On November 30, we submitted formal written comments to the State of Utah regarding the draft State Housing Plan. Our full comments can be found below. 

Utah’s housing challenges have reached a critical point. With rapid population growth, rising costs, and a decade of underbuilding, the Wasatch Region needs a coordinated, statewide approach to ensure that every Utahn has access to a safe, stable, and affordable home. The draft State Housing Plan is an important step toward that goal, and WALC strongly supports its development and adoption.

In our comments, we emphasized five major themes:

1. Utah must clearly identify the role of restrictive local zoning in creating the housing shortage.

Cities have used minimum lot sizes, parking mandates, and single-family-only zoning to block the very housing types Utah needs most. Addressing the crisis requires naming these barriers directly.

2. Strong state guardrails are essential.

We urged the state to adopt firm, statewide standards that supersede restrictive local practices when they undermine regional housing needs. Other states, including our Mountain West neighbors Arizona and Montana, among them, have already moved decisively in this direction. Utah must do the same.

3. The plan should include single-stair reform.

This modern building-code tool allows small, safe, cost-effective apartment buildings up to 4–6 stories. Including it in the State Housing Plan would unlock new housing types perfectly suited to Utah’s future communities.

4. By-right approvals and minimum zoning expectations are key to implementation.

Without clear statewide rules, Utah will continue to rely on voluntary local action—an approach that has contributed to the crisis.

5. Tenant stability and eviction prevention must move forward alongside housing supply.

Affordability solutions and renter protections are not competing priorities—they are complementary pillars of a healthy housing system. Utah must pursue both simultaneously to ensure that families can remain housed while new homes come online.

Our message to the state is simple: Utah can, and must, lead the nation with a modern, effective, and evidence-driven housing framework. Implementing strong statewide guardrails, modernizing codes, and supporting tenants will help create a future where Utahns at every income level can find a home that meets their needs.

WALC is committed to working with policymakers, community partners, and residents across the region to make this plan as strong and impactful as possible.

11/30/2025

To Whom It May Concern:

Wasatch Advocates for Livable Communities (WALC) respectfully submits this letter in strong support of the development, adoption, and implementation of a comprehensive State Housing Plan for Utah. As the Wasatch Region continues to experience rapid population growth, economic expansion, and increasing pressure on its limited housing inventory, the need for a coordinated, statewide strategy is essential to the future of the region and state. 

The draft State Housing Plan demonstrates thoughtful analysis, an evidence-based understanding of Utah’s housing conditions, and a commitment to aligning housing strategies with the state’s long-term prosperity. We commend the state for taking this step. At the same time, we urge several important refinements that will enhance the plan’s effectiveness and help ensure that it fulfills its promise.

In particular, WALC urges the State of Utah to:

1. Recognize clearly and explicitly the central role that restrictive and unnecessary local land-use policies play in creating the current statewide housing shortage.
2. Adopt strong state guardrails – policy standards that supersede local authority when local decisions undermine statewide housing goals.
3. Include single-stair reform as a critical building-code modernization tool capable of unlocking new housing types.
4. Strengthen the plan’s implementation mechanisms, including by-right processes and minimum zoning expectations for local land-use authorities. 
5. Fully support tenant stability and eviction-prevention strategies, affirming that supply expansion and tenant protections are complementary, not competing, priorities.

The remainder of this letter elaborates on these core recommendations and reflects our strong belief that Utah can lead the nation with a modern, effective, and evidence-driven statewide housing framework.

I. Utah Needs a State Housing Plan that Reflects the Scale and Urgency of the Crisis

Utah’s housing shortage is no longer a short-term imbalance; it has become a structural problem with statewide economic consequences. The draft State Housing Plan notes that Utah faces a shortage of tens of thousands of units, a gap driven by a decade of underbuilding relative to population, job growth, and expanding economic opportunity. Homes that once cost $250,000 now sell for twice that or more, rents have risen sharply, and both urban and rural communities are experiencing housing pressures previously unseen in Utah’s history. 

The plan correctly identifies several key drivers of the crisis:

• Population growth outpacing housing construction
• A severe lack of moderate-density housing options
• Labor shortages and rising construction costs
• Regulatory barriers that limit the feasibility of home construction
• Insufficient housing near employment centers and transit corridors, and in established opportunity-rich neighborhoods 
• Increasing housing cost burdens, especially for young households, seniors, and larger families 

WALC strongly supports the plan’s emphasis on aligning housing policy with the state’s long-term economic development, water management, transportation, and workforce needs. Utah’s future prosperity depends on its ability to house the families, entrepreneurs, and workers who power the state’s economy.

The State Housing Plan is an opportunity not only to describe the crisis but to clarify Utah’s vision for a housing future defined by attainability and choice. To realize that vision, however, the plan must candidly address the structural policy decisions that created the shortage, particularly the accumulated effect of restrictive local zoning across the state.

II. State Guardrails Are Essential to Align Local Practice With Statewide Housing Needs

Local governments in Utah wield extraordinary influence over what types of homes may be built, where they may be built, and in what form. Through zoning codes, minimum lot sizes, discretionary approvals, costly parking mandates, and cumbersome procedural requirements, cities throughout the state have constrained housing supply for decades. These restrictions, especially the near-total prohibition on moderate-density housing in many jurisdictions, have played a major role in creating the statewide shortage identified in the Utah Housing Strategic Plan.

For this reason, the State Housing Plan must state plainly:

Local land-use practices are a central driver of Utah’s housing crisis, and the state must adopt meaningful guardrails that supersede restrictive local authority when local decisions undermine statewide housing needs.

Such guardrails are not a radical departure from national practice. In fact, many states facing significantly less growth pressure than Utah have already taken decisive steps to ensure that local governments cannot use land-use authority to block the housing needed for a healthy regional economy.

Other States Are Already Acting: Even Without Utah’s Growth Pressures

Arizona and Montana, whose overall population growth and housing pressures are far less acute than what Utah faces, provide clear examples of the direction states are moving to address their housing affordability crises. 

Arizona House Bill 2720

Beginning in 2024, Arizona enacted HB 2720, which requires cities with populations of 75,000 or more to allow at least two accessory dwelling units (ADUs) on every single-family lot. The law also permits a third ADU on lots larger than one acre or when one ADU is deed-restricted for affordability.

Importantly, HB 2720 restricts cities from using local authority to undermine these rights. Specifically, cities:

• Cannot require additional off-street parking for ADUs
• Cannot mandate that ADUs match the exterior design of the primary dwelling
• Cannot impose setbacks greater than five feet

In other words, Arizona did not simply "legalize" ADUs; it enacted state guardrails that prevent cities from making ADUs functionally impossible to build.

Arizona House Bill 2721

A companion measure, HB 2721, requires cities over 75,000 residents to allow middle housing including duplexes, triplexes, fourplexes, courtyard apartments, townhomes, and cottage clusters as a permitted use on single-family lots within one mile of their downtowns.

In addition, for any new development of 10 acres or more, at least 20% of units must be middle housing, ensuring real housing diversity in large master-planned projects.

The law also requires that cities adopt new zoning ordinances to comply by January 1, 2026, a clear example of the state creating both a mandate and a timeline to ensure alignment.

Arizona has acted not because its housing challenges are more severe than Utah’s, but because it recognizes that housing markets are regional and statewide concerns, and that local authority must be balanced with statewide responsibility.

Utah, by contrast, faces:

• Far faster population growth, both natural growth and in-migration. 
• More severe housing shortages, driven by inadequate supply. 
• More acute affordability challenges, driven by housing shortages. 
• Greater economic risk from underbuilding given the need for a stable workforce to support Utah’s emerging and legacy economic drivers. 

And yet, Utah has not adopted guardrails anywhere near as reliable as those now in place in Arizona.

The Utah State Housing Plan should explicitly acknowledge this gap and include strategies designed to implement these guardrails. 

Housing markets, transportation systems, and workforce needs do not stop at municipal boundaries. When cities refuse to allow adequate housing or allow it only on terms that render it infeasible, the consequences ripple across the entire Wasatch Region in the form of:

• Higher prices
• Longer commutes
• Increased displacement and housing instability 
• Reduced economic mobility and long-term dependence on subsidies or support
• Higher infrastructure costs for the state
• Lost economic competitiveness
• Fewer ownership and equity-building opportunities 

The 2023 “Montana Miracle” Reforms

Montana has become one of the clearest national examples of how a state can adopt effective, bipartisan statewide guardrails to ensure that local governments cannot block needed housing. Despite experiencing far less population growth and economic pressure than Utah, Montana’s legislature passed sweeping reforms in 2023 and 2025, now widely known as the “Montana Miracle”, that modernized statewide land-use laws and rebalanced state and local responsibilities.

Taken together, Montana’s reforms illustrate a principle highly relevant for Utah: when local governments systematically restrict housing, the state must act to protect regional housing needs, statewide affordability, and economic health.

In 2023, Montana enacted a package of bills that fundamentally reshaped the state’s approach to housing, including:

SB 382 – Comprehensive Zoning and Planning Reform
SB 382 requires cities to update zoning and growth plans to reflect statewide housing needs and removes local authority to impose zoning barriers inconsistent with state standards. The bill also streamlines planning processes, limits the use of discretionary reviews, and sets statewide expectations for housing capacity.

SB 323 – Allowing Duplexes Statewide
Montana now requires cities to allow duplexes as a permitted use on all residential lots in cities above a minimum population threshold. Local governments can no longer use single-family-only zoning to prohibit small-scale density.

SB 528 – Legalizing ADUs Statewide
Cities must allow accessory dwelling units by right on all single-family lots. Local governments are prohibited from imposing burdensome parking requirements, owner-occupancy mandates, or design standards that would make ADUs infeasible.

SB 245 – Allowing Multi-Unit Housing in Commercial Zones
This law requires cities to allow multifamily housing in commercial zones, a major shift that opens significant new capacity for housing, especially along transportation corridors and in employment centers.

These reforms were spearheaded by a bipartisan coalition of legislators, business leaders, and young professionals who recognized that local governments had constrained housing supply for too long and that statewide action was needed to restore affordability.

2025: Montana Strengthens Its Guardrails Even Further

Building on the 2023 successes, Montana continued to advance housing reforms in 2025, including legislation to:

• Further streamline approvals for missing-middle housing
• Restrict local use of design review to block viable projects
• Expand opportunities for infill development
• Strengthen requirements for cities to update zoning codes consistent with statewide housing goals

These actions signal a clear recognition: local governments cannot address statewide housing shortages on their own, and the state must provide clear rules to guarantee housing capacity.

Montana’s actions demonstrate that:

• Housing production is a statewide economic function, not a purely local one
• Local zoning that prevents needed housing must be superseded by state guardrails
• Bipartisan coalitions can advance major reform when the state makes housing a priority
• State intervention is both justified and necessary when local regulations harm residents and employers

If a lower-growth, lower-pressure state like Montana can adopt effective guardrails — legalizing ADUs and duplexes, reducing barriers to missing-middle housing, modernizing city planning frameworks — then a rapidly growing state like Utah, facing far more severe housing pressures, has an even greater responsibility to do so.

Montana’s example shows that statewide action is not only possible, it is essential for any state confronting a structural housing shortage. Utah’s State Housing Plan should acknowledge this national trend and commit to adopting statewide guardrails that ensure every jurisdiction contributes meaningfully to the state’s housing needs.

The Lesson for Utah

State guardrails are essential to correcting these structural misalignments. These guardrails should include:

• • Minimum zoning guardrails for moderate-density housing statewide
  • By-right approval processes for housing that meets statewide standards
  • Restrictions on local discretion that impedes housing feasibility
  • Requirements for transit-oriented development near major investments
  • Code modernization and protections for innovative housing types

• Specific goals for the replacement of expiring deed-restricted homes 

Other states have already recognized that housing affordability cannot be left solely to local discretion. Utah, facing even sharper growth pressures, must adopt similarly decisive statewide action.

III. Single-Stair Reform: A Missing Piece in the State Housing Plan

One of the most powerful and cost-effective reforms available to Utah is single-stair reform. This building-code modernization, already gaining momentum in cities and states across the country, allows small apartment buildings typically up to four to six stories to be constructed with a single enclosed stairwell, provided that buildings meet enhanced fire-safety requirements.

Under current U.S. code norms, buildings often require two stairwells, even at small scales. This restriction:

• Reduces buildable floor area
• Limits design flexibility
• Increases construction costs
• Makes family-sized units difficult to configure
• Restricts the feasibility of small multifamily buildings on narrow or infill lots

Single-stair reform paired with sprinkler systems, enhanced materials, and strict safety standards would unlock a range of housing types ideally suited for Utah’s future:

• 4 - 6 story walk-up apartments
• Family-sized units with improved natural light
• Courtyard buildings and small mixed-use structures
• Transit-oriented housing on narrow or irregular parcels
• Small developer projects in existing neighborhoods

This reform is particularly important in a state where land is scarce, construction costs are rising, and moderate-density housing is essential to meeting demand. WALC recommends that the State Housing Plan explicitly incorporate single-stair reform as a priority for code modernization and as a core component of the state’s housing-supply strategy.

IV. Tenant Protections and Housing Stability: A Necessary Complement to Supply Expansion

The State Housing Plan correctly highlights the need for improved tenant support through housing stability. WALC strongly supports this emphasis and recommends that the plan deepen its commitment to housing stability in several ways.

1. Tenant Protections and Housing Production Are Not Mutually Exclusive

Too often, debates around housing policy create a false dichotomy between expanding supply and protecting renters. Utah must reject this framing. The housing shortage is too large and too complex to be solved with a single policy tool. A sustainable and equitable housing future requires both abundant housing supply and meaningful tenant protections.

1. Eviction Prevention and Housing Stability Benefit Both Landlords and Tenants

Research shows that eviction prevention:

• Supports small landlords
• Reduces homelessness
• Enhances educational outcomes for children
• Strengthens workforce participation
• Lowers public costs associated with shelter and crisis services

Utah should expand investments in:

• Eviction prevention and diversion
• Rental assistance
• Mediation and legal support
• Data collection on displacement trends

1. Tenant Stability Supports Housing Development

Stable communities support local businesses, increase neighborhood desirability, and make housing development more predictable and financeable. Responsible landlords benefit from avoiding preventable eviction processes when tenants can remain housed through a period of hardship. Developers benefit from communities that welcome a diverse population of renters and homeowners.

1. 4. Utah Should Strengthen Its Commitment to Health and Habitability

To better address the need to preserve Naturally Occurring Affordable Housing (NOAH), the plan should further emphasize:

• Proactive rental inspections
• Enforcement of habitability standards
• Clear communication systems between renters and landlords
• Support for rehabilitation of older rental properties

These measures improve living conditions without undermining responsible property ownership.

1. A Comprehensive Housing System Requires Both Pillars

WALC urges the state to affirm explicitly that tenant protections, eviction-prevention strategies, and support for vulnerable renters are fully compatible with and essential to the success of supply-side reforms.

Housing supply and housing stability are interdependent pillars of a resilient housing ecosystem. Utah must advance both with equal commitment.

V. Utah’s Long-Term Prosperity Depends on Strong Statewide Leadership

Without decisive action, Utah risks a future where:

• Young families leave the state and/or delay having children
• Employers struggle to recruit workers
• Commutes lengthen and traffic patterns worsen
• Infrastructure costs escalate and water resources continue to be strained
• Economic opportunity decreases as economic mobility evaporates 

But with strong state guardrails, modernized building codes, targeted tenant support, and a consistent statewide framework, Utah can remain the most dynamic, opportunity-rich state in the nation.

VI. Conclusion

Wasatch Advocates for Livable Communities strongly supports the development of the State Housing Plan and the significant work that has gone into understanding Utah’s complex housing landscape. This plan represents a critical first step, and with several key refinements– strong statewide guardrails, explicit acknowledgment of local zoning barriers, single-stair reform, robust tenant protections, and clear implementation mechanisms– it can become a national model.

Utah’s housing future depends on choices made today. WALC stands ready to partner with state leaders, local governments, the private sector, and community organizations to ensure that every Utahn has access to a safe, stable, and affordable home.

Sincerely,
Wasatch Advocates for Livable Communities