Experts Discuss the Pros & Cons of a
2-YEAR QAP
T
he topic of whether or not to support, and advocate for, a two-year Qualified Allocation Plan (QAP) has been hotly debated over the years. Year after year, TAAHP members have discussed the nuances of the various aspects of the Texas QAP. Numerous meetings and hours of discussion result in a lengthy list of recommendations to the Texas Department of Housing and Community Affairs to advocate for a myriad of changes which are intended to streamline the application while encouraging the highest and most sustainable quality of development. Depending on who you ask, you are likely to hear a series of reasons why or why not Texas should move away from an annual QAP to a bi-annual one.
Nathan Kelley TAAHP QAP Committee Chairman
Most recently, two bills were introduced in the 87th Texas Legislature that would have mandated such a change. While neither passed, the debate continues, leaving us to ponder the pros and cons of such a shift. As chairman of TAAHP’s QAP committee, I reached out to my colleagues to give me their thoughts on the subject. And while this list is not exhaustive of what many industry professionals have to say on the matter, their responses offer some very valid points that are worthy of consideration.
ON THE + SIDE
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A bi-annual approach would provide for more consistency in rule making over a two-year period.
Without annual modifications, application materials would be better and should result in the release of application materials sooner. In 2021, it was problematic that a final application was not available until about a week and a half before the freeze event happened. Even without the weather event, the timing was delayed and created an environment unnecessarily rushed completion timelines.
A 2-year QAP allows for more fully formed development plans in the second year and expands the ability to spend time on thoughtful design and engagement with community stakeholders.
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Pre-development costs would be more effectively spent by developers since the 2-year cycle allows developers to know that they are working on sites which could be competitive over two consecutive cycles.
The current single-year QAP puts applicants “under the gun” as the QAP is not finalized until December of each year and pre-applications are due less than 30 days later. A 2-year QAP would eliminate this undue pressure in at least the second year of the approved plan.
Te x a s A f f o r d a b l e H o u s i n g M a g a z i n e
