Naturally occurring affordable housing (NOAH) is privately owned rental housing that offers relatively lower rents but does not participate in a federal, state, or local housing subsidy program. These lower rents are often tied to building age, location, physical condition, and deferred capital needs. Across the Northeast and Mid-Atlantic, this housing stock is an important source of lower-cost rental housing, particularly in older multifamily buildings in urban areas where housing affordability pressures are high.
For state and utility energy efficiency programs, driving uptake at NOAH multifamily properties has historically been difficult. Comprehensive retrofits in these buildings are expensive and often require owners to navigate major project complexity, limited access to capital, thin operating margins, deferred maintenance, and tenant-related concerns such as disruption, cost shifting, and displacement risk. These factors make retrofits harder to plan, underwrite, finance, and implement in NOAH properties than in owner-occupied housing or subsidized affordable housing with clearer financing and compliance structures.
This paper examines how statewide energy efficiency and housing retrofit programs in New York, Connecticut, Massachusetts, and Maryland are adapting to low-income multifamily rental properties in markets with significant NOAH stock. The analysis uses a qualitative case study approach that draws on program documents, regulatory filings, evaluation materials, and interviews with state and utility program administrators. Case studies illustrate how statewide programs operate in local housing markets with different building typologies, ownership structures, and affordability pressures.
