Quick QAP Recap
This is the first in a series of blog posts where Cindy Wasser, Home Innovation’s Senior Manager of Green Building Programs, will share updates on our green advocacy efforts and opportunities for NGBS Green Partners to get involved.
Home Innovation actively advocates for third-party certified, green, affordable housing by providing input for state Qualified Allocation Plan (QAPs). QAPs specify a state agency’s allocation of federal Low-Income Housing Tax Credits (LIHTC). Most QAPs include criteria for energy efficiency and green building, and nearly 30 states specify green building certification as a requirement or point-based incentive. When third-party green certification is included within a QAP, NGBS Green Certification is typically recognized alongside other credible national green building programs. NGBS Green certification is affordable to implement, making it ideally suited for affordable housing. For more information about QAPs and how to get involved, contact me.
Recent QAP Updates/Opportunities by State:
OPEN ADOVACY OPPORTUNITY! CONNECTICUT
The Connecticut Housing Finance Authority (CHFA) released a draft 2022-2023 QAP for public comment. The QAP features a revamped Sustainable Design section with new subsections for Energy Conservation, Green Building, Renewables/Electrification/Resiliency, Operations/Resiliency, and Sustainable Development with Digital Literacy and Connectivity.
I participated in a public hearing on May 19th to provide feedback on the criteria. I commended CHFA for expanding its focus to include emerging topics, including resiliency; however, I requested that the point structure be revamped to better reflect the rigor and holistic nature of third-party green certifications.
Written comments are accepted by email to PublicComment@chfa.org through COB on May 28th. NGBS Green Partners are encouraged to submit similar comments as ours. Contact me if you plan to submit comments and would like to view our public comment letter.
OPEN ADOVACY OPPORTUNITY! LOUISIANA
Louisiana Housing Corporation has released a draft version of the 2022 QAP for public comment. An in-person public hearing is scheduled for June 3rd in Baton Rouge, LA, and written comments are being accepted at firstname.lastname@example.org. The draft QAP requires NGBS Green, EarthCraft, Enterprise Green Communities, or LEED certification. NGBS Green Partners are encouraged to express support for the QAP’s inclusion of third-party green certifications, including NGBS Green certification. Contact me for a sample comment letter and talking points.
OPEN ADOVACY OPPORTUNITY! WYOMING
The Wyoming Community Development Authority has released a draft 2022 QAP for public comment. A public hearing is scheduled for June 9th in Casper Wyoming, and a call-in option is available for participants. Written comments are being accepted through 5PM MDT on June 8th. The draft QAP has 15 points available for green building certifications. Fifteen points are available for LEED certification, and 10 points are available for NGBS and Enterprise. I will request that NGBS Green certification be recognized as on-par with LEED in terms of points. Our energy performance charts and point-by-point comparison reports show that NGBS Green Certification is as rigorous, if not more rigorous, than LEED certification.
In March, the Iowa Finance Authority (IFA) published its draft 2022-2023 QAP for public comment. The 9% 2022-2023 QAP noted the NGBS, Enterprise Green Communities, and LEED as alternatives to ENERGY STAR for new construction. However, the QAP only specified an architect’s “certification” that the project will meet the specified rating system; third-party certification was not required. I shared written and verbal public comments that recommended that IFA require evidence of third-party certification, rather than rely on the architect’s assertion of compliance. Home Innovation believes that on-site verification and third-party certification offers affordable housing organizations the greatest assurance of construction quality, operational efficiency, and resident comfort.
We were VERY PLEASED to see that green building was retained in the final 2022-2023 QAP, and third-party certification is now required. Thank you to all NGBS Green Partners who engaged with IFA on this issue! Bronze-level NGBS Green certification is an accepted alternative to the QAP’s ENERGY STAR requirement for new construction.
In early May, Home Innovation staff participated in a QAP Summit (listening session) for the Illinois Housing Development Authority (IHDA) 2022 QAP. We learned that IHDA intends to increase green building requirements in the 2022 QAP. Presently, IHDA envisions requiring that all funded projects meet the mandatory practices of Enterprise Green Communities, and threshold points would be available when a green building or net zero energy certification is pursued. Presently, IHDA recognizes NGBS Green, Enterprise Green Communities, and LEED for Homes (at the Silver level) within their 2020-2021 QAP. When the draft QAP is released in July, I will submit formal comments that ask IHDA to ensure that any minimum requirements are achievable regardless of the green building program pursued and offer technical assistance to IHDA. I will keep our program partners posted on this development. If you are interested in becoming engaged on this topic, contact me.
In early May, the Michigan State Housing Authority (MSHDA) released its 2022-2023 QAP for public comment. The draft QAP included language that would have required that projects receiving tax credits achieve certification to the NGBS, Enterprise Green Communities, LEED, or PHIUS+. Silver level or higher was required for NGBS and LEED. Competitive points were available for higher certification levels and net zero energy certification. I submitted written and verbal comments that commended MSHDA for advancing the green building requirements beyond that of their 2021 QAP. At the same time, I also requested that the list of the accepted certifications be amended to included only those that are based on comprehensive, multi-attribute green building rating systems. I noted that PHIUS+ is primarily an energy efficiency certification and asked that it be reclassified as an optional item for competitive points.
We were pleased to see that the final 2022-2023 QAP posted in late May reflect our feedback. The mandatory green building certification requirement includes NGBS Green, Enterprise Green Communities, and LEED as option. Competitive points are available for net zero energy certifications, including the NGBS Green+ NET ZERO ENERGY badge, and PHIUS+ certification.***