Katie Dorn
December 5, 2022
Quick QAP Recap: Winter 2022
This is an ongoing series of blog posts where Cindy Wasser and Katie Dorn share 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 us.
Recent QAP Updates/Opportunities by State:
- Alabama: The Alabama Housing Finance Agency approved its 2023 QAP. The QAP includes several prescriptive energy and water conservation practices for competitive points, but no third-party green building programs are recognized.
Home Innovation joined with other green building programs to encourage AHFA to incentivize comprehensive third-party green building programs and ensure that all funded projects at meet or exceed the 2015 IECC.
- Georgia: The Georgia Department of Community Affairs (DCA) approved its final 2023 QAP. The final QAP requires that funded projects obtain one of the following green building certifications: NGBS Green, EarthCraft, Enterprise Green Communities, LEED for Homes, or Green Globes certification.
Home Innovation submitted comments commending DCA for recognizing third-party green building certifications.
- Iowa: The Iowa Finance Authority released their final 2023 QAP. In prior rounds, green building certifications were recognized alternatives to the QAP’s energy requirements, which included ENERGY STAR Multifamily New Construction and HERS ratings. The final QAP did not include these alternatives. Energy efficiency requirements for rehabilitation projects were also removed.
Home Innovation requested that IFA recognize green building programs once again and expressed the importance of energy efficiency and green building criteria for both new and existing buildings.
- Louisiana: The Louisiana Housing Corporation published their draft 2024 QAP and accepted comments through late November. The draft QAP incentives certifications for NGBS Green, EarthCraft, Enterprise Green Communities and LEED for Homes. The draft QAP also has a separate resiliency incentive for developments that receive a FORTIFIED Silver or Gold certification.
Home Innovation praised the inclusion of credible, third-party green building programs and the inclusion of resiliency standards—as two separate incentives. However, we recommended that LHC increase the points awarded for green building compliance, as point allocation is misaligned when compared with the investment required for FORTIFIED certification and points available. Home Innovation also requested that LHC require evidence of third-party green building certification, rather than rely on the verifier’s assertion of compliance.
- Michigan: The Michigan State Housing Development Authority (MSHDA) accepted public comments to inform their 2024 QAP through the beginning of November. The current QAP requires that funded projects achieve certification to the NGBS, Enterprise Green Communities, LEED, or PHIUS+. Silver level or higher is required for NGBS Green and LEED, and competitive points are available for higher certification levels and net zero energy certification.
Home Innovation submitted comments encouraging MSHDA to retain the green building criteria included in the 2023 QAP. We will notify NGBS Green Partners when a draft QAP is released for public comment.
- Montana: Montana Housing published its draft 2024 QAP and accepted comments through late October. The draft QAP does not recognize any third-party green building programs and instead includes a list of prescriptive energy efficiency measures.
Home Innovation recommended that Montana Housing recognize credible third-party green certifications as an alternative.
- Tennessee: The Tennessee Housing Development Authority (THDA) published their final 2023 QAP. THDA previously included green building criteria within its QAP but did not include those items within the 2023 QAP.
Home Innovation requested that THDA once again recognize third-party green certification programs, as they are a tool to accomplish the agency’s goals of advancing energy efficiency and adding compliance flexibility.
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