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Western Spaces
policy guidance 2024–2025

Proposition 123 Compliance Guidelines

Compliance guidance and unit counting methodology for Colorado jurisdictions meeting Proposition 123 affordable housing commitments.

Client
Department of Local Affairs
Location
Colorado (statewide)
Deliverables
Compliance Guidelines, Unit Counting Methodology, FAQ Documentation, Informational Flyers
8
Housing categories
100s
Of jurisdictions served
4
Compliance standards set

Counting affordable housing units sounds straightforward until you try to do it. Does a deed-restricted home still count when the restriction expires next year? What about employer-provided housing that isn’t formally documented? Or a naturally occurring affordable property already counted under a different program? Proposition 123 required participating jurisdictions to show progress — and when you count turns out to matter as much as what you count.

When you count turns out to matter as much as what you count.

A unit completed before the NOFA period opens doesn’t count. One counted under two programs at once inflates the numbers. Eight distinct housing categories, each with different counting rules, made the compliance framework more demanding than the policy itself.

Western Spaces developed the compliance guidance for the Department of Local Affairs, working through the edge cases that arise when hundreds of jurisdictions try to apply one definition of progress. The deliverables included unit eligibility criteria, counting methods, documentation standards, and deadlines — designed to work for cities with housing departments and rural counties where the county clerk handles everything.