HomeMy WebLinkAboutQAP Proposed ChangesI have reviewed the 2015 Qualified Allocation Plan and find that there are
several areas where a change might enhance the opportunity for projects
that are more targeted to the very low income demographic to have a
better opportunity to be funded. Please let me know what you think.
1. Basis Boost (page 17) – The Basis Boost provides an increase of 30%
in the basis for the project if the project is located in a Qualified
Census Tract (QCT), in a HUD designated Difficult Development Area
(DDA), or for certain other considerations such as targeting a greater
percentage of the project to lower income clients. I would propose
that the Basis Boost for increasing the percentage of low income
clients be put on a sliding scale and the allowable percentage be
increased as follows:
15% of units below 40% of AMI gives a 30% Basis Boost
25% of units below 40% of AMI gives a 35% Basis Boost
10% of units below 30% of AMI gives a 30% basis Boost
15% of units below 30% of AMI gives a 35% basis Boost
25% of units below 30% of AMI gives a 40% Basis Boost
Rationale – Increasing the Basis results in greater tax credits and
thereby incents the Developer to include a larger number of lower
income units.
2. Give points for low cost per square foot or low cost per unit and limit
gross rent potential to annual cost of operation plus annual debt
retirement costs plus 7% profit. Currently, as time passes and the
AMI increases, profit margins increase for the Developer rather
thanrents holding the line to the benefit of clients.
3. Development Evaluation Criteria (page29) – Currently, in order to be
considered an application must score 900 or more points out of a
possible 1,110 points. This forces the project to do some things that
are not directly beneficial to those on the very low end of the scale
because it forces the inclusion of some items that are not totally
necessary and thereby drives up the cost of the project. I propose
increasing the total number of points available by adding possible
points for things that would incent Developers to include more very
low income units.
a. (page 29) Increase the number of allowable points for years
beyond 30 as follows, taking away the opportunity to gain a
large number of points by increasing the years by only one:
Use agreement for a total of 35 years gives 50 points
Use agreement for a total of 40 years gives 75 points
Use agreement for a total of 45 years gives 100 points
b. Change the scale to allow more points for a greater number of
low income units:
AMI % of eligible Units Points Awarded
Below 30% 10 25
20 50
30 75
40+ 100
Below 40% 20 25
30 35
40 50
Below 50% 20 20
30 30
50 50
60+ 75
Below 60% 50 20
75 40
c. Project Location – allow 100 points for being within ¼ mile of a
bus stop. This change would be to the direct benefit of very
low income clients who use public transit and don’t have a
vehicle.
d. Amenities – allow up to 100 points for amenities but change
the list as follows:
Units:
Microwave High Quality
Cabinets
High Quality
Flooring
Interior LED
Lighting
Community:
Outdoor
Community area
Community Garden Laundry Room
Car Plug ins Internet for whole
Project
Central Recycling
Bins
Garbage
Collection
Included
Exterior LED Lighting
(Parking lots, etc)
e. Allow points for targeting specific underserved populations
i. Veterans
ii. Victims of Domestic Violence
iii. Long term Montana Residents
iv. Low income Locals who have lived in an area 5 years or
longer (Bakkan)
4. Provide a open commentary section that allows for justifying special
circumstances – Limit to 1,000 words.