Home Innovation Insights

Home Innovation advocates for green certified affordable housing.

Cindy Wasser, MBA
January 25, 2022

Quick QAP Recap: Fall-Winter 2021

This is the third in an ongoing series of blog posts where Cindy Wasser, Home Innovation’s Senior Manager of Green Building Programs, shares updates on Home Innovation's 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.


You win some, you lose some. As you can imagine, our QAP advocacy efforts do not always result in our desired outcome right away. We continue to press on, monitoring and engaging for the next QAP development cycle. Below is our summary of QAP advocacy efforts throughout Fall-Winter 2021.


The following states published final QAPs with third-party green building programs included, either as a competitive or threshold item: Arizona; Georgia, Louisiana, Ohio, South Carolina; and Texas. For each of these states, I submitted public comments that praised the HFA for including credible third-party green building programs. In a few cases, we offered specific recommendations for improved consistency or clarification.

  • In our letter regarding the Ohio 2022-2023 QAP, we requested that the green building requirement for rehabilitation projects be strengthened with additional detail and references to green building certifications that include dedicated compliance pathways for existing buildings.
  • Georgia’s Department of Community Affairs has long included multiple third-party green building programs — NGBS Green; EarthCraft; Enterprise Green Communities; and LEED for Homes. Green building certification was optional until the Georgia 2021 QAP, when it was changed to a threshold item. In the Georgia 2022 QAP, Georgia Department of Community Affairs (DCA) added Green Globes Certification to the list of recognized green building programs.

    This is an unusual choice. Over 30 QAPs include green building programs, with NGBS Green, Enterprise Green Communities, and LEED as the commonly recognized options. Very few states include Green Globes as an option for green building certification.

    We support developers’ choice among credible green building labels when there is a “fair playing field.” Since Green Globes certification does not require the mid-construction inspection and performance testing, we requested that Green Globes certification be paired with additional requirements so that it is better aligned with the other recognized programs. This recommendation was not heeded for the 2022 QAP; we will continue to monitor this issue in Georgia and in other states that may choose to include Green Globes.


Sometimes it takes multiple years and regular engagement with an HFA for third-party green building programs to be added to the QAP.

  • In the fall of 2021, we coordinated with other green building advocates to request green building programs be incorporated into the Montana 2023 QAP and the Oklahoma 2022 QAP. Our recommendations were, unfortunately, not implemented this year. I will continue to monitor and expect to engage in the future.
  • The District of Columbia’s Department of Housing and Community Development published the final DC 2021 QAP in late September.

The QAP requires new construction projects between 10,000 and 49,999 sq. ft. and all rehabilitation projects to meet base-level Enterprise Green Communities certification or submit a waiver to pursue a “substantially similar standard.” LEED for Homes and LEED for Homes Multifamily Midrise are pre-approved as “substantially similar” for these categories.

New construction projects greater than 50,000 sq. ft. must obtain Enterprise Green Communities Plus or submit a waiver to pursue a “substantially similar standard.” For this category, there are no pre-approved standards.

We were disappointed that NGBS Green Certification was not included for either category. If NGBS Green Partners plan to submit a waiver requesting acceptance of NGBS Green certification, please contact us for any needed assistance.

  • The Illinois 2022-2023 QAP was published with tiered options for green building and net zero energy programs.

For the green building category, Enterprise Green Communities, LEED, NGBS, PHIUS, and ILFI are included for 7-10 points. LEED v4.1 Gold level is recognized for 7 points, and LEED v4.1 Platinum is recognized for 10 points. NGBS Green certification is recognized at the Emerald level only, for 7 points. This point structure is mis-aligned. We requested that NGBS Green certification at the Gold and Emerald levels be recognized for ten points within the Green Building Standards category, on-par with LEED v4.1 BD+C. The NGBS is just as comprehensive of the LEED rating system and requires higher energy performance. In nearly every instance where the NGBS is recognized within federal, state, and local policy/regulations, it is recognized at the same level as LEED.

For the net zero energy category, Enterprise Plus, PHIUS ZERO, LEED Zero, and ILFI Zero Energy Petal or Zero Carbon certification are recognized, for 3 points. We requested that NGBS Green+ NET ZERO ENERGY certification be recognized.

Unfortunately, neither of these recommendations were implemented. We spoke with Illinois Housing Development Authority to better understand their assessment. Our main take-away was that agency staff hold the volume of requests for a particular program with more weight than a technical assessment. As Home Innovation’s recommendations for NGBS Green recognition were not echoed by many other advocates, they did not seem as impactful to the IHDA staff. We encourage NGBS Green Partners to read the QAP Watch section of the monthly Insider Update newsletter and engage in QAP hearing and comment opportunities for the states where they work.


The following states are currently in-process developing their final QAPs. We will continue to monitor.

  • The Colorado Housing and Finance Authority (CHFA) has published a Colorado 2nd Draft 2022-2023 QAP, as well as a summary of changes. The QAP clarifies that applicants must receive third-party certification under their selected program; self-certification is not available. 2020 NGBS, LEED v4.1, and 2020 Enterprise Green Communities are accepted green building programs. In addition to green building certification, there are two energy efficiency/sustainability requirements: (1) electric-vehicle ready parking spaces; and (2) post-construction energy use intensity reporting. In our comment letter, I commended CHFA for requiring third-party green building certification and including NGBS Green.
  • The Massachusetts Department of Housing and Community Development posted the Massachusetts Draft 2022-2023 QAP. As drafted, it awards up to 3 points for Enterprise Green Communities or LEED (Gold or Platinum). Additional points are available based on energy performance, Passive House certification, electrification, clean energy, reduced embodied carbon, and enhanced accessibility.

I submitted comments that requested that DHCD recognize NGBS Green Certification based on the ICC-700 National Green Building Standard (NGBS) for 1-3 points under the Green Building Certification and Certified Exemplary Energy Performance categories of the QAP. The NGBS is equally, if not more, rigorous than the programs currently recognized—LEED, Enterprise Green Communities, and Passive House. The NGBS was also specifically designed for residential projects and is affordable to implement, making it ideally suited for low-income housing programs. NGBS Green Partners are encouraged to advocate that NGBS Green Certification be accepted as a named alternative to Enterprise and LEED. Please contact me if you plan to submit comments and would like to view our letter.

The QAP offers 2 points for green building certification to NGBS Green (Gold level), Enterprise Green Communities, or LEED (Gold level). We applauded NHHFA for including credible third-party green building program.

The QAP also requires applicants to develop and submit a short healthy housing plan with their application. We recommended that NHFFA strengthen the healthy housing requirement by requiring third-party verification to confirm that healthy housing features were fully incorporated as planned. We also identified the NGBS Green+ WELLNESS certification as a label that could offer NHHFA confidence that healthy housing features were implemented and verified.

During a recent NHHFA hearing, many advocates spoke about the need for more accessible housing in New Hampshire. We encouraged NHHFA to incorporate universal design practices from recognized rating systems and standards to reduce staff development effort and streamline implementation. We identified the NGBS Universal Design practices and NGBS Green+ UNIVERSAL DESIGN certification as tools for the agency to gain assurance that funded project include accessible features.

  • The North Carolina Housing Finance Agency posted the North Carolina 2nd draft 2022 QAP. Comments can be submitted to Rentalhelp@nchfa.com. The QAP would require newly-constructed buildings to achieve ENERGY STAR Multifamily New Construction certification. Adaptive reuse and rehabilitation projects must comply “to the extent doing so is economically feasible and allowed by historic preservation rules.” We advocated for third-party green building certification programs, including the NGBS Green, to be recognized in addition to the requirement for ENERGY STAR certification.

In addition to our work monitoring and advocating for the inclusion of NGBS in QAPs across the country, we are active in other advocacy work as well. We have some general resources available online that our program partners are free to use for your own efforts, or you can always contact me to let me know about your local situation – maybe we could collaborate.

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