Low Income Housing Tax Credits & Opportunity Housing in Massachusetts, 2018

The 2018 Massachusetts Qualified Allocated Plan (QAP) prioritizes families in "areas of opportunity" when allocating tax credits. The QAP lists eligibility requirements to receive points within this funding category, and provides point incentives for projects based on their accessibility to employment opportunities, quality education and health care.The QAP also allocates points for projects located within a community revitalization plan, including projects located in Qualified Census Tracts. 

Opportunity

In the 2018-2019 QAP, DHCD is requiring each applicant for credit to provide a narrative with the OneStop+ funding application describing services available in the community to the existing or future tenants of the project. Developers do not necessarily have to pay for the services, but must identify the services and indicate how they will notify tenants, on a regular basis, of opportunities for further education, employment training, and other important services.

Massachusetts specifies that it will continue using four priority funding categories, including location of a family project in an “area of opportunity.” The Department defines an area of opportunity in part as a neighborhood or community with a relatively low concentration of poverty based on U.S. Department of HUD data. In addition, DHCD identifies an area of opportunity as a neighborhood or community that offers access to opportunities such as jobs, health care, high performing school systems, higher education, retail and commercial enterprise, and public amenities.

-          To be eligible to receive points within this category, a family housing project typically must be located in a census tract with a poverty rate below 15%. Projects located in municipalities with overall poverty rates below 15% may also qualify for points within this scoring category. On a case by case basis, at its sole discretion, the Department will permit certain projects to receive points in this category if the poverty rate in the census tract and/or the municipality is 15% or higher, as long as the project is located in an area with compelling attributes that make the location desirable to renters. A family housing project also must include certain design characteristics: the project must be configured to contain at least 65% two-bedroom or larger units and at least 10% three-bedroom units, unless either percentage is demonstrated to be infeasible or unsupported by public demand.

If the thresholds described above have been met, DHCD will award points within this category as follows:

·         Up to 8 points for strength of public school system: based on the percentage of 10th grade students that score in the Advanced or Proficient categories using an average of the 3 MCAS tests (English Language Arts, Mathematics, and Science and Technology Engineering)

90% or above: 8 points

85% or above: 6 points

80% or above: 4 points

75% or above: 2 points

·         Up to 6 points for access to employment: based on the proximity to jobs of the municipality in which the family housing project is located

5 miles or less: 6 points

7 miles or less: 4 points

9 miles or less: 2 points

·         Up to 2 points for access to higher education: Two points will be awarded within this category to family housing projects located within two miles of community colleges and/or state colleges/universities within the University of Massachusetts system.

 

·         Up to 2 points for access to health care: Two points will be awarded within this category to family housing projects located within one mile of a major health care facility, such as a hospital, an urgent care center, or a neighborhood health clinic.

The maximum number of points awarded in this category will be 14 points.

Community Revitalization Plan:

In its 2018-19 QAP, Massachusetts DHCD awards up to six points for inclusion in a Comprehensive Neighborhood Revitalization Effort:

·         2 points for projects to be developed in locations included in formal neighborhood plans, with revitalization components enhancing access to jobs, education, and/or health care that either have been approved by the chief elected official of the host municipality or have been developed with significant, demonstrated community input, with identified resources for revitalization. The formal written plan must delineate the neighborhood; should identify properties to be demolished or rehabilitated and sites to be redeveloped; and must provide information on current and proposed access to mass transit, retail and commercial opportunities, and necessary services; and must describe in detail the nonhousing revitalization components, including a timeline and plan for completion.

·         2 additional points if the project described above is sponsored by a community-based non-profit entity certified by DHCD as a Community Development Corporation under the provisions of Chapter 40H.

·         2 points for a project to be developed in a location included in a housing production plan approved by DHCD’s Division of Community Services; or two points for projects to be developed in approved “Priority Development Areas” as determined by state agencies including MassDOT and the Executive Office of Housing & Economic Development.

Please note that projects will not be eligible for points for the “inclusion in a comprehensive revitalization effort” section unless the sponsor consents to enter into a written agreement with DHCD to evaluate on a regular basis the effects of the development on the surrounding neighborhood. These reports will include income demographics of the property’s tenants as well as reports on other community revitalization investments in the limited geographic area, concentrating on the investments potentially generated in part or in whole by the presence of the tax credit project.

DHCD will also award up to 3 points to a project located in a qualified census tract under the Conformance with Section 42 Code preferences category. This development would contribute to a concerted community revitalization plan, including investment in jobs, education, and/or health care. “Qualified Census Tract” is defined as any census tract designated by the Secretary of HUD in which 50 percent or more of the households have an income less than 60 percent of area median gross income or, in certain instances, there is a poverty rate of at least 25 percent.

Contributed By: 
National Housing Trust

Other Items of Interest