It was in the early 2000s or even 2010 that an acronym NOAH was adopted as a means of denoting rental units provided in the private market. Natural Occurring Affordable Housing refers to unsubsidized rental housing that remains relatively affordable to lower- and moderate-income households because of factors such as age, condition, location, or local market dynamicsโrather than because of government subsidies, rent restrictions, or dedicated affordable-housing programs.
Policy groups, cities, and housing advocates began tracking NOAH stock once people in the business realized that it often represents a large share of a regionโs affordable units. And since the low pricing is often, at least partly, due to aging structures it can be a product which attracts renovation, triggering a reset of rents to a higher rate.
Here is an example of a proposal to maintain NOAH properties as it appears in the city of Plymouth (MN) Housing Plan (Page 12 of 15 Chapter 4 Plymouth Housing Plan – 2040):
To that end, the City and HRA will carry out the following actions:
๏ปฟ๏ปฟCreate and maintain a list of NOAH properties located in the city;
๏ปฟ๏ปฟConsider the establishment of a dedicated funding source to assist NOAH properties that are being considered for purchase in order to maintain their affordability:
๏ปฟ๏ปฟCreate and maintain a list of all publically subsidized properties in the city along with relevant information about the property:
๏ปฟ๏ปฟContinue to have conversations with owners of publically subsidized and
NOAH properties to stay abreast of their future plans;Consider amending the City’s Rental Licensing Ordinance to provide for a 90 day notification to the City and residents of the pending sale of NOAH
property;Consider a policy that would allow tenants in “good standing” who reside at a NOAH property that has been sold to remain at the property for up to 12 months even if rental criteria for tenancy has changed that makes them no longer eligible to rent at the property; and
Research potential programs that may provide a benefit to the Sun Valley mobile home park residents.
Conceptually, this policy piece starts from a fundamental mispositioning of what housing actually is.
Housing is not an accumulation of physical buildings. A rental agreement is a month-to-month or year-to-year transaction between an owner and a renter, shaped by the circumstances of both parties and the condition of the property at that particular moment. Time alone changes a property. Each party may improve upon or fall short of their obligations. People move when a property no longer meets their needs or expectations. Landlords may change their expectations about renting based on their investment, their circumstances, or simply their willingness to take on the task.
Rental housing within a community is therefore not a fixed inventory of units. It is the general availability, at any given time, of properties and of people willing to act as landlords, meeting the expectations and needs of people who, for whatever reason, prefer to rent rather than own.
Once you try to isolate and count each NOAH property, you begin to remove the market concept of voluntary exchange. You turn a fluid market into a forced obligation: one designated unit for one designated purpose. And when subsidies come with obligations and continuing commitments, you are creating a different marketโnot one that emerges naturally through the decisions of owners and renters.
The same problem arises when we impose demands on renters. We begin to interfere with the very decision-making process through which people ordinarily adjust their housing choices to their circumstances.
It is like taking one story out of an entire market and then trying to contort the market around that story.
But naturally occurring affordable housing was already being created before anyone gave it the name NOAH. The market process was doing what it is supposed to do: constantly adjusting as owners, renters, properties, prices, expectations, and circumstances changed.
There will always be individuals who temporarily find themselves caught in a housing squeeze because their circumstances change unexpectedly. That is where targeted, temporary relief makes senseโhelping the individual through the squeeze until their situation sorts itself out.
The mistake is turning that temporary condition into a permanent category of housing and then attempting to redesign the market around it.

































































































































