The state has set vital housing targets while lawmakers built a regulatory framework that may make those targets unreachable. The math has never been reconciled — and half the maps don’t yet exist.

by Compass Vermont

Vermont needs to build between 27,867 and 41,185 new homes by 2030. That is not a long-term aspiration. It is a five-year target, established by the state’s 2025 Vermont Housing Needs Assessment, covering 2025 through the end of this decade. A middle scenario puts the target at 34,526 homes — roughly six times Vermont’s recent annual production rate.

To put those numbers in context: Vermont built an average of 1,178 homes per year during the entire decade of the 2010s, according to Vermont Housing Finance Agency data. Even in 2023 — the strongest permit year in over a decade, according to VHFA — Vermont issued just 2,456 permits, still less than 30 percent of what the state needs annually under its higher growth scenario. Hitting the lower end of the 2030 target requires building at nearly five times the 2010s rate. Hitting the upper end requires building at seven times that rate — every year — for the next four years.

The math underlying those targets has not been publicly reconciled against Vermont’s current regulatory framework. A Compass Vermont investigation suggests a significant reason why: the system Vermont has built to govern where homes can and cannot be built is still being drawn on a map — and for more than half the state, that map doesn’t exist yet.

The Land that’s left

Vermont’s land use system, reshaped by Act 181 in 2024, divides the state into tiers. Tier 1 — villages, downtowns, and city centers — is where growth is encouraged and Act 250 review is reduced or eliminated. Tier 3 — defined under Act 181 as critical natural resource areas including forests, headwaters, and primary agricultural soils — is where new development faces the most significant regulatory barriers.

The geography of that framework matters. Tier 1 eligible areas are currently estimated to cover between 2 and 3 percent of Vermont’s total land mass — with a range by county from less than 1 percent to more than 10 percent, according to Samantha Sheehan, Municipal Policy and Advocacy Specialist at the Vermont League of Cities and Towns.

According to Sheehan, regional planners estimate that approximately 60 percent of Vermont’s statewide housing targets could be met within Tier 1 eligible areas. The remaining 40 percent — as many as 16,000 homes by 2030 under the upper target — would have to be built outside Tier 1, in rural areas. Regional planners have always assumed a significant share of housing must be built in those rural areas, Charlie Baker, Executive Director of the Chittenden County Regional Planning Commission, confirmed to Compass Vermont.

Those rural areas are the same areas facing significantly expanded regulatory pressure under Act 181’s implementation.

The Road Rule problem

At the center of Vermont’s land use debate is a provision called the road rule — a component of Act 181 that subjects projects requiring private roads longer than 800 feet, or combined road and driveway networks longer than 2,000 feet, to Act 250 review under the state’s land use permitting system.

Vermont Public has reported that the road rule is expected to affect the majority of land in the state. According to Sheehan, the Department of Housing and Community Development has produced an internal analysis estimating that under the road rule and draft Tier 3 mapping, approximately 50 to 60 percent of Vermont’s land area could fall within expanded Act 250 jurisdiction. That analysis has not been publicly released or submitted as legislative testimony.

Land Use Review Board guidance indicates that a single home would generally not trigger the road rule unless its driveway exceeds 2,000 feet — a threshold more likely to affect subdivisions and larger rural development projects than individual homebuilders. But for the rural areas where Vermont’s housing plan assumes 40 percent of new construction must occur, the regulatory burden is about to grow significantly.

Governor Phil Scott called Act 181 “heavily focused on conservation” in his June 2024 veto message, arguing it “actually expands Act 250 regulation.” The Democratic supermajority overrode his veto. S.325, which passed the Senate in March 2026 and is currently before the House Committee on Environment, delays the road rule’s implementation until 2030 — but does not repeal it.

The tension is real: Vermont’s housing plan assumes a significant share of new construction occurring in rural areas. Its regulatory framework is simultaneously expanding Act 250 jurisdiction over those same rural areas. No state agency has produced a public analysis reconciling those two facts.

The maps don’t exist yet

There is a more immediate problem than the road rule.

The Tier system that governs where Vermont’s housing can be built is implemented through maps developed by Regional Planning Commissions and approved by the Land Use Review Board. As of April 7, 2026, five of Vermont’s eleven Regional Planning Commissions had submitted draft maps to the board. The remaining six had not.

“We aren’t sure what areas are going to look like for half the state just yet,” Nate Formalarie, Deputy Commissioner at the Department of Housing and Community Development, told Compass Vermont. Even the maps that have been submitted are not final — they return to the RPCs for amendment after LURB review before any map receives final approval.

Vermont is four years from its 2030 housing target deadline. The maps that will determine where new homes can be built without triggering expanded Act 250 review do not yet exist for more than half the state.

Nobody Has Done The Math

Compass Vermont reached out to key state officials and policy experts with a direct question: has any state agency produced a unified analysis showing Vermont has enough buildable land under its current regulatory framework to meet its housing goals?

None of those contacted could point to one — and the acknowledgment was notable for coming from officials deeply engaged in Vermont’s housing agenda.

Rep. Marc Mihaly, D-Calais, who chairs the House Committee on General and Housing and served as President and Dean of Vermont Law and Graduate School before retiring from that post in 2017, told Compass Vermont that the capacity analysis was disaggregated from the statewide level to regional planning commissions and then to individual towns — but was never unified into a single statewide reconciliation. “I suspect we could use more data,” Mihaly said, pointing to H.775, a bill that passed the House and is currently before the Senate Committee on Economic Development, Housing and General Affairs, which asks towns to either adopt housing targets in their plans or analyze the barriers preventing them from doing so.

That a bill must now request that data suggests the statewide reconciliation has never been done.

Leslie Black-Plumeau, Director of Research and Community Relations at the Vermont Housing Finance Agency, said she was unaware of any such analysis and suggested the question be directed to regional planners.

Charlie Baker, Executive Director of the Chittenden County Regional Planning Commission, confirmed that regional planners have always operated on the assumption that a significant share of new housing would have to be built in rural areas — but said the low end of the housing targets is achievable while the high end presents genuine challenges.

Mihaly pushed back on the premise that land supply alone is the binding constraint. “Ripping apart our current land use regulatory system to allow more housing at the current market price alone won’t solve the problem,” he said. “We could abolish Act 250, Act 181, all state permits, all local zoning, and all we’d get is $600,000 houses in places we don’t want them. We’d lose the beauty and ecology that makes the Vermont we all love and end up looking like suburban New Jersey, but with the same housing problem we have now — nothing affordable for the average Jane or Joe.”

The production gap

Even if Vermont resolves the land use question, the production history is sobering.

Vermont’s peak housing construction decade was the 1970s, when the state averaged 5,813 new homes per year, according to the 2025 Vermont Housing Needs Assessment. By the 2010s, that figure had fallen to 1,178 — a decline of nearly 80 percent over four decades.

The affordability picture has deteriorated just as sharply. The number of Vermont renters able to afford the median home price dropped from 24,500 in 2021 to 9,320 in 2024 — a decline of 62 percent in three years, according to Vermont Housing Finance Agency data.

The state’s current housing deficit — before accounting for any new growth — already stands at 7,252 homes needed simply to normalize vacancy rates and house the currently homeless, according to the 2025 Vermont Housing Needs Assessment. Chittenden County alone accounts for 1,694 of that baseline deficit.

Mihaly acknowledged the affordability dimension directly. “The underlying problem is that the market cannot produce housing at a price that Vermonters can afford,” he said. “Right now we need more subsidy. And for every dollar of state funds we don’t dedicate to such subsidy, we leave federal dollars on the table.”

What happens next

Vermont is currently navigating three simultaneous processes that will determine whether its housing goals are achievable: the Tier mapping process, which remains incomplete for more than half the state and unfinalized everywhere; the S.325 debate, which has delayed but not resolved the road rule question; and H.775, which is asking towns to produce the local housing capacity data that the state does not yet have in unified form.

S.325 delays road rule implementation until 2030. H.775 asks towns to report on housing barriers — with responses not expected until municipalities update their plans, a process that unfolds over years. The Tier mapping process has a December 2026 deadline for RPC submissions, with final LURB approvals extending beyond that.

Vermont needs between 27,867 and 41,185 new homes by 2030. None of the state officials, regional planners, or policy experts Compass Vermont contacted over the past two weeks could identify a comprehensive statewide analysis showing where those homes can go.

The Tier maps are unfinished. The unified capacity analysis has not been located. The production rate is a fraction of what the targets require. And 2030 is not a distant policy horizon — it is four years away.

Vermont has made its housing goals clear. What its regulatory framework makes possible is a question that has not been publicly answered. That gap — between what the state says it needs and what its own rules may allow — is not a detail to be resolved in committee. It is the central unanswered question of Vermont’s housing crisis.

Compass Vermont will update this story if and when a comprehensive statewide buildable land analysis is identified or produced. If you have information relevant to this reporting, contact news@compassvermont.com.