Access to Housing in Tennessee: The Federal, State, and Local Policy Levers

Josiah Hoss
May 29, 2025
Housing,Income & Poverty

Key Takeaways

  • Federal, state, and local policymakers can all influence various factors that affect housing access, supply, and affordability through existing or potential policy levers.
  • Policies can help or hinder homebuilding by affecting the costs and processes required to produce a home (e.g., local zoning, codes, and permitting).
  • Policy establishes the parameters for “affordable housing,” a specific designation for various housing programs that typically target lower-income households (e.g., state and local tax subsidies).
  • Housing development capacity is decided by policy—that is, both the land available for housing and the number of homes that can be built on it (e.g., local minimum lot-size requirements).
  • Different levels of government offer resources and programs that households can access to obtain and maintain a home (e.g., federal Section 8 rental assistance vouchers).
  • Financing options for buying a home can also be influenced by public policies, such as federally backed mortgage programs.
  • Policy choices can impact the types of up-front requirements and other barriers that individuals may face when looking for housing (e.g., state enforcement of anti-discrimination laws).
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Housing is a vital resource for all Tennesseans. Over the last two decades, population, socioeconomic, and housing development trends have driven increasing housing costs across Tennessee. This report explains the factors that influence housing access, supply, and affordability and identifies the policy levers that can affect these factors at the federal, state, and local levels.

Factors Affecting Housing Access and Affordability

Housing supply and demand determine whether a family can find affordable and available housing in their desired community. Supply-side factors determine how much housing can be built in an area, how quickly, and at what cost. Demand-side factors influence things like how many people want certain types of housing, where, and at what price points. While policy choices can also affect things like migration patterns, this report focuses on housing market policy levers. These factors include:

Supply-Side Affordability Factors

  • Building Costs — A home’s sale price or rental costs are driven in large part by how much it costs to build, including land, materials, labor, and financing costs. There is no incentive for continued production unless housing developers can balance these costs with potential sales prices to ensure profit.
  • Time — The time it takes to build a home determines the volume of production and the labor and financing costs to construct it.
  • Land — Housing can only be built if land is available on which to construct it.
  • Density — Density determines how much or how little housing can be built in any given area.
  • Financing — To build housing, developers must have access to financing that aligns with their financial needs.

 Demand-Side Affordability Factors

  • Resources — The services and financial resources available to a family are the most basic factors of whether they can afford and retain housing or not.
  • Entry Requirements — Housing can come with other up-front requirements that may pose barriers for some people (e.g., application approvals, security deposits, moving costs, credit checks).
  • Financing Options and Requirements — Mortgage qualifications and options can determine if and when people can afford to buy a home or if they remain renters.

Federal, state, and local policymakers can all influence various factors that affect housing access, supply, and affordability through existing or potential policy levers. Housing policy is an example of federalism in action, influenced by multiple jurisdictions and multiple regulatory and funding streams. For example, the construction of a single housing development may require simultaneous consideration of federal, state, and local policy requirements.

The remainder of this report reframes the factors above as goals that could improve the accessibility of housing in Tennessee and matches them with the federal, state, and local policy levers that affect them, which are summarized in Table 1. This report covers many policy levers but does not attempt to provide an exhaustive list.

Table 1

Federal, State, and Local Policy Levers to Improve Housing Affordability in Tennessee

Trade-Offs

Every policy lever highlighted in this report has trade-offs to weigh carefully. For example, expanding housing assistance or support services may improve housing accessibility but also require more public funding. Likewise, zoning changes and higher-density development—in addition to boosting supply and reducing costs—may strain local infrastructure or alter the makeup of existing neighborhoods. These changes can stir strong emotions, as people often have deep feelings about and resist policy shifts that affect the nature of the places they call home. Policymakers must balance the goals and trade-offs of improving access to housing for Tennesseans based on the distinct needs, values, and priorities of their communities and constituents.

Simplifying Homebuilding

Policies can help or hinder homebuilding by affecting the costs and processes required to produce a home. For example, federal economic actions like trade policies can affect the cost of materials required to build homes. In recent years, homebuilding has gotten more expensive and takes longer due to inflation, higher interest rates, international trade tensions, and labor and material shortages. (1) (2) (3) (4) The National Association of Home Builders estimates that recent U.S. trade tariff policy could translate to an estimated $9,000 in additional costs per new home because 7% of residential construction material costs are imported. (5) Other policy choices at the local and state levels of government can more directly impact the time and resources required to build a home.

Local governments can regulate everything from the appearance of a house to the processes required to begin development. Common examples include zoning regulations, building codes, and permitting processes:

  • Zoning limits what, where, and how much can be built and what it can look like. For example, residential development is often restricted to certain areas and assigned a specific definition of its design. Homes may be limited to a certain height, number of units, and aesthetic requirements based upon the zoning designation. Lot size requirements (discussed in the next section) are also a type of zoning requirement.
  • Codes define how homes are built—they are the “definitions” that make up various zoning designations that can apply to a property. Largely covering health and safety standards like electrical wiring, plumbing, and fire safety, codes can also include design elements such as height requirements, aesthetic features, and parking space minimums. These requirements often come with inspection processes.
  • Permitting is the official process of getting permission to proceed with a development to ensure it complies with zoning and code requirements. Sometimes, a local government may require a public hearing to gather feedback before issuing a permit.

These local regulations come with trade-offs that can hinder housing development. Local requirements can help communities guide growth to achieve desired goals, like keeping neighborhoods functional, protecting health and safety, managing infrastructure needs, protecting the environment, maintaining property values, and gathering local input. However, they can slow down homebuilding and increase costs. For example:

  • Vague or overly strict local requirements can make projects unfeasible or lead to lengthy approval processes. (6) (7) (8)
  • Special commissions that have discretion in interpreting zoning regulations or applying additional fees and requirements can make the approval process and costs unpredictable.
  • Mandates like parking requirements reduce habitable space, which can affect the type and number of units a developer can affordably build.(9)
  • Zoning hearings and additional public feedback processes on new development can lengthen approval times, increase costs, and derail projects. (10)(11)

Some local approaches can simplify the process of building homes—lowering costs and shortening timelines. For example, local governments can hold fewer or more efficient public hearings on housing projects or offer more transparent regulatory expectations. (10) (11) (12)  Other tactics include streamlining permitting processes, limiting special boards and commissions, and offering pre-approved building plans. (13)

State policy has not traditionally been a major player in regulating local zoning and building codes; however, certain laws do impact local housing policy. For example, state building regulation in Tennessee has been limited to a statewide fire code, which largely serves as a regulatory floor upon which locals can add requirements. (14) (15) For example, a new state law allows local governments to approve a single staircase for multi-unit buildings that are six stories or less. Traditionally, the state’s fire code otherwise requires two staircases, which use space that could otherwise allow for more units. However, recent studies have shown that a single stairway in smaller multi-unit buildings does not affect safety in the event of a fire. (16) (17) (18)

The state can take additional steps to simplify local regulations in the homebuilding process. For example, state law can require or incentivize local deregulation or streamlined approvals. Specific examples include:

  • Adopting a uniform statewide building code, such as in Kentucky and Florida. (19)
  • Offer pre-approved development plans that can be quickly built across the state, building upon the new policy in Memphis. (20)(13) (21)
  • Mandate or outline clear and specific language in local housing codes. (22) (23) (24)
  • Limit local approval processes to promote speed and transparency. (6)
  • Provide greater technical assistance to counties and cities without the administrative capacity to analyze and address local housing needs. (25)

Affordable Housing Developments

“Affordable housing” is a specific designation for a variety of housing programs typically targeting lower-income households. Generally, housing is considered affordable if it costs less than 30% of a household’s income. (26) (27) However, affordable housing initiatives are tailored programs for those who earn significantly below an area’s typical household income, with specific rent limits and income eligibility thresholds that vary by program. Overall, when a program refers to the development of “affordable housing”, it is largely referring to a rental program that supports the least wealthy members of a community.

Building affordable housing comes with unique financial challenges that make it particularly risky for private developers. Developers rely on “capital stacking” (i.e., a combination of investments and financing) to cover the costs of a project. (28) Because affordable units are offered below market rates, there is a gap between a development’s rental income and the costs to build and maintain it with conventional financing. (29) (30) (31) (32) As a result, affordable housing developers cannot build without a subsidy to fill this gap in their capital stack—all while facing the same regulatory and market pressures as other developers. (6) (30) (33) 

The federal government plays a significant role in supporting and subsidizing affordable housing. Federal programs and initiatives range from targeted funding for specialized populations to the largest source of funding for the construction of new affordable housing units—the Low-Income Housing Tax Credit (LIHTC). (32) (34) (See “Federal Resources for Affordable Housing Development.”) In federal FY 2025, Tennessee is expected to receive over $70 million from these programs. (35)

These programs and initiatives are largely carried out by the Tennessee Housing Development Agency (THDA) and local public housing authorities (PHAs) (See “What Are Housing Authorities?”). THDA and other PHAs distribute these resources to developers and other qualified entities—exercising discretion within federal parameters. For example, the THDA defines the criteria and a scoring guide to prioritize LIHTC applications, which subsidize the construction of affordable rental units for low-income households. (36) These criteria prioritize locations that are identified as Economic Development Areas, set-asides for rehabilitation of existing buildings, and housing for homeless Tennesseans.

Federal funds for building affordable housing by private developers are competitive, highly regulated, and often require additional financial tools. (30) Among other things, developers must acquire the property and obtain the necessary permits, demonstrate a history of subsidized development, and provide a 30-year financial plan to receive federal tax credits. Rising costs or permit delays can jeopardize a project if they cause it to fall out of compliance with funding requirements. (36)

State and local tax abatements and other cost-saving measures can help reduce the financial gap for an affordable housing development. Tools may include:

  • PILOT Programs — State law allows payment-in-lieu-of-taxes (PILOT) programs in which municipalities can offer property tax offsets, which lower the costs of developing and maintaining a property. (37)(38) Currently, cities like Nashville, Memphis, and Chattanooga all offer targeted PILOT programs for affordable housing developers. (39) (40) (41) Some municipalities may not be aware of the benefits of these programs, while the administrative capacity needed to manage and afford one may be out of reach for smaller communities. (12) (42) (43) (37) (38) (44)
  • The Community Investment Tax Credit — The THDA and the Tennessee Department of Revenue offer tax credits to financial institutions that fund affordable housing development. In doing so, financial institutions receive a financial break for funding larger affordable housing projects, shrinking the financial gap. (45)
  • Other Tax-Related Incentives — State and local governments could explore other ways to provide tax-related incentives for affordable housing development. For example, removing tax credit-related revenues from property tax assessments could be an administratively simpler subsidy for rural areas without the capacity for PILOT programs.(46) (47) (42) Additionally, areas with impact or development fees could explore ways to exempt affordable housing developers and replace those lost revenues with other funding sources. (48) (49) (50) (51)

Federal Resources for Affordable Housing Development

Low-Income Housing Tax Credits (LIHTC) — This is the largest federal program to subsidize the construction of affordable housing. (34) The credits are competitively awarded and reduce the federal income tax liability for developers for 10 years. They can vary in amount based on development costs and criteria defined by the U.S. Department of Housing and Urban Development (HUD) and THDA. (32) (34) (31) A total of $20.3 million in credits is expected to be awarded in Tennessee in federal FY 2025. (35)

HOME Grant Programs — These are federal block grant programs that go to state and local public housing authorities to build, preserve, and rehabilitate affordable homeowner and rental housing for low-income households. (135) (136) Tennessee is expected to receive $12.9 million in federal FY 2025. (35)

Community Development Block Grants (CDBGs) — The state and certain local governments receive CDBG funds for economic and community development—including public infrastructure and facilities. (35) Other targeted CDBG programs specifically fund housing for low-income residents in recovery from substance use disorder. Tennessee is expected to receive $27.6 million in federal FY 2025 as a block grant and $1.5 million for the CDBG recovery housing program. (35)

Housing Trust Fund (HTF) — HTF dollars can be used to build, preserve, and rehabilitate rental housing for the very and extremely poor. (139) These funds are allocated directly to the THDA and distributed competitively using the same structure as LIHTC allocations. (35) Tennessee is expected to receive $3.2 million in federal FY 2025. (35)

Emergency Solutions Grant (ESG) — ESG funds services and emergency housing for individuals and families facing homelessness. (138) (35) Tennessee is expected to receive $3.2 million in federal FY 2025.

Housing Opportunities for Persons with HIV/AIDS (HOPWA) — HOPWA provides short-term and permanent housing for people diagnosed with HIV/AIDS and their families. (137) (35) Tennessee is expected to receive $2.3 million in federal FY 2025. (35)

Affordable housing developers also face zoning challenges. Affordable housing projects can often be controversial due to public perception. (52) (53) (33) As a result, developers can be vulnerable to zoning changes that slow a project from when they buy property and submit plans for approval to when their permits are issued. (54) (6) One way to speed up development would be for localities to protect vested property rights. (6) (55)

Local governments have attempted to use other tools to spur private affordable housing development but are limited to those allowed under state law. For example, state law prohibits mandatory inclusionary zoning, in which local governments require developers to set aside units for affordable housing. However, the state allows for voluntary, incentive-based programs in which municipalities may provide zoning or land-use incentives to developers who offer units for sale or rent at below-market value. (56) (57) (58)

Local governments still play a role in the direct provision of affordable housing—albeit smaller than it once was. Local public housing authorities managed federally owned affordable housing properties when they were established in the Housing Act of 1937. (59)  Over time, the federal government slowly distanced itself from ownership of public housing projects and sold many buildings to private ownership to convert them into Section 8 or mixed-income projects. (60) Today, many PHAs play an administrative role by ensuring properties meet federal requirements and distributing funds to contractors who build, buy, or manage public housing projects. Although some housing authorities in Tennessee continue to contribute to the building and management of new public housing projects, this is largely achieved through public-private partnerships for mixed-income development. (61) (62)

What Are Housing Authorities?

Public housing authorities (PHAs) were originally created to implement federal housing priorities at the local level by managing and administering housing projects owned by HUD. While that remains their core purpose, they have also been used—to varying degrees—to advance local priorities.

PHAs are state and local government agencies first authorized in federal law in 1937 to build housing for low-income households using federal funding. (140) Today, PHAs have grown to have larger missions that still focus on federally-funded activities—managing public housing properties and administering most federal affordable housing programs (e.g., LIHTC, rental assistance). State and local governments, however, may use their housing agencies to lead and implement other local housing priorities and initiatives.

The Tennessee Housing Development Agency is one of 85 public housing authorities across the state. (144) THDA’s priorities are largely limited to federally-funded activities, which made up roughly 95% of the agency’s expected budget in FY 2025. (134) Meanwhile, a local PHA like Nashville’s Metropolitan Development and Housing Agency also manages other large development projects in the city (e.g., the rebuild of Second Avenue) and oversees a locally-funded PILOT program to create affordable housing units. (141)

Resources for Households

Federal, state and local governments offer resources and programs that households can access to obtain and maintain a home. However, these programs are sometimes underutilized due to stigma, administrative hurdles, a lack of awareness, or an unmet need. (91)

The federal government funds numerous programs administered by state and/or local agencies that help Tennesseans afford housing. (See “Federal Housing Resources for Households.”) The federal government funds and establishes the baseline requirements of these programs and state-based entities administer them. For example, THDA and 27 local PHAs administer the Section 8 rental voucher program in Tennessee. In most cases, states design their own requirements within federal parameters, and organizational practices by the administering agencies can shape how federal resources reach Tennesseans. For instance, Tennessee adds additional eligibility requirements and priorities to HUD guidelines for Section 8, LIHEAP, and weatherization programs in areas such as income levels, family size, region and legal status. The staffing, organization and capacity of these administrating agencies also impacts how programs operate across Tennessee. (92) (92) (93) (94)

Tennessee offers targeted assistance to help people with specific needs find housing. For example, various programs target individuals at-risk for or experiencing homelessness, provide transitional housing for youth aging out of foster care, and offer temporary rental assistance. Other programs cover in-home services that help individuals who need extra supports to maintain a home in the community—for example, aging adults, people with disabilities, or those with behavioral health needs. (95) (96) (97) (98)

Policymakers may want to consider expanding or strengthening these efforts to help more Tennesseans afford housing that meets their needs. For example, many existing programs are underutilized due to the stigma and misconceptions associated with housing assistance. Additionally, studies conducted by HUD have found that fewer than one-third to one-quarter of landlords accept rental assistance vouchers. (99) (100) (91) Efforts to raise awareness of available services and connect households in need with services tailored to their specific circumstances could help dispel stigmas and reduce housing insecurity. (101) State and local governments could also explore additional or more flexible ways to provide aid to low-income families that may not be possible under more rigid federal rental assistance standards.

Enhancing Buyer Financing Options

The financing options and costs available to buy a home are also affected by public policies, primarily at the federal and state levels. Federal policy affects everything from who can qualify for a mortgage to the cost of borrowing money (i.e., interest rates). The mortgage interest tax deduction, for example, is one of the largest federal homeowner incentives—costing the federal government an estimated $25.4 billion in foregone revenue in FY 2024. (102) Likewise, relaxed mortgage lending standards resulted in widespread delinquency that contributed significantly to the 2008 mortgage crisis. (103) (104) (105) Mortgage rules became stricter—boosting market stability and lender confidence, but also making it harder for people with little or no credit history to buy a home. (105)

The federal government backs several mortgage programs that are more accessible to eligible households than traditional mortgages. The Federal Housing Administration, the U.S. Department of Agriculture, and the Veterans Administration insure mortgages with lower down payments, less stringent credit standards, and often lower interest rates than conventional mortgages for target populations (e.g., first-time homebuyers, low-income rural residents, veterans). In doing so, these agencies take on risk (i.e., potential default) that commercial lenders typically try to avoid. (106) (107) (108)

In Tennessee, THDA connects Tennesseans with lenders offering these federally backed mortgages through the Great Choice Home Loans program. THDA works with lenders to originate these loans, applies federally mandated requirements (e.g., defines county-specific income thresholds), and trains and approves realtors to work with qualified buyers. The agency also sets additional requirements like completing a homebuyer education course. (106) (107) THDA helped originate 2,466 Great Choice loans in 2024. (109)

The state could explore ways to expand options and protect homebuyers—particularly for smaller-dollar mortgages. Smaller mortgages can be difficult to obtain from conventional lending because they’re not profitable for lenders. (110) However, smaller-dollar loans are especially important in rural areas with lower-priced homes. (111) (112) With limited mortgage access, rural households often turn to riskier financing options or forgo homebuying altogether. (113) To address this issue, some states have pursued approaches that offer more consumer protections for alternative financing. (114) Local governments in Kentucky and Indiana have also partnered with private financial intermediaries to provide smaller-dollar mortgage tools cheaper and faster. (115)

Reducing Other Household Barriers to Entry

Access to quality and affordable housing is shaped by a range of barriers, many of which are influenced by policy decisions at the federal, state, and local levels. These barriers include both formal requirements—such as credit checks and deposits—and informal challenges like limited housing stock, discrimination, or lack of information.

State and federal anti-discrimination laws and their enforcement can affect these barriers to entry. At the federal level, the Fair Housing Act prohibits discrimination in housing based on race, religion, and other protected characteristics. (116) In Tennessee, state-level protections are provided through the Tennessee Human Rights Act and the Tennessee Disability Act, which extend protections to include color, creed, national origin, sex, disability, and family status.  (117) These apply in all aspects of housing—including rental, sales, and financing and to all parties (e.g., landlords, managers, brokers). Historically the Tennessee Human Rights Commission has been responsible for enforcement—fielding 142 housing-related complaints in 2024, the largest portion of which were based upon disability discrimination. (118) (119) In 2025, these functions will be transferred to the Attorney General’s office. (120)

Policymakers may also consider addressing unanticipated costs and requirements that limit housing access for some households. Beyond discrimination, households often face a range of financial and procedural barriers that limit access to housing. These include:

  • High upfront costs, such as security deposits and down payments.(129)
  • Undisclosed or excessive fees, sometimes referred to as “junk fees,” including convenience charges and processing fees. (130) (131)
  • Strict credit requirements for market-rate rentals. (128)
  • Moving expenses. (127)
  • Lack of awareness about housing options that fit a household’s income and credit profile.(127)

These factors can compound existing challenges, forcing families to remain in substandard housing or take on unsustainable debt to secure better living conditions. (116) (99) (100) (121)

New and evolving dynamics are also shaping the housing landscape. Policymakers may want to consider the implications of:

  • AI-driven rent pricing algorithms, alleged to artificially inflate rental costs and reduce affordability. (122) (123) (124) (126)
  • Institutional investors with access to significant capital, who may outcompete individual buyers and drive-up home prices. (130)(131)
  • Mismanagement of housing stock, including both affordable and market-rate units, which can lead to vacancies or unsafe living conditions.(125) (126)

These emerging issues highlight opportunities for novel policy responses that address both traditional and modern barriers to housing access.

Parting Words

Policy choices play a crucial role in shaping access to housing. This report provides an overview of the federal, state, and local policy levers that do or could affect access to housing across Tennessee. These policy actions affect both the supply of and demand for housing by providing households and developers with the resources and opportunities they need to access what is or could be available. While these levers could increase access to housing in Tennessee, policymakers must carefully consider the unique trade-offs of each. Future reports will dive deeper into specific policy tools—including financing affordable housing development and the importance of local zoning, codes, and permitting.

References

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References

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