Rather than relying on informal negotiation between municipalities and individual developers, which has led to inconsistent and inequitable outcomes, the state should establish clear, standardized rent adjustment policies for all Local Action Units (LAUs). Negotiated approaches often lack transparency, place undue burden on municipal staff, and create frustration among property owners who feel they are treated differently from their peers. A uniform rent regulation framework would: 

• Apply consistent, enforceable rent increase cap formulas (e.g., based on CPI, wage growth, or a fixed percentage). 

• Eliminate case-by-case negotiations that can lead to disparities between developments. 

• Increase predictability for tenants, municipalities, and developers alike. 

• Reduce the administrative burden on municipal staff who are often not equipped to evaluate the financials behind rent increase requests. 

Ideally, a statewide standard should be established to ensure consistency across jurisdictions for creation of new LAUs. Implementation pathway could include a model regulatory agreement issued by EOHLC that includes standardized rent increase provisions. It will likely require a change to the 40B Guidelines (Section II) before implementation. Municipalities along with EOHLC could conduct a legal review to determine how existing agreements can be amended to include rent caps. Key components of a strong rent-increase-cap language 

• A Maximum Annual Rent Increase Cap: A clearly defined percentage limit on annual rent increases, such as 5% or the lesser of CPI (Consumer Price Index) or AMI growth. 

• Tied to Local Economic Indicators: Rent caps should consider wage growth and cost-of-living changes, ensuring that rent remains in line with what households can reasonably afford. 

• Enforcement Mechanisms: Explicit language on how and when municipalities can deny rent increase requests if they exceed the cap. 

• Transparency Requirements: Mandate clear communication to tenants and municipalities about planned rent adjustments to prevent unexpected spikes. 

• Managing affordability regulations differently for vacant and occupied units can create more flexibility while maintaining tenant protections. Differentiating between occupied and unoccupied units can allow for reasonable rent increases upon turnover while protecting current tenants from sudden financial strain. When a unit becomes vacant, developers have an opportunity to reset rents within affordability guidelines without negatively impacting existing tenants. Potential strategies include: 
  • Allowing maximum allowable rent increases in vacant units, while ensuring the occupied units see lower rent increases. 
  • Gradual rent adjustments for occupied units to prevent displacement when affordability terms change. 

  However, care must be taken to avoid incentivizing “soft evictions,” where tenants are pressured to leave without formal eviction in order to re-rent the unit at a higher rate. Additional thought and research are needed to design safeguards that uphold flexibility without undermining tenant protections. 

The current process for administering Local Action Units (LAUs) is often fragmented and reactive, with municipalities relying on informal communications, email chains, and manual spreadsheets. To improve efficiency and reduce administrative burden, municipalities and the state should implement a more structured and consistent approach to LAU administration. Key strategies include: 

• Standardized forms to ensure consistency in developer applications and rent increase requests. 

• Formalized review and approval processes that include clear checklists, timelines, and routing protocols to guide staff through each stage of LAU administration. 

• Centralized data management systems that reduce reliance on manual tracking and make it easier to monitor affordability compliance over time. 

• Clearly defined roles and responsibilities for each party involved to reduce confusion and promote accountability. 

Description of the Graphic:

The graphic has three columns of information.

First column: Current LAU Process

• Rent Proposal Submission: Developer sends email with rent proposal to the town.
• Review: Town negotiates with the developer via email. Information is sent to the EOHLC.
• Documentation and Approval: Spreadsheet used to track rents, tenant details, and income verification. Approve notice goes to the developer.

Second column: Potentially Improved Process

• Rent Proposal Submission: Developer submits rent proposal via standardized online form. The 30-day time limit starts. Automate receipt and tracking.
• Review and Initial Assessment: Coordinator reviews the proposal using a checklist. Preliminary assessment. Checklists.
• Structured Negotiation: Formal negotiation communication (developer, housing trust, PB). Use video conferencing tools for remote negotiations to ensure timely discussions. Remote meet.
• Documentation and Approval: Use a centralized database (smartsheet) to track data. Central database.
• Monitoring: Clarify roles. Automated reminders.

Third Column: Best Practices

• Standardized submission forms
• Formalized review and approval process
• Centralized data management
• transparent reporting and monitoring
• Clear role definitions

• Municipalities should collaborate to establish Shared Housing Services Offices (SHSOs) that provide centralized support for affordable housing administration. A SHSO is a regional, multi-jurisdictional entity that supports member communities by efficiently managing and overseeing affordable housing. By supplementing local staff capacity, an SHSO offers specialized expertise and dedicated personnel to ensure ongoing monitoring and administration of affordable housing programs. Additionally, this regional collaboration fosters a platform for municipalities to exchange ideas, strategies, and best practices on shared challenges and initiatives. In the case of LAUs, by pooling resources at the regional level, municipalities can improve efficiency in monitoring compliance, processing rent adjustments, and assisting tenants. SHSOs can also serve as a hub for technical assistance, data management, and policy implementation, reducing the administrative burden on individual municipalities while ensuring consistent oversight and enforcement of affordability requirements. 

  Best Practice: Regional Housing Coordinator Program (RHC) run by CMRPC 

  The Regional Housing Coordinator is a staff member housed within Central Massachusetts Regional Planning Commission (CMRPC) that is available to assist municipal staff as well as Affordable Housing Trusts and Community Preservation Committees. 

  Housed within CMRPC’s Regional Collaboration and Community Development team, the coordinator aids in expanding the capacity of both municipalities and relevant housing agencies. The RHC Program operates on a regional membership model, providing each participating town with housing coordination services based on its unique needs. 

  CMRPC hired the Regional Housing Coordinator in close collaboration with an advisory committee comprising representatives from each member town. The committee meets regularly to review the program’s progress, provide feedback, and collaborate on shared challenges. This collaborative structure has helped foster a sense of community among the towns and has ensured that the RHC’s efforts are responsive to local priorities while leveraging regional insights. 

  RHC is a strong model for how regional staffing support can enhance local housing capacity. The program has boosted local housing capacity by providing expert support, improving public engagement, and helping towns secure grants. It also fostered peer learning across communities. A key challenge has been balancing varied workloads across towns and responding to shifting needs highlighting the importance of flexibility and sustainable staffing models. 

Description of Graphic:

Regional Benefits of Shared Housing Services Offices (SHSOs)

Text to the left of a tall blue triangle says: Helping municipalities plan, permit, monitor, and maintaining their affordable housing stock.

White text on the blue triangle says: Regional Housing Model. To the right of that are three rows of information over the triangle.

First row: Proactive Compliance Monitoring – preserve units, maintain housing inventory.

Second row: Resource Efficiency – access to regional renters and buyers, leverage existing resources.

Regional Approach – common solutions for common challenges, housing through the municipal lens.

• Enhancing data sharing from the state would improve municipal capacity to track and enforce affordability restrictions while reducing the administrative burden by streamlining access to essential housing data. It would also support long-term affordability preservation by enabling proactive compliance management. Additionally, better data access would facilitate regional coordination, allowing municipalities to identify trends and collaborate on effective affordable housing strategies. As of April 2025, there is an opportunity to support IMAGE HD Bill that can help implement this recommendation. More details on the bill.