Have you reviewed the proposed changes in Part 2040 of the LOW-INCOME HOUSING CREDIT QUALIFIED ALLOCATION PLAN? qap-comments.doc What will be its impact on rural NY and upstate projects? While it seems that DHCR has made changes to reserve the right to distribute as they wish geographically and to the special needs they wish to serve- does that in fact imply a change in policy?
While smart growth is important to us all, the number of points for affordability seem to be dwarfed by the number of points for energy efficiency and green project materials and siting. Most rural areas simply cannot support a projects with a dense concentration of units, solar power generation and siting near transportation hubs. We strive to select sites near services, main roads and know that using safe, energy efficient materials will make our units more affordable over time. But can we compete on this point scale?
NEW YORK STATE RURAL ADVOCATES 
The changes to the QAP certainly favor the urban areas rather than the rural. Our projects are cited where we can find affordable land and have at least a marginal hookup to water/sewer. In many cases we must use a raised bed septic system, when constructing over 8 units, and we need land to acommodate the “bed”. In the past there has always been a point system where those projects, hopefully, with the most points are considered for an award. Who will be in charge of choosing those applications to be awarded? The thrust in DHCR is to rehabilitate projects in the urban area. What about the rurals where most of the housing stock is over 60 years old and in need of major repairs?