HomeMy WebLinkAbout08-18-2025 - Study Session Agenda Packet STUDY SESSION AGENDA
CITY COUNCIL MEETING
CITY OF WHEAT RIDGE, COLORADO
Monday, August 18, 2025
6:30 p.m.
This meeting will be conducted as a virtual meeting, and in person, at: 7500 West 29th
Avenue, Municipal Building, Council Chambers.
City Council members and City staff members will be physically present at the
Municipal building for this meeting. The public may participate in these ways:
1. Attend the meeting in person at City Hall. Use the appropriate roster to sign
up to speak upon arrival.
2. Provide comment in advance at www.wheatridgespeaks.org (comment by
noon on August 18, 2025)
3. Virtually attend and participate in the meeting through a device or phone:
Click here to pre-register and provide public comment by Zoom (You must
preregister before 6:00 p.m. on August 18, 2025)
4. View the meeting live or later at www.wheatridgespeaks.org, Channel 8, or
YouTube Live at https://www.ci.wheatridge.co.us/view
Individuals with disabilities are encouraged to participate in all public meetings
sponsored by the City of Wheat Ridge. The City will upon request, provide auxiliary
aids and services leading to effective communication for people with disabilities,
including qualified sign language interpreters, assistive listening devices, documents
in Braille, and other ways of making communications accessible to people who have
speech, hearing, or vision impairments. To request auxiliary aid, service for effective
communication, or document in a different format, please use this form or contact
ADA Coordinator, (Kelly McLaughlin at ada@ci.wheatridge.co.us or 303-235-2885) as
soon as possible, preferably 7 days before the activity or event.
Public Comment on Agenda Items
1. 2025 Private Activity Bond Allocation
2. Proposition 123 Update and Expedited Review Process
3. DRCOG Regional Housing Needs Assessment
4. Housing Updates
5. Building Code Update
6. Staff Report(s)
7. Elected Officials’ Report(s)
ITEM NO. 1
Memorandum
TO: Mayor and City Council
FROM: Patrick Goff, City Manager
DATE: August 18, 2025
SUBJECT: 2025 Private Activity Bond Allocation
ISSUE:
The City of Wheat Ridge has received an allocation of $2,080,116 for the purpose of
issuing Private Activity Bonds (PABs) in 2025 under the state ceiling imposed by the Tax Reform Act of 1986. Staff recommends assigning the City’s allocation to Foothills
Regional Housing (FRH) which has agreed to issue PABs for the Ridge affordable
housing mixed-use project at approximately Ridge Road and Miller Street.
PRIOR ACTION:
The City of Wheat Ridge has traditionally assigned the City’s PAB allocation to either the
Colorado Housing and Finance Authority (CHFA) or the Metro Mayors Caucus for single
family mortgage revenue bonds. The last allocation assignment was approved in 2011
to CHFA. Since 2011, neither CHFA nor the Metro Mayors Caucus were accepting applications for allocations because of the decline in the financial markets and the
impact that has had on investor interest in PAB. Between 2012 and 2018, the City’s
allocation was relinquished to the statewide balance for distribution to applicants by the
Department of Local Affairs.
City Council assigned the City’s 2019, 2020 and 2022 PAB allocations to FRH for the
Caesar Square Apartments project, the 2021 PAB allocation for the Allison Village
affordable housing project in Arvada and the 2023 and 2024 PAB allocation to The Ives
affordable housing project.
FINANCIAL IMPACT:
There is no direct financial impact to the City of Wheat Ridge. However, injecting PAB
capital into the community has a direct impact on real estate, construction, and
financial markets by stimulating economic activity and jobs.
BACKGROUND:
PABs are tax exempt bonds designed to offer low-cost financing to private sector
borrowers for projects that create jobs and expand the tax bases of local communities. PABs may be used to finance a broad array of community development projects
including housing, manufacturing, higher education, infrastructure, and environmental projects. The bonding authority which allows the issuance of PABs is Volume Cap,
created under the federal Tax Reform Act of 1986. The federal government allocates a
Study Session Memo – 2025 PAB Allocation
August 18, 2025
Page 2
maximum amount of Volume Cap use to each state annually, based on population.
Per Colorado statute, the Department of Local Affairs (DOLA) administers the state’s
allocation of Volume Cap. Under the statute, 50 percent of Colorado’s allocation is given to five statewide authorities, with DOLA deciding the proportional allocation of each.
As a political subdivision of the state and an authority, CHFA is eligible to receive an
allocation of Volume Cap, which it uses to issue tax exempt bonds throughout
Colorado. CHFA uses its annual allocation to issue tax exempt bonds for single family mortgages, multifamily rental developments, manufacturers, and mortgage credit
certificates.
The remaining 50 percent of annual Volume Cap is allocated to local issuing authorities.
A local issuing authority consists of “any city, town, county, or city and county which has a population in any year which would result in the local issuing authority having any
allocation of the state ceiling in excess of one million dollars” (CRS 24-32-1702-8). After
allocating Volume Cap to local issuing authorities, any remaining balance becomes
available by application to the statewide balance.
RECOMMENDATIONS:
Staff recommends assigning the City’s PAB allocation to FRH for the Ridge affordable
housing mixed-use project at approximately Ridge Road and Miller Street.
ATTACHMENTS:
1. Memo from FRH, dated June 28, 2025
11941 West 48th Avenue, Wheat Ridge, CO 80033, Phone: 303.422.8600 ∙ Fax: 303.422.3229
Admin. Fax 720.974.5808 Colorado Relay 711 ∙ Web: www.foothillsrh.org
June 28, 2025
Patrick Goff, City Manager
City of Wheat Ridge
7500 W 29th Ave
Wheat Ridge, CO 80033
RE: Request for 2025 Private Activity Bond Cap to Support Affordable Housing
Dear Mr. Goff,
The Jefferson County Housing Authority d/b/a Foothills Regional Housing (FRH) is the housing authority
serving Colorado’s 774 square mile Jefferson County. FRH provides housing opportunities including
affordable apartments, rental assistance vouchers, emergency home repairs, housing navigation, new
development and redevelopment in both incorporated and unincorporated areas of Jefferson County.
Our mission is to create vibrant, stable communities in areas of opportunity, via bold and strategic
initiatives, and to provide families and individuals with housing options driven by compassion and
respect throughout Jefferson County. FRH’s portfolio includes 23 rental properties with 1300 units. Our
mission is not achievable without the partnership of entities such as the City of Wheat Ridge.
FRH is currently working through pre-development activities to ultimately produce new affordable
housing on a site within the City of Wheat Ridge and intends to submit an application to the Colorado
Housing and Finance Authority for an allocation of Low-Income Housing Tax Credits (LIHTC) as soon as
2026 (bond cap allocations can be carried forward for 3 years). This site is referred to herein as the “Ridge”
site. The Ridge site was recently purchased from the State of Colorado. It is located across the street
from a major commuter rail station (Transit-Oriented Development). This is a particularly large site and
is anticipated to be able to allow for siting of not just long term affordable residential units, but also mixed-
use space that could accommodate the co-locating of partners such as Red Rocks Community College,
Stride and Jefferson County Human Services. All residential units will be set aside for households earning,
on average, less than 60% of the Area Median Income. A site rezone would be required, as is the
demolition/remediation of existing blighted structures that is currently underway.
The city’s support of this project will directly benefit the local economy in generating likely over $50
million in construction costs alone, including many job creation opportunities. This investment will allow
FRH to secure affordability and increase housing supply by building new Transit-Oriented,
environmentally sustainable, service-enriched units in the City of Wheat Ridge. By doing so, we will
create long-term, high quality affordable assets that will serve as a welcoming place to call home for
lower-income Wheat Ridge residents for decades to come.
ATTACHMENT 1
To meet the federal requirements of the 4% LIHTC that will finance this investments, FRH requests that
the City of Wheat Ridge assign the entirety ($2,080,116) of its 2025 Private Activity Bond (PAB) cap to
FRH who is the Bond Issuer for the Ridge project. FRH has also requested and received assignments of
2022, 2023, and 2024 (pending) PAB cap from Golden and Jefferson County in an effort to continue
supporting other affordable housing needs of our jurisdiction. Additionally, FRH routinely contributes
over a million dollars towards its redevelopments by deferring developer fees and land carryback loans
as construction capital sources.
FRH is authorized under the relevant statutes, cited in the attached Assignment Resolution, to issue
housing revenue bonds as private activity bonds for this or other (third party) qualifying “projects”
within the statutory definition and FRH agrees to pay all legal costs and meet all requirements of state
and federal statutes related to this assignment and any subsequent carryforward. FRH agrees to handle
the issuance, assignment, and carryforward of any excess bond cap not utilized in a timely manner to
finance this project by assigning it other qualifying projects with a sequential preference for affordable
FRH portfolio projects (several rehab or infill projects are currently under consideration within FRH’s
affordable portfolio), City of Wheat Ridge affordable projects, Jefferson County affordable projects, and
finally Colorado affordable projects.
We look forward to the opportunity to present this request to Wheat Ridge City Council.
Sincerely,
Amy Case-Miranda
Deputy CEO
ITEM NO. 2
Memorandum
TO: Mayor and City Council
THROUGH: Patrick Goff, City Manager
FROM: Shannon Terrell, Senior Housing Planner
Jana Easley, Planning Manager
Lauren Mikulak, Community Development Director
DATE: August 18, 2025
SUBJECT: Proposition 123 Update and Expedited Review Process
ISSUE:
In 2022, Colorado voters approved Proposition 123, creating a statewide affordable
housing fund. In October 2023, the city filed a commitment with the Department of Local Affairs (DOLA) to increase the supply of affordable housing by 3% annually or 218
units within 3 years. To maintain eligibility in the second cycle (2027-2029) for Proposition 123 funding, local governments must establish an expedited review process
for qualifying affordable housing projects.
This memo provides updates on the city’s unit commitments and awarded grant funds
during the first cycle, as well as progress toward meeting the expedited review requirement. Staff are seeking council direction on implementing an expedited review
process for affordable housing developments to maintain eligibility for Proposition 123
and to secure grant funding of $50,000 from DOLA to assist with allowable planning
activities under the Local Planning Capacity grant guidelines.
PRIOR ACTION:
On September 25, 2023, council adopted Resolution 46-2023, authorizing the city to file
a commitment with the State of Colorado to increase its affordable housing supply and
become eligible for Proposition 123 funds. The city submitted its commitment in October 2023.
PROPOSITION 123 UPDATE:
In 2022, Colorado voters approved Proposition 123, creating a statewide affordable
housing fund. Governor Jared Polis signed House Bill (HB) 23-1304 Proposition 123
Affordable Housing Programs into law on June 5, 2023, which governs the use of funds jointly managed by the Department of Local Affairs (DOLA) and the Governor’s Office of
Economic Development and International Trade (OEDIT). To be eligible for Proposition
Study Session Memo – Proposition 123 Update and Expedited Review Process
August 18, 2025 Page 2
123, local governments must 1) file a commitment to increasing the number of affordable
units by 3% annually, and 2) establish an expedited review process.
In October of 2023, Wheat Ridge filed a commitment to DOLA to build 218 affordable
units by December 31, 2026. By the end of 2026, Wheat Ridge expects to have 98 units
toward our Proposition 123 commitment. Although this projected unit count falls short
of the original commitment, it does not disqualify the city from future participation. The legislation allows jurisdictions to reapply for funding during subsequent cycles. The city
would sit out for one calendar year and be eligible to reapply in 2028.
Foothills Regional Housing plans to develop two properties over the next five years, with
an estimated 350 affordable housing units in phased developments. The timelines for these projects are heavily impacted by competitive funding from Low Income Housing
Tax Credits (LIHTC), which still provide the majority of equity for affordable projects. If funded, these projects would enable the City to meet the 3% annual growth requirement
in the second cycle.
Grant Funds Awarded
Proposition 123 funds have been beneficial to our community. Since filing our commitment in 2023, DOLA has awarded almost $3 million in Prop 123 grant funds to
the city and Foothills Regional Housing, including:
- $130,000 in Local Planning Capacity funds awarded to the city to support the
implementation of OpenGov, the city’s new permitting and planning software
- $2.1 million in Land Banking funds awarded to Foothills Regional Housing for acquisition of the Ridge Road project, intended to support the future
development of 200 affordable units
- $750,000 in Concessionary Debt funds awarded to Foothills Regional Housing to support predevelopment activities on the Ridge Road project.
These investments demonstrate the financial value of ongoing participation in Proposition 123.
EXPEDITED REVIEW:
To remain eligible for the second cycle of Proposition 123 (2027-2029), local
governments must implement a codified expedited review process that guarantees a
decision on qualifying affordable projects within 90 calendar days. A final decision can include an approval or denial. The policy must be adopted before the start of the second
cycle in January 2027.
Study Session Memo – Proposition 123 Update and Expedited Review Process
August 18, 2025 Page 3
The state legislation requires that an expedited review process shall apply to affordable
housing projects that:
- Include at least 50% deed-restricted, affordable units
- Are affordable to renters earning 60% of Area Median Income (AMI)
- Are affordable to for-sale households earning 100% of AMI
Per state law, the expedited review process would apply to a portion of the city’s
application types including site plan, civil construction drawings, building permit, variances, waivers, special use permits, conditional use permits, and planned
developments. Staff are currently piloting an expedited process this fall for Phase 2 of
the Ives development in collaboration with Foothills Regional Housing. The outcome will inform how the city can improve its expedited process and refine the policy before full
compliance is required by the second cycle.
Early Adoption Incentive Program
To encourage early compliance, DOLA launched an incentive program for early adoption
of an expedited review policy. DOLA will award up to $50,000 in grant funding to local
governments that implement a state-compliant process by December 31, 2025. The funds can be spent on allowable planning activities under the Local Planning Capacity
grant guidelines. If received, the incentive funding can help cover the cost of a housing
linkage fee nexus study, which was discussed with council during the July 7 study
session.
To meet the requirements of the early adoption incentive program, the city must
implement an expedited review process by the end of this year. Staff hopes to bring
forward a resolution of intent to council in the coming months, followed by proposed
municipal code amendments in early 2026, based on outcomes from the pilot. DOLA
has confirmed that this approach satisfies the requirements of the early adoption incentive program.
RECOMMENDATIONS:
Staff recommend moving forward with a resolution stating the city’s intent to implement an expedited review policy for affordable projects by the end of 2025 to
access early adoption incentive funds and maintain eligibility for Proposition 123
funding.
NEXT STEPS
To help guide the discussion on August 18, staff is seeking direction on the following
questions:
1. Does council support implementation of an expedited review process for
qualifying affordable housing projects?
Study Session Memo – Proposition 123 Update and Expedited Review Process
August 18, 2025 Page 4
2. Does council support advancing a resolution to pursue the early adoption
incentive program?
If Council is supportive, staff will:
• Draft and present a resolution of intent for Council consideration in the coming
months.
• Finalize the expedited review process and pilot it on active FRH projects.
• Prepare and present formal municipal code amendments in early 2026.
ITEM NO. 3
Memorandum
TO: Mayor and City Council
THROUGH: Patrick Goff, City Manager
FROM: Shannon Terrell, Senior Housing Planner
Jana Easley, Planning Manager
Lauren Mikulak, Community Development Director
DATE: August 18, 2025
SUBJECT: DRCOG Regional Housing Needs Assessment
ISSUE:
On May 30, 2024, Governor Polis signed Senate Bill (SB) 24-174, the Sustainable
Affordable Housing Assistance Act, into law. The bill requires local governments to
perform a Housing Needs Assessment (HNA) that complies with the state methodology
and baseline components specified by DOLA by December 31, 2026. However, local governments are exempt from this requirement if they participate in a state-compliant
Regional Housing Needs Assessment (RHNA).
While the city already has an HNA as part of its Affordable Housing Strategy and Action
Plan (AHS), this plan does not meet all the requirements of the state bill. To meet the state requirements, the city has two options:
1. Revise and update the AHS by 2026, or
2. Participate in DRCOG’s RHNA.
The goals of the August 18 study session are to review the requirements of SB24-174, review DRCOG’s Regional Housing Needs Assessment (RHNA), and seek Council
direction on participating in DRCOG’s RHNA to comply with SB24-174.
PRIOR ACTION:
The city’s Affordable Housing Strategy and Action Plan was adopted by city council on
January 9, 2023. SB24-174 has not been discussed with council.
LEGISLATIVE CONTEXT:
On May 30, 2024, Governor Polis signed Senate Bill (SB) 24-174, the Sustainable
Affordable Housing Assistance Act, into law. The bill contains three main components:
1. Housing Needs Assessments (HNA)
2. Housing Action Plans (HAP)
Study Session Memo – DRCOG Regional Housing Needs Assessment
August 18, 2025 Page 2
3. Water Supply and Strategic Growth Elements
This memo focuses on the housing-related components of the state bill, and specifically
on the Housing Needs Assessment (HNA). Under SB24-174, local governments must
complete a state-compliant Housing Needs Assessment (HNA) or participate in a
Regional Housing Needs Assessment (RHNA) by December 31, 2026. In addition, local
governments must adopt a Housing Action Plan (HAP) by January 1, 2028. Both components must follow state methodology, meet baseline requirements, receive
approval from the Department of Local Affairs (DOLA), and be updated every six years.
The city has an existing HNA and HAP as part of the Affordable Housing Strategy and
Action Plan (AHS), which is intended to be a 5-year workplan with a horizon of 2028. The plan was adopted prior to the passage of SB24-174, but the bill allows a pathway
for existing plans. DOLA reviewed the plan for conformance and approved the HNA for
substantial compliance. However, the AHS is missing key required elements and would
need to be updated by the end of 2026 to comply with these new state requirements.
To meet the state requirements related to the HNA, the city has two options:
1. Update the AHS by 2026, which would require staff time and funding, or
2. Participate in DRCOG’s Regional Housing Needs Assessment, which provides a
compliance pathway and gives the city more time to update the AHS at a later
date.
To meet state requirements related to the HAP, future discussion will be necessary. A
compliant HAP must be adopted by January 1, 2028. DOLA has not yet reviewed HAPs for compliance, and it is unknown if our AHS meets the HAP requirement. The HAP, or
strategy associated with an HNA, must be calibrated based on the analysis and needs
identified in the HNA, both locally and regionally. Staff anticipate that the AHS will need to be updated by 2028 to include reference to the housing needs identified in the RHNA.
DRCOG REGIONAL HOUSING NEEDS ASSESSMENT:
The Denver Regional Council of Governments (DRCOG) completed its Regional Housing
Needs Assessment (RHNA) in October 2024. The development of the Denver Area Regional Housing Needs Assessment included two distinct endeavors. The first was an
analysis of regional data to identify gaps in housing supply and affordability across
income levels and household types. The second consisted of extensive engagement with stakeholders across various housing sectors to identify systemic barriers to
developing housing. Throughout the development of the RHNA, DRCOG collaborated closely with local government officials, housing developers, community organizations,
advocates, finance professionals, and economists.
The purpose of DRCOG’s RHNA was to establish an objective, data-driven
understanding of the baseline housing need for both the current and future population.
Study Session Memo – DRCOG Regional Housing Needs Assessment
August 18, 2025 Page 3
The project began before SB24-174 but has been reviewed by DOLA and deemed
compliant with the state requirements for a Regional Housing Needs Assessment.
The RHNA is attached along with an executive summary. The analysis revealed the
following:
• Despite periodic building booms, the region has not produced enough housing to
keep pace with population and job growth.
• Housing supply is less than demand in every household income category.
• Low-income households (below 50% of Area Median Income) represent the
greatest need for additional housing. See the “Regional Housing Need by
Income” chart below.
• An aging population and smaller household trends will require more diverse
housing types.
• Housing types and affordability are unevenly distributed across the region. In the
Denver region, 500,000 housing units are needed to address current and future
needs across the income spectrum by 2050.
• Of the 500,000 housing units, 223,000 units are needed over the 10-year period
between 2023 and 2032. See the “Total Regional Housing Need” graph below.
Exhibit 1: Total Regional Housing Need
Source: DRCOG Regional Housing Needs Assessment
Study Session Memo – DRCOG Regional Housing Needs Assessment
August 18, 2025 Page 4
Exhibit 2: Regional Housing Need by Income
Source: DRCOG Regional Housing Needs Assessment The engagement efforts with local government staff, lending and investment
institutions, developers, professional associations, state and regional agencies, consultants, infrastructure/utility providers, and advocacy organizations included
discussions on increasing housing supply.
The primary identified barriers to addressing housing needs fall into five categories:
• Land use and zoning.
• Infrastructure.
• Development costs and market factors.
• Funding and finance.
• Community consensus and collective action.
A detailed description of the barriers can be found in the RHNA (Attachment 1).
HOUSING NEEDS IN WHEAT RIDGE:
DRCOG’s analysis included the 9 counties and 48 cities and towns that make up their membership. The RHNA calculated the housing need for the Denver region and then
distributed the need among different submarkets (see “Regional Submarket” map below). Wheat Ridge is mostly contained within the Central submarket, with the northern
portion above I-70 considered to be in the North Central submarket. After completing
regional analysis, DRCOG then allocated housing needs among individual municipalities based on population, employment, transportation, and housing data. Housing markets
are regional, and the methodology and data analysis reflect this.
Study Session Memo – DRCOG Regional Housing Needs Assessment
August 18, 2025 Page 5
Exhibit 3: Map of DRCOG RHNA Submarkets
Exhibit 4: Table of DRCOG RHNA Submarkets
Understanding each municipality's housing needs is essential because housing policy is
often developed and implemented at the local level of government. These numbers provide decision-makers with a better understanding of the scale and scope of the
region’s housing needs so they can make informed decisions about housing strategy in
their community.
Exhibit 3 below shows how many housing units are needed in Wheat Ridge over the
Study Session Memo – DRCOG Regional Housing Needs Assessment
August 18, 2025 Page 6
10-year period from 2023 to 2032, and at what income levels those units are needed.
The precise number is not as important as understanding the scale and scope of the need and developing a strategy proportionate to the need. In total, Wheat Ridge will
need to build 2,410 units to keep up with the demand, most of those being affordable to
households earning less than 50% Area Median Income (AMI).
Exhibit 3: Wheat Ridge 10-year Housing Need
Exhibit 4 below shows the proportion of rented homes in our community where households are spending 30%+ and 50%+ of their income on housing costs. It also
shows how this proportion has changed between 2000 and 2022. Implementing a
housing strategy that is proportionate to the housing need would provide relief to these households in our community.
Exhibit 4: Share of Wheat Ridge Households Who are Cost-burdened
BENEFITS OF PARTICIPATION:
As noted above, the city’s 2023 Affordable Housing Strategy does not comply with the
Study Session Memo – DRCOG Regional Housing Needs Assessment
August 18, 2025 Page 7
requirements of SB24-174. To comply with this state law, staff are recommending that
Wheat Ridge endorse DRCOG’s RHNA. This does not contradict, invalidate, or supersede our local policy document. DRCOG’s RHNA and the city’s Affordable Housing Strategy
complement each other as the RHNA contains more quantitative data and the 10-year
housing need for Wheat Ridge appears to align with staff’s analysis of projected growth.
Participation in the DRCOG RHNA is not compulsory. However, there are notable advantages to a local jurisdiction’s choosing to participate:
• It exempts the local jurisdiction from the requirement to conduct and publish a
state-compliant local housing needs assessment by the deadline of December
31, 2026, which would require significant staff time and funding to hire a
consultant with expertise in the subject matter.
• It maintains flexibility for the local jurisdiction to still develop its own state-
compliant housing needs assessment later. Future planning efforts at the local
level can then utilize data from the local housing needs assessment, or other
data sources, for their housing action plan.
Further, housing markets are regional. Choices about where to live are based on access
to jobs, affordability, schools, amenities, childcare and other factors that often
transcend jurisdictional boundaries. A regional housing needs assessment offers a shared analysis for an interjurisdictional issue. A regional approach fosters shared
collaboration to address the scale and scope of housing needs and develop strategies that match the nature of housing demand.
RECOMMENDATIONS:
Staff recommend participating in the DRCOG’s RHNA to satisfy the HNA requirement as
a temporary compliance measure. Participating in the DRCOG RHNA will give the city
extra time to update the AHS and enable us to save financial resources by utilizing
DRCOG’s technical analysis, data tools, and regional projections.
NEXT STEPS
To help guide the discussion on August 18, staff are seeking direction on the following
questions:
1. Does council agree with staff’s recommendation to participate in DRCOG’s
Regional Housing Needs Assessment for the purpose of complying with SB24-
174?
2. If so, does council have any comments regarding the RHNA that they would like
to share with DRCOG?
To formally participate in the RHNA and use it to satisfy the HNA requirement, local governments must:
Study Session Memo – DRCOG Regional Housing Needs Assessment
August 18, 2025 Page 8
• Review the RHNA during a public meeting, and
• Submit any comments to DRCOG during the review window, open from July 14 to
September 12, 2025.
This meeting aims to fulfill the legislative requirements if the council chooses to
participate in the RHNA.
ATTACHMENTS:
1. DRCOG Regional Housing Needs Assessment
July 2024
Regional Housing Needs Assessment
Denver Regional Council of Governments
Prepared for: Denver Regional Council of Governments (DRCOG)
ECOnorthwest
222 SW Columbia Street • Suite 1600 • Portland, OR 97201 • 503-222-6060
ATTACHMENT 1
DRCOG Regional Housing Needs Assessment 1
Acknowledgments
ECOnorthwest prepared this report with support from, guidance and input of several
partners, including staff, and leadership of the Denver Regional Council of Governments
(DRCOG), Community Planning Collaborative and MIG. We are especially grateful to
participants in the project Advisory Group composed of representatives from DRCOG
member governments, state agencies, environmental advocacy groups transportation
planning professionals, private housing developers, mission driven housing developers,
housing finance professionals, consultant land use attorneys, nonprofit housing advocates,
economists and data scientists.
That assistance notwithstanding, ECOnorthwest is responsible for the content of this report.
The staff at ECOnorthwest prepared this report based on their general knowledge of the
economics of housing and regional economies. ECOnorthwest also relied on information
derived from government agencies, private statistical services, the reports of others,
interviews of individuals, or other sources believed to be reliable. ECOnorthwest has not
independently verified the accuracy of all such information and makes no representation
regarding its accuracy or completeness. Any statements nonfactual in nature constitute the
authors’ current opinions, which may change as more information becomes available.
ECOnorthwest
♦ Tyler Bump
♦ Lee Ann Ryan
♦ Justin Sherrill
♦ Amanda Ufheil-Somers
Community Planning Collaborative
♦ David Driskell
♦ Micah Epstein
MIG
♦ Mark De La Torre
♦ Avery Wolfe
DRCOG
♦ Sheila Lynch
♦ Kris Valdez
♦ Andy Taylor
♦ Emily Daucher
♦ Zachary Feldman
♦ Nora Kern
♦ Emily Lindsey
♦ Dillon McBride
♦ Corey McGinnis
DRCOG Regional Housing Needs Assessment 1
Preparation of this report has been financed in part through federal grants from the United
States Department of Transportation, Federal Highway Administration, Federal Transit
Administration and the Colorado Department of Local Affairs.
For more information about this report please contact:
Lee Ann Ryan
ryan@econw.com
ECOnorthwest
206-388-0079
DRCOG Regional Housing Needs Assessment 2
Table of Contents
Executive Summary.................................................................... 1
1. Introduction and context ..................................................... 3
2. Regional housing needs ...................................................... 7
3. Submarket housing needs ................................................. 16
4. Systemic barriers to meeting housing needs ..................... 24
5. Moving toward a regional strategy ..................................... 29
DRCOG Regional Housing Needs Assessment 1
Executive Summary
Denver’s past and future growth
requires more housing
The Denver region has experienced rapid growth
in recent years, with a 17 percent increase in
residents since 2010 and a 33 percent increase in
jobs. Many of the region’s 3.4 million residents
struggle to find affordable and accessible housing
in their location of choice as home prices and
rents have increased far faster than incomes.
The Regional Housing Needs Assessment provided
the opportunity for local governments, non-profits,
industry representatives and other organizations
involved in housing preservation and production
across the Denver region to better understand the
scope, scale, and nature of housing issues in the
region. The Denver region while interconnected
through jobs and transportation, has historically
approached housing policy at the town, city, and
county level.
Addressing the regional housing needs will require
greater coordination across local jurisdictions as
many of the barriers are too complex and broader
than one local community can take on alone and
there is tremendous opportunity to more efficient
address barriers collaboratively.
Measuring regional housing need
DRCOG conducted this Regional Housing Needs Assessment to establish an objective, data-
driven understanding of the baseline housing need for both the current and future
population.
Using a methodology shaped by best practices and the guidance of a local Advisory Group,
the Regional Housing Needs Assessment estimates that 511,000 units are needed across
the region by 2050 to meet both the needs of the current population and to accommodate
projected population growth and changing demographics. Just over 300,000 of these
housing units will need to be affordable to households earning 60 percent or less of the
Overview
The region needs to build 511,000
units by 2050 to meet current and
future housing needs.
Despite periodic building booms,
the region has not produced
enough housing to keep pace with
population and job growth.
Much of the new housing in the
region does not support the
diversity of housing needs across
all income levels and household
types.
Diverse factors create barriers to
housing production.
A regional housing strategy is
critical to coordinate efforts
across sectors and align housing
development with broader regional
goals for transportation and
economic development.
DRCOG Regional Housing Needs Assessment 2
median income. Older adults will make up a greater share of the population, shaping trends
around housing needs, such as income and mobility.
Understanding barriers to housing production
The barriers to producing more housing—and at a higher rate than past trends— vary
significantly depending on the unique characteristics of each community and evolve over
time in response to changing circumstances. The interplay between factors such as market
conditions, the regulatory environment, infrastructure availability, community consensus,
and financial resources can hinder the delivery of new housing. These barriers are especially
challenging to creating housing affordable at low and moderate incomes—either by
preventing them from moving forward altogether or by resulting in the development of fewer
units than what might be allowed or desired under current conditions.
Moving toward a regional housing strategy
Addressing regional issues requires regional partnership. Many stakeholders in the region,
including DRCOG’s member governments, have long identified the need for coordinating
regional housing efforts to address the overall housing supply and affordability challenges.
Local communities, however, often struggle with access to consistent and reliable data, or
staff capacity, to develop and implement strategic and effective housing policy.
A regional strategy is intended to foster shared understanding, collaboration, and actions to
help member governments, in partnership with other stakeholders, make progress toward
addressing the region's housing needs. As part of this Regional Housing Needs Assessment,
DRCOG collaborated with public and private sector partners across the region to develop a
framework that will serve as the foundation for creating a regional housing strategy starting
in late 2024. By working collaboratively to develop a comprehensive regional housing
strategy and integrate it with other key planning efforts, DRCOG and its partners can take a
significant step toward fostering more equitable, resilient, and livable communities for all
residents of the Denver region. The Regional Housing Needs Assessment aims to provide a
thorough analysis of housing needs and to develop a better understanding of barriers related
to housing production, creating a strong foundation for developing the regional housing
strategy. The forthcoming regional housing strategy will build upon the findings and insights
presented in this report.
DRCOG Regional Housing Needs Assessment 3
1. Introduction and context
The Denver region has experienced substantial growth over the last decade. Since 2010,
the population has increased by 17 percent to 3.4 million residents, while the number of
jobs increased by 33 percent. However, housing production has failed to keep pace with
population growth. As vacancy rates hit historic lows, home prices and rents have soared.
The median home sale price in Denver reached $550,000 as of December 2023, increasing
by 180 percent over the last decade while incomes increased by 55 percent during the
same period.1 Home sale prices and rents are out of reach for median income earners, and
over 51 percent of renters cost-burdened across the region.2 Moreover, the most recent
Point-in-Time count showed the highest number of unsheltered homeless people in the
region since 2008.3,4 These trends grow more acute within local communities, particularly
when disaggregated by race, income, age, and other demographic factors, exacerbating
issues of housing access, displacement, and inequity.
Housing markets are regional
People make choices about where to live based on access to jobs, affordability, schools,
amenities, childcare and other factors that often transcend jurisdictional boundaries.
Despite this shared regional market, housing policy and planning in the Denver region has
primarily occurred at the town, city or county level, resulting in fragmented efforts that
have struggled to adequately account for and address regional dynamics that shape
housing demand, supply, and ultimately, affordability. Greater efforts for coordinated policy
and planning are needed to better address housing barriers that local communities cannot
take on alone.
DRCOG supports regional planning and coordination
The Denver Regional Council of Governments (DRCOG) is a planning organization in which
local governments collaborate to set policies, guidelines, and funding priorities across key
areas including transportation, growth and development, aging, and disability resources.
DRCOG’s member governments include 9 counties and 49 cities and towns as shown in
Exhibit 1. Representatives from these governments work together to make life better for
those who call the region home.
1 Redfin; Zillow, 2023
2 Denver County Median Family Income 2023
3 Metro Denver Homelessness Initiative
4 Point-In-Time Count is an annual survey conducted in the United States to assess homelessness. The Point-In-
Time Count serves as a snapshot of homelessness in a community by providing an estimate of the overall
scope of homelessness on a single night. It includes both sheltered (those in emergency shelters and
transitional housing) and unsheltered (those without shelter) populations.
DRCOG Regional Housing Needs Assessment 4
Exhibit 1: DRCOG Planning Area
Source: DRCOG
In 2017, DRCOG adopted Metro Vision, which is the
long-range plan for growth and development across
the Denver region. The plan provides guidance and
coordination between counties and municipalities
on regional land use, transportation, and a variety
of other government policies. It is centered around
promoting sustainable, managed growth for the
Denver region, with implementation occurring
through local initiatives aligned with Metro Vision's
overall framework. The plan recognizes that many
of the effects associated with growth—such as
traffic, air quality and housing costs—cross
jurisdictional boundaries and local governments
must work collaboratively to address them.
Metro Vision recognizes the interconnections
between DRCOG’s traditional planning focus on
transportation, growth, and aging and disability
needs with housing, economic development, community health, and resilience. One of Metro
REGIONAL PLANNING PROCESS
New Role for Housing in
Transportation Planning
In 2021, the federal Infrastructure
Investment and Jobs Act amended the
scope of the metropolitan
transportation planning process,
related to the factors a Metropolitan
Planning Organization must consider,
adding housing, alongside
transportation improvements, and state
and local planning growth and
economic development patterns.
DRCOG Regional Housing Needs Assessment 5
Vision’s overarching themes is “healthy, inclusive, and livable communities” with desired
outcomes related to increased housing diversity to meet the needs of residents of all ages,
incomes, and abilities. To this end, Metro Vision outlines specific objectives to diversify the
region’s housing stock, increase the regional supply of housing attainable for a variety of
households, and increase opportunities for diverse housing accessible by multimodal
transportation.
As the designated metropolitan planning organization for the Denver region, DRCOG is well-
positioned to convene member governments and regional stakeholders, provide consistent
guidance, data, and tools to help advance Metro Vision and encourage collaboration to meet
the diverse housing needs across the region. This support from DRCOG allows local
jurisdictions to focus on how they can influence development—by managing and
encouraging new housing in ways that are consistent within a community’s specific vision.
Ultimately, increasing housing options relies on local policy, but regional coordination
enables strategic and consistent action toward creating more equitable access and housing
affordability across the Denver region.
Building toward a regional strategy
DRCOG is approaching regional housing planning in two distinct pieces over the next two
years. The first piece is a Regional Housing Needs Assessment, which developed a
methodology and conducted an analysis to quantify housing needs across the region through
2050, as represented in Exhibit 2. This analysis helps provide a baseline understanding of
the scope and scale of housing issues across the region and identifies key barriers to
housing production.
Throughout the development of the Regional Housing Needs Assessment, the project team
engaged key groups whose work touches on regional housing issues from different
perspectives. An Advisory Group composed of representatives from local government, state
agencies, housing developers, service providers, and advocates met six times throughout the
project to provide feedback and guidance on the approach, methods, and key barriers to
producing more needed housing in the Denver region. This group also helped establish the
framework for a regional housing strategy.
In addition to the Advisory Group, the project team convened multiple focus groups and
individual stakeholder meetings representing an array of interests and perspectives across
approximately 200 participants. These conversations gathered critical information about
municipal planning, infrastructure and utilities, the homebuilding sector, affordable housing,
regional economic development, housing finance, aging services, and climate and
sustainability issues. Input from this wide range of participants helped illuminate the
challenges faced by public and private sector actors working to increase opportunity in the
region and identify how a coordinated housing strategy could support those efforts. See
Appendix A for a more detailed summary of stakeholder engagement activities.
DRCOG Regional Housing Needs Assessment 6
Exhibit 2. Regional Housing Needs Assessment Process
The Regional Housing Strategy, expected to begin in late 2024, will involve working with
local governments and housing partners across the region to develop a strategy to
collectively address these identified housing needs.
What is a regional housing needs assessment?
Regional Housing Needs Assessments are critical tools for quantifying housing needs at a
regional level. A housing needs assessment uses data on key demographic factors, housing
stock characteristics, market trends, and forecasted population and job growth to
understand the number of housing units an area will need to produce to meet current and
future housing need over a specified planning period. With thoughtful design, these
assessments offer planners and policymakers a more comprehensive and nuanced
understanding of housing need for people across the income spectrum and with different
household characteristics, which allows for a more targeted and effective approach to
meeting diverse needs.
DRCOG Regional Housing Needs Assessment 7
2. Regional housing needs
DRCOG conducted this Regional Housing Needs
Assessment to establish an objective, data-driven
understanding of the baseline housing need for both the
current and future population. Understanding the total
need and affordability gaps at all income levels will
critically inform local, regional and statewide efforts to
address housing need. In addition, this housing needs
assessment will serve as a foundation for the development
of a regional housing strategy which will articulate what we
can do collectively as a region. Throughout this Regional
Housing Needs Assessment development, the following guiding principles were identified by
DRCOG staff, the consultant team, and the Advisory Group to inform the process.
Proactively determine housing need for the region.
Develop a data-driven approach to policy and planning.
Maintain transparency around data sources, limitations, and methodological
choices.
Align with Metro Vision planning areas and goals.
Align future strategy development with subregional and local needs.
Key Findings
The key findings section summarizes important takeaways about regional housing needs.
Further context and discussion follow.
» The region needs to build 511,000 units by 2050 to meet current and future housing
needs. While housing is needed at all income levels, housing that is affordable to
households earning less than 60 percent of Area Median Income represents the largest
share. The market will not deliver this type of housing on its own, particularly at the
volume needed. Government subsidies and creative partnerships with private market
actors will be required to meet housing needs.
» Adults aged 65 and older will comprise a larger share of the population by 2050 and
household sizes are shrinking. These shifts in household composition along with
forecasted housing need by income category shows that jurisdictions and the region
» This chapter
summarizes DRCOG’s
approach,
methodology, results
and key findings for
regional housing
needs.
DRCOG Regional Housing Needs Assessment 8
will need to plan for more diverse housing options for a broader range of household
incomes to meet current and future housing needs.
» The Denver region has seen booms and busts in housing production over the past
several decades. Yet new housing has not kept pace with overall population growth
over the same period. A steep decline in construction during the Great Recession
contributes to the shortage of needed housing today. As an additional challenge, the
existing housing stock does not support the diversity of housing needs across all
income levels and household types.
» The differences in need and supply across submarkets highlight the range of housing
dynamics across the region and demonstrate the need for more tailored strategy
development for submarkets and the local governments within them. Opportunities to
align housing with transportation access, job centers and other key factors also differ
across regional submarkets and highlight the different roles they can play in meeting
the region’s overall housing needs.
How to measure regional housing need
This Regional Housing Need Assessment estimates the number of households across the
Denver region that will need dwelling units affordable to them between 2023 and 2050. This
estimate of needed housing is created using Census data on population and housing,
regional population forecasts, and other local data sources. A detailed description of the
data sources and methodology used in this RHNA is included in Appendix C.
At a high level, the method used in this Regional Housing Needs Assessment has two
primary components:
♦ Future need: To project future housing need, the analysis uses the State
Demography Office’s projected household growth for the Denver region through
2050. This household projection gets translated to housing units by factoring in a
healthier vacancy rate that enables greater mobility within the housing market and
across the region. This number is then compared to the current supply of housing.
♦ Current need: To estimate current need, two components must be included.
Underproduction is the estimated number of housing units that are needed to
provide sufficient housing to current residents that are well captured in census
surveys. Homelessness need is the estimated number of housing units that are
needed for those currently experiencing homelessness who are not well captured in
census surveys.
Regional housing needs
The analysis shows the Denver region will need to produce just over 511,000 new housing
units between 2023-2050 to address current need, driven by underproduction and people
experiencing homelessness, and future need, driven by anticipated population growth. A
DRCOG Regional Housing Needs Assessment 9
breakdown by component of the total housing need through 2050 for the Denver Region is
shown in Exhibit 3 below.
Exhibit 3: Summary of housing need by component, 2023–2050
Component Housing units Share
Current need 52,000 10%
Future need 458,000 90%
Total units 511,000 100%
Source: ECOnorthwest analysis; DRCOG synthesis of State Demography Office 2022 Household Forecast;
and U.S. Census Bureau, American Community Survey 5-year 2013 Public Use Microdata Sample
estimates; Metro Denver Homeless Initiative State of Homelessness Report, 2022–2023
Total housing need by income
The Regional Housing Needs Assessment allocates total housing needs by 2050 based on
different income levels, recognizing that households across the income spectrum need
affordable housing options. Exhibit 4 shows the distribution of total needed units by Area
Median Income relative to the current supply of housing affordable to households earning
those incomes.5 Exhibit 5 shows the distribution of total needed units by income and
housing need component.
Housing needs for the Denver region are heavily skewed toward lower income households.
An estimated 303,000 housing units for households earning 0–60 percent of the Area
Median Income are needed to meet current and future demand. The private market typically
fails to deliver housing affordable to these income levels, as they require a patchwork of
financial subsidies to build and maintain. Housing needs are lower for households in the 60–
80 percent Area Median Income range, partly due to an existing supply of housing affordable
to these income levels.6 Just over 187,000 units serving higher earning households above 80
percent of Area Median Income are also needed. The market can potentially produce
housing for these income levels on its own, assuming supportive local policies are in place.
5 According to the Department of Housing and Urban Development, housing is considered affordable for a
household if their housing costs do not exceed more than 30 percent of their annual income, including
additional expenses such as insurance, property tax, and utility expenses. This standard of affordability traces
back to rent caps established for public housing tenants.
6 While there is a relative match between the number of households at this income level and the number of
housing units affordable to them, mismatches at lower and higher income levels increase the competition for
moderately priced housing. As a result, many communities observe a shortage of available housing affordable
to households earning between 60 and 100 percent of Area Median Income.
DRCOG Regional Housing Needs Assessment 10
Exhibit 4: Housing need compared to current supply by income, 2023–2050
Source: ECOnorthwest analysis; DRCOG synthesis of State Demography Office 2022 Household Forecast
and U.S. Census Bureau, American Community Survey 5-year 2013 Public Use Microdata Sample
estimates; Metro Denver Homeless Initiative State of Homelessness Report, 2022–2023
DRCOG Regional Housing Needs Assessment 11
Exhibit 5. Housing need components by income, 2023–2050
Source: ECOnorthwest analysis; DRCOG synthesis of State Demography Office 2022 Household Forecast
and U.S. Census Bureau, American Community Survey 5-year 2013 Public Use Microdata Sample
estimates; Metro Denver Homeless Initiative State of Homelessness Report, 2022–2023
10-year scaled estimate
The Regional Housing Needs Assessment estimates need through 2050, but this estimate
can be adjusted for a shorter planning horizon to better understand the number of units
needed in the near term and to align policies and strategies with current market conditions.
Therefore, the analysis includes results adjusted for a 10-year horizon, out to 2032. All of
current need units are included in the 10-year scaled estimate. The 10-year estimate
represents 42 percent of the total need through 2050.
Over 216,000 housing units are needed in the Denver region between 2023 and 2032 to
address current need, driven by underproduction and people experiencing homelessness,
and future need, driven by anticipated population growth through 2032. A breakdown by
component of the housing need through 2032 for the Denver region is shown in Exhibit 6
below.
Exhibit 6: 10-Year scaled estimate of housing need
Component Housing units Share
Current need 52,000 24%
Future need 164,000 76%
Total units 216,000 100%
DRCOG Regional Housing Needs Assessment 12
Source ECOnorthwest analysis; DRCOG synthesis of State Demography Office 2022 Household Forecast
and U.S. Census Bureau, American Community Survey 5-year 2013 Public Use Microdata Sample
estimates; Metro Denver Homeless Initiative State of Homelessness Report, 2022–2023
Exhibit 7 shows the 10-year distribution of total needed units by area median income
relative to the current supply of housing affordable to households earning those incomes.
The distributions reflect the assumptions and methods, discussed above, that allocate all
units to address homelessness and more of the units to address underproduction to the
lowest income categories. Therefore, the 10-year estimate still shows the greatest need in
the 0–60 percent Area Median Income categories.
Exhibit 7. 10-Year scaled estimate of housing need compared to current supply by income
Source: ECOnorthwest analysis; DRCOG synthesis of State Demography Office 2022 Household Forecast
and U.S. Census Bureau, American Community Survey 5-year 2013 Public Use Microdata Sample
estimates; Metro Denver Homeless Initiative State of Homelessness Report, 2022–2023
Key trends driving regional needs
Many factors shape the details of current and future housing needs, including demographic
shifts and economic trends. In the Denver region, a few key trends are important for
understanding why housing needs are heavily skewed toward lower income households. A
more detailed assessment of demographic and housing trends is provided in Appendix B.
DRCOG Regional Housing Needs Assessment 13
The region’s population is aging
According to the 2022 Colorado State Demography Office household forecast for 2023
through 2050, adults over the age of 65 will become a larger share of population than they
are currently. Since retirement often coincides with fixed or lower incomes compared to
working years, the growth in the older adult population will contribute to a rise in the share
of lower-income households overall. While some older adults may have accumulated greater
wealth over their working years, many have fixed incomes that leave them susceptible to
increasing housing costs. Others may have that wealth primarily as home equity, and thus
locked into a home that may not meet their changing needs. The expected growth in this
segment of the population contributes to the pressing need for more affordable housing
options that also meet the mobility needs of older adults across the Denver region.
Exhibit 8. Percent of households by age range, 2022 & 2050, Denver region
Source: DRCOG synthesis of State Demography Office 2022 Household Forecast and U.S. Census Bureau,
American Community Survey 5-year 2013 Public Use Microdata Sample estimates.
Existing housing supply has not kept pace with demand
In a growing region, new housing supply is needed to accommodate new households arriving
to the area, natural population growth, changing preferences, and natural turnover and
vacancy. New housing supply is essential to allow households the option to move and self-
DRCOG Regional Housing Needs Assessment 14
sort into the neighborhoods, housing types, and affordability levels that meet their needs
and optimize their regular travel behaviors. Housing markets in growing areas like the
Denver region need ample and well-distributed new supply. In a well-supplied housing
market, households can move through the stock via a process called “filtering” or the
“housing ladder.” Over time, housing ages and depreciates, becoming relatively more
affordable for different households.
New market-rate housing is typically priced for and occupied by higher income households,
while new subsidized housing is usually priced for low-income households. Many higher
income households move into newly constructed units from older, smaller or more
affordable housing, which is then vacant and available for households with moderate
incomes. When there is an adequate supply of new housing for a region’s population, this
dynamic creates a steady, though slow, process of increasing the supply of affordable
housing through “filtering” as properties age (Exhibit 9). Some properties will eventually be
demolished if they age or depreciate until they are no longer habitable or the cost of needed
renovations exceeds the value. In under-supplied markets, however, this filtering process
can slow further, stop, or move in reverse. In very tight housing markets, with steep
competition for housing units, higher income households will occupy older or lower-cost
units, causing a “mismatch” between what those households can afford and their actual
housing costs. At the same time, lower income households will experience this “mismatch”
by having to pay a larger share of their income toward housing as competition increases
rents. Renovations can also reposition lower cost units for higher income households. When
competition and demand concentrate in specific locations, these dynamics contribute to
neighborhood gentrification and the loss of affordable housing units.
Exhibit 9. Illustration of housing market filtering
Source: ECOnorthwest
Housing production in the Denver region has largely kept pace with population growth in the
last several years, and notably the share of multifamily units is growing. The region is still
working from a place of historic underproduction and the existing housing stock does not
support the diversity of housing needs across all income levels and household types. This
DRCOG Regional Housing Needs Assessment 15
has created a mismatch between household income and housing costs, where households
are occupying housing units that generally cost less than the household can afford or they’re
likely occupying housing units that cost more than their income can afford, demonstrating a
substantial need for more affordable housing options for lower income households making
between 0–60 percent of Area Median Income and a need to continue delivering market-rate
units that more adequately meet the demand for middle and higher-income households.
Even when filtering is occurring and housing is becoming relatively more affordable over
time, governments still must invest in building new regulated affordable units to meet the
needs of lower income residents. This type of housing almost always needs government
intervention and public subsidy to be developed. Voucher-based assistance that subsidizes
lower income residents’ access to market-rate units is another way to help meet this need,
though limited funding results in long waiting lists for households that qualify.
DRCOG Regional Housing Needs Assessment 16
3. Submarket housing needs
In consultation with DRCOG staff, the project team
created a model for distributing the 10-year scaled
estimate of the Regional Housing Needs Assessment
results among five submarkets.
Understanding housing need at a submarket level can
better account for local differences rather than relying on
regional trends or averages. This approach allows for
more targeted strategy and policy development to support
investments based on the distinct needs within specific
submarkets, rather than utilizing a one-size-fits-all approach. Defining submarkets also
provides a basis for understanding shared responsibility that can support potential future
collaboration between neighboring jurisdictions to address their shared housing needs.
The submarkets in this Regional Housing Needs Assessment are contiguous areas that were
defined by evaluating how housing location decisions are made across the region in relation
to commute patterns and employment locations. This approach allows DRCOG and
stakeholders to understand how households make decisions related to job location, housing
affordability, and transportation access. Exhibit 10 shows the five submarkets—West,
Central, North Central, North, and Southeast—used in the Regional Housing Needs
Assessment.
Exhibit 10. Regional submarkets
Source: ECOnorthest analysis of ACS 1-year 2022 PUMS and LODES data. Note that delineation follows
Public Use Microdata Areas and thus extend beyond DRCOG boundary in the North Submarket.
» This chapter
summarizes DRCOG’s
approach,
methodology, results
and key findings for
submarket housing
needs.
DRCOG Regional Housing Needs Assessment 17
Submarket housing needs
Regional housing need was distributed to the submarkets based on criteria that reflect both
current conditions and needs and forecasted future conditions and needs. The criteria
include factors that shape the demand for housing, align with regional planning goals for
greater affordability across the region, and recognize the intricate relationship between
transportation infrastructure and employment centers to improve access to job
opportunities and reduce commute times. At a high level, the categories and rationale
behind the criteria are as follows:
♦ Population: Housing need corresponds directly to population size.
♦ Regional jobs: Employment is a driver of housing demand. Better matching of job
and housing locations creates more options for housing, shortens commute times,
and eases strain on the region’s transportation systems.
♦ Multimodal accessibility: Metro Vision outlines a plan for more compact urban
development and a greater use of transit, walking, and biking for daily activities.
♦ Housing availability: Low rental vacancy rates help illuminate places where housing
is particularly in high demand and short supply, relative to the region as a whole.
♦ Housing affordability: Every community in the Denver region has a role to play in
planning for housing affordable to a range of incomes. Areas with a smaller supply of
affordable housing contribute to regional inequities in access to opportunity and
suboptimal transportation outcomes.
DRCOG can also use the above criteria to distribute the resulting submarket shares of
regional need among local jurisdictions. Such a process will help illustrate local housing
need by income in a regional and submarket context. The project team has equipped
DRCOG staff to be able to run and refine this model as needed and as inputs to the regional
housing needs estimate change, such as regional population and jobs forecasts from the
State Demography Office.
Exhibit 11 shows the 10-year scaled estimate of total regional need—approximately
216,000 units distributed across the five regional submarkets, broken out by component of
need.
Exhibit 11. Summary of submarket share of regional need, 10-year scaled estimate
Submarket Current need Future need Total units
Central 14,000 56,000 70,000
North 8,000 29,000 37,000
North Central 7,000 27,000 34,000
Southeast 21,000 48,000 69,000
West 2,000 4,000 6,000
Source: ECOnorthwest analysis; DRCOG Small-Area Forecast (2020), DRCOG synthesis of State
Demography Office 2022 Household Forecast, U.S. Census Bureau, ACS 1-year 2022 PUMS estimates;
MDHI 2022–2023 State of Homelessness Report.
DRCOG Regional Housing Needs Assessment 18
Submarket housing need by income
Differences in need across the submarkets highlight the imbalance of housing demand
across the region relative to existing supply and affordability, as shown in Exhibit 12 and
Exhibit 13. These differences contribute to problematic transportation outcomes, such as
longer commutes and less access to opportunity. Variation across the submarkets also
demonstrates the need to develop tailored strategies to meet varied needs across the region.
Exhibit 12. Submarket share of regional need by income, 10-year scaled estimate
SUBMARKET 0–30% 30–60% 60–80% 80–
100%
100–
120% >120% TOTAL
Central 27,000 17,000 3,000 9,000 3,000 11,000 70,000
North 14,000 9,000 2,000 5,000 2,000 5,000 37,000
North Central 13,000 8,000 2,000 4,000 2,000 5,000 34,000
Southeast 29,000 17,000 3,000 8,000 3,000 9,000 69,000
West 2,300 1,300 300 600 200 700 6,000
Total 85,000 52,000 11,000 27,000 10,000 31,000 216,000
Source: ECOnorthwest analysis; DRCOG Small-Area Forecast (2020), DRCOG synthesis of State
Demography Office 2022 Household Forecast, U.S. Census Bureau, ACS 1-year 2022 PUMS estimates;
MDHI 2022–2023 State of Homelessness Report.
Note: Components of need do not sum to total because of rounding.
Exhibit 13. Submarket share of total need compared to current supply, 10-year scaled
estimate
DRCOG Regional Housing Needs Assessment 19
Source: ECOnorthwest analysis; DRCOG synthesis of State Demography Office 2022 Household Forecast
and U.S. Census Bureau, American Community Survey 5-year 2013 Public Use Microdata Sample
estimates; Metro Denver Homeless Initiative State of Homelessness Report, 2022–2023; DRCOG 2020
Small-Area Forecast
Regional submarket factors
Variation in housing need across the submarkets reflect different ways in which these areas
have been affected by and responded to broader regional trends. These more localized
trends can be used to inform policy decisions that support meeting a broader regional
need.
Population and job growth has been uneven
While the Denver region as a whole has seen significant job and population growth over the
past several decades, these trends have not been distributed across the submarkets
proportionately, as shown in Exhibit 14 and Exhibit 15.
The Southeast submarket, which includes cities such as Aurora, Castle Rock, Littleton, and
Englewood saw the highest total population growth over the last 20 years with over 366,000
new people. While the Central submarket, which includes Denver and Lakewood, saw
population grow by only 26 percent, this still accounted for over 210,000 new people over
20 years. The North Central region, which includes Northglenn, Westminster, Brighton and
Commerce City, also grew rapidly with a 41 percent increase in population. The North
submarket, encompassing cities like Boulder, Erie, Longmont, and Louisville, experienced
the highest rate of population growth, 53 percent. The more isolated West submarket grew
the least over the last two decades.
Exhibit 15 shows that the Southeast submarket has seen the largest increase in jobs since
2000, followed by the Central and North submarkets. These submarkets have all increased
jobs for different reasons, for example land supply and new commercial development in the
Southeast submarket, urban intensification and redevelopment in the Central submarket,
and growth in institutional employment and tech and supportive industries in the North
submarket. While employment growth is forecast to grow at slower rates through 2050, job
growth will continue to occur, which will lead to increased demand for housing across the
submarkets.
DRCOG Regional Housing Needs Assessment 20
Exhibit 14. Population change, regional submarkets, 2000–2020
Source: ECOnorthwest analysis of U.S. Census Bureau Decennial Census 2000, 2020.
Exhibit 15. Job growth, regional submarkets, 2005–2021
Source: ECOnorthwest analysis of LODES data 2005 and 2021.
DRCOG Regional Housing Needs Assessment 21
New housing supply varies across the submarkets
Housing production trends across the submarkets can help paint a more complete picture of
regional dynamics, especially in the context of the population and job growth trends. As
shown in Exhibit 16, the submarkets have experienced varied amounts of new construction
and differences in the types of housing being built.
Exhibit 16. Housing production, regional submarkets, 2000–2020
Source: ECOnorthwest analysis of U.S. Census Bureau Building Permit Survey.
Note: Unincorporated portions of the regional submarkets are not included in these totals.
The Central submarket has seen a large increase in housing production after recovering
from the 2008 recession. The Central submarket saw both the fastest housing recovery post-
recession as well as seeing new housing production at rates both higher than other
submarkets and higher than the previous 2002–2008 period of economic expansion. During
the post-recession market recovery, the Central submarket began shifting toward more
dense multifamily development in response to previous plans and policies. In 2022, the
Central submarket delivered over 9,200 housing units, substantially more than its pre-2008
recession peak year.
The North submarket has returned to pre-recession levels of housing production, but new
housing development is not occurring at rates that reflect rapid population growth in the
submarket. The submarket had a record year in 2018, delivering just over 5,300 units. In
2022, over 4,000 units were built, similar to its early 2000s pace. While single-unit
development continues to make up the largest share of new housing, there has been a
notable increase of new multifamily units that make up a larger share of new production
than in the pre-2008 economic cycle.
The North Central submarket appears to have struggled to fully recover post-recession
compared to other submarkets. Housing production remained slow, with just under 3,000
DRCOG Regional Housing Needs Assessment 22
units delivered in 2022, well below its pre-recession peaks and not in line with observed
population growth, which can lead to housing pressures in the submarket.
The Southeast submarket has recovered to its pre-recession housing production levels,
especially over the last few years. The submarket saw a record production year in 2021 with
over 9,100 housing units permitted, and another 6,500 units in 2022. The Southwest
submarket also saw a large increase in the share of multifamily production in 2021 and
2022.
The West submarket's production pace stayed relatively flat over the past decade. Fewer
than 2,000 housing units were permitted between 2000 and 2020, which contributes to both
limited housing availability and relatively slow population growth that has occurred in many
of these smaller communities across the foothills.
Differences in housing production are partially reflected in the different rates of housing
vacancy across the submarkets, as shown in Exhibit 17.
Exhibit 17. Vacancy trends by regional submarket, 2000–2022
Source: ECOnorthwest analysis of U.S. Census Bureau Decennial Census 2000, 2010; American
Community Survey 5-year 2022 estimates.
The North Central, Southeast, and Northern submarkets currently have the lowest vacancy
rates for both ownership and rental housing in the region, indicating constrained housing
markets as shown in Exhibit 17. The Central submarket indicates vacancies are slightly
higher than other submarkets likely due to higher rates of recent multifamily development
that has led to absorption periods for a larger volume of new units. The West submarket
DRCOG Regional Housing Needs Assessment 23
has seen relatively stable vacancy rates since 2000 due to relatively slow changing housing
stock given the less urban character of communities in the submarket.
DRCOG Regional Housing Needs Assessment 24
4. Systemic barriers to meeting
housing needs
Two key challenges in meeting the Denver region’s housing
needs include building housing that supports the diversity of
housing needs across all income levels and household types
and ensuring that diverse housing options exist across the
region’s submarkets. When looking at the region as a whole, the
production of market-rate housing has kept better pace with the
demand from higher income households. This level of
production needs to be sustained to continue meeting projected
needs, and should be more evenly distributed across
communities to create more opportunity for residents to make
choices based on their needs and preferences. At the same
time, the region will need to significantly increase the
production of affordable housing, especially for the lowest income households to meet the
scale of existing and future needs.
The barriers to meeting housing needs described in this report were identified by regional
stakeholders including, local government staff, representatives from lending and investment
institutions, developers, professional associations, state and regional agencies, consultants,
as well as infrastructure/utility providers and advocacy and service organizations. The
barriers to producing more housing—and at a higher rate than past trends—are varied,
operate at multiple levels, and interact in complex ways. These obstacles are not uniform
across the region; they vary significantly depending on the unique characteristics of each
geographic location and evolve over time in response to changing circumstances. Typically,
it is the combination and intersection of these barriers that hinders housing projects—
especially those affordable at low and moderate incomes—either by preventing them from
moving forward altogether or by resulting in the development of fewer units than what
might be allowed or desired under current conditions.
The categories discussed below highlight key issues that affect how and how much housing
is built in the region. Appendix D contains a more detailed discussion of each category and
examples of how these barriers are experienced in communities across the Denver region.
Land use and zoning
Land use refers to the way in which land is utilized and managed, including how land
should be allocated for various purposes, such as residential, commercial, industrial,
agricultural, recreational, or conservation areas. Land use planning provides a vision for
» This chapter
summarizes the varied
and intersecting
barriers to producing
more housing overall
and more diverse types
of housing in the
region.
DRCOG Regional Housing Needs Assessment 25
future development within neighborhoods, districts, towns, cities, counties, regions or other
defined planning areas. Local jurisdictions play a crucial role in determining the balance of
land uses within their boundaries through comprehensive plans, zoning ordinances, and
development standards. They aim to ensure that the allocation of land aligns with the
community's vision, goals, and priorities while considering factors such as economic
development, environmental sustainability, and quality of life.
Zoning regulates local land use by establishing guidelines and restrictions used to control
and guide property development in various areas within cities, towns, and counties.
Communities are divided into districts or zones, each with specific regulations governing
allowed uses, building size, dimensional requirements, density, parking, and other
development standards.
Land use and zoning barriers include:
» Zoning that supports a narrow range of housing types limits the land available for more
housing production and options.
» Open space and off-street parking requirements limit housing production by making
many types of housing infeasible in many locations.
» Exclusively commercial zones also reduce the land available for more housing
production.
» Permitting and procedures reduce housing production feasibility through greater costs
including additional time, other delays, uncertainty, and risk.
» Where local regulation-based incentives are not matched to needed housing types, the
value of such incentives are not able to make up for additional costs needed to increase
housing production and options.
Infrastructure
Infrastructure refers to the fundamental facilities and services that support a community's
development and operation. In the context of housing, key infrastructure includes
transportation networks such as roads, public transit, sidewalks, and bikeways; water and
sewer systems; stormwater management systems for collecting and treating runoff; energy
sources such as electricity and natural gas; and community facilities such as schools and
parks. The costs and construction of new infrastructure are often shared between the private
and public sectors where private developers install infrastructure related to their projects
and public sector agencies provide and maintain larger, off-site infrastructure systems,
funded through taxes, user fees, and impact fees charged to developers. However, over time,
the roles of the private and public sectors in providing and funding infrastructure projects
have become more blurred due to funding challenges. Increasingly, private developers are
required to contribute more to off-site infrastructure improvements, while public agencies
DRCOG Regional Housing Needs Assessment 26
need to explore innovative partnerships and financing mechanisms to deliver and maintain
necessary facilities and services.
Infrastructure barriers include:
» Limited infrastructure funding leads to a heavy reliance on user fees, potentially
burdening existing residents. Additionally, jurisdictions face the risk of taking on
burdensome bond obligations, so they often delegate infrastructure development to
developer-led special districts.
» Limited capacity of existing systems may require developers to facilitate upgrades
themselves. These added costs can make housing projects less financially feasible,
especially for affordable housing, resulting in less housing production, fewer units in the
projects that do move forward, or a focus on higher-priced housing units that can absorb
these additional costs.
» The presence of multiple service providers within a single jurisdiction complicates
efforts to coordinate and potentially reduce or waive development fees.
» Access to opportunity presents a dual challenge in housing development. Areas that are
destination-rich, compact, walkable, and well-served by existing transit typically have
higher land costs, making development more expensive. Communities along historically
underinvested corridors have concerns about the loss of more affordable housing options
when the real estate market responds to regional transit improvements.
Development costs and market factors
The most important factor determining whether and what kind of housing gets built in our
communities is financial feasibility. Both for-profit and nonprofit developers need the
expected revenues of a finished project to at least cover the cost of repaying loans, providing
a return on any investor equity, and covering their staffing and operational expenses. Local
policies contribute to total project costs—regulations governing the size, unit density,
materials and other design factors all affect a project budget. At the same time, broader
market conditions influence the basic costs of development in ways that can make housing
more expensive or less likely to be built.
Development costs and market barriers include:
» Rising interest rates and insurance costs affect housing development by slowing down
development activity across all housing types, particularly affordable housing projects.
» Elevated land values may discourage public agencies from providing their holdings to
support housing production due to their limited revenue options.
» Securing adequate water supply often incurs costs beyond just the infrastructure needed
for delivery, further increasing development expenses.
DRCOG Regional Housing Needs Assessment 27
» The construction industry faces a labor shortage, stemming from employment levels that
have not fully recovered since the Great Recession, further exacerbated by high housing
costs and the cyclical nature of Colorado's development industry.
» Construction defect liability laws have discouraged developers from building dense
ownership housing, particularly condominiums.
Funding and finance
The terms "funding" and "financing" are often used interchangeably, but there is an
important difference between the two. Funding describes the ultimate sources of money to
pay for development costs and generally comes from private developers (for-profit or
nonprofit) and investors or public sector partners (whether from local revenue sources,
state funds, or federal funds). For affordable housing especially, the limited amount of
funding available from all sources is the primary challenge to ramping up construction and
preserving the affordable housing that already exists.
Financing describes mechanisms to distribute funding, such as loans, grants, and equity
investments (among others). The features and requirements of different financing tools
have implications for development costs, and some tools are better suited—or restricted,
as in the case of tax credits—to certain kinds of development. Even jurisdictions that have
limited sources of funding may be able to adjust how they finance development in order to
better leverage funds to meet housing production needs.
Funding and finance barriers include:
» There’s an over-reliance on limited federal resources for affordable housing
development, with annual applications for federal tax credits in the state consistently
exceeding the available supply.
» The lack of a dedicated source of regional gap funding creates challenges for projects
that often face delays or even cancellation due to the time-consuming and complex
process of assembling gap funding from multiple sources.
» Local incentive programs (e.g., voluntary inclusionary zoning) designed to boost
affordable housing production often fall short of their intended goals.
» Existing funding programs for affordable housing development often favor larger-scale
projects with experienced developers because of perceived lower risk, putting smaller
communities at a disadvantage.
Community consensus and collective action
Beyond official rules, processes, and market factors, community consensus and collective
action play crucial roles in shaping the local and regional housing landscape. The
commitment of key stakeholders and elected officials is essential for enacting policies and
DRCOG Regional Housing Needs Assessment 28
allocating resources that support housing development. A lack of commitment or consensus
can derail even well-intended efforts to meet housing needs. Similarly, collective action by
community members and advocacy groups can either push housing initiatives forward or
oppose development. Community consensus and collective action barriers include:
» Local resistance to new housing development, particularly affordable housing and
diverse housing types, poses a significant barrier to addressing housing needs.
» The lack of consistent local data hinders a comprehensive understanding of housing
needs across different jurisdictions.
» Colorado's state tax policy, particularly the Taxpayer Bill of Rights (TABOR), significantly
constrains the government's ability to generate revenue that keeps pace with population
growth and demographic changes. This often limits the capacity of government to fund
housing initiatives and related services.
Interplay of barriers to building housing
Organizing barriers into key groups can help inform development of a future regional
housing strategy with a framework that addresses both the broad issues and the on-the-
ground experiences in the region. The interplay between factors such as market conditions,
the regulatory environment, infrastructure availability, community context, and financial
resources can lead to unintended outcomes. For example, land use and zoning barriers may
create mismatches between areas with access to needed infrastructure, land prices or
market demand to support feasible construction of more housing. Such interplay limits
location flexibility and choices for the development of more housing and more housing
options, affecting many sectors’ ability to meet regional housing needs. Solutions to address
these barriers will need to be multifaceted, well-researched, and comprehensive.
DRCOG Regional Housing Needs Assessment 29
5. Moving toward a regional
strategy
Addressing a regional issue requires regional partnership.
Many stakeholders in the region, including DRCOG’s
member governments, have long identified the need for
coordinating regional housing efforts to address the overall
housing supply and affordability challenges. Local
communities often struggle with access to consistent,
reliable, and granular data for understanding demographic
and housing trends that can establish a baseline to inform
strategic and effective housing policy. Some communities
may also lack the technical expertise and/or staff capacity
to maintain regular coordination between neighboring
jurisdictions that is necessary to meaningfully address
housing affordability.
With a long history of regional planning and coordination, DRCOG is well positioned to
convene diverse partners through the development of a regional strategy. A regional housing
strategy will align efforts across the region and identify collective actions to address housing
supply and affordability. DRCOG has collaborated with stakeholders and partners, including
the Advisory Group, to develop a framework, described below, that will serve as the
foundation for creating a regional housing strategy.
Components of a regional strategy
A regional strategy is intended to foster shared understanding, collaboration, and actions to
help jurisdictions make progress toward addressing the region’s housing needs. The
housing strategy will aim to address the region's current and future housing needs outlined
in this report while better coordinating housing and transportation. The framework offers
preliminary purpose and vision, guiding principles, and focus areas to kickstart the process
of developing a regional strategy led by DRCOG, in partnership with member jurisdictions,
and other stakeholders.
Purpose and vision
Defining statements of purpose and vision help orient the strategy toward achieving broader
goals for regional collaboration beyond the specific outcomes related to meeting housing
needs. This preliminary vision builds on DRCOG’s mission as a regional planning
organization and its relationship with member jurisdictions.
» This chapter outlines a
framework for
developing a regional
housing strategy to
address the housing
needs and challenges
identified in the
Regional Housing
Needs Assessment.
DRCOG Regional Housing Needs Assessment 30
♦ Support and further Metro Vision and the 2050 Metro Vision Regional Transportation
Plan.
♦ Develop a consistent, data-informed, and equity-centered approach to analyzing and
responding to housing needs while coordinating with the current and planned
transportation system.
♦ Foster a culture of shared responsibility for addressing housing needs.
♦ Build consensus around a shared framework for action.
♦ Increase capacity within local communities to advance housing strategies and
respond to evolving needs.
♦ Build a region that is more resilient, inclusive and equitable.
Guiding principles
The following principles offer guidance for how a regional housing strategy can focus efforts
and encourage coordinated action that accommodates a variety of partners. To achieve
those ends, a regional housing strategy should:
» Align with the region’s equity vision for communities that offer access to opportunity and
meet the needs of all races, ages, incomes, and abilities.
» Be data-informed, grounded in a shared understanding of the region’s diverse housing
needs.
» Ensure flexibility in responding to the contexts of communities across the region.
» Be comprehensive in addressing the barriers to more housing and more diverse types.
» Reflect the unique roles and authorities of each sector while facilitating collaboration
and shared accountability.
» Identify resource requirements to ensure actionable plans and deliver desired outcomes.
» Balance near-term results with long-term resilience to meet housing needs under varied
economic conditions.
Focus areas and intended outcomes
Clearly articulated outcomes are an essential component of a regional housing strategy.
Organizing outcomes around the identified barriers to housing production in the Denver
region clarifies how specific actions and interventions can directly address challenges and
contribute to overall housing goals.
Exhibit 18. Example outcomes of a regional strategy, by focus area
Focus area Intended outcomes
DRCOG Regional Housing Needs Assessment 31
Land Use, Zoning &
Regulatory Processes
Increased housing supply aligned with regional and local
needs (by household size, income, location, and
preferences).
Infrastructure Better alignment between housing development and
infrastructure availability, condition and capacity.
Development Costs &
Market Factors
Construction of more—and more diverse and affordable—
housing options.
Funding & Capacity Expanded and sustained affordable housing and preservation
efforts.
Community Consensus &
Collective Action
Improved policy alignment, resource leveraging, and broad
support for addressing shared housing needs.
Implementation considerations
Additional factors related to implementation will be critical to define through the strategy
development process. These include:
♦ Roles and Responsibilities: For each intervention, outlining the sector or specific
actors best positioned to lead, those who will play supportive or complementary
roles, and identifying DRCOG’s role will set the stage for coordinated action.
♦ Costs and Timeline: Estimating the scale of investment, sources of funding, and time
required for implementation will help jurisdictions prioritize and sequence actions to
meet their local needs.
♦ Impact: Given the diversity of barriers and issues the regional housing strategy aims
to address, it may be valuable to characterize the impact of specific interventions,
whether it directly results in additional housing unit, is focused on a specific
segment of housing need (such as low-income or older adult housing) or contributes
to capacity-building among jurisdictions or partners.
What is DRCOG’s role?
Given DRCOG’s broad reach and role in shaping regional development, it is uniquely
positioned to coordinate regional housing needs and strategy, particularly because of its
formal planning roles in regional transportation and growth, its ability and role in regional
population forecasting, and collection of growth and permit data. Engagement conducted
among a broad segment of member governments, housing developers, public agencies,
community-based organizations, policy organizations and service providers suggests that
DRCOG can build on these existing roles and strengths as the region moves toward
DRCOG Regional Housing Needs Assessment 32
developing a housing strategy and taking a more coordinated, collaborative approach to
addressing housing needs on a regional level than ever before.
DRCOG is recognized as a valuable partner in ways that can be leveraged for regional
housing work:
♦ Convening and facilitation: DRCOG has been an effective and trusted convener of
diverse stakeholders on issues of regional planning and policy that can facilitate
greater resource alignment and partnerships.
♦ Data collection and analysis: DRCOG is seen as an important source for
comprehensive, standardized data for jurisdictions and other stakeholders across the
region.
♦ Technical assistance: DRCOG has a record of providing technical assistance to
member governments that supplements and extends their local capacities.
♦ Education: DRCOG's current role in sharing information and providing education on
regional issues can be leveraged to share best practice strategies on implementation
at the local level.
Participants identified additional roles DRCOG could step into or expand from its current
activities:
♦ Policy alignment: DRCOG could be a voice for the region at the state level to help
ensure that new legislation and policies related to housing are aligned with other
programs and priorities (e.g., transportation investments, climate planning) and are
designed and funded for effective implementation.
♦ Funding coordination: DRCOG has been successful in setting the regional agenda for
transportation planning and directing investments in line with those goals. A greater
role with understanding, communicating and addressing regionwide housing needs
could provide an additional new lens through which to evaluate and consider regional
transportation system investments as well as housing-transportation coordination
strategies.
How DRCOG plans to move forward
DRCOG will continue to engage member governments and other regional partners and
stakeholders in a robust and collaborative process to craft a regional housing strategy
starting in late 2024. This process will involve working closely with local communities,
housing providers, advocates, and other key stakeholders to build on the shared vision and
guiding principles outlines in this report and develop an actionable strategy for addressing
the region's housing needs.
A critical component of developing the regional housing strategy will be conducting
extensive community engagement to gather input and insights from a wide range of
perspectives. DRCOG recognizes that meaningful community engagement is essential for
DRCOG Regional Housing Needs Assessment 33
crafting effective solutions that are responsive to the diverse needs and priorities across the
Denver region. This engagement will aim to build broader awareness of regional housing
challenges, identify local concerns and opportunities, and foster buy-in and collective
ownership of the resulting strategy.
The regional housing strategy will serve as an important tool for integrating regional housing
priorities into DRCOG's other major planning initiatives. DRCOG will utilize the housing
strategy to guide updates to Metro Vision and the Metro Vision Regional Transportation
Plan. By aligning these plans with the housing strategy, DRCOG can ensure a more
comprehensive and coordinated approach to addressing the region's housing needs in the
context of transportation investments and other regional priorities. By working
collaboratively to develop a comprehensive regional housing strategy and integrate it with
other key planning efforts, DRCOG and its partners can take a significant step toward
fostering more equitable, resilient, and livable communities for all residents of the Denver
region.
Appendix B. Regional Trends 1
Appendix B. Regional Housing Trends
Housing need and availability across the Denver region is not evenly distributed among its diverse
and growing population, particularly for groups that face historic and ongoing disadvantages due to
systemic inequities. As housing prices across the Denver region have soared out of reach for many
households, an affordability crisis threatens long-time residents with displacement, puts
homeownership out of reach for many households, stretches seniors on fixed incomes too thin, puts
more people at risk of becoming homeless, and threatens the ability for the region to attract workers
that support economic growth.
A comprehensive regional housing needs assessment is critical for understanding the nature and
extent of the challenge and to start developing effective solutions and more equitable outcomes. This
section is intended to provide context for the results of the Regional Housing Needs Assessment. It
provides an overview of demographic and housing market trends contributing to growing
unaffordability, while also highlighting nuanced factors that are key to developing an effective
regional housing strategy.
Key Findings
» The Denver region has experienced consistent and strong population growth (20
percent), job growth (33 percent), and increases in median family income (55
percent) over the past 12 years. Employment growth in the technology, sciences, and
healthcare sectors have contributed to an influx of higher-income households.
» The demographic composition of the region is shifting. The region is becoming more
racially and ethnically diverse, with growth in the Hispanic and Black populations,
among other communities of color. Adults 65+ will comprise a larger share of the
population by 2050. Household sizes are shrinking. All of these trends will have
implications for the types of housing needed throughout the region.
» Housing production has largely kept pace with population growth in the last several
years. But the region is still working from a place of historic underproduction and
the existing housing stock does not support the diversity of housing needs across all
income levels and household types. Cost-burdening in the region has increased
substantially since 2000, most acutely for Black renters.
» Median family income grew 57 percent between 2015–2023, which has likely
resulted in widening income inequality across the region. While home sale prices
have risen 180 percent over the last decade, housing affordability and stability
continues to be a challenge for a growing share of low and middle-income
households.
Appendix B. Regional Trends 2
Population and employment growth
The Denver region has experienced substantial growth
over the past decade. Between 2010 and 2022, the
population increased by about 20 percent to reach
just over 3.6 million residents. During this same time
period, the number of jobs in the region increased by
33 percent, adding nearly 550,000 jobs to surpass 2.2
million total jobs in the region by 2022. This period of
economic growth also fostered a tremendous increase
in the median family income (MFI), increasing by
about 55 percent since 2010, as shown in Exhibit 1.
Exhibit 1: Population, Job, and Income Growth, 2000-
2022, Denver Region
2010 2022 % CHANGE 2010–
2022
Population 3,003,317 3,617,790 20%
Jobs 1,675,019 2,223,734 33%
MFI $75,900 $117,800 55%
Source: DRCOG synthesis of State Demography Office Household Forecasts.
The number of jobs in the
Denver region is expected to
continue growing through
2050. Exhibit 2 shows recent
and forecasted job growth for
the region and the state
through 2050. By 2050, the
state is expected to add over
950,000 jobs, representing
an almost 27 percent
increase. Of that growth, the
Denver region is expected to
grow by over 560,000 new
jobs, representing a 25
percent increase to reach 2.7
million jobs by 2050.
Exhibit 2: Job growth, 2050, Denver region
Source: DRCOG Small-Area Forecast (2020) and DRCOG synthesis of State
Demography Office 2022 Household Forecast.
The region’s job growth has been fueled by expansion across several key industry sectors, as
shown in Exhibit 3. There has been substantial growth in professional, scientific, and technical
services, healthcare and social assistance, construction, and accommodation and food services.
» Data presented in this section
comes from a variety of sources.
Therefore, the geographies the
sources cover do not always align
perfectly with DRCOG’s official
jurisdiction boundary. At times,
the “Denver region” refers to
DRCOG’s 10-county region, the
Denver Metropolitan Statistical
Area, or the PUMA-based region.
Appendix B. Regional Trends 3
The influx of high-paying jobs in in professional, scientific, and technical services helps explain
the increase in incomes observed across the region. As the region has grown, so too has
employment in the service sector, as reflected by new jobs in accommodation and food
services.
Exhibit 3: Change in jobs by sector, 2005–2023, Denver region
Source: DRCOG Small-Area Forecast (2020) and DRCOG synthesis of State Demography Office 2022 Household
Forecast.
Appendix B. Regional Trends 4
Demographic and household characteristics
Race and ethnicity
As of 2022, approximately 66
percent of residents in the Denver
region identify as white. The
second largest share of the
population, at 22 percent,
identifies as Hispanic. Black
residents make up the next
largest share at about 4 percent
of the total regional population.
The Denver region’s demographic
profile has shifted over the past
decade with increasing diversity,
with increases in Black, Hispanic,
and Asian populations, along with
those who identify as multiple
races, shown in Exhibit 4.
Exhibit 4: Race and ethnicity, 2009–2022, Denver region
Source: State Demography Office
Age trends
Exhibit 5 shows that the Denver
region's population is expected
to shift toward a higher share of
older households by 2050.
Currently, households headed
by those over age 65 are 23
percent of the total population.
As the millennial generation
ages, the share of households
over 65 is projected to reach 32
percent of the total population.
Meanwhile, the share of
households headed by 26 to 45
year-olds will decrease from 34
percent to 27 percent of the
total.
Exhibit 5: Change in Age, 2023 & 2050, Denver Region
Source: State Demography Office 2022 Household Forecast
Appendix B. Regional Trends 5
This gradual shift towards an older population has implications for the types of housing,
transportation, healthcare, and community services needed to provide age-friendly, livable
neighborhoods for older adults across the Denver region.
Income growth
Median family income
(MFI) in the Denver
region grew steadily
from 2000 to 2015 but
began to grow
substantially after
2015, as shown in
Exhibit 6. Between
2015 and 2023, MFI
rose by 57 percent,
corresponding with
accelerating
population growth and
an influx of high-
income earning jobs in
fields like technology
and healthcare.
Exhibit 6: Median family income, 2000–2023, Denver region
Source: U.S. HUD
Household composition
Households sizes have gotten
smaller in the Denver region over
the past two decades. In 2000, the
average household size was about
2.5 persons per household,
decreasing to about 2.4
individuals per household by
2022. Exhibit 7 shows the current
spread of household sizes in the
region. Currently, 65 percent of
the region’s households consist of
1 to 2 residents, while
approximately 27 percent contain
3 to 4 people. A decline in
household size reflects national
trends of delayed marriage and
childbearing, increased single-
person living, and aging baby
boomers residing alone or with a
partner. With smaller households
Exhibit 7: Household composition, 2022, Denver region
Source: Census 2000, Census 2010, 2022 ACS 1-year, 2022 ACS 5-year
Appendix B. Regional Trends 6
predominant across two-thirds of
the regional population, demand
has likely risen for smaller housing
units. However, it’s important to
consider the range of household
types that exist and how their
housing needs will differ over time.
.
As the Denver region’s demographic and household composition continue to evolve in the coming
decades, the region will need to collectively consider how these changes shape housing demand
across the socioeconomic spectrum. With an aging population, smaller households, rising
incomes yet risk of displacement, and growing racial and ethnic diversity it is critical that
housing policy interventions are made proactively to addresses the specific needs of a changing
population.
HOUSEHOLD COMPOSITION
People of Color households tend to have larger than average household size than the white
household averages. Nationally, Asian, Black, and Latine people are more likely to live in
multigenerational households compared to white people.
» Larger households and multigenerational households may need larger homes or
specific housing types that accommodate the greater number of household members.
These households may experience difficulty finding units of an appropriate size and
design for their household needs.
Appendix B. Regional Trends 7
Housing characteristics and market trends
Housing trends
Exhibit 8 shows that the
region’s existing housing profile
is predominantly single-family
detached units, which account
for 58 percent of the region’s
housing stock. The next largest
share (16 percent) is larger
apartment buildings (20+
units). However, a key
component of the inventory is
smaller apartment buildings in
the range of 2–19 units per
building, which represents
about 21 percent of the total
housing stock and tends to
offer more affordable rents
than larger new construction.
Exhibit 8: Housing types, 2022, Denver region
Source: 2022 PUMS 1-year
Preserving the stock of these smaller apartment buildings will be an important component in
developing a regional housing strategy. With many households unable to afford current home sale
prices and the inventory of affordable rentals limited and at risk of redevelopment pressures,
maintaining existing apartment supply can help create more stability and inclusivity across the
region’s neighborhoods.
Appendix B. Regional Trends 8
Tenure
Housing needs and
preferences often differ
between homeowners and
renters. Exhibit 9 shows
the number of bedrooms
by housing tenure for the
Denver region. Among
ownership households,
most units contain 3 or 4
bedrooms. Renter
households typically live in
smaller units with just 1 or
2 bedrooms. However, this
distribution by tenure can
also reflect missing unit
types and sizes by tenure
across the market.
Exhibit 9: Bedrooms by housing tenure, 2022, Denver region
Source: 2022 PUMS 1-year
With many households priced out of the ownership market in the region, ensuring the rental stock
can provide more options for larger households should be considered. Additionally, providing
smaller and less expensive ownership options for increasing smaller household sizes is also
important to serving an unmet need in the region.
Vacancy
Exhibit 10 shows vacancy
trends for the Denver region
from 1985–2020. Low vacancy
rates indicate a limited supply
of available housing units that
often corresponds with more
sharply increasing housing
prices. Vacancy rates reached
their highest point, since the
late 1980s and early 1990s,
around the time of the 2008
recession. Once the market
began to recover, vacancy rates
began to fall significantly.
However, as housing production
picked up while the market
recovered, a substantial number
of new units were added to the
overall supply around 2015.
Exhibit 10: Vacancy rates, 1985–2020, Denver region,
Source: State Demography Office
Appendix B. Regional Trends 9
After 2015, vacancy rates
started to rise again, but
remained relatively low. As of
2020, the vacancy rate was
about 4.9 percent.
Home sale prices
The regional housing
market experienced
stable home prices
between 2008 and 2012,
as shown in Exhibit 11.
However, as the economy
recovered from the 2008
recession and housing
demand returned, home
values began escalating
at historic levels starting
around 2012. Fueled by
population and job
growth and lagging
construction, sale prices
soared by over 180
percent between 2012
and 2022. Within the
past five years alone,
home sale prices
increased by 52 percent.
Exhibit 11: Home sale prices, 2008–2022, Denver region
Source: Zillow
Household incomes however have not kept pace with rising homeownership prices despite
experiencing substantial growth over the same time period. The region now faces an extreme
mismatch between incomes and for-sale housing stock that locks many households out of
homeownership.
Appendix B. Regional Trends 10
Rent prices
Exhibit 12 shows that
rents in the Denver
region have increased
slower than home sale
prices, but still rose by
about 32 percent over
the last five years. Even
though rents have not
increased at the same
rates as home sale
prices, rising housing
costs have still put
substantial financial
pressure on many
renters in the region.
Exhibit 12: Median rent, 2015–2023, Denver region
Source: Zillow
With vacancy rates decreasing amid a growing and changing population, the demand for housing
continues to place upward pressure on rents.
Housing production
Exhibit 13 shows housing
production trends across the
Denver Region from the last 20
years. The region was
producing a substantial
amount of housing prior to the
2008 recession, (also
suggested by rising vacancy
rates in Exhibit 10). However,
the housing market was slow
to recover after 2008 and did
not recover to pre-recession
rates until around 2015. In
2021 and 2022, the region
saw record levels of housing
production, and while 2023
saw a slow-down, production
levels are still strong.
Exhibit 13: Housing production, 2003–2023, Denver region,
Source: U.S. HUD State of the Cities Data Systems
While collective housing production in the Denver region over the last few years has been
adequately responsive to overall population growth, the supply is still struggling to recover from
the several years where production slowed dramatically, but the population was still growing.
Moving forward, it will also be important to focus on how production may or may not be meeting
the needs of the diverse households across different income categories in the region.
Appendix B. Regional Trends 11
Exhibit 14 breaks down
housing production by building
scale to provide an
understanding of housing
different development types
have been delivered over time.
Through 2006, the majority of
housing produced across the
region was single-family
detached housing. However,
beginning in 2007, multi-
family development has
become a larger share of
annual housing development,
reaching its highest levels
between 2021–2023 when over
50 percent of all housing built
in the region was in
developments with 5 or more
units.
Exhibit 14: Housing production by scale, 2003–2023, Denver region,
Source: U.S. HUD State of the Cities Data Systems
With housing costs outpacing income growth throughout the region, preservation of existing
affordable housing, both naturally occurring and subsidized, as well supporting range of housing
types that are both market-rate and income-restricted affordable housing development will be key
in helping the region meet housing needs.
Cost-burdened households
Current high and rising rates of cost-burdened households across the region indicates that the
current housing supply, both in type and volume, is not sufficient to meet the region’s needs. A
household is considered to be cost-burdened if it spends more than 30 percent of its income on
RENTERS AND COST-BURDENING
Renters are more likely to be cost-burned than homeowners for a few reasons:
» Renters typically have lower incomes than homeowners.
» Rents adjust more frequently compared to mortgages, which are usually fixed-rate and
stable over several decades. Renter households are more vulnerable to price increases.
» Stricter income and asset qualifying rules associated with mortgages compared to rental
applications generally make it less likely for homeowners to overspend on housing costs.
Appendix B. Regional Trends 12
housing costs, and a household is considered to be severely cost-burdened if it spends more 50
percent on housing costs.
Exhibit 15 shows the number and
share of renter households across
the region that are cost-burdened
and severely cost-burdened. As of
2022, approximately 51 percent
of renters in the Denver region
were cost-burdened, with 25
percent of them being severely
cost-burdened. This represents
an increase of about 12 percent
in the total share of cost-
burdened renters since 2000,
when the percent of cost-
burdened renters in the region
was about 39 percent.
Exhibit 15: Cost-burdened renter households, 2000 and 2022
Source: 2000 Decennial Census, 2022 ACS 5-year Estimate
Exhibit 16 shows the share of cost-
burdened renters disaggregated by
race and ethnicity for the Denver
region. Black renter households
experience the highest rate of cost-
burdening at about 60 percent,
including 34 percent who are
severely cost-burdened – the highest
share of renter households that are
classified as severely cost-burdened
across all demographics. Hispanic
and "All other groups" also
disproportionately cost-burdened,
when compared to White and Asian
renters that experience the lowest
rate of cost-burdening across the
region.
Exhibit 16: Cost-burdened households by race and ethnicity
Source: 2000 Decennial Census, 2022 ACS 5-year Estimate
Appendix B. Regional Trends 13
Exhibit 17 shows the spatial
distribution of renter
households "renting up" across
the region—meaning the
household is renting a unit that
is costs more than what their
income can reasonably afford.
While an imperfect measure of
cost-burdening, it can help
illustrate where renters in the
region are spend more for
rental housing.
Exhibit 17: Share of renters renting “pp”
Source: 2022, PUMS 1-year
The Boulder area shows the highest rates of renters renting up, partly due to its large student
population but more broadly due to its constrained and unaffordable housing market. Areas just
north and southeast of Denver also show high shares of renters renting up. These areas are more
suburban in nature and likely lack a more diverse housing supply where there are more renters in
higher cost single-family rentals. Conversely, in areas where the housing stock offers greater
diversity of prices and unit types, cost-burdening among renters appears lower.
Exhibit 18 shows the range of housing costs measured by percent of Annual Median Income
(AMI), meaning housing that is affordable to those income brackets. In every housing price
category, there are households with different incomes occupying those units, some units are
“matched” to a households incomes, and some are not. The analysis shows the greatest
mismatch occurring in units suitable for incomes between 60–100 percent AMI. This mismatch
indicates there is not enough housing supply available in other affordable price ranges. As a
result, some households are forced to overspend to secure housing, while others opt for lower-
priced units that don't match their income level. These mismatches highlight gaps in the housing
stock at certain price points for specific income groups.
Appendix B. Regional Trends 14
Exhibit 18: Mismatch between income and housing costs
Source: ACS PUMS 1-year 2022
The level of cost-burdening across the region points to an
undersupply of affordable housing options, especially for
lower-income residents. While there has been a sharp
uptick in new development in the last few years which has
brought much needed market rate housing to the market,
low- and moderate-income households are increasingly
finding it difficult to find attainable housing. In addition
to increasing the diverse housing options across the
region, more inclusive and equitable housing growth
focused on affordability would help alleviate cost
pressures facing many of the region’s households.
Tackling the mismatch between housing supply and
demand across submarkets and income levels is key to
meeting a broader spectrum of housing needs.
HOUSING MISMATCH
How to read the chart
» Each square represents 1,000
homes.
» For example: 22,000 of the rental
homes in the region that are
affordable to 0–60 percent AMI are
rented by 60–80 percent AMI
income households, so they are
“renting down,” meaning their
income suggests they could afford
a unit at a higher cost than they
are currently occupying.
Appendix B. Regional Trends 15
Homelessness
Metro Denver Homelessness Initiative is the
designated Continuum of Care for the Denver
Metro Area and is responsible for managing the
Homeless Management Information System
(HMIS) that complies with HUD’s data
collection, management, and reporting
standards. The HMIS system collects client-level
data and data on the provision of housing and
services to homeless individuals and families
and persons at risk of homelessness.
Exhibit 19 shows annual PIT count for the
Denver Metro between 2008–2022. In 2022, the
Denver Metro reached its highest count of
unsheltered people included in the PIT count
since 2008. In 2023, the region reached its
highest number people located in emergency
shelters and reached it’s the lowest year of
people located in transitionary housing in the
last 14 years.
Exhibit 19: Annual Point-in-Time Count, Denver Metro, 2008–2023
Source: Metro Denver Homeless Initiative
ANNUAL POINT-IN-TIME COUNT
Metro Denver Homelessness Initiative
According to MDHI’s 2023 State of
Homelessness report, between July 1, 2021
and June 30, 2022, approximately 27,860
people accessed MDHI services or housing
related to homelessness across the region’s
HMIS Partner Agencies. A total of 6,884
people were included in the annual Point-In-
Time Count (PIT) conducted in January 2023.
Of those included in the PIT count on that
evening:
» 51% of those were in an emergency shelter
» 19% were in transitionary housing
» 30% were unsheltered
Appendix B. Regional Trends 16
Comprehensive data on those experiencing homelessness is notoriously challenging to obtain due to
the transient nature of the population and lack of coordination between the variety of agencies, non-
profit, and service providers that work in the homelessness space. PIT counts severely undercount
those experiencing homeless and can only offer a snapshot of what homelessness might look like on
an individual night. However, using the HMIS data likely overcounts, as it includes all people that
sought housing-related services through MDHI or one of its partner agencies, though not all of those
people necessarily need housing.
Appendix C. Regional Housing Needs Assessment Technical Methodology 1
Appendix C. Regional Housing Needs
Assessment Technical Methodology
Introduction
The Denver Regional Council of Governments (DRCOG) seeks to develop a methodology for a
regional housing needs assessment to understand baseline needs and improve regional
coordination on housing planning and production. Colorado does not currently mandate a specific
methodology for assessing housing need at any jurisdictional level, though many local
governments do undertake such analyses on an ad hoc basis. This project serves as a foundation
both for regional level-setting and future analysis and methodological refinement. As such, the
project team’s methodology is as important to document and explore as its findings.
This memo is technical in nature. It is written for an audience familiar with demographic
forecasting, housing market function, and the data that are generally used to understand and
project housing need. The final report summarizes the results for decision-makers and other
interested parties, and incorporates the results of stakeholder engagement that were conducted
concurrently with this assessment.
Measuring regional need
A regional housing needs assessment estimates the number of households in each income
category across the Denver region that will need dwelling units that are affordable to them, now
and through 2050. This memo summarizes the project team’s methodology for accomplishing
this goal, with a focus on the primary methodological decisions and key assumptions used.
The methodology describes the source data, components of the assessment, and the analytical
steps to calculate housing need.
Data sources
The choice of datasets is fundamental to the methodology’s ability to achieve its guiding
principles. ECOnorthwest and DRCOG evaluated available data sources, including national, state,
and regional sources, and built on past experience with regional housing needs assessments. We
determined that the most appropriate primary data source is 1-year Public Use Microdata
Sample from Census (PUMS), as it provides annually updated data that is more accurate and
reliable than other options available at the regional level. PUMS provides more current data than
other sources we considered, such as the Comprehensive Housing Affordability Strategy (CHAS)
or the 5-year sample of the American Community Survey (ACS). The Census Bureau produces the
PUMS files so that data users can create custom tables that are not available through pre-
tabulated (or summary) ACS data tables. PUMS are available for geographies of about 100,000
people, called Public Use Microdata Areas (PUMAs). The Denver region has 25 PUMAs.
Appendix C: Regional Housing Needs Assessment Technical Methodology 2
ECOnorthwest supplemented PUMS data with several other sources:
i Colorado State Demography Office—a division of the Department of Local Affairs
(DOLA)—population (2022), household (2022), and employment (2020) forecasts.
o DRCOG provided the project team with a modified version of the 2022 household
forecast. The initial total number of households by age group and household size
is derived from a synthetic population generated from the 2013 5-year PUMS
estimates. Growth rates by age group and household size from the State
Demography Office’s forecast are used to calculate household counts through
2050. DRCOG then adjusted the county-level distribution of households based on
housing development data from Zonda and CoStar in 2022 to 2024 to shift
household growth to higher unit growth counties. Finally, DRCOG makes a small
adjustment to the regional household count in each year to account for differences
in persons per household between the State Demography Office forecast and
DRCOG’s synthetic population.
i DRCOG small-area forecast for households and employment from 2020. The household
and employment totals in the forecast are based on the forecasts from the State
Demography Office. The household incomes in the small-area forecast are based on
2013 5-year PUMS data.
i Metro Denver Homeless Initiative (MDHI) State of Homelessness Report, 2022–2023
provided data about the number of people experiencing homelessness in the region.
i U.S. Census Bureau’s Longitudinal Employer-Household Dynamics Origin-Destination
Employment Statistics (LODES) from 2020 helped identify regional submarket
geographies.
i Rental market data from CoStar informed assumptions about the price filtering of
multifamily housing over time.
i U.S. Census Bureau’s Building Permit Survey and DOLA’s Municipal Housing Estimates,
2010–2020 informed assumptions about the rate of residential building demolition.
Key metrics
In addition to demographic and housing stock data, the methodology uses measures of housing
market function, such as vacancy and affordability, throughout the process. The details of these
metrics are described below.
Vacancy measures
This analysis uses different measures of vacancy throughout the process, depending on context
and intended comparison.
i Historic rate: The observed historic rate of vacancy—4.7 percent—is the 75th percentile
of national vacancy between 1980 and 2010 (using decennial Census and ACS 1-year
Appendix C: Regional Housing Needs Assessment Technical Methodology 3
data at the Metropolitan Statistical Area level). ECOnorthwest used this rate to measure
underproduction in order to compare the current supply to the amount of housing that
would have kept pace with national vacancy trends.
i Observed rate: The current observed rate of vacancy of 6.5 percent is reported in ACS 1-
year data, with second and vacation homes removed. ECOnorthwest used this rate to
compare submarket vacancy rates with current national trends to identify areas with
housing markets that are more constrained than average.
i Target ratio: The target ratio of 1.072 housing units per household—or roughly 7
percent vacancy—comes from scholarly literature about adequate vacancy to support a
more flexible housing market, with greater affordability. ECOnorthwest used this ratio
when calculating future housing demand so as not to project a currently constrained
housing market into the future.
Housing affordability
Matching households to available housing units based on income requires a crosswalk from
household income to reported prices for both owned and rented housing.
i Owned units: The affordability of owned units is calculated using a price-to-income ratio
of 3.36, where the income needed to afford a home is 3.36 or more of the home’s
reported value. U.S. HUD uses this ratio to measure housing affordability in its
Comprehensive Housing Affordability Strategy (CHAS) data, and is based on
underwriting requirements for the Federal Housing Administration’s loan insurance
programs.1
i Rented units: We use U.S. HUD’s standard of rental affordability, where housing costs
cannot exceed 30 percent of a household’s gross income.2
i Adjusting for unit size: By default, AMI measures assume a four-person household. To
better match units to households by income, ECOnorthwest adjusts the affordability of a
unit based on the number of bedrooms using U.S. HUD’s adjustment factors,
summarized in Exhibit 1. This adjustment prevents an overestimation, for example, of
one-bedroom units affordable to a four-person household that could not comfortably
occupy that unit. ECOnorthwest applies these adjustment factors to each housing unit
observation in the PUMS data to determine the income needed to afford that unit. For a
one-bedroom unit, the household income that could afford the unit is 75 percent of the
income needed to afford the nominal rent, assuming U.S. HUD’s affordability standard
of 30 percent of gross income.
1 Paul Joice, “CHAS Affordability Analysis.” U.S. HUD, working paper, May 20, 2013.
2 U.S. HUD programs include utility costs in total housing costs. Our analysis considers only reported
rental prices.
Appendix C: Regional Housing Needs Assessment Technical Methodology 4
Exhibit 1. HUD multipliers to adjust housing affordability
Number of Bedrooms 0 1 2 3 4 5
Adjustment Factor 0.70 0.75 0.90 1.04 1.16 1.28
Source: U.S. HUD
Components of housing need
The estimation of total regional need derives from three component parts: future need,
underproduction, and units to address homelessness. The details of these components are
described below.
Future need
In this analysis we calculate the total units that will be needed to accommodate the population in
2050. Population forecasts provided by the State Demography Office account for natural
population changes from birth rates (fertility) and death rates (mortality) and migration-related
population changes from people moving in and out of a region. The study of demographics is
complex and factors in macroeconomic statistics like fertility rates, health and longevity rates,
the racial and ethnic makeup of the region, and other factors.
We compare the estimate of the total households that will need housing in 2050 to the current
supply of housing. We assume that the current supply will carry forward, with some loss due to
demolitions as buildings age out of their useful life. This approach does not assume a rate of
housing production or number of units that will be built over the planning horizon based on past
trends. Because the Regional Housing Needs Assessment is intended to support housing planning
and policy, understanding current and future need in total is crucial. Assuming a rate of
production results in discounting or underestimating that future need in ways that can perpetuate
underproduction and an overall shortage of housing.
Future need is calculated using the following steps:
i Future households. The project team used data from the State Demography Office,
provided and modified by DRCOG, for projected household growth through 2050.
DRCOG adheres to the official regional projections of the Colorado State Demography
Office for all modeling associated with the DRCOG small-area forecasts, making only
minimal adjustments.
i Future housing gap. We project the current supply of housing into 2050, with
adjustments to account for units that cannot be occupied and those that will be lost
over time to demolitions. The assessment of occupiable units—or the current housing
supply—removes homes designated in Census data as second or vacation homes and
homes lacking complete plumbing and kitchens, since those units are not available for
long-term occupancy. The project team assumed that 0.1 percent of units will be lost
each year to demolitions due to the age and diminished value of the structure. This is
roughly equivalent to the national rate of demolition. Because units more likely to be
demolished are older or in disrepair, and thus likely to be more affordable, all
Appendix C: Regional Housing Needs Assessment Technical Methodology 5
demolished units are taken out of the supply distributed to the lowest income segments
in the next step. ECOnorthwest then multiplied future households by a target ratio of
households to housing units of 1.072 (or roughly 7 percent vacancy) to arrive at the
target supply of housing units. The difference between the target supply and the
projected future supply is the total future housing need.
i Unit income distribution. DRCOG’s small-area forecasts include nominal household
income, which allowed the project team to model the future distribution of incomes
across the Denver region. DOLA’s control total household forecasts are cross-tabulated
by householder age and household size, as are DRCOG’s small-area forecasts. Using
this connection, ECOnorthwest applied the income distributions by household size and
age (converted to percent-of-AMI using 2013 data on regional AMI) from the small-area
forecasts to the regional DOLA household forecast. Exhibit 2 illustrates this shift in the
income distribution by age between 2022 and 2050 using household estimates for
which householder age and income data is available, from PUMS and DRCOG small-area
forecasts.
Exhibit 2. Householder Age Distribution by Income, 2022 and 2050
Source: 2022 distribution based on U.S. Census Bureau, ACS 1-year 2022 PUMS. 2050 distribution based
on DRCOG Small-Area Forecast (2020), and DRCOG synthesis of State Demography Office 2022 Household
Forecast.
ECOnorthwest also adjusted the affordability of units to account for market filtering over
time. Based on an internal analysis of regional housing stock using CoStar rent and
building data, ECOnorthwest assumed that rental housing units reduce in price by 0.4
percent of AMI per year (e.g., a unit affordable at 50 percent AMI today will be affordable
Age group
18–24
25–44
45–64
65+
18–24
25–44
45–64
65+
Appendix C: Regional Housing Needs Assessment Technical Methodology 6
at 46 percent AMI in 10 years). A separate analysis of ownership housing units using
regional assessor’s data indicated no region-wide price filtering of owned housing units.
Underproduction
Underproduction, or the lack of enough units to meet demand, is a key reason that housing
markets experience rising prices. Accounting for current underproduction is a key feature of the
Regional Housing Needs Assessment methodology. This component accounts for the number of
housing units that are not available, but should be if the region had produced enough units each
year to match the historic national vacancy rate of 4.7 percent. If the region has not met this
threshold, housing is likely too scarce and prices will rise. Households with the lowest incomes
will struggle most to find scarce units, cost burdening will increase, and rates of homelessness
may also increase. In other words, underproduction leads to cost burdening.
There are a few approaches to identifying a housing shortage. One way that is commonly used
because it can be completed at the city-level given available data sources, is to identify all
households that are cost burdened in each geography, with an assumption that each cost-
burdened household needs a unit that is affordable to them. Yet simply summing the number of
cost-burdened households and calling that a “housing shortage” projects an oversupply of
housing in the market, because cost-burdened households do have existing units, even if they are
not sorted into those units by income in ways that they can afford. This is the reason that the
Regional Housing Needs Assessment does not use this method to identify the shortage of
housing. The cost-burden method is a useful way to understand the shortage of affordable units
in a market and adds helpful information to inform housing production policies. It is not,
however, a satisfactory way to understand the number of units that are needed in an entire
housing market.
ECOnorthwest’s methodology takes a different approach to the shortage analysis: it identifies the
number of units that would be needed to achieve a sufficient balance of units to current
residents—including households that have not formed due to limited housing options—and then
categorizes those units across the current distribution of household income. This approach
recognizes that underproduction in a housing market results in greater cost burdening for lower-
income households. The analysis of underproduction and housing for people experiencing
homelessness serves the purpose of estimating housing needed to meet immediate housing
needs, primarily for the lowest-income residents.
Current underproduction is calculated using the following steps:
i Current households. The current number of households is calculated using ACS 1-year
2022 PUMS data and an analysis of missing households. Missing households represent
residents who are currently sharing housing—for example, young adults living with
parents or adults living with roommates—who would otherwise occupy their own units if
there were additional housing supply that they could afford. ECOnorthwest calculated
the number of missing households for age cohorts using a baseline measure of
headship rates in 2000. These 2000-era householder rates are calculated for each 10-
year age cohort using decennial Census data. The rates are then applied to the 2022
PUMS-derived population of the same age cohorts to calculate the estimated number of
Appendix C: Regional Housing Needs Assessment Technical Methodology 7
households the region would have today under pre-recession economic conditions. This
hypothetical estimate is then compared against the actual total number of households
by age cohort. Where the actual number of households is less than the hypothetical
target, the difference is the number of missing households.
i Target supply. The region’s current number of households, combined with missing
households, is multiplied by a historic national vacancy rate of 4.7 percent to arrive at
the target supply of housing units. Underproduction occurs when the total number of
occupiable units in a region is less than the target supply. Units that represent current
underproduction are subtracted from the total future need calculated for the future
need component.
i Unit income distribution. Because underproduction leads to cost burdening in the
market, the effects of underproduction are most acutely felt by those with lower
incomes who need access to affordable housing now, in today’s market. In this analysis,
underproduced units are distributed into percent-of-AMI income bins proportionate to
the income distribution of cost-burdened renter households in the region, as reported in
PUMS data.
Homelessness need
The second component of regional need is the calculation of units needed for the population
currently experiencing homelessness. This is a key feature of the recommended methodology.
Populations experiencing homelessness are generally not captured in foundational datasets
derived from the Census because the Decennial Census and the American Community Survey rely
on counting and sampling people with addresses, which those struggling with homelessness may
not have. These people are also not accounted for in estimates of underproduction that rely
either on a target vacancy rate or a national ratio of housing units to households—nationally,
many communities struggle with homelessness despite having an average vacancy rate or an
overall ratio of 1.072 housing units for every household.
Determining unit need for homeless residents required particular attention, because available
datasets have many limitations, most importantly undercounting populations. We relied heavily
on the limited research that is available on this topic, and discussion with DRCOG staff and
stakeholders with expertise in research and providing services for those experiencing
homelessness in the Denver region.
Housing to address homelessness is calculated using the following steps:
i Total homeless households. We used data from the Metro Denver Homeless Initiative
(MDHI) State of Homelessness Report, 2022–2023 to estimate the number of
households experiencing homelessness. MDHI data is calculated from a combination of
Point-in-Time count data as well as tracking the number of people accessing services
from providers across the region. MDHI’s State of Homelessness Report tabulated total
individuals seeking services and individuals in families as a subtotal. ECOnorthwest
converted the individuals-in-families subgroup to households using the regional persons
per household (as observed in PUMS data), and assumed the remainder are single-
person households.
Appendix C: Regional Housing Needs Assessment Technical Methodology 8
¾DRCOG staff have indicated that they intend to continue discussions with MDHI to
learn more about what information MDHI and its partners collect for their
operational and strategic planning purposes. In addition to ways additional
discussion might inform future housing strategy development, DRCOG staff may
also identify opportunities to use the information collected across MDHI's
Continuum of Care to refine the above process for future assessments of housing
need.
i Unit income distribution. There is no existing, quality dataset with information about
the incomes of people who are experiencing homelessness, but we know that many
households that are experiencing homelessness have incomes and still cannot find an
available home that is affordable to them. Based on the literature and ECOnorthwest’s
experience assessing housing needs in other regions, the project team distributed all
units needed to address homelessness to the lowest income segment of 0–30 percent of
AMI.
Additional considerations
In addition to the principal components discussed above, the project team considered other
demographic trends and housing supply factors as part of the Regional Housing Needs
Assessment methodology. These factors were not incorporated into the methodology at this time,
for reasons explained below. As DRCOG continues to refine its approach to the Regional Housing
Needs Assessment, update data sources, respond to changing conditions, and incorporate new or
additional policy priorities, there may be a place for these and other factors in future
assessments.
i Demand for second and vacation homes: When planning for future housing need, any
loss of units to second and vacation homes effectively requires building more units to
keep up with household formation. Units lost to second and vacation homes can occur
through conversions of existing housing stock but could also include some purpose built
second and vacation homes. The project team evaluated the trends in the stock of
second and vacation homes in the Denver region to determine whether to include
demand for these units into the model. Currently, second and vacation homes are a very
small share (generally less than 2 percent) of homes across the Denver region, with a
slightly larger share in mountain communities in the west (approximately 7 percent).
Across the region, the share of second and vacation homes has been declining over
time. Given these figures, the project team did not include loss of future units to second
and vacation homes as a variable in the model for future need. Second and vacation
homes are removed from the current stock of available housing for the purposes of
estimating current needed units compared to households (i.e., underproduction).
i Induced or reduced in-migration: If jurisdictions in the Denver region build housing and
make progress toward increasing supply, the region may become more affordable and
competitive relative to other metro areas. A more affordable housing market may spur
more migration to the region than is accounted for in the State Demography Office’s
population growth projections, including from nearby counties from which people
already commute to the region for work. Given that this modeling relies on the
performance of other metro area housing markets relative to the Denver region’s, the
Appendix C: Regional Housing Needs Assessment Technical Methodology 9
project team did not undertake the extensive modeling necessary to account for this
potential effect. Additionally, the converse could occur if the Denver region sees in-
migration levels below what the State Demography Office forecasts for the region to
maintain a labor force sufficient to help make up for residents projected to age out of
their prime working years, which could occur if progress is not made toward increasing
supply. Because the Regional Housing Needs Assessment will continue to be updated
with new data and evolve over time, future assessments will incorporate growth trends
captured in the state’s population growth methodology, including changes in migration.
i Land capacity: The Regional Housing Needs Assessment estimates the need for housing
based on current and future population trends and distributes that need across the
region based on demographic factors, features of the housing market, and regional
transportation resources. The project team also adjusted the distribution of needed
housing to accommodate varying shares of water and protected open space across the
region. The Regional Housing Needs Assessment does not include more granular
information about developable land. The project team recognizes that cities in the
region face varied on-the-ground conditions, such as the supply of land, infrastructure,
access to water, and other considerations. Many of these issues relate to policy choices
about how to use land to meet community needs. The Regional Housing Needs
Assessment provides information to support DRCOG and its member jurisdictions to
address these varied challenges to help meet the regional need for more housing.
Results
The following Exhibits present the results of the Regional Housing Needs Assessment for a time
horizon of 2023–2050 and a 10-year scaled estimate.
Exhibit 3. Summary of Housing Need by Component, 2023–2050
FUTURE NEED UNDERPRODUCTION HOMELESSNESS
NEED TOTAL UNITS
458,896 26,330 26,394 511,620
90% 5% 5% 100%
Source: ECOnorthwest analysis; DRCOG Small-Area Forecast (2020), DRCOG synthesis of State Demography
Office 2022 Household Forecast, U.S. Census Bureau, ACS 1-year 2022 PUMS estimates; MDHI 2022–2023
State of Homelessness Report.
Exhibit 4. Housing need components by income, 2023–2050
COMPONENT OF
NEED 0–30% 30–60% 60–80% 80–
100%
100–
120% >120% TOTAL
Future need 138,435 118,798 16,527 72,542 24,820 87,774 458,896
Underproduction 9,377 10,176 4,704 1,340 732 – 26,330
Homelessness
need 26,394 – – – – – 26,394
Total 174,206 128,974 21,231 73,882 25,552 87,774 511,620
Appendix C: Regional Housing Needs Assessment Technical Methodology 10
Source: ECOnorthwest analysis; DRCOG Small-Area Forecast (2020), DRCOG synthesis of State Demography
Office 2022 Household Forecast, U.S. Census Bureau, ACS 1-year 2022 PUMS estimates; MDHI 2022–2023
State of Homelessness Report.
Exhibit 5. 10-Year scaled estimate of housing need
FUTURE NEED UNDERPRODUCTION HOMELESSNESS
NEED TOTAL UNITS
163,891 26,330 26,394 216,615
76% 12% 12% 100%
Source: ECOnorthwest analysis; DRCOG Small-Area Forecast (2020), DRCOG synthesis of State Demography
Office 2022 Household Forecast, U.S. Census Bureau, ACS 1-year 2022 PUMS estimates; MDHI 2022–2023
State of Homelessness Report.
Exhibit 6. 10-Year scaled estimate of housing need components by income
COMPONENT OF
NEED 0–30% 30–60% 60–80% 80–
100%
100–
120% >120% TOTAL
Future need 49,441 42,428 5,902 25,908 8,864 31,348 163,891
Underproduction 9,377 10,176 4,704 1,340 732 – 26,330
Homelessness
need 26,394 – – – – – 26,394
Total 85,212 52,604 10,606 27,248 9,596 31,348 216,615
Source: ECOnorthwest analysis; DRCOG Small-Area Forecast (2020), DRCOG synthesis of State Demography
Office 2022 Household Forecast, U.S. Census Bureau, ACS 1-year 2022 PUMS estimates; MDHI 2022–2023
State of Homelessness Report.
Note: Components of need do not sum to total because of rounded unit counts.
Exhibit 7. 2023 Supply of housing units and future demand by income, 2050 and 10-year scaled
estimate
TIME HORIZON 0–30% 30–60% 60–80% 80–
100%
100–
120% >120% TOTAL
2023 Supply 104,069 224,311 199,039 133,118 140,029 612,485 1,413,051
2050 Demand 278,275 353,285 220,270 207,000 165,581 700,259 1,924,670
10-Year scaled
estimate
demand
189,281 276,915 209,645 160,366 149,625 643,833 1,629,665
Source: ECOnorthwest analysis; DRCOG Small-Area Forecast (2020), DRCOG synthesis of State Demography
Office 2022 Household Forecast, U.S. Census Bureau, ACS 1-year 2022 PUMS estimates; MDHI 2022–2023
State of Homelessness Report.
Submarket share of regional need
While the Regional Housing Needs Assessment produces an aggregate estimate of current and
future housing needs for the entire Denver region, effective planning and policy to achieve that
housing will happen within more localized geographies. To understand how total need could be
distributed across the region to align with growth trends, local needs, and DRCOG’s Metro Vision,
Appendix C: Regional Housing Needs Assessment Technical Methodology 11
the project team distributed total need among five regional submarkets. The result is an estimate
of the number of needed housing units by income for five submarkets within DRCOG’s service
area (which this report refers to as the submarket share of housing need).
Submarket geographies
Once the project team identified PUMS as the best available data source for the Regional Housing
Needs Assessment, defining submarkets using PUMAs offered the best option to move between
the regional and submarket levels with consistent data sources and boundaries.
Key methodological decisions
The project team considered two approaches to defining submarkets: 1) creating contiguous
areas or 2) defining non-contiguous submarkets by demographic or planning conditions, such as
grouping urban centers (as defined in Metro Vision) together. The project team decided to define
submarkets as contiguous areas to better reflect how regional housing submarkets function and
support potential future collaboration between neighboring and nearby jurisdictions to address
shared housing needs.
ECOnorthwest conducted a cluster analysis using multiple statistical methods to create draft
maps of contiguous market areas. The project team determined that five clusters captured
meaningful differences across the region while not overcomplicating the analysis (and future
development of targeted strategies). Specifically, the project team used two primary methods to
identify potential PUMA-based submarkets: 1) a SKATER algorithm to identify similar areas based
on demographic data, and 2) the Walktrap network clustering analysis informed by commute
patterns using origin-destination data from LODES (2020). The SKATER analysis used the
following inputs all pulled from PUMS 2022 1-year data:
i Share of population earning below 80 percent of Area Median Income (AMI)
i Share of renters and share of cost-burdened renters (paying more than 30 percent of
total income in housing costs)
i Average household size
i Share of households with children
i Share of households older than 64
i Share of multifamily housing
i Average home value
i Average gross rent
i Share of renter households
The draft maps produced through these analyses are shown in Exhibit 8. After conducting
independent SKATER and Origin-Destination analyses, the project team decided to use clusters
informed by commute patterns. This version of submarket geographies was then manually
adjusted by the project team to reassign two PUMAs into a fifth submarket to separate the rural
Appendix C: Regional Housing Needs Assessment Technical Methodology 12
mountain areas in the west as a distinct submarket. The project team also made a manual
adjustment to avoid splitting two large jurisdictions into separate submarkets.
Exhibit 8. Submarkets considered in the analysis
SUBMARKETS CONSIDERED METHOD AND CONSIDERATIONS
SKATER (Spatial ‘K’luster Analysis by
Tree Edge Removal)
This version of K-means analysis seeks to
reduce the total variation of all
demographic variables within the
specified number of submarkets, with
the requirement that clusters are
spatially contiguous.
Origin-Destination Clustering
This analysis used origin-destination
information from LODES to implement
the Walktrap network clustering
algorithm that uses the flow to jobs as
weights. Like SKATER, this network
analysis was designed to find
statistically-significant clusters.
Appendix C: Regional Housing Needs Assessment Technical Methodology 13
SUBMARKETS CONSIDERED METHOD AND CONSIDERATIONS
Origin-Destination informed SKATER
This analysis attempted to synthesize the
two algorithmic methods by including the
number of commutes from each PUMA to
each Origin-Destination cluster
identitfied in the Walktrap method as an
additional input to the SKATER model,
alongside the demographic variable
inputs used in the original SKATER
clustering model.
Revised Origin-Destination Clustering–
final map for the Regional Housing
Needs Assessment
This revised map reassigned 2 PUMAs in
the Origin-Destination clustering map to
create a fifth submarket. This map
preserves Denver within a single
submarket and creates a distinct
submarket for the mountain areas in the
west.
Source: ECOnorthwest; ACS 1-year 2022 PUMS data; LODES 2020.
Distributing regional need among submarkets
In consultation with DRCOG staff and the advisory group, ECOnorthwest created a model for
distributing the 10-year scaled estimate of the Regional Housing Needs Assessment results
among the five submarkets based on criteria that reflect both current conditions and needs and
forecasted future conditions and needs. The criteria include factors that shape the demand for
housing and align with regional planning goals for greater affordability across the region and
matching growth with multimodal transportation systems. At a high level, the categories and
rationale behind the criteria are as follows:
i Population: Housing need corresponds directly to population size.
i Regional jobs: Employment is a driver of housing demand. Better matching of job and
housing locations creates more options for housing, shortens commute times and
distances, and eases congestion and vehicle travel on the region’s transportation
systems.
Appendix C: Regional Housing Needs Assessment Technical Methodology 14
i Multimodal accessibility: Metro Vision outlines a plan for more compact urban
development and a greater use of transit, walking, and biking for daily activities.
i Housing availability: Low rental vacancy rates help illuminate places where housing is
particularly in high demand and short supply, relative to the region as a whole.
i Housing affordability: Every community in the Denver region has a role to play in
planning for housing affordable to a range of incomes. Areas with a smaller supply of
affordable housing contribute to regional inequities in access to opportunity and
suboptimal transportation outcomes.
Exhibit 9 summarizes the criteria included in the model, the method of calculating and applying
each criterion, and the data source for each input.
Exhibit 9. Summary of Distribution Criteria for Submarket Share of Total Housing Need
CRITERION METHOD DATA SOURCE
Current conditions
Share of regional population, 2022 Positive weight DRCOG Small-Area
Forecast (2020)
Share of regional jobs, 2022 Positive weight DRCOG Small-Area
Forecast (2020)
Share of pedestrian/transit-
accessible jobs and households
(< 0.5 miles)
Calculate travel distance of
each census block to nearest
transit amenity in RTD data;
positive weight
DRCOG Pedestrian
Focus Areas
Share of housing units needed to
meet national vacancy rate
Calculate gap between
submarket vacancy and the
observed national rate of 6.5
percent; inverse weight
ACS 1-year 2022
PUMS
Share of region’s affordable units
(0–60% AMI) Inverse weight ACS 1-year 2022
PUMS
Future conditions
Share of regional population, 2033 Positive weight DRCOG Small-Area
Forecast (2020)
Share of regional jobs, 2033 Positive weight DRCOG Small-Area
Forecast (2020)
Share of developable land
proximate to planned Rapid Transit
System network
Calculate share of land within
0.5 miles of the RTS network
and Pedestrian Focus Areas,
removing protected open
space and water; positive
weight
DRCOG RTP 2050
Network
Share of "short” commutes Share of commutes under 30
minutes; positive weight
ACS 1-year 2022
PUMS
Broadly, the inputs that reflect current conditions distribute the units of the Regional Housing
Needs Assessment that represent current needs—those for underproduction and homelessness.
Appendix C: Regional Housing Needs Assessment Technical Methodology 15
Inputs that reflect future conditions distribute the future needs component of the results. The
model weights each of the current and future conditions inputs equal relative to one another and
distributes units to submarkets based on each submarket’s share of each input.
The example below illustrates the steps in this method using the future condition input related to
future transit access:
1. The share of developable land proximate to planned Rapid Transit System determines 25
percent of future need (100 percent divided equally among four inputs).
2. The Central submarket has 37 percent of the land proximate to the planned Rapid Transit
System network.
3. The Central submarket will receive 37 percent of 25 percent of the total regional future
need from this input.
Results
Exhibit 10. Summary of submarket share of regional need by phase, 10-year scaled estimate
SUBMARKET HOMELESSNESS
NEED UNDERPRODUCTION FUTURE NEED TOTAL UNITS
Central 7,110 7,093 56,047 70,250
North 4,219 4,209 28,710 37,138
North Central 3,509 3,500 27,167 34,176
Southeast 10,653 10,628 48,250 69,531
West 902 900 3,717 5,520
Source: ECOnorthwest analysis; DRCOG Small-Area Forecast (2020), DRCOG synthesis of State Demography
Office 2022 Household Forecast, U.S. Census Bureau, ACS 1-year 2022 PUMS estimates; MDHI 2022–2023
State of Homelessness Report.
Exhibit 11. Submarket share of regional need by income, 10-year scaled estimate
SUBMARKET 0–30% 30–60% 60–80% 80–100% 100–
120% >120% TOTAL
Central 26,544 17,251 3,286 9,221 3,229 10,720 70,250
North 14,379 9,059 1,786 4,753 1,670 5,491 37,138
North
Central 12,951 8,386 1,604 4,473 1,567 5,196 34,176
Southeast 28,994 16,598 3,636 8,168 2,905 9,229 69,531
West 2,344 1,310 295 633 226 711 5,520
Total 85,212 52,604 10,606 27,248 9,597 31,348 216,615
Source: ECOnorthwest analysis; DRCOG Small-Area Forecast (2020), DRCOG synthesis of State Demography
Office 2022 Household Forecast, U.S. Census Bureau, ACS 1-year 2022 PUMS estimates; MDHI 2022–2023
State of Homelessness Report.
Note: Components of need do not sum to total because of rounded unit counts.
Appendix C: Regional Housing Needs Assessment Technical Methodology 16
Exhibit 12. Submarket share of regional need by income and phase (current/future), 10-year scaled
estimate
PHASE 0–30% 30–60% 60–80% 80–
100%
100–
120% >120% TOTAL
Central
Current 9,636 2,741 1,267 361 197 – 14,203
Future 16,908 14,509 2,018 8,860 3,032 10,720 56,047
North
Current 5,718 1,627 752 214 117 – 8,428
Future 8,661 7,432 1,034 4,538 1,553 5,491 28,710
North Central
Current 4,755 1,353 625 178 97 – 7,009
Future 8,195 7,033 978 4,294 1,469 5,196 27,167
Southeast
Current 14,438 4,107 1,899 541 296 – 21,281
Future 14,556 12,491 1,738 7,627 2,610 9,229 48,250
West
Current 1,223 348 161 46 25 – 1,803
Future 1,121 962 234 588 201 711 3,717
Total 85,212 52,604 10,606 27,248 9,597 31,348 216,615
Source: ECOnorthwest analysis; DRCOG Small-Area Forecast (2020), State Demography Office Employment
(2020) Forecast, DRCOG synthesis of State Demography Office 2022 Household Forecast, U.S. Census Bureau,
ACS 1-year 2022 PUMS estimates; MDHI 2022–2023 State of Homelessness Report.
Note: Components of need may not sum to totals above because of rounded unit counts
Exhibit 13. Submarket share of total need by distribution model criteria
Source: ECOnorthwest analysis; DRCOG Small-Area Forecast (2020), State Demography Office Employment
(2020) Forecast, DRCOG synthesis of State Demography Office 2022 Household Forecast, U.S. Census Bureau,
ACS 1-year 2022 PUMS estimates; MDHI 2022–2023 State of Homelessness Report.
ITEM NO. 4
Memorandum
TO: Mayor and City Council
THROUGH: Patrick Goff, City Manager
FROM: Shannon Terrell, Senior Housing Planner
Jana Easley, Planning Manager
Lauren Mikulak, Community Development Director
DATE: August 18, 2025
SUBJECT: Housing Updates
ISSUE:
The State of Colorado Legislature passed several bills in the 2024 session aimed at
addressing affordability and increasing housing supply across the state. Since March 2025, City Council has taken action to comply with three of these bills: HB24-1007
(Residential Occupancy Limits), HB24-1304 (Minimum Parking Requirements), and HB24-1152 (Accessory Dwelling Units).
The purpose of this memo is to provide a status update on the city’s progress toward
compliance with state housing legislation, including an informational update on HB24-
1313 (Housing in Transit-Oriented Communities), and preview future discussions related to the Housing Fund. No council direction or discussion is necessary on these
topics at this time; this memo is for informational purposes only.
PRIOR ACTION:
State land use and housing legislation was discussed at the March 17, 2025, study
session. Council adopted three ordinances to comply with the state bills: two on May
12, 2025, to bring the City’s ADU and residential occupancy regulations into compliance
with HB24-1152 and HB24-1007, and another on June 23, 2025, to comply with HB24-
1304’s minimum parking reform requirements. Staff submitted reports to the Colorado Department of Local Affairs (DOLA) at the end of June related to the ADU and parking
bills, along with a preliminary report to comply with HB24-1313 (Housing in Transit-
Oriented Communities).
STATE LEGISLATIVE UPDATES
On March 17, 2025, staff presented information about several bills from the 2024 Colorado Legislative Session concerning land use and housing and their impact on
Wheat Ridge. The bills discussed include:
Study Session Memo – Housing Updates
August 18, 2025 Page 2
• SB24-005: Landscaping Practices for Water Conservation
• HB24-1313: Housing in Transit-Oriented Communities
• HB24-1007: Prohibit Residential Occupancy Limits
• HB24-1304: Minimum Parking Requirements
• HB24-1152: Accessory Dwelling Units
Over the last few months, staff and council have taken action on several of the bills that
required compliance by June 30, 2025. Staff submitted the following reports to DOLA at
the end of June:
• Zoning requirements for HB24-1304 Minimum Parking
• Zoning requirements and certification as an ADU Supportive Jurisdiction for
HB 24-1152 ADUs
• Preliminary reporting for compliance with HB24-1313 Housing in Transit-Oriented
Communities
DOLA is still reviewing the reports and staff will provide an update on DOLA’s review as necessary.
HB 24-1313 Transit-Oriented Communities
On May 13, 2024, Governor Polis signed House Bill (HB) 24-1313 Housing in Transit-
Oriented Communities (TOC) into law. This bill creates a category of local governments titled “Transit-Oriented Communities” and requires those communities to align local
residential zoning with regional transit investments. While staff provided a brief
description of this bill back in March, the state has released additional guidance that
provides clear direction on a pathway to compliance.
The purpose of the bill is fundamentally to ensure that cities do not prohibit transit-
supportive housing densities where they are served by regional transit. The bill is based
on the acknowledgement that 1) more housing is necessary in the metro area and 2)
housing and transportation investments are better leveraged when they are aligned. To
that end, the purpose of the bill is to ensure that local zoning allows housing development at transit-supportive densities along certain higher-frequency bus lines
and at light rail and commuter rail stations (the state calls these locations “Transit
Areas”).
Because local zoning regulations vary from city to city, the state has established a standardized formula to assess local compliance with the state law. The bill defines
transit-supportive densities as 40 dwelling units per acre in designated areas and allows
local governments to designate certain locations within Transit Areas known as “Transit
Centers” where these densities are required. In combination, these two inputs (a
density of 40 du/acre and the acreage of a community’s Transit Centers) result in a community’s “Zoning Capacity.” Zoning Capacity is essentially the transit-supportive
residential development target established by the state for each city.
Study Session Memo – Housing Updates
August 18, 2025 Page 3
The state has also established a standardized methodology by which communities
must demonstrate whether or not they meet that Zoning Capacity—which is the state’s goal of having sufficient transit-supportive zoning in proximity to rail and higher
frequency bus routes.
It’s important to note that the Zoning Capacity is not indicative of what could actually be
developed nor is there any expectation of full build-out. Most transit corridors are mixed use areas including a wide range of residential, commercial, and employment land uses
as well as parks and open space amenities. The purpose of the Zoning Capacity analysis is not to predict future residential development, but rather to demonstrate that
communities are meeting the goal of allowing relatively higher (or transit-supportive)
densities where transit service is provided.
What does this mean for Wheat Ridge? Fortunately, much of the city’s past planning and zoning efforts have already considered
alignment of housing policy and transportation investments. For example, Wadsworth
Boulevard hosts the city’s highest frequency bus route. It was identified in 2006 planning documents as an appropriate location for relatively higher densities, it was
exempted by voters from the charter height and density limits in 2008, and it was rezoned to Mixed Use-Commercial in 2012. Similarly, at the city’s Wheat Ridge Ward
commuter rail station, transit-related planning efforts began in 2005 shortly after RTD’s
voter-approved FasTracks. The area was exempted by voters from the charter height
and density limits in 2008, and several properties were rezoned to mixed use districts
between 2012 and 2016.
The state has designated five Transit Areas in Wheat Ridge based on RTD’s fixed-route
transit service and frequency (see Exhibit 1). In recent months, staff have worked
closely with DOLA to analyze existing zoning within those areas, as well as surrounding
areas such as the 38th Avenue corridor and the Lutheran Legacy Campus. A preliminary analysis report was submitted to DOLA on June 26, 2025. This report included both the
total acreage of the city’s Transit Areas and the densities allowed by current zoning.
Study Session Memo – Housing Updates
August 18, 2025 Page 4
Exhibit 1: DOLA-designated Transit Areas
Although some areas—particularly along Harlan and Sheridan—do not individually meet
the Zoning Capacity target, the state allows cities to direct growth to appropriate
locations through the designation of Transit Centers. Exhibit 2 includes a map of identified zone districts that permit the required transit-supportive densities that could
become our Transit Centers. When all identified zone districts are considered together,
staff believe the city meets or exceeds its required Zoning Capacity. The Zoning
Capacity calculation and Transit Center designation is not due to the state until
December 31, 2026. Exhibit 2 was submitted to DOLA as part of the preliminary report that was due at the end of June.
Study Session Memo – Housing Updates
August 18, 2025 Page 5
Exhibit 2: Eligible Transit-Supportive Zone Districts
At this time, staff does not anticipate changing the city’s zoning to comply with the
state’s transit-supportive Zoning Capacity goal. However, staff will continue working with DOLA to confirm compliance. A report on the city’s Zoning Capacity in designated
Transit Centers is due to DOLA by December 31, 2026. Staff may return to council for an update before that submittal, if necessary.
HOUSING FUND PROGRAMS AND WRHA ROLE
In the first half of 2026, study sessions with City Council and the Wheat Ridge Housing
Authority (WRHA) will focus on exploring potential uses for the Wheat Ridge Housing
Fund, as well as possible modifications to the Housing Authority’s role. Council will be
asked to share its priorities related to housing, and discussions will center on potential programmatic directions. For example, Council may choose to retain a portion of the
fund for gap financing while directing the remaining resources toward specific housing-
related initiatives. These could include support for accessory dwelling units (ADUs),
first-time homebuyer assistance, housing preservation, or expansion of existing City
Study Session Memo – Housing Updates
August 18, 2025 Page 6
housing programs, among other things. Staff will present a menu of program options
and seek input on near-term priorities. Once the Housing Fund is programmed, it may create an opportunity to reengage the WRHA and transition it from its current dormant
state into a more active advisory role.
NEXT STEPS
As noted above, no council direction or discussion is necessary on these topics at this
time; this memo is for informational purposes only. Future study sessions will be
scheduled when direction is required, or updates are available.
Item No. 5
Memorandum
TO: Mayor and City Council
THROUGH: Patrick Goff, City Manager
FROM: Lauren Mikulak, Community Development Director
Renee Meriaux, Chief Building Official
Steve Peck, Deputy Chief Building Official
DATE: August 18, 2025
SUBJECT: Building Code Update
ISSUE:
The City currently enforces the 2018 International Building Codes which were adopted in Wheat Ridge in 2020. The City typically updates the building codes every 4-6 years.
The full suite of 2024 International Codes were released last year, and staff is proposing
to adopt the updated building codes by the end of this year.
This memo is organized as follows:
• The Background section describes the current and proposed organization of the municipal code (Chapter 5) and lists the international, national, and state codes
to be adopted.
• The Local Amendments section describes the 12 local amendments (some
administrative and some technical) proposed by staff and supported by the
Building Code Advisory Board. The purpose of the August 18 study session is to
seek Council direction on these code provisions.
PRIOR ACTION:
When the 2024 codes were released early last year, a study session was held with City
Council on March 25, 2024. That memo provided background information on the city’s current codes, the update process, and the key changes in the 2024 I-Codes. Staff
received the requested council direction to proceed with the code update process.
The code was amended in December 2024 to simplify the licensing framework for
building contractors (Ordinance 1809), but the larger code update project was put on hold while a new building permit portal (OpenGov) was implemented.
In preparation for this code update, staff have studied the 2024 code changes,
evaluated existing local amendments, reviewed fire code amendments with the city’s
fire districts, and engaged builders and water districts related to fire sprinkler requirements.
Study Session Memo – Building Code Update
August 18, 2025 Page 2
On August 11, 2025, the city’s Building Code Advisory Board (BCAB) convened to
discuss the proposed building code update and to review the local amendments proposed below. The recommendations within this memo reflect their consensus.
BACKGROUND:
Current Code Organization In the Municipal Code, Chapter 5 (Buildings and Building Regulations) is considered the
city’s building code. It is organized into four articles: Article I (In General), Article II (Administration and Enforcement), Article III (Technical Codes), and Article IV
(Contractors). The organizational structure of Chapter 5 dates back to 1996. Many
provisions remain unchanged since 1996, though five major updates have occurred since then to update technical codes (in 1998, 2004, 2010, 2014, and 2020).
The most significant challenge with the current organizational structure is that
administrative provisions are spread across several places: in Article II, in the various
I-Code books themselves (in their respective Chapter 1), and in the local amendments to those I-Codes in Article III. This fragmented approach requires staff and customers to
piece together provisions from several different places, and it requires code interpretation to determine which takes precedence where language conflicts.
Proposed Code Organization This year’s code update includes a structural change to Chapter 5 by consolidating all
administrative provisions into one place in Chapter 5. Under this approach, staff and customers will find all information related to plan review, permitting, inspection, and
enforcement procedures in one place allowing significantly improved navigation of the
building permit process in Wheat Ridge.
A draft outline for Chapter 5 is enclosed as Attachment 1. The chapter will still be organized into several articles:
• Article I remains largely the same; several definitions are proposed to be
removed to avoid repetition with the I-Codes.
• Article II is overhauled to merge all administrative provisions in one location. This will lengthen Article II because it will incorporate into the municipal code all
provisions of IBC Chapter 1 which were previously adopted by reference.
• Article III will focus exclusively on technical codes. It includes a new introductory
section that lists in one place all of the international, national, and state codes
that are adopted by the city (this concise list is missing now and would be
helpful). Each subsequent section in Article III will include any local amendments to technical codes. With the removal of administrative provisions, Article III will
become significantly shorter in length.
• Article IV remains focused on contractor licenses. Because this was recently
updated in December 2025, no changes are proposed at this time.
Study Session Memo – Building Code Update
August 18, 2025 Page 3
This approach will enhance ease of use for staff and customers. It may also simplify
future code updates; if the administrative framework remains effective, future updates can focus solely on the technical codes in Article III.
Adopted Codes
This code update will adopt the same I-Code books as the last cycle, but the 2024
versions will replace the 2018 versions (available here):
• 2024 International Building Code (IBC)
• 2024 International Residential Code (IRC)
• 2024 International Fuel Gas Code (IFGC)
• 2024 International Mechanical Code (IMC)
• 2024 International Plumbing Code (IPC)
• 2024 International Energy Conservation Code (IECC)
• 2024 International Existing Building Code (IEBC)
• 2024 Swimming Pool and Spa Code (ISPSC)
• 2024 International Private Sewage Disposal Code (IPSDC)
• 2024 International Property Maintenance Code (IMPC)
• 2024 International Fire Code (IFC)
In addition to the I-Codes, the update will include:
• National Electric Code, as adopted by the State of Colorado
• Accessible and Usable Buildings and Facilities standard (ICC/ANSI A117.1)
• Colorado Model Electric Ready and Solar Ready Code
• Colorado Model Low Energy and Carbon Code
Per Colorado House Bill (HB) 22-1362, the latter two Colorado model codes are required to be adopted when any jurisdiction updates their building codes. Two experts of those
codes joined the August 11 BCAB meeting to provide background and to explain how these state model codes amend the IECC based on input from Colorado building
officials and contractors. Staff recommends and BCAB concurred to adopt these energy
codes as-is to meet the state’s minimum requirements.
The city may also be required to adopt the Colorado Wildfire Resiliency Code, but staff is still learning more about this recently released code and will discuss with BCAB and
council in 2026.
LOCAL AMENDMENTS:
Staff and BCAB are recommending 12 local amendments to the I-Codes this cycle and
seeking council concurrence on those amendments. The first five relate to
administrative provisions and the next seven relate to technical code provisions.
Study Session Memo – Building Code Update
August 18, 2025 Page 4
Proposed Administrative Code Updates
Chapter 1 of the IBC is the administrative foundation for the code. It outlines how the code is applied, enforced, and interpreted. It does not contain technical construction
requirements but instead governs how the code functions. A majority of the prior local
amendments to Chapter 1 will remain in place.
Listed below are the changes proposed with this code adoption cycle. Staff is seeking consensus on these topics:
1. Modify Permit Expiration – Under the I-Codes, building permits are valid for 180
days. In Wheat Ridge, previous local amendments have consistently extended
this period to 365 days. Staff is recommending a modified approach: that permits expire 180 days after the last inspection.
This allows longer-duration projects to remain active without the need for formal
extensions, while still setting a shorter expiration timeframe for stalled projects.
Though rare, this approach also supports earlier intervention when a property is involved in a nuisance or code enforcement case. The code retains the Chief
Building Official’s authority to grant one or more extensions for justifiable cause.
2. Modify Permit Cancellation/Revocation – Current provisions related to permit
cancellation or revocation are inconsistent with the permit expiration timeframe. For example, the municipal code allows permits to be cancelled if work does not
commence within 60 days, but this is not consistently enforced. Permits may also be cancelled if work is abandoned for 120 days, though this can be difficult
to verify. In practice, a permit usually remains valid for 365 days.
The proposed amendment would align the permit cancellation standard to the
180-day permit expiration timeframe; if work does not commence or is abandoned for 180 days, the permit may be cancelled. The section would also be
updated to clarify the procedure for providing such notice.
3. Modify Refund Policy– The I-Codes state that “the building official is authorized
to establish a refund policy,” and Wheat Ridge’s policy is codified in Chapter 5. The proposed change clarifies that not more than 80 percent of the permit fee
may be refunded when no work has been done under a permit.
Currently, the code allows for up to 100 percent to be refunded; however, in
practice, staff time is typically invested in permit intake and initial processing. Reducing the potential refund to 80 percent better reflects this administrative
effort and makes the refund amount more predictable for applicants. All other
refund provisions would remain unchanged, including the requirement that
refund requests be submitted in writing within 180 days of fee payment.
Study Session Memo – Building Code Update
August 18, 2025 Page 5
4. Clarify Valuation – Provisions related to project valuation are currently located in
multiple sections of the code and can be difficult for customers to navigate. Staff is proposing to consolidate these references and improve clarity. The most
significant change is the addition of a formal definition for the term valuation:
Valuation. For the purposes of permit review and fee calculation, valuation
refers to the total fair market value of all construction work, including both materials and labor. Valuation applies regardless of who performs the
work; this means that even if a property owner completes the work themselves, the value of labor must still be included. Permit fees are
assessed based on this total valuation in accordance with the adopted fee
schedule.
Valuation is a common source of confusion, and the definition will help address customer questions. Additionally, the code will be updated to clarify that the City
will reference the February edition of the ICC Building Valuation Data (BVD),
rather than the most recent publication. There is no change to the long-standing practice of how valuation will be calculated—notably, the city will continue to use
the higher of the applicant-stated valuation or the city’s calculated valuation to determine fees.
5. Modify Wall Permit Exemption – The municipal code includes a list of project scopes that are exempt from permit requirements. Staff is proposing one
change to this list. Historically, retaining walls have been exempt when they are “not over 4 feet in height measured from the bottom of the footing to the top of
the wall.” In practice, this standard is problematic: the bottom of the footing is
not visible or measurable after construction (especially in cases where the question arises later, often in response to neighbor concerns or complaints).
Staff is recommending that the exemption be modified to apply to walls not over
3 feet in height, measured from the top of the adjacent grade. This change aligns
with common code enforcement practices, improves enforceability, and better
reflects the structural significance of taller walls.
Proposed Technical Code Updates
There are very few technical code amendments being proposed this cycle. Several code
books will be adopted without any local amendment (including the energy code, pool,
and existing building codes). A majority of the local amendments from prior code
adoption cycles will remain in place, including amendments in the IBC, IFC and IMC and related to specific policy topics:
• Allowances for churches to function as emergency shelters
• Allowances for hoop houses (a more affordable alternative to greenhouses)
• Marijuana-related mechanical requirements and hazard occupancies
Study Session Memo – Building Code Update
August 18, 2025 Page 6
• Exempting residential lawn sprinklers from permits
• Exempting residential decks of a certain size/height from permits
Several local amendments are simply dimensional standards or other units of
measurements based on climate or geography. Similar to prior adoption cycles, these
are related to:
• Ice barrier and roof flashing
• Sewer depth
• Heating and cooling
• Fuel gas pressure
• Pool enclosure heights
• Maximum height for weeds
• Fire access dimensions
Listed below are the more notable changes proposed with the 2024 building code
adoption. The goal of these amendments is to defer as much to the base codes as
possible. Staff is seeking consensus on the following:
6. Remove Plumbing Fixture Thresholds– Prior local amendments, replaced
International Plumbing Code (IPC) Section 403.1 and imposed local thresholds
for requiring separate male and female restrooms based on occupant load and
occupancy type. This code update proposes to remove this custom approach. By reverting to the base IPC, the code aligns with international standards, removes
unnecessary complexity, and most importantly allows greater flexibility in restroom design—including the use of single-user, unisex, or all-gender
restrooms.
In existing buildings, the International Existing Building Code (IEBC) already
allows the CBO to waive additional fixture requirements when upgrades are impractical. Overall, this change aligns with model code language and increases
flexibility without reducing accessibility or usability.
7. Remove Outdated Codes – Chapter 5 has several references to codes that no
longer apply. This includes the 1997 Uniform Code for the Abatement of Dangerous Buildings (which has been replaced by the IPMC) and the NFPA 99
Standards for Health Care Facilities (the state adopts these codes and has
jurisdiction over health care facilities; cities are not required to also adopt and enforce). These references will be removed to avoid confusion.
8. Remove Local Framing Amendments – Prior local amendments modified the
base code requirements for nonbearing walls (R602.5, R602.7.3), lath (R703.6.1)
and attic access (R807.1 and 1209.2). With the seismic design category in Wheat
Study Session Memo – Building Code Update
August 18, 2025 Page 7
Ridge and the clarity provided by the 2024 code, deferring to base codes on these
topics is more appropriate than retaining these local amendments.
9. Remove Solar-Ready Amendments – When the 2018 I-Codes were published, they
included new solar-ready provisions in IECC and IRC appendices. The city
adopted most of those provisions but reduced the requirements for townhome
construction. Because of new state law (discussed below), the city will be required to adopt the state’s solar-ready codes, and these prior local
amendments will be removed.
10. Modify Test Pressure – Prior local amendments modified the IRC and IFGC
related to test pressure measurements and duration (IRC G2417.4 and IFHC 406.4). Based on discussions with Xcel, contractors and inspectors; the
proposed code update would remove these local measurements. Contractors are accustomed to the model code, and Xcel’s delivery pressure does not warrant a
customized approach in Wheat Ridge. Because the base code provides only a
calculation (1.5 x delivery pressure) instead of a psig threshold, the local amendment will remain to provide that threshold but will be aligned with the base
code approach.
11. Add Framing/Reporting Requirements for Basement Slabs – Because of the
expansive soils in the front range, it is standard practice to either require wall framing on basement slabs or to require a soils report. This requirement is
proposed to be added more explicitly to the IRC:
Wall Framing on Basement Slabs shall be added to R403.1.8 Foundations on
expansive soils after R403.1.8.1:
R403.1.8.2 Wall Framing on Basement Slabs Non-bearing walls on basement floor slabs should be built to accommodate not less than 1-½ inches of floor
movement, unless documented geotechnical observation and written
approval by the Engineer of Record indicate such accommodation is not
necessary.
12. Residential Sprinkler Requirement – In recent code cycles, one of the most
substantive amendment discussions has related to residential fire sprinklers.
The base IFC and IRC require sprinklers in single-unit, duplex, and townhome
units. Historically, Wheat Ridge and several peer communities have amended
this requirement out of the code. Attachment 2 includes the position paper from the city’s two fire districts (West Metro and Arvada) and a summary of feedback
from water districts and builders.
At a minimum, staff recommends clarifying in the code that if sprinklers are
Study Session Memo – Building Code Update
August 18, 2025 Page 8
installed, they must be a 13D system to avoid complex backflow requirements.
The Building Code Advisory Board (BCAB) is aligned with builder feedback in not recommending sprinklers for single-unit, duplex, or townhome projects. In
contrast, the fire districts recommend sprinklers in all settings and, at a
minimum, in townhomes; fire district representatives may be present at the
August 18 meeting to speak to their position.
Staff is seeking council direction on whether to maintain the current approach of
not requiring sprinklers or to require them in certain housing types such as townhomes. If sprinklers are proposed to be required, staff recommends a
delayed implementation schedule, so builders and homebuyers can adequately
plan for the additional system and tap fee costs.
RECOMMENDATIONS AND NEXT STEPS:
For amendments 1 through 11, staff is seeking council concurrence on the staff and
BCAB recommendation. For item 12, related to residential sprinklers, staff is seeking council direction.
After city council’s August 18 discussion and direction, staff will finalize the Chapter 5
code language. The draft code will be presented to BCAB in September and presented
to City Council for a public hearing in October. With this schedule, the new code would take effect January 1, 2026. This timing aligns with the city’s ISO rating, for which the
adopted building code version is a factor that can directly impact property owners’ property and flood insurance rates.
ATTACHMENTS:
1. Draft Outline of Chapter 5 2. Stakeholder Input on Residential Sprinklers
ATTACHMENT 1
Draft Outline for Chapter 5 (Buildings and Building Regulations)
Below is a draft outline for the reorganization of Chapter 5. Articles I and IV remain largely the same as they are today, but the organizational structure of Articles II and III
will be revised to better separate administrative and technical code provisions.
Article I – In General
Section 5.1 – Purpose (no change)
Section 5.2 – Definitions
• Because definitions appear in this section and in the I-Codes language clarifying
precedence will be added.
• Definitions which appear in both Chapter 5 and in the 2024 I-Codes will be
removed.
• A definition for the term “valuation” will be added.
Section 5.3 – Scope (no change)
Section 5.4 – Resolution of Conflict (no change)
Section 5.5 – Enforcement and remedies
• This content is over 12 years old and needs to be updated to align with current
practice and other updates in the municipal code.
• This content will be moved into Article II.
Article II – Administration and Enforcement
This article will be overhauled to merge the existing provisions with all provisions
contained within Chapter 1 of the International Building Code (IBC). Topics will include:
• Applicability
• Authority (of the Chief Building Official and Building Code Advisory Board)
• Enforcement (procedures for enforcement and updated references the municipal code’s provisions related to administrative citation, civil enforcement, and
criminal enforcement)
• Keeping of Records (updated because plans are now electronic instead of paper)
• Right of Entry (updated to align with IBC)
• Requirement for Building Permits (minimal change)
• Application Requirements (consolidates content from multiple sections)
• Expiration, Extension and Cancellation of Permits
• Fees (fee amounts do not live in the code, so this refers to the fee schedule which is updated as part of the annual budget process)
ATTACHMENT 1
Attachment 2 – Draft Outline – Page 2
Article III – Technical Codes
This article will focus exclusively on technical codes—referencing all adopted codes and
enumerating any local amendments. Sections will include:
• Adopted Codes – This is the list of all international, national and state codes and the associated appendices which the city adopts:
o 2024 International Building Code (IBC)
o 2024 International Residential Code (IRC) with the following appendices:
- BB (tiny homes)
- BE (radon)
- BF (patio covers)
- BO (existing buildings)
- CA, CB, and CC (excerpts from the fuel gas code)
- CE (venting diagrams)
- CF (water piping details)
- CH (pools and spas for residential contexts)
o 2024 International Fuel Gas Code (IFGC)
o 2024 International Mechanical Code (IMC)
o 2024 International Plumbing Code (IPC)
- excluding Chapter 14 (subsurface graywater)
o 2024 International Energy Conservation Code (IECC)
o 2024 International Existing Building Code (IEBC)
o 2024 Swimming Pool and Spa Code (ISPSC)
o 2024 International Private Sewage Disposal Code (IPSDC)
o 2024 International Property Maintenance Code (IMPC)
o 2024 International Fire Code (IFC) with the following appendices:
- B (fire flow)
- C (fire hydrant locations)
- D (fire apparatus access roads)
- F (hazard ranking)
- H (hazardous materials)
- O (valet trash and recycling in R-2)
o National Electric Code, as adopted by the State of Colorado
o Accessible and Usable Buildings and Facilities standard (ICC/ANSI
A117.1)
o Colorado Model Electric Ready and Solar Ready Code
o Colorado Model Low Energy and Carbon Code
• A separate section for each code book will be included to enumerate the local amendments, if applicable.
Article IV – Contractor Licenses
This article includes 14 sections related to the licensing of contractors including
requirements related to license types, insurance, testing, and fees. This Article was updated by City Council in December 2024 by Ordinance 1809 and is not proposed to be
amended during this code update process.
ATTACHMENT 2
Residential Sprinkler Stakeholder Input
Staff sought input from several stakeholders on the topic of residential sprinklers. A
survey was distributed to the city’s water districts where 3 of 5 responded. A separate
survey was sent to residential builders and developers including the Homebuilders
Association, and 7 responses were submitted. Enclosed is a summary of the stakeholder feedback that was provided.
Also attached is a joint position paper from the two fire districts that serve Wheat Ridge:
West Metro Fire District and Arvada Fire District.
Attachment 2 – Sprinkler Input – Page 2
Summary of Water District Feedback on Residential Fire Sprinkler Requirement
1.General Sentiment
•All three districts indicated that residential sprinklers are technically feasiblewithin their systems.
•However, cost impacts, coordination challenges, and meter sizing/backflow
issues were recurring themes.
•Only Edgewater and CMWC have any experience implementing sprinklerrequirements (and only for duplex/multifamily), while Valley has not
implemented them because jurisdictions they serve (Wheat Ridge, Arvada) havenot required them.
2.Water Supply Impacts
•Valley: No appreciable increase in demand expected, but a 1" tap requirementskews long-term demand projections and significantly increases customer costs.
•Consolidated Mutual (CMWC): It’s possible to support sprinkler systems, but
coordination, pressure variability, and system design are critical challenges.
•Edgewater: Can support sprinkler systems, but emphasized the importance ofusing 13D or P2904 systems to avoid complex backflow requirements.
3.Implementation Challenges & Lessons Learned
•CMWC (based on Lakewood experience): Major issues with:
o Backflow coordination – Passive purge systems require documentation
and close collaboration with fire/building departments.
o Meter sizing/tap fees – Developers often need to upsize from a ¾” to 1”
service, potentially doubling tap fees (e.g., $27K → $54K).
o Shutoff implications – If water is shut off (e.g., for non-payment), the
home becomes uninhabitable due to sprinkler requirements.
o Communication gaps – Developers were often unaware of requirements
until too late in the process.
•Valley: Has not yet implemented sprinkler systems in residential projects
because no jurisdictions served currently require them.
•Edgewater: Supports sprinklers in multifamily/duplexes, but wants to avoidsystems that trigger annual backflow testing and added customer burden.
4.Impact on Development Review
•CMWC: Minimal change to plan review timing, but requires closer coordination
with building departments, especially around meter sizing and systemverification.
•Valley: No direct review changes, but added administrative burden for long-term
demand projections and billing.
•Edgewater: No major changes, but backflow tracking and coordination require
additional staff time.
Attachment 2 – Sprinkler Input – Page 3
5. Key Considerations if Implemented
•Meter/Tap Fees:
o All three districts flagged tap upsizing as a cost issue for developers and
long-term cost burden for homeowners.
o Valley: Monthly water bills increase by nearly $50/month for a 1" tap vs. a
¾”.
•Backflow:
o CMWC & Edgewater recommended allowing or requiring 13D or P2904
systems, which eliminate the need for testable backflow devices.
•Customer Awareness:
o Both CMWC and Valley recommended that developers and buyers be
clearly informed upfront of sprinkler-related costs and maintenance
obligations.
6. Benefits or Drawbacks
•Conservation: Sprinkler systems use little to no water under normal conditions,so not a concern from a water use standpoint.
•Drawbacks:
o Significant coordination demands
o Cost implications for taps, billing, and backflow testing
o Risk of confusion and miscommunication if not coordinated early in
planning process
7. Recommendations / Additional Thoughts
•Phase in requirement (CMWC): Consider delaying implementation of thesprinkler mandate, even if broader code changes move forward.
•Limit scope (Edgewater): If required, consider limiting to townhomes or
multifamily to reduce complexity and cost impact on single-family homes.
•Developer notification (CMWC): Require that the sprinkler requirement bedisclosed early—at the planning phase—to avoid confusion or project redesigns.
Attachment 2 – Sprinkler Input – Page 4
Summary of Builder/Developer Feedback on Residential Fire Sprinkler Requirement
1. General SentimentAll responding builders expressed strong concern or opposition to a mandatory
residential fire sprinkler requirement. While some acknowledged the life safety value,
the overwhelming consensus was that the economic impact outweighs the benefits for
single-family and townhome construction.
2. Would Sprinkler Requirement Impact Decision to Build in Wheat Ridge?
•Yes – All builders who answered this question said yes, it would negatively
impact their interest in building in Wheat Ridge.
•They cited increased costs, decreased housing attainability, and competitiveness
concerns compared to surrounding jurisdictions.
3. Top Concerns Raised
Cost Impacts:
•Installation estimates ranged from $6,000 to $30,000 per home, depending on
system type, meter upgrades, backflow requirements, and design complexity.
•Developers cited a price per square foot of $4.50–$10, far above the $1.75figure presented by fire districts.
•Larger water taps (¾” to 1”) increase utility fees by up to $5,000, plus added
impact fees and permit costs.
•Annual maintenance, inspections, and homeowner confusion or neglect werealso key concerns.
Housing Attainability:
•Multiple builders emphasized that sprinkler mandates reduce affordability andcould price out thousands of potential homebuyers.
•The HBA noted that each $1,000 added to the cost of a home prices out ~2,373
households in Colorado.Design and Construction Challenges:
•Added architectural/engineering work, delays, and uncertain permitting
standards were flagged as problematic.
•Trade capacity and lead times to install sprinkler systems were cited as current
bottlenecks.
•Pressure and flow requirements may trigger offsite infrastructure upgrades.
Questionable Need in New Homes:
•Builders argued that modern construction, with hardwired smoke detectors, fire-
retardant materials, and sealed electrical systems, already provides strong firesafety.
•Concerns about false activations, water damage, and minimal benefit in small-
scale homes were frequently noted.
4. Perceived Benefits of Sprinklers
Attachment 2 – Sprinkler Input – Page 5
•Limited acknowledgment of life safety value—particularly in larger multifamily or
denser infill contexts.
•Some noted that sprinklers may reduce fire damage and support faster
suppression.
•A few supported voluntary adoption or incentives, but not mandates.
5.Suggestions for Feasibility or Mitigation
Several developers proposed alternative approaches or mitigating measures ifsprinklers were required:
•Financial offsets: tap or impact fee reductions, permit incentives, cost-sharing
(of note, the city has no ability to influence water district tap fees)
•Flexibility: make sprinklers optional or allow performance-based alternatives likeenhanced detection or passive fire protection.
•Grace period: allow 12+ months for builders to adjust pricing and schedule
capacity.
•Incentives for density: offer bonus units or narrower street allowances (thoughsome noted minimal benefit due to utility constraints, and the city is limited in
offering density bonuses because of charter provisions).
•Regional consistency: avoid deviating from most other Front Range jurisdictions,
many of which have amended out the IRC requirement.
6.Additional Considerations and Context
•Multiple builders referenced peer cities (e.g., Arvada, Erie, Jefferson County)where sprinklers are not required or are being reconsidered.
•Developers were critical of fire district cost estimates, saying they do not align
with market experience.
•Some expressed willingness to work with fire departments on clearer standardsor compromises, but felt strongly that a blanket requirement is not warranted for
detached or low-density homes.
7. Representative Quotes
•“The marginal benefit of sprinklers is far outweighed by the cost and risk burden
they impose.”
•“Sprinkler systems alone could price out more than 35,000 households.”
•“Making them optional would be a far more balanced approach.”
•“We recommend against adopting a residential fire sprinkler mandate.”
RESIDENTIAL FIRE SPRINKLERS
Requiring residential fire sprinkler systems in new construction offers significant benefits for home
builders and developers, both in terms of marketability and long-term value. Homes equipped with fire
sprinklers are increasingly attractive to safety-conscious buyers and can be promoted as premium,
forward-thinking builds that prioritize family safety. These systems also help limit fire damage, reducing
liability risks and potentially lowering insurance costs. Additionally, trade-offs can lower infrastructure
costs for developers and builders. By embracing this life safety system, builders not only enhance the
desirability of their properties by creating modern, resilient communities.
•1-3% the cost of a new home. This is both a
local and national statistic.
•Various IRC trade-offs, 2-hr fire walls and
protection of structural members in unfinished
basements are no longer required and many
others.
•Reduces greenhouse gas emissions by up to
98%.
•Reduces the required fire flow for the
underground water supply (water conservation).
•Reduces water usage at a fire by as much as
91%.
•Reduces environmental impacts from
contaminated runoff.
•Fewer fire hydrants are required because we
will not need to use them at sprinklered homes.
•Narrower roads are allowed because we will not
need as many apparatus at these fires.
•Fewer fire apparatus access roads are required
•Required in the International Residential Code
(IRC) since 2009, but locally amended out
•Reduces fire damage by 97%. The national
average fire loss is $45,019 where the AFPD
average is $62,268. National statistics show that
with sprinkler systems, the average loss is
$2,166.
•Smaller fires will displace the citizens for shorter
durations, if at all, and cost less to repair.
•Very reliable – not any more susceptible to
breaks any more than domestic plumbing.
Water damage can be remedied easier than fire
damage.
•Little to no maintenance, just need to make sure
sprinklers are not obstructed or painted.
•Fires typically contained by one (1) sprinkler
•Possible insurance breaks (0.0%-10% depending
on carrier and system coverage).
•Houses become uninhabitable in approximately
two (2) minutes. These systems provide the
much-needed time to evacuate a home.
•Life safety of the citizens and firefighters – fires
will be smaller and will not put anyone into an
immediately dangerous to life and health
situation.
•Cancer prevention for AFPD personnel –
although these will not eliminate carcinogenic
exposures, it will significantly reduce them.
•Put water on the fire well before we arrive.
Although we have good response times, the
sprinkler system will be many minutes faster at
putting water on the fire than we will.
•Activate upon heat detection (at least 150
degrees) and not smoke. Burnt food or steam
from a shower will not activate these systems.
•Compliments smoke alarms
•Multiple system types allowed (13D & P2904)
Many progressive surrounding communities have maintaind this in their codes, Westminster, Superior,
Broomfield, Lakewood, Commerce City, Lousiville, Golden, Boulder, Boulder County, Castle Pines,
Federal Heights, Cherry Hills Village, Avon, Snowmass Village, and Erie.
*The cost will vary depending on whether it is a custom home or a tract home. Tract homes costs are lower than custom homes.
Attachment 2 – Sprinkler Input – Page 6