Affordable housing in New Jersey has suffered its latest setback, as the New Jersey Department of Community Affairs has indicated that it will fall 8,000 units short in construction of affordable units funded by the Special Needs Housing Trust Fund. Despite its expenditure of $168 million, only 2,000 units for disabled and homeless people have been constructed. In response to inquiries from Senator Codey, the New Jersey Commissioner of Community Affairs Lori Grifa explained that “the reality is that $200 million does not produce 10,000 units, unless they can be produced for $20,000 per unit, which is an impossibility in New Jersey” according to the Star Ledger’s article, "N.J. Sen. Codey Calls On State To Explain How It Spent $168M From Special Needs Housing Fund." This may mean that the state and the New Jersey Supreme Court will look to developers more than ever to finance and construct affordable housing to assist municipalities in satisfying their fair share obligations. It may also mean that municipal Third Round Housing Element and Fair Share plans, now stayed pending the New Jersey Supreme Court’s consideration of the Third Round Rules, will come under additional challenge to extent that those plans relied on public or municipal funding.