Enterprise Analysis of 2006 QAPs Finds States Stressing “˜Green’ Even More

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Tax Credit Advisor August, 2006: States are continuing to advance their efforts to require increased energy efficiency, healthier environments, and more sustainable building sites for low-income housing tax credit developments, according to a recent study from Enterprise (formerly The Enterprise Foundation). The study summarizes these new “green” requirements, as specified in the 2006 qualified allocation plans (QAPs) of 14 state housing finance agencies. In doing so, Enterprise updates a state-by-state report on the subject that it published in 2005.

“It is fair to say that in every case the green elements in combination constitute a significant policy priority for the state,” the new report concluded. “Developers applying for tax credits in these states will need to seriously consider achieving a high level of sustainability to be in the best position to receive credit allocations in 2006.”

Like its 2005 report, Enterprise’s 2006 study enumerates three different areas of “green” development requirements: those related to smart site locations, energy and resource conservation, and healthy living environments.

The Smart Site Locations category focuses on policies encouraging development next to existing resident services, transportation, and jobs. Energy and resource conservation touches on policies that prod developers to exceed applicable energy codes, minimum insulation factors, water conservation, and smart choices in building materials. The healthy living environment grouping zeros in on policies covering environmental site abatement plans and indoor air quality.

The report provided an analysis of new green requirements in 2006 QAPs from HFAs in California, Connecticut, Georgia, Iowa, Maine, Massachusetts, Nevada, New Jersey, New Mexico, New York, North Carolina, Ohio, Pennsylvania, and Virginia.

States Add, Revise Sections

Enterprise reported that nine of these state HFAs – California, Iowa, Maine, Massachusetts, Nevada, New Jersey, New Mexico, Ohio, and Virginia – added new sections to their QAP, or revised existing standards, to cover all three of Enterprise’s green categories.

Connecticut’s QAP added a new category awarding points to developments located on a sites close to grocery stores, community recreational facilities, and access to public transportation. The agency also adopted “Standards of Design and Construction” that cover sustainable design, construction, and maintenance.

The new green requirements enumerated in Georgia’s QAP focused on indoor air quality and energy and resource conservation. New York added a new project scoring criteria for energy efficiency, awarding points to developments that use energy-efficient measures that exceed minimum code requirements. North Carolina’s 2006 QAP mentioned that the state’s mandatory design standards would henceforth include sustainability and energy-efficiency requirements. Pennsylvania, meanwhile, added a new selection category covering energy conservation methods, and required that developers verify in their tax credit applications that these energy conservation efforts are being included in the development process.

New Jersey and Ohio indicated that they will award additional funding to tax credit developments that meet more demanding sustainability requirements. Ohio specified actual dollar amounts, saying that it will make available as much as $4,000 per unit in a development – and up to $750,000 in a single development – to cover construction costs of green initiatives undertaken by developers.

New York has adopted a “Green Building Initiative,” separate from the standards enumerated in its 2006 QAP, that awards bonus points to HOME and housing trust fund applicants if they provide energy-efficient measures that result in savings at least 30 percent above those required by code. This initiative is applicable to developments that combine LIHTC credits and HOME or trust fund financing.