Comment Detail

Comment

Since applications are scored, and the applicants may represent very different population sub-groups, the system of scoring should be equitable, absent of "weighted" scoring for specific consumer groups or grantor priorities, or for type and category of housing. Of highest importance are the housing needs in the applicant's service area.

Examples:

1. 5 points for using donated or below market rate properties. The availability of donated development property is a blessing, reducing costs and the need for AHP funding. Applicants not having the opportunity for such a blessing are penalized;

2. Underserved communities. Rental projects for supportive housing can get up to 8 points. Where are the equitable home ownership scoring opportunities that are not applicable to rental developments?

3. Native American Housing. 2 points. Ditto #2

4. Rural Housing. 4 points. For urban projects, what points not available to rural projects can be scored?

5. Large units. 2 points. Demographic shifts of the past decade trend to smaller homes. Local need should drive housing development.

6. Rental housing for extremely low (under 30% AMI) households. 2 points. Habitat for Humanity has demonstrated that home ownership is possible for this population Why only rental housing?

7. Creating economic opportunity. 5 points. This has been trendy over the hast 20 or so years. The principle is that if we put families in neighborhoods of more affluent means, they will rise to the neighbors level. There are contravening considerations. Property is more expensive in higher income neighborhoods and amenities needed to not stand out both increases costs and brings about pressure from families who see those differences and feel devalued if the home you build for them does not have those design features and amenities. Each home built in a low-to-moderate income community improves that community.

The over-arching point I am attempting to make is that the playing field should be level. The scoring model currently being used is much like those of governmental funding sources, where cultural/political fingers are placed on the scales. Be fair.