Comment Detail

Comment

I would like to submit comments concerning the 2018 AHP Proposed Amendments. The comments provided are my own and not on behalf of our Authority or our Board of Commissioners but as an individual who works for a development agency that has successfully utilized the AHP funds.

First and foremost I would like to commend you for undertaking this update and note that some of the proposed changes offer benefits to agencies that utilize the funds. My comments are geared to only those areas that I believe may not be a benefit.

The first area of concern is with the proposed outcomes framework. I believe your goal is to gear funds toward your highest priorities, but I believe in an effort to make that happen you have surrendered transparency and reduced the flexibility of the funds. Examples we have been shown clearly display that member banks will be required to meet the federal priorities and those goals will take a higher priority than the local needs or opportunities. Currently the projects are scored, and those scores are very simple to follow as we develop a potential project. We know that if the project scores well enough, it makes the cut and if it doesn’t score well it will not. Under the new outcome based requirements I am very concerned with the option of a possible “re-ranking” of applications in order to achieve the federal priorities. This does not seem fair and furthermore may promote projects that are not ready, or are not well organized to be awarded funds in order to meet the priorities. This structure will make the winning awards difficult to understand why certain projects won and others lost. In the next rounds it will be difficult to modify your projects to perform better because while the new submission may score better, the “re-ranking” in a different round may make the same or improved project rank differently.

The next concern I have is with the changes to the development team evaluation. Many times as a project is assembled a great development team for that moment in time is selected, but agencies may wish to retain the right for various reasons to bid these services or move them to a better professional if circumstances change. If the teams are committed and locked on the date of application, while they may be experienced and ready at that time, the market may change, staff changes may take place, schedules may change, or they may no longer be the best value. Under the current model, team members know that until the awards are made and the final contracts are issued the market is competitive. Prices must be fair and professionals must be ready to execute upon award. The new model changes that market. It may cause projects to be delayed because professionals have committed to other projects prior to the award of the AHP project and now do not have the available time. Additionally, fees may climb because team members will be expected to give a price at the time of application and prepare for any variables for months or years before the actual project award and subsequent time to bid.

I thank you for the opportunity to comment and again commend the agency on the undertaking.

Sincerely,