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patrick.russell

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 #1 

This is the staff Draft of the 2019 Qualified Allocation Plan (“QAP”). This DRAFT document has been prepared by staff and has taken into account extensive input over the course of the year. It has NOT been reviewed with the Board nor had Board member input.

 

TDHCA welcomes stakeholder input on this staff DRAFT. While this DRAFT creates an opportunity for discussion and stakeholder input, the input we receive will NOT be treated as “public comment” under the rulemaking provisions of the Administrative Procedures Act as it may or may not (depending on input) ultimately be the version of the rule presented to the Board for publication in the Texas Register for official public comment.

 

We anticipate that at the September Board meeting a proposed form of the QAP will be presented for consideration and possible action to approve publication in the Texas Register.   That will establish the official public comment period. 

 

Input may be directed to Patrick Russell at patrick.russell@tdhca.state.tx.us or posted to the TDHCA online forum (below). Any input is requested to be provided by August 17, 2018, by 5:00pm Austin local time. You should monitor the Department’s website on this matter because it is possible that, in response to input, staff may post one or more revisions as a way to further discussion and understanding.

 
Attached Files
doc 2a_2019_StaffDraft_Blackline_doc.doc (716.00 KB, 50 views)
xls Renter_Cost_Burden_2011_2015_CHAS_Census_Tract_Texas_Only.xls (1.40 MB, 31 views)

patrick.russell

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 #2 
Please note that staff has posted an updated staff draft in light of questions we have received about the first tie breaker factor, found in 10 TAC §11.7(1).

The proposed tie breaker factor has not changed; staff has simply sought to further clarify the intent of that tie breaker factor.

Because some stakeholders have requested the data regarding rent burden for households at or below 80% AMFI, staff has also uploaded a spreadsheet that ranks every census tract  in Texas according to the criteria set forth in that tie breaker factor.
Diana

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 #3 
Development Site Limitations.  TALHFA (which represents bond issuers and other housing professionals) would like to request that the Maximum Development Size limitation of 80 units in Rural Areas be increased to 120 affordable units, if such number is supported by a market study.  This would allow the 4% PAB program to serve cities, currently considered rural, but on the fringes of metropolitan areas. 
Diana

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 #4 
Rehab Cost Limits:  As it relates to tax-exempt bond developments, TALHFA would like a standard for minimum rehab costs that is more reflective of the actual need for rehab than an arbitrary dollar amount such as is currently in the Threshold Criteria. There is an opportunity to preserve naturally-occurring affordable housing through the 4% PAB program, but some of these communities may have had more recent rehab and only need $15,000 of rehab per door.  The actual costs of the area, investor and lender requirements, and quality of the existing housing should be the determinants for how much rehab is required. 
Diana

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 #5 
Points for Common Amenities.  Community Theaters in family and workforce housing communities are much more "lounge oriented" than the traditional settings that we find in senior communities.  I would request that the word "theater" be omitted as an adjective for seating in this context to allow for a wider array of options - particularly since "theater seating" is an undefined term. 
SallieB

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 #6 
Underserved

Please specify what year will be used to gather the HUD Fair Market Rent data for the Affordable Housing Needs Indicator for underserved points.

SallieB

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 #7 
Readiness to Proceed

Another month for the readiness to proceed deadline moved to the last business day of November is great (p 45). Please note that the date on p 21 still says the end of October.


SallieB

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 #8 
Neighborhood Organization
  • Quantifiable Community Support defines a Neighborhood Organization in existence as of the beginning of the Application Acceptance Period (p 41).
  • Neighborhood Organization Notifications (p 85) define it as in existence 30 days prior to the beginning of the Application Acceptance Period.
  • Please make the QCP support definition consistent with the Neighborhood Organization notifications requirement of being in existence 30 days prior to the beginning of the Application Acceptance Period.
SallieB

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 #9 
Concerted Revitalization

The QAP states that a comprehensive plan by itself does not equate to a concerted revitalization plan. I have written and worked on multiple comprehensive plans as a public servant. This sentence suggests that a distinct area within a comprehensive plan would not be eligible if there wasn't another planning document to accompany the comp plan. Cities often put their planning and revitalization priorities within a comprehensive plan and not a separate planning document. Comprehensive plans are bonafide and robust growth guiding documents. They are derived through hundreds of hours of public input. They come with a hefty price tag, up to six digits for major metropolitan areas. I'd like to see the sentence deleted deferring to the additional CRP characteristics in the following sections to ensure that the City or County does indeed seek and support revitalization in the area of interest.

patrick.russell

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 #10 
Staff has received requests to post a draft 2019 QAP with the blackline more clearly marked. Attached is the QAP from the September Committee and Governing Board Books, but with the blackline marked in red.

 
Attached Files
pdf 3_2019_QAP_Redline.pdf (1.49 MB, 15 views)

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