Did you know that you can influence the criteria states consider when evaluating Low Income Housing Tax Credit (LIHTC) applications to help increase tribal projects’ competitiveness? Because states’ plans for allocating LIHTCs often favor developments in large urban cores (where tribal projects typically aren’t located), Travois spends quite a bit of time during each state’s public comment period educating state officials on how their plan could be changed to ensure tribal projects have an equal opportunity to compete for LIHTCs.
I recently had the opportunity to collaborate with tribes in Arizona to advocate for key changes to the Arizona Department of Housing’s 2016 Arizona Qualified Allocation Plan (QAP). ADOH is already one of the more proactive states in addressing tribal projects’ needs as it is one of only a few states that specifically reserves a portion of its LIHTCs for tribal projects. Over the past 10 years, 19 awards have been made to tribal projects in Arizona, all within this tribal set-aside. These projects have brought more than $180 million in investor equity to Indian Country in Arizona, and have constructed or rehabilitated more than 750 housing units.
The tribal set-aside has taken many forms over the years, and most recently it has been for up to $1.5 million in LIHTCs to fund multiple projects. For 2016, ADOH listened to the tribal community’s input and increased the set-aside more than 16 percent to $1.75 million! This will guarantee funding of two to three tribal projects annually that simply cannot compete outside the set-aside.
ADOH also revised a section of its QAP that previously required supportive services be contiguous to (i.e. share a boundary line with) the project in order to earn points. An unintended consequence of this requirement was that tribes would have to build a new community facility in a project to house the services, even if the services were already being offered at an existing tribal building (whether built as a previous LIHTC phase or with another funding source). Tribes would therefore have to divert LIHTCs away from housing units to build a community structure that wasn’t really needed.
ADOH again listened to the feedback submitted by tribal entities and Travois and revised the definition to allow multi-phase subdivision projects on tribal land to utilize existing community buildings that are within a half mile walking distance of the project.
We’d like to give a big thank you to all of the Arizona tribal entities that submitted comments to ADOH requesting these and other changes to the 2016 QAP!
Advocating for changes in a state’s plan is a vital, but often overlooked, component of making your housing dreams a reality. If you would like to join us in future efforts to promote affordable housing on tribal lands in your state, please contact me at firstname.lastname@example.org or sign up for our email and blog updates at www.travois.com.