Each year, North Carolina Housing Finance Agency (NCHFA) asks for public comments on the minimum standards of its Qualified Allocation Plan (QAP) that sets construction and energy efficiency requirements and options for Low Income Housing Tax Credit (LIHTC) projects, mostly for multifamily new construction rentals and some rehabs.
Also each year, organizations like NCBPA submit comments in support of increasing the minimum energy efficiency standards and available incentives for developers that go above and beyond. As in past years, NCHFA’s 2020 QAP does not increase energy efficiency requirements at all.
Unfortunately, the minimum standards are still set to ENERGY STAR 2.0 – a program that technically does not exist any more and is also below North Carolina’s new 2018 Energy Conservation Code, making the requirements unlawful.
File Your Public Comments by September 4th Online
NCBPA encourages all industry professionals to file comments in support of the many building performance and energy efficiency recommendations included in our public comments. To do so, please follow these steps by September 4th:
Click below to download our public comments with wording that can be used to file your own.
Click here to view the Attachments that we have included in our filing. These are referenced on the last page of our comments.
- Prepare your comments using our letter as a template. Remember, the more customized and detailed your comments are to your business, your wants for the program or the projects you work on, the better..
- When ready, click here to submit your comments to Chris Austin at NCHFA. Do so by September 4th.
- Let us know if you have any feedback on the plan that you’d like NCBPA to share with our members, partners and industry-at-large.
Here is a summary of NCBPA’s comments:
Dear Mr. Austin,
On behalf of our member companies and professionals working across the state, North Carolina Building Performance Association (NCBPA) submits the following comments regarding the 2020 Qualified Allocation Plan (QAP) program.
As designed, the 2020 QAP continues an unnecessary and uninformed trend of maintaining poor energy efficiency standards that contribute to increased energy burden for tenants and increased operating costs for owners. Conversely, increasing these standards and offering additional points to developers that go above and beyond during new construction – when doing so is most cost effective – would reduce energy burden and afford developers and the agency many additional benefits.
As many other states have already done, North Carolina can increase its standards in cost-effective manners that benefit all parties. But, NCHFA must first commit to doing so. At present, the program’s minimum energy efficiency standard of ENERGY STAR 2.0 does not technically exist any more and falls below North Carolina’s new 2018 Energy Conservation Code (NCECC) requirements in key areas including Total Duct Leakage. Building to the 2020 QAP standards is unlawful. NCHFA must take immediate action to address this and likely other energy code deficiencies.
NCBPA recommends that NCHFA initiates a nine-month study beginning November 1, 2019 to develop cost-effective energy efficiency requirements and options for the 2021 QAP that include:
- Increasing the program’s minimum energy efficiency standards from ENERGY STAR 2.0 to Version 3.0 or higher.
- Analyzing the costs and benefits of these changes with involvement from key stakeholders.
- Identifying short-term utility, foundation, state or federal incentives that would assist developers in making the transition to improved energy efficiency requirements and options.
- Providing points for optional energy efficient, green and high performance measures, ratings and certification programs.
NCBPA, our members and partners are ready and willing to assist NCHFA in addressing these issues and opportunities. Thank you for the opportunity to provide the following recommendations.
Contact NCBPA’s Ryan Miller at 919-521-3385 or Ryan@BuildingNC.org with questions and comments.
Thank you in advance for your participation!
