We request TDHCA increase the number of starting points for Renovations from 3 to 5 as the majority of the items on the list are either not meaningful/low priority for our residents or are absolutely impossible to implement in a Preservation project.  It is difficult to even reach 2 points in a Rehab, and that is if LED fixtures are allowed in place of “track lighting”.  By requiring these items, this is NOT the most effective use of the LIHTC resource.

1. Covered entries (0.5 point);

   Can be accomplished in most renovations.

2. Nine foot ceilings in living room and all bedrooms (at minimum) (0.5 point);

   Can NOT be accomplished if original building does not have this feature.

3. Microwave ovens (0.5 point);

   While this can be provided, it becomes burdensome for the owner to maintain another appliance. We also find in renovations, tenants already have their own, preferred microwave. This item drives up R&M when units are turned and increases capital cost of construction.

4. Self-cleaning or continuous cleaning ovens (0.5 point);

   While this can be provided, I am unconvinced “self-cleaning” adds value for our residents.  I personally have never “self cleaned” an oven my entire life!  It again, becomes burdensome to have management always ensure replacement stoves have this feature.

5. Refrigerator with icemaker (0.5 point);

   Preservation projects need to be retrofitted to have an ice maker.  This type of appliance again, causes an additional burden on the owner to ensure the ice make is always working, driving up R&M for a project and increasing capital cost of construction.

6. Storage room or closet, of approximately 9 square feet or greater, separate from and in addition to bedroom, entryway or linen closets and which does not need to be in the Unit but must be on the property site (0.5 point);

   This item is nearly impossible to add if the property does not already have storage space. If it could be added, it would be a low priority item.

7. Energy-Star qualified laundry equipment (washers and dryers) for each individual Unit; must be front loading washer and dryer in required accessible Units (2 points);

   This item is impossible to add if the original building did not have space for in-unit W/D. Even if their was space, this would be extremely expensive for ongoing R&M to maintain these appliances, increasing operating cost, thus decreasing debt leverage and ultimately the construction budget.

8. Covered patios or covered balconies (0.5 point);

   This item is impossible to add if the original building does not have individual patios or covered balconies.

9. Covered parking (may be garages or carports, attached or freestanding) and include at least one covered space per Unit (1.5 points);

   This adds unnecessary costs to the development budget when there are many other more important items that would take priority over adding shade to parking lots.

10. 14 SEER HVAC (or greater) or for Rehabilitation (excluding Reconstruction) where such systems are not being replaced as part of the scope of work, a radiant barrier in the attic is provided (1.5 points);

    This can become impossible for Rehabilitations that are PTAC only units and have minimal attic space.

11. High Speed Internet service to all Units (can be wired or wireless; required equipment for either must be provided) (1 point);

    Adds considerable cost on the Operating Expenses, reducing debt leverage and ultimately reducing the capital budget for other items.

12. Built-in (recessed into the wall) shelving unit (0.5 point);

    This is difficult to do in Rehabilitation when there are many other higher priorities that need to be addressed prior to paying for recessed shelving.

13. Recessed or track LED lighting in kitchen and living areas (1 point);

    In a renovation, it may be impossible to do recessed cans based on the existing ceiling and track lighting is a dated and unattractive lighting option.  We recommend that LED fixtures be the requirement for kitchen and living areas.

14. Thirty (30) year roof (0.5 point);

    This can be accomplished.

15. Greater than 30 percent stucco or masonry (includes stone, cultured stone, and brick but excludes cementitious and metal siding) on all building exteriors; the percentage calculation may exclude exterior glass entirely (2 points);

    This becomes extremely expensive and unnecessary for rehabilitations that do not currently have 30% Masonry.  

16. Breakfast Bar (a space, generally between the kitchen and dining area, that includes an area for seating although actual seating such as bar stools does not have to be provided) (0.5 points);

    This can be difficult to do in Rehabilitation depending on the current kitchen lay-out.  Again, there are many higher priorities that need to be addressed prior to paying for a breakfast bar if currently non-existent. This could also increase the number of days a resident is out of their unit for renovation as we go from only cosmetic changes (cabinetry/countertops) to knocking out walls.  This increases construction cost and relocation budget unnecessarily. 

17. Walk-in closet in master bedroom (0.5 points);

    Impossible to create in an existing building without this current feature.

18. Electric Vehicle Charging Station (0.5 points); and

    I am unclear of the cost of this item or how difficult and expensive it would be to maintain and operate. Furthermore, I have never seen an electric vehicle at any of our affordable housing communities and I am not convinced this is an amenity a low income family would use today.

19. Ceiling fans in all bedrooms (0.5 points).

    This can be accomplished.