Quick QAP Recap: Summer 2023

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.

This spring, the NGBS Green team invested effort into educating Illinois and Utah HFA staff about the value and cost of third-party green building certification programs and advocating for NGBS Green Certification to be recognized equally with other credible programs.

Recent QAP Updates/Opportunities by State:

Illinois: In the 2022-2023 IL QAP, the Illinois Housing Development Authority (IHDA) recognized NGBS Green Certification for lesser points than LEED and chose not to recognize NGBS Green+ NET ZERO ENERGY certification alongside Enterprise Green Communities Plus and LEED Zero. This was done despite written comments from Home Innovation and local NGBS Green Partners.

Ahead of the 2024-2025 QAP release, Michelle and Cindy visited with IHDA staff to share an overview of NGBS Green and reiterate our feedback on the QAP Sustainable Development criteria.

When IHDA hosted QAP Summits in May to receive feedback for the 2024-2025 QAP, we shared the meeting information with local NGBS Green Partners and encouraged their participation in these important listening sessions.

During these sessions, IHDA discussed changes that will be reflected in the 2024-2025 QAP, which included adjusted points for NGBS Green Certification to be on par with LEED and Enterprise Green Communities. It also added NGBS Green+ NET ZERO ENERGY certification as an option for points under their net zero energy section. This was the best possible outcome for NGBS Green! We are pleased to see our hard work pay off and that Illinois affordable developers pursuing NGBS Green will be equally competitive with their peers pursuing other green building programs.

The IL draft 2024-2025 QAP will be released for public comment in early August 2023. We encourage NGBS Green Partners working in Illinois to submit written comments and participate in upcoming public hearings to indicate their support for these important changes!

Utah: The Utah Housing Corporation (UHC) held a public hearing for the 2023-2024 draft QAP on May 22nd. This draft added new “Alternative Certification” programs that can earn five points under the “Energy Certification” scoring section. In this draft of the QAP, projects could earn five points for certifying to one of the following: Enterprise Green Communities (EGC); ENERGY STAR NextGen; DOE Zero Energy Ready Homes; Passive House; Green Globes; or WELL Building Standard. Points were NOT available for NGBS Green or LEED certification. Self-certification was also allowed for NGBS Green and LEED, whereas third-party certification was required for the other programs.

In previous QAPs, points were only awarded to projects that certified to Enterprise Green Communities, since the program previously did not charge a certification fee.

Home Innovation staff attended the public hearing and submitted written comments requesting that UHC allow competitive points for NGBS Green and LEED certification, so that those third-party programs would be treated similarly to Enterprise Green Communities and the newly-added Alternative Certification programs. Our comment letters referenced publicly-available fee schedules from the recognized green building programs. We identified that NGBS Green certification fees are typically $12,300-16,800 less than the certification fees for the newly added Alternative Energy Certification programs.

On June 1st, an updated 2024 QAP was approved by the board and posted on the UHC website. In this updated QAP draft, NGBS Green and LEED were added to the “Energy Certification” section to earn five points for certification. Additionally, the QAP now requires third-party certification for all programs, including NGBS Green and LEED. We are pleased to see that the updated draft reflects our feedback and that Utah Housing developers can now pursue NGBS Green certification for points under the QAP.