Two identical housing projects can cost five times more depending on the city. This is not because of construction, but because of regulations.

Part One of this 3-part series, Affordable Housing at Risk, established the national landscape of regulatory costs and the impact they have on residential affordable housing. This part, Part Two, continues the analysis by Principal Architect Patrick Chopson, AIA, examining how this quiet epidemic plays out across America’s largest metropolitan areas.

By comparing both a typical single-family residential development and a 100-unit multifamily development in the 10 biggest U.S. metros, Chopson reveals just how dramatically regulatory fees, timelines, and mandated requirements can differ from city to city.

These disparities, sometimes a 40x difference in cost, cannot be explained by construction complexity, climate, or engineering needs. Instead, they reflect fundamentally different policy choices that either accelerate housing production or slow it to a crawl. What emerges is a clear and data-rich picture of how local regulation shapes affordability, access, and the pace of new housing across the country.

Affordable Housing Measuring the Residential Costs Across America's Largest Metros

This analysis examined regulatory costs for two scenarios across the nation's 10 largest metropolitan areas by population: a typical 2,000-square-foot single-family home and a 100-unit multifamily development. The findings reveal dramatic disparities in both costs and timelines that cannot be explained by construction complexity or local conditions alone.

New York: Complexity As the Default Setting

The New York metropolitan area imposes some of the nation's most complex regulatory requirements, with up to 11 municipal agencies potentially reviewing a single project.

For a 2,000-square-foot single-family home costing $400,000 to construct, regulatory expenses range from $49,000 to $99,000, representing 12% to 25% of construction costs.

Direct permit fees run $6,000-$8,000, but the real burden comes from mandated professional fees totaling $31,000-$62,000, including required architects, engineers, energy compliance consultants, and the uniquely New York phenomenon of permit expediters who navigate the bureaucratic maze for $3,000-$8,000.

Multifamily development faces even steeper barriers. A 100-unit project encounters regulatory costs between $3.3 million and $7.3 million, or 9% to 21% of the $35.2 million construction budget. The Uniform Land Use Review Procedure (ULURP) for discretionary projects alone can consume 24-36 months, with carrying costs accumulating at $50,000-$80,000 monthly. The 485-x tax incentive program requires prevailing wages of $64-$74 per hour for projects over 100 units, increasing construction costs by 29% in high-demand areas.

Timeline:

• 2–6 months for as-of-right single-family construction

• 12–36 months for multifamily projects

• 2.5 years (average) for zoning changes

• Only 21,000 housing units were permitted in Manhattan during the entire 1990s

• This is fewer than the 13,000 units permitted in 1960 alone

Los Angeles: The Impact Fee Capital

Los Angeles demonstrates how impact fees can dominate regulatory costs. For single-family homes, total regulatory expenses reach $55,500-$99,000 (14-25% of $400,000 construction), with the Affordable Housing Linkage Fee adding $2,000 at the low end. The real shock comes with multifamily development, where that same linkage fee jumps to $12 per square foot, generating $960,000 in fees alone for an 80,000-square-foot project.

Total multifamily regulatory costs in Los Angeles reach $7.9 million to $11.7 million for a 100-unit development, representing 26% to 38% of the $30.4 million construction budget. Beyond the linkage fee, California's school impact fees add nearly $2 million ($19,558 per unit), creating a combined impact fee burden of $3.5-$3.9 million. Add another $1.9-$3.4 million in consultant fees for architects, engineers, traffic studies, and California Environmental Quality Act (CEQA) compliance, and developers face regulatory costs exceeding one-third of their construction budget before breaking ground.

Timeline:

• 3–6 months for single-family homes

• 495 days (median) for Transit-Oriented Communities (TOC) multifamily projects

• 747 days (nearly 25 months) for non-TOC discretionary developments

• Executive Directive 1 provides expedited review for 100% affordable housing projects

Chicago: The Midwest Efficiency Model

Chicago demonstrates that large, dense cities can maintain relatively streamlined processes. Single-family regulatory costs total $35,500-$69,000 (9-17% of $400,000 construction), the lowest among the three largest metros. Direct permit fees start at just $3,500-$5,000, and Chicago's relative lack of impact fees compared to California cities saves tens of thousands per project.

For multifamily development, Chicago's regulatory burden of $2.6-$5.3 million (7-14% of $36.8 million construction) substantially undercuts both New York and Los Angeles. The city offers multiple permitting tracks including Self-Certification (10-day approval), Easy Permit (same-day for qualifying projects), and Developer Services for complex projects—innovations that saved months compared to coastal competitors.

Timeline:

• 70 days (2.3 months) on average for standard residential permits

• 10 days with self-certification

• 180 days when zoning changes are required

• New construction commercial approval time was reduced from 276 days (2023) to 189 days (2024) due to process improvements

Dallas-Fort Worth: Recent Reforms with Mixed Results

Dallas underwent dramatic fee increases in May 2024, raising building permits by 649% for single-family homes ($100 to $749) and 190% per unit for multifamily ($225 to $652 per dwelling unit). These increases sparked controversy but came alongside significant timeline improvements, residential permits dropped from 3-4 months to a median of 8 days, and commercial permits fell from 276 to 189 days.

Total single-family regulatory costs in Dallas range from $8,100-$16,100 (2.7-5.4% of construction), though suburban areas with higher impact fees push this to $12,100-$26,100 (4.0-8.7%). Multifamily projects face $463,000-$930,000 in regulatory costs, or 6.8-10.8% of the $6.8-12 million construction budget. The proposed street impact fee could add $140,000-$200,000 to multifamily projects if implemented.

Timeline:

• 8 days (median) for residential permits (down from 3–4 months)

• 189 days for commercial new construction

• Suburban jurisdictions such as Frisco, McKinney, and Rowlett impose impact fees of $6,000–$15,000 per single-family home

Houston: No Zoning, But Not No Cost

Houston, Texas is famous for lack of comprehensive zoning. This creates a unique regulatory environment, but impact fees (particularly for water and wastewater) still impose substantial costs. Single-family homes face $3,400-$11,400 in regulatory costs (1.2-4.1% of $280,000-$360,000 construction), the lowest among major metros. Water impact fees of $2,091 per service unit and wastewater fees of $1,746 comprise the largest component, though homes priced below the median ($265,575 as of 2021) and under 3,000 square feet can qualify for exemption.

Multifamily development encounters $489,000-$732,000 in regulatory costs (6.4-7.5% of construction), with water and wastewater impact fees totaling approximately $268,000 for 100 units. Houston's efficient permitting processes residential permits in just 5-10 business days and commercial projects in 4-8 weeks, timelines that translate directly into lower carrying costs and faster project delivery.

Timeline:

• 1–2 weeks for simple residential permits

• 4–8 weeks for commercial projects

• A minimal zoning framework and online permitting system enable permitting speeds unmatched by more heavily regulated jurisdictions

Miami: Comprehensive Impact Fees and Hurricane Requirements

Miami-Dade County, Florida, employs the most comprehensive impact fee structure in this analysis, assessing fees across mobility, fire and emergency services, police, parks, schools, and water/sewer. Single-family homes face total regulatory costs of $15,200-$27,500 (4.9-7.2% of $310,000-$380,000 construction). School impact fees of $2,448 per home represent a dramatic undercharge compared to peer counties—Broward County charges $7,047 and Palm Beach $6,608, suggesting Miami-Dade leaves substantial revenue uncollected.

Multifamily development encounters $843,000-$1.5 million in regulatory costs (7.4-10.5% of construction), with impact fees alone totaling $460,000-$740,000. Florida's stringent hurricane and flood requirements add $20,000-$40,000 in specialized engineering and $8,000-$15,000 for flood plain analysis when applicable. Multi-agency review involving county departments plus municipal approvals within city limits extends timelines to 3-6 months for large developments.

Timeline:

• 6–8 weeks for small projects

• 2–4 months for medium projects

• 3–6 months for large multifamily developments

• Plan review for large projects:

• - 24 hours to 10 business days for initial review

• - Subsequent review cycles and multi-agency coordination significantly extend total timelines

Washington DC: Historic Preservation and High Professional Fees

The District of Columbia imposes regulatory costs of $84,000-$128,000 (21-32% of construction) on single-family homes, among the highest percentages nationally. Direct permit fees of $19,000-$25,000 exceed most competitors, but architectural and design fees of $48,000-$75,000 (12-18.8% of construction costs) comprise the largest single component. Projects in historic districts face additional $2,000-$10,000 in review costs and 2-4 months of timeline delays.

Multifamily development faces estimated regulatory costs of $7.3-$9.1 million (38-41% of an $18-22.5 million project), applying national multifamily averages to the DC regulatory environment. Approval timelines range from 6-18 months depending on project complexity and historic district involvement.

Timeline:

• 3–6 months for standard single-family construction

• 6–12 months for projects in historic districts or those requiring variances

• 6–18 months for multifamily developments

• Expedited review available at 1.5–2× standard fees, reducing timelines by ~50%

Atlanta: A Tale of Two Jurisdictions

The Atlanta metropolitan area reveals the starkest contrast between efficient and burdensome regulatory processes. Single-family regulatory costs in Atlanta city range from $55,500-$94,600 (18.5-31.5% of $300,000 construction), but the real story lies in approval timelines. A 2005 study documented that building permits requiring 4 weeks in efficient metro Atlanta counties took up to 40 weeks in Atlanta city, a 10x time penalty that translates into $20,000-$40,000 in additional carrying costs.

Atlanta city's process requires navigating up to 11 distinct municipal agencies, with multiple plan resubmission cycles common. By contrast, suburban counties like Gwinnett, Cobb, and Clayton maintained 4-week timelines even during the COVID-19 pandemic by consolidating inspection functions (one combined inspector versus Atlanta's four separate inspectors for plumbing, electrical, HVAC, and structural). These counties exceeded pre-pandemic permit issuance numbers while DeKalb County—which closed its permit office to the public, saw permits decline 31% and earned a "worst permitting office in the metro area" rating from contractors.

Multifamily development faces estimated regulatory costs of $4-$5.4 million (35-40% of $11.4-13.5 million construction), with timelines of 3-6 months in efficient counties versus 6-12+ months in Atlanta city for complex projects.

Timeline:

• 4 weeks in efficient suburban counties

• Up to 40 weeks historically in the City of Atlanta: Timelines have improved with 2023 Phase 1 reforms and new digital systems

• DeKalb County opened a one-stop permitting office (July 2021) after major COVID-era delays

• The 36-week gap between Atlanta and efficient counties shows that regulatory burden is a policy choice, not a necessity

Philadelphia: The Stormwater Bottleneck

Philadelphia's regulatory costs for single-family homes total $50,800-$88,600 (16.9-29.5% of $300,000 construction), with the city's 1% Development Impact Tax adding $3,000 on a $300,000 project. Standard Department of Licenses & Inspections review takes 15 business days (3 weeks) for one/two-family residential, with accelerated 5-day review available for an additional $540 fee.

The critical bottleneck emerges with the Philadelphia Water Department's stormwater review, which can extend up to 8 months for Post-Construction Stormwater Management Plans. This single agency review period exceeds the entire permit approval timeline in efficient jurisdictions, adding substantial carrying costs. A 2010 study found Philadelphia's development permit process typically required 156-571 days, with projects involving variances or ordinances potentially exceeding 1,000 days.

Multifamily projects face estimated regulatory costs of $3-$6 million (22-33% of $13.5-18 million construction), with the Development Impact Tax alone totaling $135,000-$180,000. Up to 14 city agencies may process a single building permit, creating coordination challenges and unpredictable delays.

Timeline:

• 15 business days for standard residential review

• 5 business days with accelerated review (+$540)

• Up to 8 months for PWD stormwater review

• 12–18 months total for complex multifamily projects

• 18–24+ months when variances or special exceptions are required

Phoenix: Location-Dependent Impact Fees

Phoenix, Arizona presents unusual geographic variation in regulatory burden based on the city's 14 designated fee service areas. Single-family regulatory costs range from $8,000 in low-infrastructure areas to $50,000+ in high-infrastructure zones, with impact fees varying from $0 to $17,765 per home. Average regulatory costs total approximately $28,000 (9.4% of $300,000 construction), with Maricopa County averaging $11,076 in impact fees for a 2,000-square-foot home.

Multifamily development encounters $1.3-$1.9 million in regulatory costs (5.8-8.7% of $21.8 million construction), with impact fees ranging from $361,800 to $975,000 depending on location within the metro. Arizona's 2023 passage of SB 1103 authorized administrative staff approval of plats and site plans without City Council review, saving approximately 30 days in approval time. Phoenix also offers an Express Pass Program providing site plan approval in 3 business days for qualified projects.

Timeline:

• 2–4 months for single-family permits

• 9–18 months for major multifamily projects

• Administrative approval reforms and the Express Pass Program now offer faster pathways for qualifying projects

The Regulatory Cost Comparison for Not-So Affordable Housing

National Average: $93,870 (23.8% of home price)

The $124,600 gap between Houston’s minimum regulatory cost ($3,400) and Washington D.C.’s maximum ($128,000) demonstrates that regulatory burden varies by a factor of nearly 40x across major American cities. This variation cannot be explained by differences in construction complexity, seismic requirements, or climate—it reflects fundamentally different policy choices about how much process and how many fees to impose on housing construction.

National Average: 40.6% of total development costs

The multifamily data reveals even starker disparities. Los Angeles imposes 5-6 times higher regulatory costs than Houston for identical projects, driven almost entirely by policy choices around impact fees and approval complexity rather than genuine differences in construction requirements. The $960,000 Affordable Housing Linkage Fee alone exceeds Houston's entire regulatory burden for a 100-unit project.

Affordable Housing or Otherwise: A Thing of the Past?

The metro-by-metro comparison makes one conclusion unavoidable: the cost of building affordable housing in the United States is determined far less by concrete, steel, or labor than by the regulatory systems that govern them. Cities with predictable processes and limited discretionary review (like Houston and Chicago) deliver homes at a fraction of the cost and time required in places like Los Angeles, Washington D.C., and New York.

Meanwhile, the most extreme cases show regulatory burdens consuming up to 40% of total development costs, adding years to approval timelines, and pricing out thousands of potential homes before construction even begins.

With these differences laid bare, Part Three (coming soon) will turn toward the solutions, highlighting the policy reforms, streamlined processes, and accountability measures that can make affordable housing not just possible, but scalable.

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About cove’s Principal Architect Patrick Chopson, AIA

Patrick Chopson, AIA, is Co-Founder and Principal of cove, an AI-powered architecture firm transforming how buildings are designed and delivered. A licensed architect with 20+ years of experience, technologist and building scientist, Patrick focuses on the intersection of AI and Architecture.

He previously co-founded the building performance consultancy Pattern r+d and co-authored Build Like It’s the End of the World (Wiley, 2025), a guide to decarbonizing AEC. His work has been featured in Architect Magazine, TechCrunch, and ArchDaily, and he regularly collaborates with developers and industry leaders on next-generation solutions.