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