MICAH's Letter To Comment on the 2021 Qualified Allocation Plan

August 26, 2019

Thank you for the opportunity to comment.

Specific Comments on the 2021 Qualified Allocation Plan and repeating some of our comments made on the 2020 plan:

  1. We support long term affordability as a preference priority.

  2. We support the point increase for minority owned/women-owned(MBE/WBE) business enterprise but we support an increase from 3 to 20 points (at least), not 3 to 4 points. The only way our smaller diverse developers can compete with organizations with 15-40 plus years of experience is by providing them opportunities through a greater number of points. An additional way is to increase to MBE/WBE organizations’ involvement is by awarding additional points to non- MBE/WBE organizations that contract with minority owned/women-owned business enterprises in the community and hiring diverse people in the community where the housing development is being placed.

  3. We have concerns about the increase in per developer or general partner tax credit limit and the impact that may have on the ability of newer diverse organizations attempting to access tax credits.

  4. Revise the State Designated Basis Boost: We support Preservation Basis Boost. We have concerns about the strategic priority of supportive housing without the requirement that residents be involved in supportive services. Only residents with chemical health issues are required to be involved in supportive services in the 2020 and 2021 QAP as indicated in Article 5.4c. We are concerned with the potential new mandates in Medicaid to work and volunteer, that many in supportive housing not involved in services, will not be able to successfully complete the requirements or be waived from participating. This may put their Medicaid resources at risk, thus potentially destabilizing their lives and their ability to live independently in a tax credit housing unit.

  5. Greater Minnesota Housing Work force Housing: We encourage a change to allow the letter of support may come from more than one business employing a total of 20 or more full time employees. This would allow communities with small growing businesses to provide the employer’s support letter through a joint letter of more than 1 employer. This could also support the housing needs of smaller communities with a more diverse employment base (not dependent on one major employer) to access tax credits. Suggest changing Article 9.0 b 1 and 2)

  6. Rural Development / Small Project Set Aside of Funds- We support this set aside for small projects of 12 units or less to help preserve and develop housing in Rural Development Service areas.

  7. Community Development Initiative: Local stakeholders must include people impacted by the housing crisis and/or in need of affordable housing at all decision making tables. (Article 9.0e). We are excited that the 2022 QAP will include sustained engagement with community stakeholders including people most impacted by affordable housings needs. (Who want and need to decide the types of housing they want developed.) We encourage basic interactive listening sessions on the Sect 42 program and QAP public comments with groups including Street Voices of Change, Freedom from the Streets, and One Family One Community in the metro area and to partner with other groups organizing people impacted by the housing crisis in greater Minnesota. MICAH will begin interactive listening sessions on a monthly basis this fall on local, state, federal policies and history of homelessness as a part of national Housing Now 2020.

  8. We support Article 10.3b Scoring- Tiebreaker. This gives priority to a community that has not received tax credits in the last two years.

  9. Article 11.1 Record Keeping- Number 2. Please add race and national origin as information collected about the tenant in addition to ethnicity.

  10. Article 11.2 number 7 Certification and Review Provisions: In addition to no finding of a discrimination act. Please identify any discrimination claims made about the property.

  11. Article 11.2 number 8 Safety: Please include in preservation units built before 1968 that they must be Lead Safe.

  12. Access to Higher Performing School Methodology. We support locating tax credit units in these areas. We do have concerns, that some school districts have redrawn school district boundaries after affordable units have been developed in their community which may segregate students from tax credit and other affordable units into a specific school. We recommend a binding agreement with community and school district that this will not occur as a condition of receiving tax credits.

  13. Economic integration: We support housing choice and opportunities throughout the Twin Cities Metropolitan area and State. Local stakeholders must be involved including people impacted by the housing crisis and/or in need of affordable housing at all decision making tables.

  14. Location Efficiency Methodology. We encourage higher points (at least 7) for walkability and short commutes (under 5 miles). We have large industries such as FedEx in Rogers and Amazon in our South Suburbs where land may be available for development for housing in close proximity for workers to walk or a short drive to work. Projects attempting to develop units in these locations currently cannot score high enough to access tax credits because of the current priorities given to public transportation lines in this section. We believe this is also true in Greater Minnesota where many of our rural public transit systems have seen dramatic reduction in services and cannot score enough points to make projects eligible for tax credits. We appreciate the change from access to public transportation/ dial a ride from within 2 hours to within the same day.

  15. Please identify sub allocators that have entered into Joint Powers agreement with Minnesota Housing under which Minnesota Housing will perform the HTC award and compliance monitoring.

Ongoing Concerns:

1. MICAH continues to disagree with MHFA about its role with sub-allocators. Minnesota has a unique manner of distributing Low Income Housing Tax Credits through the allocation to MHFA and sub-allocation to other entities. MICAH believes that MHFA has obligations under the Fair Housing Act to ensure that all resources it has, it is appropriated, allocated, or sub-allocates or grants are used in a manner that decreases segregation and promotes housing choice, opportunities and choice throughout the metropolitan area and State. The 2020 and 2021 QAP plan, Article 3.4, clearly identifies the Metropolitan Council as having a role in the determining the distribution of LIHTC in the Metropolitan area.

2. MICAH continues to be concerned about the potential segregation in communities that receive the 10% set aside for non- profits and additional resources that are provided to projects in sub-allocators communities. We believe that without further review by MHFA of both the non-profit site location and its proximity to other affordable housing in that community, that MHFA may be promoting segregation through the non-profit set aside. We recognize and support the critical need for reinvestment and renovation of properties in highly segregated, high poverty areas. We encourage specific investment in those communities with minority owned developers that are community based, who will hire people, especially minorities, within the community and contract with minority and women businesses in that community to keep the investment and wealth in that community. Local stakeholders must be involved including people impacted by the housing crisis and/or in need of affordable housing at all decision making tables.

Thank you for the opportunity to comment


Sue Watlov Phillips, M.A.
Executive Director, MICAH

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