AHFA 2016 Draft Low-Income Housing Credit Qualified Allocation and HOME Action Plans
Public Comment Form
Commenting Period October 7, 2015 – November 6, 2015
All comments regarding the Draft Plans must be submitted using this form. General Comments may be submitted at the bottom of
the form. Comments which include cut-and paste text (or redlined or re-worded sections) of the proposed Plans will be rejected.
Please provide full explanatory and careful comments regarding your proposed changes, keeping in mind that your proposed
changes might have an unintended consequence for a different project or location in the state. All forms should be submitted to
ahfa.mf.qap@ahfa.com as an attachment to the email. Other documentation, e.g., product information or photos, may also be
submittedt6. Upon close of the commenting period, all comments will be posted at www.ahfa.com for review.
11/6/2015
Name: Tom Champion Organization: Gulf Coast Housing Partnership, Inc.
334-306-9235
Plan Section
Email: champion@gchp.net
Phone:
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C-11: Flood maps along the coast have been redrawn recently
so that a great deal of property along the coast is now
included within the 100-year flood plain. An example is
Downtown Mobile that is in dire need of affordable housing.
Downtown Mobile is now largely located in a 100-year flood
plain. Since for Housing Credit Only applicants there is an
exception for existing residential properties that provide
evidence of flood insurance, we recommend this exception be
extended to existing Certified Historic Buildings. This will
promote both historic preservation and urban redevelopment
goals in one of our major cities while not excluding them from
the possibility of the much needed new housing.
C-12: In urban areas of denser population with high demand
for affordable housing a 2.5 mile radius can and does
emcompass multible sub-markets and is too broad a radius.
We recommend reducing the radius from 2.5 to 2.0 miles. If
this is not acceptable, than at minimum we recommend an
exception based on population served, i.e. allowing a senior
property to be constructed if the previously constructed
property that is not placed in service or 90% occupied is a
family property so as not to exclude specific poplulations in
need of housing, particularly in densly populated urban areas.
The Alabama Historic Rehabilitation Tax Credit program
sunsetted in 2015. While we hope it will be put back in place
in future legilsative sessions, the language should be updated
to read "provides sufficient evidence that the project qualifies
for the Alabama Historic Rehabilitation Tax Credit or the
Federal Historic Rehabilitation Tax Credit. The State Historic
Preservaton office must approve all nominations and Part II
submissions to NPS so State control of this process remains.
We recommend the addition of a 4 point amenity "Rooftop
deck with sitting areas". Particularly in dense urban areas
AHFA 2016 Draft Low-Income Housing Credit Qualified Allocation and HOME Action Plans
Public Comment Form
Commenting Period October 7, 2015 – November 6, 2015
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and/or the rehabilitation of Historic Buildings there is not
sufficient green space for outdoor fitness areas, pavilions and
such so we consider this as a nice substitute amenity.
The rehabilitation of existing Certified Historic Buildings
presents unique challenges in working within the parameters
of the existing structure and in accordance with NPS and SHPO
standards. While deviations based on these requirements are
often needed, a review of the existing stadards by
experienced Historic design professionals and consultants has
indicated that the DQS For Attached Rehabilitation of an
Existing Building are most applicable as a base for the
rehabilitaion of a Certified Historic Building. Therefore, we
recommend the DQS clarify that Certified Historic Buildings
fall under the DQS for Attached Rehabilitation of an Existing
Building.
The DQS standards for Attached Rehabilitation of an Existing
Building mention efficiency units but to not provide any net
unit area requirements for those units. We rocommend
adding an efficiency unit at 425 s.f.. We have found loft
style/effieciecy units to be highly desirable particularly in
urban redevelopment. In addition, these units per the
comment above are helpful when rehabilitating Certified
Historic Buildings to maximise the use of space for residents in
the existing structures.
AHFA 2016 Draft Low-Income Housing Credit Qualified Allocation and HOME Action Plans
Public Comment Form
Commenting Period October 7, 2015 – November 6, 2015
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