders to improve the design of the state’s multifamily energy efficiency programs. This program design strategy recognizes NOAH as a distinct housing sector and seeks to address the segment’s specific barriers, including the need for predevelopment funding, streamlined program access, outreach and engagement strategies that specifically target NOAH properties, and embedded protections to protect tenants from post-upgrade increases in rent.
Massachusetts
The Low Income Energy Affordability Network (LEAN) Multifamily program provides resources for energy efficiency improvements and building equipment upgrades through Community Action Programs, which leverage their longstanding community presence to drive program uptake at both subsidized and unsubsidized affordable properties. Unsubsidized properties can participate in LEAN Multifamily if at least half of a building’s households earn at or below 60 percent of AMI. Owners are required to submit affordability documentation, such as deed restrictions or regulatory agreements, but the program also allows for owner attestation of tenant income via tenant income surveys or household income lists. Owners can access comprehensive property upgrades in exchange for agreeing to protect tenants from post-upgrade rent increases for a defined period of 5 to 10 years, depending on the building’s size. The program is part of Mass Save and is jointly administered by LEAN and the Massachusetts energy efficiency program administrators.
Maryland
The Mulifamily Energy Efficiency and Housing Affordability (MEEHA) program coordinates state efficiency and affordable housing preservation goals, offering grants and loans for building equipment, building envelope weatherization, and electrification measures. Offered by the Maryland Department of Housing and Community Development, MEEHA recognizes the expense and complexity of multifamily retrofits, providing generous per-unit funding allocations and allowing owners to use some funding for limited health and safety repairs like mold or asbestos remediation. MEEHA also uses cost effectiveness criteria to ensure program funds deliver meaningful energy savings and requires affordable rent commitments based on the level of support property owners receive from the program.
Lessons for Future Program Design
Although each state has developed its own approach, several common themes emerge across these programs:
- Streamlined program access for small property owners with limited capacity, including single points of entry for multiple programs and proxy-based income eligibility such as rent-roll based formulas rather than direct engagement with tenants to verify household income.
- End-to-end technical assistance through trusted, locally embedded organizations that can help owners navigate financing and manage retrofit projects.
- Predevelopment funding for energy audits and feasibility studies.
- Flexible capital for health and safety barrier remediation and electrical panel and wiring upgrades.
- Tenant protections that limit rent increases for properties that benefit from state or utility energy efficiency programs.
- Stronger coordination among housing and energy agencies in recognition of the shared goals of advancing energy efficiency and preserving affordable rents at income-qualifying multifamily properties.
Treating NOAH as a Distinct Program Target
NOAH properties represent the largest share of affordable multifamily housing across much of the region. They are home to millions of renters who deserve to benefit from healthier buildings, lower energy bills, and more resilient communities. Recognizing NOAH as its own market segment allows states and utilities to design programs that better reflect the realities of these properties – and dramatically expands access to energy-saving investments.
The innovative programs highlighted in NEEP's white paper demonstrate that effective solutions already exist. By designing programs to meet the realities of NOAH properties – including flexible eligibility, accessible financing, technical assistance, and strong tenant protections – states and utilities can bring energy efficiency to the buildings where millions of low- and moderate-income renters already live. And in doing so, they can help ensure that these homes remain affordable for years to come.
