March 9, 2017
The Honorable Donald J. Trump, President
Dear President Trump:
We are writing on behalf of the members of the National Multifamily Housing Council (NMHC) and the National Apartment Association (NAA) who represent the $1.3 trillion apartment industry and its nearly 39 million residents. We applaud your efforts to overhaul the federal regulatory landscape and reduce the burdens felt by American businesses of all types in complying with a profusion of unnecessarily costly and complex regulations. We believe that some federal regulations strayed from their intended purpose and instead stifled innovation and hampered economic growth at a time when our nation continues to recover from the worst recession since the Great Depression.
The multifamily sector is under increasing pressure to meet booming demand across the country. Experts believe this trend will continue, if not increase, due to a host of factors including demographic change and evolving consumer preferences. Our industry, and particularly apartment owners and developers, must balance a wide array of concerns regarding project viability, regulatory cost and compliance at all levels of government. While many regulatory hurdles and costs, such as impact fees, continual environmental reviews and antiquated zoning processes, are within the purview of state and local policymakers, there are a wide array of existing federal regulations that contribute to making housing less economically feasible to develop.
We believe that regulations must have demonstrable benefits that justify the cost of compliance and that federal agencies should be aware that broad-stroke regulations often have disproportionate effects on industries that serve as key drivers of our economy. Excessive regulation and compliance uncertainty result in costly mandates that divert resources from the production and operation of multifamily housing. The apartment industry faces a flood of regulations from a wide range of federal agencies including the Department of Housing and Urban Development (HUD), the Environmental Protection Agency (EPA), Department of Labor (DOL), Occupational Safety and Health Administration (OSHA), and the Department of Energy (DOE).
Given your great interest in removing regulatory barriers to development and growth, NMHC/NAA would like to highlight some of the specific federal regulations that slow or prevent development of housing that is affordable, challenge otherwise legitimate business practices designed to ensure safe and decent housing for residents, decrease access to capital and make it difficult to transfer family-owned businesses from one generation to another. The regulations outlined in the attached document, while well-intentioned in nature, have negatively impacted the development and management of multifamily housing at a time when our industry strives irelessly to address the shortage of housing for American families. We urge the Administration to pursue reforms or rescind these regulations.
We appreciate the opportunity to share the multifamily housing industry’s view on the importance of regulatory reform. We look forward to working with you and your Administration towards our shared goal of building housing that is affordable to more Americans and spurring continued economic growth across the country. Please call upon us if we can serve as a resource to you in this regard.
Douglas M. Bibby
National Multifamily Housing Council
President & CEO
National Apartment Association
The Honorable Michael Pence, Vice President
The Honorable Gary Cohn, Director, National Economic Council
The Honorable Mick Mulvaney, Director, Office of Management and Budget