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Naturally Occurring Affordable Housing (Rental or Ownership)

Naturally Occurring Affordable Housing (NOAH) refers to housing that remains affordable without government subsidies or Affordability Mechanisms. These units are affordable due to factors such as location, age, or market conditions.

Under Proposition 123, local governments may count NOAH units toward their affordable housing growth commitment if they are newly built, converted, or preserved after the commitment filing date.

  • Newly Built: Brand-new construction units that are naturally affordable, without any Affordability Mechanism.
  • Newly Preserved: Existing units maintained as affordable through repairs, renovations, or interventions to prevent market-rate conversion, without any Affordability Mechanism.
  • Newly Converted: Former non-residential buildings (e.g., offices, hotels, industrial spaces) or high-cost units transitioned into naturally affordable housing, without any Affordability Mechanism.

Counting NOAH Units

To count toward Proposition 123 Commitments, NOAH units must be:

  • Newly added to a jurisdiction’s housing stock after the date of a jurisdiction’s commitment filing.
  • Affordable at or below 60% AMI for rental units or 100% AMI for ownership units by the end of the commitment cycle.
  • Naturally affordable without Affordability Mechanisms.
  • Meets Affordability Thresholds at the time of identification, with confirmation at the end of the commitment cycle that they remain within Affordability Thresholds. 

Identifying NOAH Units

Jurisdictions may consider the following approaches to identify NOAH units, recognizing that additional methods may also be appropriate:

  • Rental: Utilize lease records, rental listings, rent rolls, regional housing reports, third-party reports and analytical products, or similar verifiable data sources to identify NOAH rental units affordable to those at 60% AMI and below.
  • Ownership: Utilize historical and current sales data, local assessor databases, buyer loan data, regional housing reports, third-party reports and analytical products, or similar verifiable data sources to identify NOAH ownership units affordable to those at 100% AMI and below.

The method to count and identify NOAH is to calculate the affordable home price to a household at 100% AMI and calculate the affordable rent price to a household at 60% AMI, and then use those prices to identify units in a database such as the MLS, assessor’s office, CoStar, or other sources for home sales and rental information:

  • To identify NOAH ownership properties, calculate the price of a home that would be affordable to a household at 100% AMI based only on Principal and Interest (do not include taxes and insurance) - that means that Principal and Interest combined would be equal to or less than 30% of monthly income for the 100% AMI household.
    • You may choose to use the different AMIs for different household sizes to calculate affordable prices for homes with different sizes/bedrooms. 
    • There is no need to verify the actual income of those who purchased a home.
  • To identify NOAH rental properties, calculate the affordable monthly rent for a household at 60% AMI, based solely on the monthly rent (do not include utilities, lot rent, or anything other similar costs) - that means that the monthly rent would be equal to or less than 30% of monthly income for the 60% AMI household. 
    • There is no need to verify the actual income of renters.
  • Documentation should be submitted through the compliance portal and should include: 
    • Your calculations of affordable home and rental prices, including:
      • The AMIs used in your calculations
      • The mortgage interest rate average for your compliance period
      • The estimated median down payment percentage
    • A spreadsheet from the data source(s) you used that shows the NOAH units you’ve identified, including: 
      • Address 
      • Sale date / rent date
      • Sale price / monthly rent
      • Number of bedrooms
      • Any other information relevant to the units you’ve identified for compliance purposes
  • Affordability needs to be verified at the end of the compliance term (which, for NOAH purposes, will be November 1, 2026), meaning that you need to make sure the NOAH units you’ve identified haven’t been re-sold or rented-again at a price higher than your calculated affordable prices.

Useful Data Sources for Identifying NOAH

Local Assessor’s Office / Tax Records
CoStar
MLS Databases (REcolorado, Colorado Real Estate Network)

Additional Supporting Resources

Housing Needs Assessment
CHFA Market Feasibility
State Demography Office

Compliance Submission

When submitting NOAH units for compliance, jurisdictions must confirm that:

  • No Affordability Mechanism is in place for the unit.
  • The unit is a new addition to the jurisdiction’s housing stock after the commitment filing date.
  • The unit has remained within Affordability Thresholds and has not been rented or sold above Affordability Thresholds by the end of the Commitment Cycle. Documentation for this will be accepted starting November 1 of the final cycle year. This documentation may include:
    • Updated rental data or lease agreements (without personal data).
    • Property sale records to verify ownership affordability.
    • Market data comparisons demonstrating continued affordability.

This form should be used to report problems or issues with this website. Questions pertaining to a program or service provided by DOLA should be addressed to contact information located on the specific program pages.

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