Housing Policy Is Climate Policy
The 21st Century ROAD to Housing Act is a reminder that housing policy is climate policy. The bipartisan Act is, first and foremost, a much-needed vehicle for housing supply and housing finance. It addresses the significant under-supply of housing that has driven up prices and created deep affordability challenges for millions of Americans. But the Act will also affect our climate, whether directly or indirectly, for better or worse, because how and where we build housing significantly affects climate emissions.
I describe below the provisions of the Act that may have climate impacts, depending on how the Act is implemented. Most of the provisions remove regulatory barriers, create new authorities, or authorize pilot programs, but they do not, by themselves, mandate climate-positive outcomes; several also depend on appropriations that the Act does not provide.
Whether they translate into lower emissions and more resilient homes will largely be determined by agency rulemaking and state and local implementation. That is precisely why this Act deserves the attention of both housing and climate advocates: it opens real opportunities, and realizing its climate benefits will require sustained, coordinated engagement as federal agencies write the rules and state and local governments decide how to act on them.
Energy Use in Buildings
There are several provisions in the Act that will directly or indirectly impact energy use in buildings.
The Whole-Home Repairs program (Sec. 202) is designed to directly improve the energy efficiency of affordable homes if Congress appropriates funding. The Act directs HUD to provide grants to state and local implementing organizations to administer whole-home repairs, including energy and water efficiency, resilience, and weatherization work, for low-income homeowners and small landlords. The program is designed to overcome a key challenge to weatherizing housing: the need to address deferred maintenance before energy-efficiency upgrades can be implemented. The Act tackles this challenge by bundling repairs with weatherization and encouraging coordination with the DOE’s Weatherization Assistance Program at both the federal and grantee levels.
One provision (Sec. 301) will directly and negatively impact energy efficiency in manufactured housing, which is among the largest sources of unsubsidized affordable housing in the country. The Act nullifies a 2022 Department of Energy (DOE) final rule mandating energy conservation standards for manufactured housing based on the 2021 International Energy Conservation Code (IECC). Instead, the Act gives HUD sole authority to adopt energy-efficiency standards without specifying a minimum level of stringency. This will likely result in standards less stringent than the IECC and higher utility costs for residents.
That weaker standard also limits the benefit of a second manufactured housing provision: the PRICE Act, which funds the repair or replacement of older homes. The PRICE Act (Sec. 304) authorizes a seven-year competitive grant program to support improvements to manufactured housing communities. Eligible uses expressly include weatherization and upgrades to reduce utility costs. For the oldest units — those built before June 15, 1976, when federal construction and safety standards took effect — grant funds may be used only to replace them, not to repair or modernize them, and those replacement units need only meet whatever standard HUD adopts under the provision described above. As with the other programs described here, these benefits depend on appropriations the Act does not itself provide, and weatherization is one of several eligible uses rather than a required focus.
The Act also opens the door to more energy-efficient housing by expanding the number of public housing units that can participate in the Rental Assistance Demonstration (RAD) program (Section 212). RAD supports the recapitalization of aging public housing by providing long-term rental assistance contracts that can be used to secure private financing for major building upgrades. Current RAD guidance requires participating properties to use the most energy- and water-efficient options that are financially feasible and cost-effective, as determined by a Capital Needs Assessment. Furthermore, many RAD properties seek Low Income Housing Tax Credits (LIHTC) from housing finance agencies (HFA) as part of the recapitalization financing stack. Many HFAs incentivize high-performing construction, including renewable energy, to qualify for tax credits.
Location Efficiency
The Act includes several tools to promote infill, compact housing development. Encouraging compact development can result in significant reductions in carbon emissions. RMI estimates that state-level land-use reform to encourage compact development could reduce annual U.S. pollution by 70 million tons of CO2 equivalent by 2033, with about half of that reduction attributable to reduced vehicle travel. The Act provides incentives and technical assistance to support such state-level reforms, though it does not itself require them.
The Act seeks to encourage multifamily development on smaller, urban lots by helping local governments legalize "point-access block" (single-staircase) residential buildings up to 6 stories tall (Sec. 102). The Act directs HUD to create language and technical guidelines to assist localities in drafting single-stair codes. By enabling localities to eliminate the requirement for a second staircase and long hallways, the guidelines could allow developers to build more efficiently on small, narrow urban lots that were previously difficult to develop.
The Act also directs HUD to support state and local governments in reforming zoning requirements that restrict the availability of a range of housing options, including higher-density and transit-oriented housing (Sec. 107). HUD must publish guidelines and best practices, including recommendations to eliminate regulatory barriers, such as legalizing multifamily units, lifting bans on Accessory Dwelling Units (ADUs), reducing minimum lot sizes, increasing building heights, eliminating or reducing mandatory parking minimums, and allowing upzoning in areas immediately surrounding public transit hubs. HUD must also develop state policy frameworks that include best practices to encourage local governments to adopt regulatory reforms.
The Act streamlines and modernizes federal environmental and administrative reviews for housing-related projects (Sec. 206). Infill projects consisting of new construction, rehabilitation, or development of residential housing units are categorically excluded from certain costly and time-consuming review requirements. The streamlined review categories also include the conversion of existing office buildings into residential units, a pathway that adds housing in developed, typically transit-served commercial areas where the benefits of location efficiency are strong. Faster, more predictable approvals should encourage increased development. Importantly, the Act preserves certain review requirements related to ensuring that housing is not sited in areas at risk of flooding.
The Act also supports location-efficient housing by creating a new HUD grant program to assist states, localities, and regional planning agencies in planning and implementing activities that promote various types of housing strategies (Sec. 207). The language is explicit that grant funds may be used to plan and implement strategies to advance “sustainable or location-efficient community development goals” and “increase access to public transportation,” among other eligible activities. Of course, the location-efficient and transit-access language is statutorily authorized but not statutorily required, meaning HUD can prioritize it or not, depending on the administration’s policies.
Resilience
The Act includes several provisions that support housing resilience. The most consequential of these is the Reforming Disaster Recovery Act (Sec. 504), which authorizes the Community Development Block Grant–Disaster Recovery (CDBG-DR) program for three years and establishes a permanent Office of Disaster Management and Resiliency within HUD to administer it. CDBG-DR is the federal government's primary tool for long-term housing recovery after federally declared disasters, but it has historically operated as an ad hoc appropriation that requires a separate rulemaking process for each disaster, resulting in years-long delays in delivering recovery funds to affected residents. Codifying the program and creating a permanent administrative home should accelerate post-disaster housing recovery and institutionalize resilient, mitigation-oriented rebuilding rather than rebuilding to pre-disaster vulnerability standards.
The Act also creates a Temperature Sensor Pilot Program (Sec. 106), authorizing HUD to provide grants to public housing agencies and owners of federally assisted rental housing to install temperature sensors in dwelling units, with tenant permission, to ensure compliance with temperature-related housing quality standards. Indoor heat exposure is an increasingly serious resilience concern in affordable housing, as summers lengthen and intensify, and many older buildings were designed for climates that no longer exist. The pilot is modest in scale, but it provides a structured way to document where extreme temperatures put residents at risk, which can, in turn, justify investment in cooling, envelope upgrades, and heat pumps.
Several provisions discussed earlier also carry resilience benefits. The PRICE Act’s replacement of pre-code manufactured homes (Sec. 304), for example, can yield more storm-resistant units in one of the most climate-vulnerable segments of the housing stock, and the Whole-Home Repairs program (Sec. 202) funds resilience work alongside weatherization.
Finally, the Act streamlines the environmental review process for voluntary acquisitions of disaster-impacted properties located in floodways, floodplains, or other high-risk areas — placing such acquisitions into a faster review tier while preserving the cross-cutting environmental and floodplain review requirements that protect against poor siting decisions. This makes managed relocation programs administratively easier to implement where they exist, though the Act does not itself authorize or fund acquisition programs.
As with the other provisions described above, the resilience benefits described here depend on appropriations the Act does not provide (Sec. 1202 authorizes no additional funds), on HUD prioritizing resilience in its implementation choices, and on state and local grantees using the new authorities at scale. The Office of Disaster Management and Resiliency, in particular, is only as effective as its staffing and budget allow.
The Work Ahead
For housing and climate advocates, the climate impact of the 21st Century Road to Housing Act will be determined over the coming months and years through federal rulemakings and the model codes that states and localities choose to adopt. That makes implementation the work that matters. The Act provides housing and climate advocates with a shared, concrete agenda. At the federal level, that means engaging agencies as they write the rules and design the programs. At the state and local level, it means shaping how those rules are translated into codes, zoning, and projects — so that the Act delivers both its climate benefits and the affordable homes our communities need.