How Project 2025’s Proposals Might Impact CRE

“Project 2025” has been the buzz phrase trending across the political sphere and business world for the last few weeks.

And the hotly debated 900-page blueprint for conservative governance took on new significance Monday in light of President Joe Biden’s weekend decision to abandon the 2024 presidential race — a move that instantly forced the already chaotic U.S. election into a new level of disarray. 

For commercial real estate, industry players who only care about their real estate business need to focus on just a few dozen pages in the Project 2025 tome. One slim section includes everything that has to do with U.S. affordable housing policy and how that could boomerang throughout the entire multifamily sector. 

The 900-page document takes a firm stance in support of maintaining single-family zoning in municipalities across the country, urging any future conservative administration to push back against the expansion of multifamily zoning.

And together with suggestions for placing new limits on certain types of housing vouchers and eliminating federal transit subsidies, the document is at odds with many efforts underway to improve housing access, including in Republican-led states. 

“It’s really striking that the language around land use and single-family zoning is out of sync with many conservative thought leaders and Republican policymakers,” said Jenny Schuetz, a Brookings Institution senior fellow and an expert in housing and land use regulations. “Researchers at right-leaning think tanks like the [American Enterprise Institute] and Mercatus are strong advocates for zoning reforms that give property owners more flexibility.” 

AEI has proposed what it calls “live local urban villages” that mix housing types and small commercial properties. 

Moves to reduce the amount and type of housing vouchers as expressed in Project 2025 would definitely reduce the number of affordable housing developers, but market forces would fill the gap, said Ed Pinto, a senior fellow and co-director of the AEI Housing Center.

The Heritage Foundation-authored 2025 Presidential Transition Project, more commonly known as Project 2025, suggests extensive policy shifts and is self-characterized as a “governing agenda” to “take back our government.” Although Republican presidential nominee and former President Donald Trump has distanced himself from the document, it is widely seen as a blueprint for a potential second Trump administration. 

While Trump has said on social media and during recent rallies that he doesn’t know anything about Project 2025, at least 140 people associated with the former president — including his Housing and Urban Development director, Ben Carson, who authored the section on housing and HUD — helped formulate this policy vision. Just-named running mate J.D. Vance is also friends with the head of The Heritage Foundation. And in the first year of Trump's presidency, he enacted two-thirds of The Heritage Foundation's recommendations.

Further disavowing Project 2025, the Trump campaign has pointed voters to Trump’s own policy plan, dubbed Agenda47, and the official Republican Party platform as his agenda.

The Heritage Foundation declined to respond to questions for this story. Bisnow also reached out to Carson’s nonprofit, the American Cornerstone Institute, and didn’t receive a reply.

Setting aside the question of how closely linked Project 2025 is with Trump, the policy shifts around housing assistance and zoning would in many ways repeat efforts Trump made during his previous presidential term to change housing policy.

Trump spoke openly about preserving the “suburban dream” and rejecting any top-down zoning dictates that would challenge local control. Many of the budget proposals during his first term advocated for severe cuts to HUD programs and a sharp reduction in the number of vouchers. For many housing advocates, Project 2025 reads like déjà vu. 

“A lot of this is pretty familiar, in terms of what they were trying to push in the first Trump administration,” said Sarah Saadian, National Low Income Housing Coalition senior vice president of public policy and field organizing. 

The document references protecting the sanctity of local decisions on zoning rules and protecting single-family neighborhoods.

“A conservative Administration should oppose any efforts to weaken single-family zoning,” Project 2025 says.

The AEI’s Pinto interprets the vision in the document as being more about eliminating exclusionary zoning and letting local governments have control over zoning decisions. 

A 2023 paper by the National Association of Housing and Redevelopment Officials says that “restrictive land use regulations and zoning laws have been linked to higher housing prices, and reduced construction activity.”

This zoning stance seems to step back from broader efforts in different cities and states to encourage more development and density, according to Schuetz. Republican-led states like Utah, Montana and Florida have enacted zoning reforms to boost housing production, including moving away from exclusive single-family zoning.

“It’s not like there are serious proposals from either side of the aisle for the federal government to broadly preempt state and local authority over land use, so why is Project 2025 so worried about a nonexistent issue?” Schuetz said. 

Trump has been vocal about reducing regulatory barriers to housing production, including telling Bloomberg Businessweek, “Zoning is a killer.” The recently approved 2024 Republican platform only mentions single-family homes and housing to own. Under Trump’s administration, HUD published a substantial report on ways to reduce regulatory barriers. Hewing to existing single-family zoning, which would limit space for additional multifamily production, seems to embed a specific barrier. 

Ryan von Weller, chief operating officer for Florida-based Wendover Housing Partners, advised the legislators who wrote and passed Live Local, the Florida housing law that has led to increased apartment production in commercial and industrial areas of the Sunshine State. He said that if policy leaves areas zoned for single-family housing off the table, regulations would need to be altered to encourage building elsewhere.

“If you're going to put a hard stop on rezoning a single-family area, you’ve got to give something else,” he said. “You're going to have to have people build somewhere commercially or industrial. You have to give people an option to build affordable, workforce or any multifamily, really.” 

The National Multifamily Housing Council, National Apartment Association and Urban Land Institute all either declined to talk for this article or weren’t available.

Project 2025 would also achieve long-term Republican policy goals around federal spending on housing programs, according to Will Fischer, senior director of housing policy for the Center on Budget and Policy Priorities. Fischer pointed to a long history of efforts by GOP representatives and administrations to make fairly significant shifts to rental assistance programs, including more work requirements and added limits on the amount of time a family can utilize vouchers.

“Vouchers are primarily used in private market housing,” Fischer said. “Cutting them is going to be very disruptive because they help around 5 million households.”

The language of Project 2025, specifically the portion emphasizing choice and mobility in housing vouchers over site-based subsidies, follows conservative beliefs about the consequences of making development decisions, Pinto said. 

“The problem with site-based vouchers is it freezes the use of that property,” he said. 

Fischer also pointed to previous efforts to add more work requirements, which would likely restrict the number of Americans who could access assistance. This would especially impact low-income renters in HUD properties, 9 out of 10 whom are either already working, seniors or have a disability.

A significant cut in the number of vouchers or voucher funding would have an impact on the affordable housing market by reducing the financial support many developers and operators depend on, von Weller said.

“For the affordable world, it’s a very big deal,” he said. “It would be very bad to curtail the amount of vouchers out there. It helps us to build more units and to finance the project in a more favorable fashion. It increases the amount of units we can build.”

The issue of homelessness has also been a flash point in city politics and a frequent complaint for property owners and downtown developers. Project 2025 would seek to end Housing First, the generally accepted strategic approach advocated by the federal government that seeks to immediately provide housing to quickly get the unhoused access to mental health resources, substance use treatment and social services. 

Saadian fears that the loss of support for this strategy — coupled with the June Supreme Court decision in City of Grants Pass v. Johnson, which makes it easier for cities to criminalize homelessness — may ultimately mean more people living on the street and increased pressure on local officials to pursue more arrests and ticketing of the unhoused. 

Another worry for Saadian is the governmentwide suggestion in Project 2025 that more career bureaucrats would be replaced with political appointees, which she fears would strip HUD of needed expertise. 

“I've talked to some of my colleagues who have worked for previous Republican administrations, and I don't think they would want to go back,” she said. “Who are the adults in the room who really know housing, who care deeply about this? What I see is like déjà vu from Round 1 of the administration, and things might be even harder this time around.”