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?