Expanding Green Buidling Incentives in Low-Income Housing

Department of Housing and Community Development
1800 Martin Luther King Avenue SE
Washington, DC 20020

Dear Mayor Bowser, Director Donaldson, Senior Advisor Pelletiere, and District of Columbia Stakeholders:

Thank you for providing this opportunity to comment on the draft 2019 Low-Income Housing Tax Credit Qualified Allocation Plan. We represent a group of environmental, equity, and green building organizations committed to achieving the District’s sustainability and affordability goals.

DHCD’s Qualified Allocation Plan plays a vital role in setting guidelines for the allocation of Low-Income Housing Tax Credits and also has the ability to drive innovation and demand for better-built homes and communities in the District of Columbia.

We applaud the District’s landmark Green Building Act requirements for DC-Government-financed projects to meet Enterprise Green Communities, LEED for Homes, or LEED for Multifamily Midrise—all of which include robust reporting, inspections and verification of green and energy features. However, we were discouraged to see the draft of the 2019 QAP had a reduction of points, in comparison with the 2017 QAP, awarded to buildings seeking to go above and beyond the basic legal requirements in the District and deliver higher performing buildings than are mandated by the Green Building Act.

The undersigned believe that the benefits of green building—in particular, the reductions in energy and water utility costs and healthy indoor air quality—should accrue to all residents in the District, regardless of their income status. In fact, utility and health-related costs are the next highest costs for low-income individuals after rent/mortgage payments. Controlling these costs is essential to maintaining affordability in the District. The incentive points in the QAP are an excellent mechanism for supporting developers that want to do right by their tenants.

Therefore, we believe that the green Building incentives should actually be increased to 10 points, not decreased, for projects that achieve Living Building Challenge, Net-Zero Certified, or Passive House standards. Buildings constructed to these standards use significantly less energy and require less maintenance than typical buildings. The superior quality and efficiency of the building enclosure maintain consistent interior temperatures far longer than a code-built building, making them naturally resilient. Further, these projects could achieve an 80% or more reduction in energy costs and a corresponding steep reduction in carbon and greenhouse gas emissions. For income-restricted residents, the utility savings could be life-changing.  In properties with owner-paid utilities, these savings can be reinvested in critical wraparound services such as afterschool care, job training, and other services frequently provided by the city’s affordable housing providers.

In addition to supporting affordability, these high-performance standards will help the District achieve our ambitious carbon neutrality by 2050 target and prepare for the net-zero energy building codes scheduled for implementation by 2026 in the Clean Energy DC Plan. To meet these goals, it is critical to begin building local capacity for designing and constructing ultra-low energy and water use buildings. By awarding ten points in the QAP for these standards, DHCD will be providing a strong incentive for development teams to innovate, test options, make design alterations, and seek out the best and most cost-effective high-performance design solutions at very early stages of design.  Similar incentives have been successfully adopted in several jurisdictions including Pennsylvania, Vermont, and New York City. Research conducted on projects submitted to the Pennsylvania Housing Finance Agency found that there was only a 2 % incremental projected cost for building to Passive House over a typical multifamily project. The financial return via utility cost savings and environmental impacts via avoided carbon emissions provide a strong justification for further incentivizing these high-performance standards.

Please increase – not decrease – incentives for Green Building and ultra-low energy consumption for the Low-Income Housing Tax Credits in DC.  DHCD has the opportunity through this QAP to help project teams to learn how to incorporate low energy strategies from the very beginning of the project when the power for cost optimization is strongest. We are working hard to protect our future through environmentally responsive buildings, and we need your help to continue.
 

Sincerely,

Andrea Foss
Sustainability Director
Steven Winter Associates, Inc.

Cliff Majersik
Executive Director
Institute for Market Transformation (IMT)

Chris Weiss
Executive Director
DC Environmental Network

Mark Rodeffer
Chair
Sierra Club DC Chapter