Prosperity Indiana submitted comments on Indiana's 2022 Draft Qualified Allocation Plan (QAP). In the comments, we expressed appreciation for the complex task of balancing our state’s substantial affordable housing needs in setting the priorities through the QAP. To inform our response, Prosperity Indiana consulted our membership, inviting members to attend the virtual hearing for this draft plan and to provide feedback through an online member meeting and over email. PI's comments represent the feedback we received from our membership of community development practitioners.
We appreciate that the current draft 2022 QAP addresses some of the preferences and concerns expressed by our membership regarding prior plans. This includes recurring feedback that there were so many set-asides, too few credits were awarded under critical categories, meaning high scoring projects were not funded. In the past, we have recommended eliminating, combining, or reducing points for some of the categories, which has been acknowledged by the elimination of the Stellar and Workforce Housing categories.
We also appreciate the circumstances of this one-year plan being drafted as IHCDA also grapples with the housing and community development needs brought on by an ongoing pandemic. Many of our members are on the front lines of COVID-19 response and recovery, and some who would typically be active in this process are preoccupied by ensuring basic needs are met in their communities. Given that, we affirm holding off on multi-year planning efforts when an issue with longer-term ramifications can be addressed at a later time.
Throughout this process, some clear themes emerged regarding the current QAP, even though our membership and the populations and geographies served are diverse. Far and away, we received the most feedback on the proposed penalty for filing for a qualified contract release. In the interest of partnership and working towards shared community development goals, we are providing those themes – as well as some of the more technical suggestions – from member responses to address concerns from members as you continue work on the 2022 QAP draft. These responses are not necessarily presented verbatim but represent the spectrum of perspectives we received.
Please click here to see PI's full comments on the draft 2022 QAP.