QAP Recap: Fall 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.

This quarter continues to show most states encouraging or requiring green building certifications; however, there are still some states that do not recognize national certification programs. We also see more emphasis on green building programs than water-related certifications. Home Innovation continues to encourage states to recognize green building certifications and add incentives for further sustainability efforts such as water efficiency or net zero energy.

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 by State:

Arizona: The Arizona Department of Housing (ADOH) released their 2024-2025 draft QAP. Projects can earn 10 points for certifying to one of the following green building certifications: NGBS (silver or higher), LEED (silver or higher), or 2020 Enterprise Green Communities. The public comment period closes on September 8th.

Home Innovation submitted comments praising ADOH for including third-party green building certifications. We also recommended that ADOH incentivize the achievement of third-party water efficiency ratings; specifically add a Water Efficiency section to the 2024-2025 QAP where buildings can earn points for pursuing a Water Rating Index (WRI) score.
Connecticut: The Connecticut Housing Finance Authority released their Final 2024-2025 QAP. The QAP offers 2 competitive points to projects certifying to NGBS at the Gold level, Enterprise Green Communities 2020, or LEED at the Gold level. Projects can earn 3 points for certifying to NGBS at the Emerald level, LEED at the Platinum level or LBC Core Ready.
Georgia: The Georgia Department of Community Affairs released their draft 2024-2025 QAP. The draft QAP requires projects to obtain a green building certification to one of the following recognized programs: NGBS Green, LEED for Homes, Enterprise Green Communities, or EarthCraft. The 2024-2025 draft QAP removed Green Globes Certification as an option for this requirement.
Iowa. The Iowa Finance Authority (IFA) released their 2024 Final QAP. No third-party green building programs are recognized. Projects can earn two points for meeting the requirements of the Iowa Green Streets program, in lieu of meeting energy requirements.

Home Innovation staff submitted public comments and attended the virtual public hearing, requesting that IFA include third-party green building programs as an alternative to the Iowa Green Streets Program.
Maryland: The Maryland Department of Housing and Community Development (DHCD) published a draft of the 2023 Maryland QAP and Multifamily Rental Financing Program Guide. The QAP awards points as follows:
- 10 points - projects that achieve NGBS Green, Earthcraft, Enterprise Green Communities, Green Globes, or LEED certification
- 8 points - projects built to one of the rating systems that do not achieve certification; for this option, the DHCD guide says “The certifying entity’s published scoring checklist and scorecard must be submitted and completed by the project architect or a qualified third party, and they must provide a statement explaining how the items listed on the checklist will be verified during construction.”
- 1 to 6 points - based on prescriptive sustainability features
  
  Note: Home Innovation’s NGBS Green Scoring Tools are only authorized for purposes of certification. We ask that partners not use the scoring tool to demonstrate achievement of QAP criteria when NGBS Green certification is not being pursued. If you have any questions about this policy, please contact us.
Michigan: The Michigan State Housing Development Authority (MSHDA) released their Final 2024-2025 QAP. MSHDA’s Green Policy requires all projects to receive one of the following third-party green building certifications: NGBS Green, LEED, or Enterprise Green Communities. Projects may earn additional points for receiving an additional higher level of certification, to one of the following: NGBS Green + NET ZERO ENERGY, LEED Zero Energy, Enterprise Green Communities Plus, or PHIUS Core.
New Mexico: The New Mexico Mortgage Finance Authority (MFA) released their draft 2024 QAP. The draft 2024 QAP does not recognize any third-party green building programs. MFA accepted written comments through September 5th.

Home Innovation submitted comments requesting that MFA expand its Property Standards requirements to incentivize or require that funded projects certify to a comprehensive green building or water efficiency rating program, specifically, recognizing the ICC-700 National Green Building Standard (NGBS) and the embedded Water Rating Index (WRI).
Ohio: The Ohio Housing Finance Agency (OHFA) released their 2024-2025 draft QAP. The current QAP requires projects to certify to one of the following green building certifications: NGBS (silver or higher), LEED (silver or higher), or 2020 Enterprise Green Communities. The 2024-2025 draft added Green Globes Certification and PHIUS Core Certification as additional options to this “Green Certification” section requirement.

Home Innovation submitted comments praising OHFA for requiring green building certifications for all new construction projects, and specifically for including NGBS Green. Home Innovation also recommended that the Green Globes certification option be paired with additional requirements, so that the option is on-par with the other residential green building programs that require mid-construction inspections and performance testing. Further, we recommended that the PHIUS Core option be removed from the Green Standards list as a mandatory requirement and instead be treated as a competitive point opportunity.
Pennsylvania: The Pennsylvania Housing Finance Agency published their final 2024 QAP. The QAP awards 10 points for new and rehabilitated buildings certified to 2020 NGBS Silver level, Enterprise Green Communities 2020, or LEED v4 Silver level. They also award 10 points for preservation developments certified to 2020 NGBS Whole Building Remodel, Bronze level; 2015 NGBS Functional Area Remodel, Bronze level; Enterprise Green Communities 2020 Moderate Rehab; or LEED v4 O&M, Certified level.
South Carolina: South Carolina released their draft 2024 QAP. In Appendix C1, projects can earn five points under the “Sustainable Buildings” section for earning one of the following green building certifications: NGBS Green, LEED for Homes, EGC, EarthCraft, or CHiP HOME program.
Tennessee: The Tennessee Housing Development Agency published their draft 2024 QAP. They held a virtual public hearing on August 30th and were accepting written comments until September 9th. The current QAP and draft 2024 QAP do not recognize any third-party green building programs.

Home Innovation submitted comments requesting that the agency include green building programs in the QAP. HI staff also attended the public hearing and made oral comments reiterating the importance of including third-party green building programs in state QAPs.