How to Use State and Local Fiscal Recovery Funds for Affordable Housing Production and Preservation
Introduction
State and Local Fiscal Recovery Funds for Affordable Housing Production and Preservation represent one of the most significant opportunities in recent U.S. history to address the nation’s deepening housing crisis through direct federal support. Authorized under the American Rescue Plan Act (ARPA) of 2021, these funds provided over $350 billion in unrestricted aid to state, territorial, tribal, and local governments — with explicit flexibility to invest in affordable housing as both an economic recovery tool and a social equity imperative.

As cities and counties grapple with rising homelessness, escalating rents, aging public housing stock, and persistent racial disparities in homeownership, the strategic use of State and Local Fiscal Recovery Funds for Affordable Housing Production and Preservation has become not only permissible but essential.
This summary explores how governments can legally, effectively, and equitably deploy these resources to build new units, rehabilitate existing structures, prevent displacement, and strengthen community resilience — ensuring that every dollar spent today lays the foundation for long-term stability.
Understanding the Opportunity: Why Use State and Local Fiscal Recovery Funds for Affordable Housing Production and Preservation?
The need is urgent. According to the National Low Income Housing Coalition, there is a shortage of over 7 million affordable rental homes for extremely low-income households in the United States. In nearly every major city, rent burdens exceed 50% of income for more than half of renters earning below the area median. At the same time, decades of underinvestment have left public housing infrastructure in disrepair — the Department of Housing and Urban Development (HUD) estimates a backlog of $70+ billion in unmet capital needs across federally assisted properties. The State and Local Fiscal Recovery Funds were designed to counteract pandemic-driven economic shocks, but their scope extends far beyond immediate relief. The U.S. Treasury explicitly permits recipients to use these funds for “investments in water, sewer, or broadband infrastructure; health services; behavioral healthcare; and addressing the negative economic impacts of the pandemic — including on workers and businesses.” Crucially, this includes affordable housing development and preservation, especially when linked to job creation, public health, or economic revitalization. When we consider State and Local Fiscal Recovery Funds for Affordable Housing Production and Preservation, we are not just talking about constructing buildings — we are investing in health outcomes (stable housing reduces ER visits), education (children in stable homes perform better), workforce participation (housing near transit enables employment), and racial justice (Black and Latino households face systemic barriers to homeownership). By aligning housing investments with broader recovery goals, jurisdictions can meet federal compliance requirements while delivering transformative impact. Moreover, unlike traditional HUD grants, which come with rigid program rules and competitive applications, State and Local Fiscal Recovery Funds offer unprecedented autonomy. Recipients determine priorities based on local conditions — making them ideal for tailored, data-driven interventions that reflect community needs. Eligibility and Compliance: How State and Local Fiscal Recovery Funds for Affordable Housing Production and Preservation Align with Federal Rules To ensure responsible use, the U.S. Department of the Treasury issued detailed guidance outlining eligible uses of ARPA funds. For housing, two key criteria must be met:- The activity must respond to the public health emergency or its negative economic impacts, and
- It cannot replace routine government spending (i.e., it must be “supplemental,” not “supplanting”).
- Building permanent supportive housing for people experiencing homelessness — directly tied to health and safety.
- Rehabilitating deteriorating multifamily units occupied by low-income tenants — preventing displacement due to uninhabitable conditions.
- Providing gap financing for developers building affordable units in high-cost markets — where private capital alone cannot close funding gaps.
- Supporting homeownership programs for first-time buyers from marginalized communities — addressing long-standing wealth gaps exacerbated by the pandemic.
- Environmental reviews (under NEPA),
- Labor standards (Davis-Bacon prevailing wage),
- Civil rights protections (Fair Housing Act, Title VI),
- And reporting obligations via the Reporting Portal for State and Local Fiscal Recovery Funds.
Strategic Investment Areas: Where to Direct State and Local Fiscal Recovery Funds for Affordable Housing Production and Preservation
Not all housing investments yield equal returns. To maximize impact, jurisdictions should prioritize projects that combine affordability, sustainability, location efficiency, and community engagement. Key strategic areas include:1. Preserving Existing Affordable Housing Stock
Many of the nation’s most vulnerable renters live in privately owned, unsubsidized buildings constructed between 1960 and 1980 — often called “naturally occurring affordable housing” (NOAH). These properties are increasingly at risk of being sold, renovated, and repositioned into market-rate units. Using State and Local Fiscal Recovery Funds for Affordable Housing Production and Preservation allows governments to acquire or provide grants to preserve these units — avoiding displacement and maintaining neighborhood diversity. For example, a city could use ARPA funds to purchase a 50-unit NOAH property facing foreclosure, then transfer ownership to a nonprofit or land trust with enforceable affordability covenants lasting 30+ years.2. Accelerating New Construction Through Gap Financing
Even with tax credits and subsidies, many affordable housing developments face funding shortfalls. State and Local Fiscal Recovery Funds for Affordable Housing Production and Preservation can fill critical gaps — particularly for projects serving extremely low-income populations (≤30% AMI), supportive housing, or mixed-use developments with ground-floor services. Funds may be used for:- Land acquisition,
- Predevelopment costs (planning, engineering, legal fees),
- Hard and soft construction costs,
- Utility extensions,
- Or developer fee support.
3. Supporting Homelessness Prevention and Rapid Re-Housing
Chronic homelessness surged during the pandemic. State and Local Fiscal Recovery Funds for Affordable Housing Production and Preservation can finance:- Permanent supportive housing (PSH) with wraparound services,
- Transitional shelters with move-in readiness programs,
- Security deposit and rental assistance to prevent evictions,
- Or landlord incentives to accept vouchers.
4. Rehabilitating Public and Federally Assisted Housing
Public housing authorities manage over 900,000 units nationwide, many of which suffer from deferred maintenance. ARPA funds can supplement HUD’s Capital Fund program to repair roofs, plumbing, HVAC systems, and accessibility features — improving living conditions and extending asset life. Additionally, funds can support Rental Assistance Demonstration (RAD) conversions — helping public housing agencies access private capital by transitioning to long-term Section 8 contracts.5. Expanding Homeownership Opportunities
While much focus is on rentals, State and Local Fiscal Recovery Funds for Affordable Housing Production and Preservation can also support homeownership for underserved groups. Eligible uses include:- Down payment and closing cost assistance,
- First-time homebuyer counseling,
- Acquisition and rehabilitation of vacant or foreclosed homes for resale at below-market rates,
- Or establishing community land trusts to ensure long-term affordability.
Implementation Models: Proven Ways to Deploy State and Local Fiscal Recovery Funds for Affordable Housing Production and Preservation
Success depends not just on what you fund, but how you deliver it. Jurisdictions have adopted several effective models:1. Direct Grants to Nonprofit Developers
Cities like San Francisco and Atlanta established competitive grant programs using ARPA funds to award multi-million-dollar awards to experienced nonprofits focused on deeply affordable housing. Applications required proof of community input, anti-displacement safeguards, and green building standards.2. Loan Funds and Revolving Capital Programs
Some states created low-interest loan pools — e.g., Minnesota’s $100M ARPA-backed Affordable Housing Loan Fund — allowing developers to borrow at favorable terms, repay over time, and recycle capital for future projects.3. Land Banking and Acquisition Trusts
Municipalities used funds to purchase vacant lots or distressed properties, then transfer them to mission-driven builders at reduced cost. This reduces overall project expenses and prevents speculative flipping.4. Partnerships with Community Development Financial Institutions (CDFIs)
CDFIs act as intermediaries, deploying ARPA funds efficiently while providing technical assistance to small developers. Their track record in underserved markets makes them ideal partners in advancing State and Local Fiscal Recovery Funds for Affordable Housing Production and Preservation.5. Incentive Programs for Private Landlords
To expand supply quickly, some counties offered ARPA-funded incentives to landlords who agree to rent to voucher holders or keep rents capped for three+ years. These “supply-side” strategies complement construction efforts.Equity and Community Engagement: Ensuring State and Local Fiscal Recovery Funds for Affordable Housing Production and Preservation Benefit Those Most in Need
A core principle of ARPA is equity. The Treasury encourages recipients to prioritize populations disproportionately impacted by the pandemic — including Black, Indigenous, Latino, LGBTQ+, disabled, and formerly incarcerated individuals. To uphold this commitment, jurisdictions must embed equity into every phase:- Data-driven targeting: Use disaggregated demographic data to identify neighborhoods with the greatest need.
- Community-led planning: Hold public hearings, work with tenant unions, and involve residents in design decisions.
- Local hiring and contracting: Require developers to hire locally and award subcontracts to minority-owned businesses.
- Anti-displacement safeguards: Pair new development with tenant protections, right-to-counsel programs, and relocation assistance.
Monitoring, Reporting, and Long-Term Sustainability
All recipients must report expenditures semi-annually through the U.S. Treasury’s portal, detailing:- Amount spent,
- Project description,
- Number of units produced or preserved,
- Target population served,
- And expected completion date.
- Dedicated local revenue streams (e.g., housing levies),
- Zoning reforms to allow density near transit,
- Partnerships with state housing finance agencies,
- And advocacy for renewed federal investment.