Federal housing statistics track a well-known sequence: permits, starts, construction, completions. These data points, published monthly by the Census Bureau and widely followed by policymakers, economists, and industry analysts, form the basis of nearly every conversation about whether the United States is building enough housing. But there is a critical stage of the development process that precedes all of them, one that no federal agency systematically tracks: the entitlement stage, in which a project receives approvals for zoning or land-use from a local government but has not yet applied for a building permit.
This post presents our estimate that ~750,000 multifamily units in the United States currently sit in this planned, or entitled-but-not-permitted stage. We describe how we arrived at that figure, what data we used, what we assumed, and where the estimate is most uncertain.
We also estimate that these planned multifamily developments represent $225-265 billion in total investment if they could be unlocked. Unlocking them would contribute meaningfully to the overall housing shortage.
The Entitlement Phase
The housing production pipeline has several distinct phases, each governed by different actors, timelines, and constraints. The entitlement stage—obtaining discretionary land-use approvals like zoning changes, conditional use permits, planned unit developments, and environmental clearances—is typically the most politically contentious and time-consuming phase of development. In cities like San Francisco, it can take 15 months or more; in jurisdictions that allow by-right development, it can be bypassed entirely.
Once a project is entitled, the next step is to prepare detailed construction documents and apply for a building permit. A building permit is typically a ministerial approval: if the plans conform to building codes and the project has its entitlements, the permit should be issued. In normal market conditions, projects move through this stage relatively quickly—Census Bureau data from the Survey of Construction shows that roughly 80% of multifamily projects begin construction within two months of receiving a building permit.
The entitled-but-not-permitted stage, then, is a bottleneck where projects that have cleared the politically difficult hurdle of initial approvals can nonetheless stall for economic reasons: unfavorable interest rates, tight construction lending, elevated construction costs, or insufficient equity capital. This is the stage where policy and capital most directly intersect, and where the current financing environment appears to be creating the most significant challenges.
The commonly cited Census series of “authorized but not started” units—which shows roughly 117,000 multifamily units nationally—captures only projects that have already pulled building permits but haven’t broken ground. It tells us nothing about the much larger inventory of projects that are entitled but haven’t reached the permit stage at all. The table below situates our estimate alongside the federal statistics that are currently available.
Table 1. Multifamily Housing Pipeline Stages
| Pipeline Stage | Units | Source |
| Entitled but not permitted | ~750,000 | This analysis |
| Authorized but not started | ~117,000 | FRED / Census Bureau |
| Under construction | ~1,000,000 | Census Bureau / Yardi Matrix |
| Annual multifamily permits | ~500,000 | Census Bureau |
| Annual multifamily completions | ~500,000 | Census Bureau |
There is No Official Data
There is no national database of entitled housing projects. The Census Bureau’s building permit survey covers roughly 900 of the approximately 20,000 permit-issuing jurisdictions in the country, and it begins tracking projects only at the permit stage. HUD does not collect entitlement data, and no other federal agency does either.
What does exist are small chunks of local data. Some cities, like San Francisco, Boston, New York, publish pipeline reports that track projects through the entitlement process. Private data providers like Yardi Matrix, CoStar, and RealPage track development pipelines nationally, but their categories do not map cleanly to the entitled-not-permitted stage as we define it. Industry associations like NMHC conduct surveys that capture some of the relevant dynamics, such as the share of projects experiencing delays. Academic and nonprofit research, particularly from Enterprise Community Partners on the California affordable housing pipeline, provides additional data points.
The result is that any national estimate of the entitled-but-not-permitted inventory requires synthesizing fragmentary data from fundamentally different sources that use different definitions, cover different geographies, and track different subsets of the pipeline. This is not an ideal basis for estimation, but we believe the exercise is worthwhile because the policy implications of the pipeline’s existence and approximate scale are significant, and because the alternative, ignoring the stage entirely because the data is imperfect, leaves policymakers working with an incomplete picture of the housing production process.
Three Approaches to a National Estimate
We used three complementary methodologies to triangulate a plausible range. Each has identifiable strengths and weaknesses, and the fact that they produce overlapping ranges despite using different data and logic provides some confidence in the synthesized estimate.
Approach 1: Metro-Level Extrapolation
The most direct approach is to aggregate pipeline data from metros where local sources publish entitlement or pipeline figures, and then extrapolate to a national total based on each metro’s share of national multifamily permitting. We collected the following data points from municipal planning departments, local news reporting, and industry sources.
In San Francisco, the Planning Department’s Housing Dashboard reports roughly 52,000 units approved but stalled. The average entitlement process in the city takes approximately 450 days, and the full permit process averages 627 days. In Boston, reporting on BPDA estimates indicates 23,000 units stuck in the pipeline, with an additional 20,000 units on pause under MassHousing’s Chapter 40B program (Bisnow). The city launched a $110 million Housing Accelerator Fund specifically to unlock stalled projects. In the broader Bay Area, Enterprise Community Partners reports approximately 41,000 affordable units in the near-construction pipeline.
New York City’s Real Estate Board of New York counts 100,000 units in the active pipeline. The city recorded 33,974 completions in 2024—the highest figure since 1965—but new permits fell to their lowest level since 2012 (REBNY). In Seattle, a Kidder Mathews analysis found that 50 to 70 percent of permitted projects were not proceeding to construction, and permit applications fell to just 1,800 units in 2024, down from a peak of 7,400 in 2020–21. In Houston, industry data shows 38,149 units in the proposal stage.
These metros collectively account for roughly 20% of national multifamily permitting and report 200,000 to 250,000 entitled or stalled units. Scaling proportionally to the national permitting base implies a national total of 1.0 to 1.25 million units.
The value of this approach is that it uses actual reported pipeline data from real jurisdictions. The metro-level figures are the most concrete data points in the entire analysis. However, the metros with available data are not representative of the country. They skew heavily toward high-cost, high-regulation coastal markets with atypically long entitlement timelines—precisely the places where you would expect the largest entitled-but-not-permitted inventories. Sun Belt markets like Atlanta, Phoenix, and Dallas, which account for a large share of national multifamily permitting, have shorter entitlement timelines and are underrepresented in the available data. For this reason, we believe the metro extrapolation likely overstates the national figure, and we weight it accordingly in the synthesis.
Approach 2: Pipeline Ratio (Yardi Matrix)
The second approach uses private-sector pipeline tracking data from Yardi Matrix, one of the most widely used multifamily data providers in the industry. Yardi tracks a total development pipeline of approximately 4.27 million multifamily units across all stages, from early prospective through under construction. Of those, roughly 1.1 million are classified as “planned”—a category that Yardi defines as projects with site control and some level of planning or approval, but not yet under construction. We estimated that 40 to 60 percent of these “planned” units have received land-use entitlements but have not yet applied for building permits, producing a range of 440,000 to 660,000 units.
The value of this approach is that it draws on a comprehensive national dataset from a provider whose business depends on tracking development activity accurately, and it avoids the geographic bias of the metro extrapolation. That said, Yardi’s “planned” category does not map precisely to our definition of entitled-but-not-permitted. Some “planned” projects may still be in pre-entitlement stages; others may have already applied for permits. The 40–60% assumption is an informed estimate, not a data-driven calculation. Additionally, Yardi’s coverage, while extensive, does not capture every project—particularly smaller developments in secondary and tertiary markets. For these reasons, we believe this approach slightly understates the true figure.
Approach 3: Timeline-Based Flow Analysis
The third approach models the entitled-but-not-permitted inventory as a function of flow: how many units enter the pipeline each year, and how long they spend in the entitled stage before proceeding to permitting. If approximately 350,000 multifamily units receive permits annually (the recent national average), and the average project spends 12 to 18 months in the entitled-but-not-yet-permitted stage, then the steady-state inventory is the annual flow multiplied by the average time in stage: 350,000 × 1.0 to 1.5 years = 350,000 to 525,000 units. We then applied an upward adjustment of 30 percent to reflect the current environment, in which high interest rates and tight construction lending have caused an abnormally high number of entitled projects to stall rather than proceeding to permitting on their normal timeline (Fannie Mae). This produces a range of 455,000 to 682,500 units.
The value of this approach is that it uses a clean analytical framework that does not depend on fragmentary local data, and the logic is transparent and reproducible. On the other hand, the “stall adjustment” of 30% is a judgment call. It reflects what we observe in metro-level data—Seattle’s 50–70% non-proceeding rate, for example—but it is not derived from a systematic national measurement. The approach also assumes that the annual permit flow is a reasonable proxy for the annual flow of newly entitled projects, which may not hold perfectly in a period when fewer projects are moving through the pipeline.
Synthesis
Table 2. Triangulation of National Estimates
| Approach | Low Estimate | High Estimate |
| Metro-level extrapolation | 1,000,000 | 1,250,000 |
| Yardi Matrix pipeline ratio | 440,000 | 660,000 |
| Timeline-based flow analysis | 455,000 | 682,500 |
| Synthesized estimate | 750,000 | 750,000 |
The synthesized estimate of 750,000 reflects the simple average across the high and low estimates of these three methods.
What the Pipeline Is Worth
The entitled-but-not-permitted pipeline also represents a substantial volume of potential real estate investment activity. Using industry estimates of average total development cost per multifamily unit—which includes hard construction costs, land acquisition, soft costs (architecture, permitting, legal, financing), and developer fees—a reasonable national blended figure falls in the range of $300,000 to $350,000 per unit.
At 750,000 pipeline units, that implies approximately $225 to $265 billion in total development value, with a midpoint of roughly $245 billion. These figures are necessarily rough, and the per-unit cost varies enormously by market—Boston reports development costs of $500,000 to $600,000 per unit, while Sun Belt markets can come in well below $250,000—but the order of magnitude is clear. The shadow pipeline represents a quarter-trillion dollars in real estate development that is approved, planned, and waiting on financing conditions favorable enough to proceed. Unlocking even a fraction of this pipeline would represent one of the largest single injections of new housing investment in decades.
Our Assumptions
Several key assumptions underlie the estimate, and we want to be transparent about each of them.
We define “entitled” as having received discretionary land-use approvals—conditional use permits, planned unit developments, zoning variances, and similar approvals—but not yet having applied for or received building permits. We exclude projects still in environmental review or pre-application stages. This definition is narrower than what some cities report in their pipeline data (which may include projects at earlier stages) and broader than what others report (which may include only projects with final, unconditional approvals). The definitional inconsistency across jurisdictions is a real limitation.
We assumed that high-regulation coastal markets have larger entitled-but-not-permitted pipelines per unit of permitting activity (due to longer timelines and more frequent stalls), but that Sun Belt markets contribute significant absolute volume due to their higher overall development activity. The available data does not allow us to verify this assumption rigorously.
The estimate reflects the 2024–2025 environment of elevated interest rates and tight construction lending. We believe the entitled-but-not-permitted pipeline is at or near historical highs due to the convergence of several factors: a 2021–2022 entitlement surge (when low interest rates encouraged aggressive project planning), the 2023–2025 financing environment that has prevented many of those entitled projects from proceeding, and developer reluctance to let entitlements expire given the sunk costs of the entitlement process. In a more favorable interest rate environment, the pipeline would likely be smaller, as projects would proceed to permitting more quickly.
We relied on Census Bureau Survey of Construction data showing that approximately 80% of multifamily projects begin construction within two months of permit issuance. This supports the premise that the entitled-to-permitted transition, rather than the permitted-to-started transition, is a primary bottleneck in the current environment.
Known Unknowns
We take the limitations of this estimate seriously, and we think any user of the estimate should as well. Several factors could cause the true figure to differ meaningfully from our range.
The estimate could be too high if the geographic skew in available data is more severe than we have accounted for. The metros with published pipeline data are among the most regulated and most expensive development environments in the country. If Sun Belt and secondary markets have substantially smaller entitled-not-permitted inventories per unit of permitting activity—which is plausible, given their shorter entitlement timelines and more permissive regulatory environments—then the metro extrapolation overstates the national figure by more than we have assumed. The Yardi-based approach and the flow analysis provide a check on this, but they have their own uncertainties.
The estimate could be too low if the Yardi Matrix data significantly undercounts entitled projects. Yardi’s coverage is extensive but not comprehensive, and smaller projects in secondary markets may not appear in their database. The flow analysis also uses annual permit volume as a proxy for the rate at which projects receive entitlements, and if the entitlement rate substantially exceeds the permit rate in the current environment (because projects are being entitled but not proceeding to permits), the flow-based estimate would understate the true inventory.
Double-counting is a real risk. Some units reported in metro-level pipeline data likely also appear in Yardi’s “planned” category. We have attempted to account for this in the synthesis by not simply averaging the three approaches, but some residual double-counting may persist.
Definitional inconsistency across jurisdictions means that the metro-level data points are not strictly comparable. San Francisco’s “approved but stalled” figure may include different project stages than Boston’s “stuck in pipeline” figure or New York City’s “active pipeline.” We have attempted to apply consistent definitions, but the underlying data was collected for local purposes, and not with our national categorization in mind.
Expiration dynamics mean that some units in our estimate will never be built. Entitlements typically expire after two to three years, and projects that do not proceed to permitting within that window lose their approvals. The pipeline is not a static inventory; it is a flow, with projects entering through new entitlements and exiting through permitting, expiration, or abandonment continuously. Our estimate is a point-in-time snapshot of the stock, not a forecast of how many of these units will ultimately be constructed.
What the Estimate Does and Doesn’t Say
We are claiming that the entitled-but-not-permitted multifamily pipeline is large, on the order of several hundred thousand units at minimum, and plausibly approaching one million. We are claiming that this pipeline is not captured in federal housing statistics and is therefore invisible to policymakers who rely on Census Bureau data to understand the state of housing production. And we are claiming that the pipeline appears to be unusually large in the current environment due to the convergence of a recent entitlement surge and a subsequent financing freeze.
We are not claiming precision. This is an order-of-magnitude estimate based on fragmentary data rather than a point count. We are not claiming that all of these units can ultimately be built; some will expire, some will be redesigned, and some sites will change hands. We are also not claiming that this pipeline is evenly distributed across the country; available evidence suggests it is concentrated in high-cost coastal metros, though the data does not allow a definitive geographic breakdown.
What the estimate does suggest is that there exists a substantial inventory of multifamily housing projects that have completed the most difficult and time-consuming stage of the development process—land-use entitlement—and are waiting on economic conditions favorable enough to proceed to construction. The scale of this inventory, even at the conservative end of our range, implies that the near-term housing supply response to improved financing conditions could be considerably faster than what permit-based forecasting models would predict, since these projects would not need to cycle through years of planning and approval before breaking ground.
Recommendations for Better Data
The most important conclusion of this exercise may be a negative one: the United States does not have adequate data on its housing development pipeline. The Census Bureau’s building permit survey is a valuable and well-designed instrument, but it begins tracking projects only at the permit stage, which is relatively late in the predevelopment process. Adding even a simple question about pre-permit pipeline status to existing surveys—or creating a new survey instrument that tracks entitlements at the state or metro level—would substantially improve our ability to forecast housing supply and design effective policy interventions. The Minneapolis Federal Reserve has recently highlighted the need for better pipeline data at the state level.
Several states are already moving in this direction. California’s Housing Element law requires local jurisdictions to report on their progress toward housing production goals, and the state’s Annual Progress Reports contain some entitlement-stage data. New York City’s Department of City Planning publishes a detailed housing production snapshot. Massachusetts tracks projects through the MassHousing 40B process (Boston Indicators). These state and local efforts could serve as models for a more systematic national approach.
In the meantime, we plan to update this estimate periodically as new metro-level data becomes available, and we welcome engagement from researchers and practitioners who can help refine the methodology. The entitled-but-not-permitted pipeline is too large and too policy-relevant to remain a blind spot in our understanding of the housing market.