Providing Effective QAP Input (post 10 of 10)

Published by Mark Shelburne on Thursday, September 23, 2021 - 12:00am

This post is part of a series on QAPs:

  1. Introduction
  2. Set-Asides
  3. Thresholds
  4. Selection Criteria
  5. Underwriting
  6. Creating a Competition
  7. Special Case of Cost Policies
  8. 114 Different Criteria
  9. Drafting Considerations
  10. Providing Effective Input

Qualified allocation plans (QAPs) are intensely collaborative efforts. Agencies actively seek comments in many forms. Staff considers all input, but not all input is equally effective.

How to Submit Effective Input

This post focuses primarily on enhancing the impact of written submissions, but the concepts also work in other settings.

1. Be specific.

This suggestion is listed first because it is by far the most important. General or vague requests rarely have any impact. Also, don’t assume the agency knows exactly what you want to happen. Ideally, write out proposed text word for word. Similarly, examples and results (especially with numbers) are far more convincing than opinions.

2. Weigh in early and often.

Do not wait until the draft comes out. Comment beforehand, especially if seeking major departures from established practices. There’s a chance the agency will incorporate your idea in what it posts. Keep in mind official periods are often a formality; most agencies at least effectively accept input year-round.

Feel free to submit more than once, particularly in response to multiple drafts. Any subsequent messaging should move the discussion forward, don’t simply repeat the same statements.

3. Communicate and learn.

The email/letter should be just one part of an overall communication starting long before the submission. Those active in a state should meet with agency personnel periodically, including at industry events. While potentially an opportunity to make a case, it’s far more valuable to instead listen and learn their concerns, goals and limitations. The knowledge gained in these interactions will inform future comments.

Be certain to pay attention to other interested parties’ perspectives as well. You might be able to form alliances, respond to their arguments, or perhaps even change your mind.

4. Understand.

How the QAP helps or impedes certain types of development is not always obvious. There is a real risk of misdiagnosing the perceived problem based on incorrect assumptions. If so, your comments will miss the mark or potentially make matters worse.

5. Express support.

Mention what you like about the current policies. Others may be critical, and so you could lose something beneficial by saying nothing. In other words, don’t assume everyone agrees with you. No matter how confident in your position, almost nothing is universally popular.

6. Focus on substance over style.

Style of presentation and grammar are, at most, secondary. Time spent on the formalities of language can result in delayed submissions and missed chances. What matters is the quality of the content. Sending an email is quicker than writing a letter and is just as effective.

7. Be realistic, fair and professional.

Recognize the agency’s and program’s limitations. Using “spin” (carefully manipulated presentation) won’t gain support with knowledgeable decision-makers. Tell it straight, including any aspect that isn’t helpful to your case. Also, remember the people reading the comments care about their work and deserve respect. They’re only human, so insults are unlikely to advance your cause.

8. Be patient.

QAPs can be like battleships: powerful tools that require time to change course. Don’t think you’ve wasted time if a QAP doesn’t reflect your input. The idea may be ahead of its time and need longer to evolve. Plus, remember that the outcome could’ve been worse had you been silent.

Conclusion

States need to hear from interested parties to make QAP improvements. Few have researchers focused on affordable rental housing, and the academic community rarely engages with low-income housing tax credit practitioners.

Stated another way, if you’ve read this far, do your part and submit comments.