124 implementation actions and counting

Aaron Shroyer and Sarah Brundage at NAAHL have the essential federal implementation guide for the ROAD Act. None of the law's ~47 housing sections are wholly self-executing: NAAHL counts 124 discrete implementation actions across eleven agencies, with 58 due within the first year. HUD owns 88 of them, including nine rulemakings (environmental review streamlining, the chassis definition, offsite construction financing, HOME reform). It might take awhile: HUD finalized roughly four significant rules per year last term, and its current agenda already has 54 rules queued. The staffing math is worse: the three HUD offices holding three-quarters of the workload are down 27–30% from FY25, and the General Counsel's office that must clear everything is down 35%. Meanwhile a dozen new programs (pattern-book grants, the Innovation Fund, PRICE, single-stair Point-Access Block grants) exist only on paper until Congress appropriates funding, and several sunset within three to seven years…so every year of delay compresses their operating window. Think tanks and university research specialists in housing should be ready to step up and help HUD’s limited headcount move these research, guidance, and rulemaking procedures forward.