February 2, 2018
New Hampshire Housing Finance Authority
2019 Qualified Allocation Plan (QAP)
Thank you to all who attended the 2019 QAP Forum on January 22, 2018.
The purpose of the public forum was to gather input from stakeholders regarding scoring categories and other discussion topics.
For those of you that were unable to attend and would like to see what topics were discussed, the PowerPoint presentation is on our website at in the Proposed 2019 QAP & Application Schedule at http://www.nhhfa.org/low-income-housing-tax-credits.
Authority staff discussed the input we received on the six discussion points. Below is a brief summary of the feedback we received.
Discussion Point #1
The New Hampshire QAP currently requires that all projects receiving LIHTCs enter into an affordability period for 99 years. By law, the minimum is 30 years. Would you favor a change to a shorter affordability period? What is the right length? How would you feel about a different period for projects using 4% and 9% LIHTCs?
  • The majority of the participants said that the 99 year affordability period is too long and recommended a period between 30 and 45 years giving greater flexibility in working with other financing sources and it would align more closely with permanent loan terms, which are usually for 30 years. Others recommended that we keep the 99 year period, that it has value, and to consider 99 years for 9% credits but reduce the period for 4% credits. Based on the feedback we received, we are considering the recommendation to reduce the affordability period, at least for the 4% credit deals.
Discussion Point #2
The New Hampshire QAP awards significant points for "proposed and likely" contributions of other permanent funding sources, with a much smaller additional incentive for firm commitments. New Hampshire Housing is considering rebalancing these points categories so that firm commitments are much more valuable relative to proposed and likely funding sources. How would you feel about this change?  Do you have any thoughts about the merit of incentivizing leveraged funds, more generally?
  • Many agreed that committed funds are more valuable and would ensure that projects move forward more quickly, therefore committed funds should be worth more points. Others expressed concerns with up-front costs for developers in order to get to a commitment prior to applying for LIHTCs, deadlines for expending other funds (CDBG currently has an 18 month deadline for expending the funds, for example), and site control. It was stated that "firm commitments" should be defined in the QAP. At this time, we are reviewing the comments received on this discussion topic. 
Discussion Point #3
The points incentive for providing a 600 square foot community room was added to the QAP two years ago. Is it still a good idea? Authority staff have considered removing this points category, in part because some projects have ample community space in adjacent facilities, and in part because we have been told that the space is underutilized in some properties. If you didn't get points for building a community room, would you still include one in your projects? Why or why not?
  • Participants stated that in general community rooms are beneficial and that they would likely still build them, but that the cost should be removed from the TDC cap and that the QAP should provide guidance and clarification on what makes a common area a "community room". Others suggested scoring waivers for access to a nearby space and that community rooms should be tied to services. Another comment made is that 600 sq. ft. does not make sense for smaller properties and we should consider the size of the project by area or by unit count to determine the minimum size needed for a community room. Based on this feedback, we are considering either revising the QAP to remove this points category or revise the language to base the minimum square footage on project or unit size and to define "community room" more specifically.
Discussion Point #4
Several market rate developments have been built or proposed in New Hampshire that include micro-apartments of 250 to 400 square feet. Do you think these types of units have a place in affordable housing?
  • Many participants agreed that they should be allowed but not incentivized. Participants questioned the longer term viability and made comments on areas in the state that may have a market demand for these types of units, such as Portsmouth. Others stated these would not be family units and that they would not be marketable years down the road. At this time we are not planning to propose revisions to the QAP in regards to micro-apartments.
Discussion Points #5 & 6
What issues do you think we should be considering in revising the Qualified Allocation Plan? If you ran New Hampshire Housing and could rewrite the QAP, what is the first thing you would change?
  • The following comments and recommendations were received:
             o Re-examine points for 811 units; 811 units can cause issues with vacancy and
                waiting for/finding an eligible household. Smaller developers may be at a
                disadvantage.
             o Reduce points for 25% of total units designated as market units to 20%.
             o Remove the 3 points awarded for non-profit CHDOs.
             o Review the pros and cons of moving to a 2-year QAP.
             o Discuss costs and tax structure effects moving forward.
             o Energy efficiency - leave this up to developers. Less emphasis on energy.
             o Restructure several points categories to align more closely with other funding
                sources.
             o Keep the QAP and application process as simple as possible.
             o Incentivize further growth in downtown developments.
             o Consider a set-side for homeless housing (with services).

SAVE THE DATE!

Please join us on Thursday, February 15, 2018 from 1:00 pm to 3:30 pm for our second 2019 QAP public forum to gather input from stakeholders on scoring criteria and other items of discussion. This forum will be held at the NHHFA offices, 32 Constitution Drive, Bedford, NH in the Pemigewasset Conference Room (please enter at the east entrance).

As always, we value your input and appreciate your continued commitment to providing affordable housing. If you have any questions or are unable to attend this forum and would like to submit comments, please contact Natasha Dube, Program Manager-LIHTC by email ndube@nhhfa.org.

Please RSVP to Jessica McCarthy at jmccarthy@nhhfa.org  by February 8, 2018 so that we can have an accurate head count.

About New Hampshire Housing: As a self-supporting public benefit corporation, New Hampshire Housing Finance Authority promotes, finances and supports affordable housing. The Authority operates a number of rental and homeownership programs designed to assist low- and moderate-income persons with obtaining affordable housing.  www.nhhfa.org