HOUSING IMPACT ANALYSIS Figure 3-2 Housing Impact Analysis Trigger Values 0 200,000 400,000 600,000 800,000 1,000,000 1,200,000 1,400,000 1,600,000 1,800,000 2,000,000 NUMBER OF HOUSES IMPACTED (per year)$100 million/year standard for total impact Modified standard for housing impact $0 $50 $100 $150 $200 $250 $300 $350 $400 $450 $500 IMPACT PER HOUSE (per year) Using this Figure, if the point corresponding to average cost impact of a rule and number of affected housing units lies above and to the right of the dashed line, an in-depth analysis is required, even if the point lies below the heavy line (i.e., total impact is less than $100 million). There are some serious issues with this method. Even if the underlying principle is acceptable, it could prove arbitrary or difficult to select an appropriate dashed line for the modified standard. The way the groups are defined could affect the sensitivity of this procedure and change the results. Unfortunately, the approach becomes unwieldy or complex to implement when many different groups are affected by different amounts. Assessing the groups one at a time seems incomplete while aggregating them and using average impacts masks the extremes and is essentially the current approach. Simultaneous evaluation of multiple groups without aggregation could be very difficult.9 3.2.3 Standard Based on Large Impact in a Small Market Area. Triggers that compare overall impact to a fixed dollar threshold do not addr
ess the possibility of
substantial impacts on homes in a
small market area. Rules such
as designation of critical habitat
for an endangered species might fall in this cate
gory, imposing relatively large costs on homes in
9
In principle, any number of groups could be used to develop a "cumulative impact" curve, showing how many
households have impact greater than or equal to any given value. Then the cumulative impact curve would
have to be compared to the criteria (e.g., the dashed
line in the Figure). If the
cumulative impact curve rose
above the criteria curve at any point, then th
e in-depth analysis would be triggered.
53
H
OUSING
I
MPACT
A
NALYSIS
a small geographic area. A separate test for co
ncentrated impacts could be devised to address
this. So, for example, an in-depth HIA could
be triggered if impacts averaging more than a
specified amount (say, $1,000 per unit or 0.5 per
cent of value) are expe
rienced by at least a
minimum number of units per year (say, 10,000) in
a market area or areas up
to a given size (say,
containing up to 5,000,000 housing units). If so,
then an in-depth HIA would be required to
accompany the RIA. The problem is that data n
eeded to make this determination appear to go
beyond what will usually be available in a RIA.
3.2.4
Standard Based on Disproportionate Impa
ct on Lower-Income
or Rental Housing.
Concern about housing affordability is commonly
driven by concerns a
bout the inability of
lower-income households to pay the cost of d
ecent housing along with all the other costs of
ordinary living. The triggers id
entified so far do not discriminate
between impacts on entry-level
homes or apartments and impacts on luxury housi
ng, yet many would consider a regulation that
adversely affects inexpensive housing to be more socially detrimental than a regulation that has a
comparable impact on luxury homes. For this tri
gger, the regulation is assessed specifically for
its impact on consumer costs of lower-cost
housing (for example, housing occupied by
consumers below median income). If the total
impact on consumer costs of these housing units
exceeds a fixed cutoff (such as $50 million per year),
then an in-depth HIA would be triggered.
However, compliance costs are usually based on
the physical characteristics of the unit, so
determining cost as a function of
occupant income instead could
be difficult. Similarly, given
that incomes of renter households are generally below incomes of owner-occupants, and in view
of the societal interest in facilitating the tran
sition into homeownership, a special trigger based
specifically on impacts on re
ntal housing might be warranted. So, for example, even where total
housing impacts do not reach $100 million, if they
are substantial and are concentrated in the
rental sector then an in-depth
HIA would be triggered. A se
parate trigger for rental housing
impacts could be used for this purpose.
While the foregoing sec
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