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Healthy Building Practices In Qualified Allocation Plans

Feb 25, 2021

The health benefits to affordable housing are numerous—from mental well-being, alleviating overcrowding, and providing resources for health care. Only a handful of states, however, are using all the tools at their disposal to ensure affordable housing is constructed with public health and wellness in mind through the government’s largest initiative for developing affordable housing—the Low-Income Housing Tax Credit (LIHTC) program. In a relationship that is inextricably linked, the inclusion of healthy products and materials is a necessary mechanism for building healthy, affordable homes for low-income families.

States can use funding from LIHTCs to signal that the health of individuals constructing and living in these buildings are of the utmost importance. Housing developments that prohibit or limit the use of harmful materials safeguard builders and residents from exposure to toxic chemicals that can have severe and long-term consequences. Inadequate housing and building materials—including insulation, paints and sealants; roofing problems, heating, plumbing and electrical deficiencies, water leaks and intrusion; and pests—can lead to health conditions such as respiratory illness, asthma, lead poisoning and cancer.

By setting requirements or rewarding points in QAPs for product and building certifications—or specific health and locality provisions—states can raise health standards in affordable housing.

States have broad discretion in administering LIHTCs through state designed qualified allocation plans (QAPs). A majority of QAPs include scoring criteria that award points for items like siting the building in a more desirable location, adding extra amenities, or meeting building health and sustainability standards above and beyond the state minimum requirements.

While states—typically through their housing finance agencies—must ensure that properties awarded tax credits abide by income eligibility and affordability requirements, they also have the responsibility to design QAPs that align with their policy goals. Through highlighting the use and need of healthy products that are locally-made, states can demonstrate their desire to improve affordable housing conditions, create jobs, and reduce greenhouse gas emissions.

The BlueGreen Alliance Foundation’s (BGAF) staff reviewed QAPs of all 50 states and the District of Columbia and analyzed the various types of policies in use across the country. We looked for requirements for third-party building certifications and health-specific policies, such as certifications for building products or requirements or incentives for non-toxic products. We also collected policies that incentivized or required local product sourcing. 46 states—and D.C. —met at least one of these thresholds, with Arkansas, Kansas, Kentucky and West Virginia being the only states that do not require or incentivize any form of healthy or energy-efficient building practices in their QAPs, and at most only provide general non-binding guidelines.

The purpose of accumulating this information is to encourage states to incentivize buying healthy and locally-made products and strengthen their QAP guidelines to require rather than incentivize third-party certifications.

 

Building Certifications

 

It’s important to note that not all building certifications are created equal. These standards consider environmental, economic, and social aspects of affordable housing, and various measures must be met to achieve certification. While many include language on locality or health, they do not require them. Projects can ignore health checklist items if the builder chooses to prioritize other items, such as energy efficiency or sustainability. For example, the Colorado Housing and Finance Authority requires applicants for LIHTCs to provide evidence their proposed project will receive a green building certification, with both Enterprise Green Communities and the National Green Building Standards (NGBS) listed as options. However, Enterprise Green Communities mandates projects use low-VOC interior paint, low-VOC primers and coatings, and non-VOC emitting flooring, all of which are optional if the development is certified through NGBS.

While most states have different overall standards and requirements for new construction as opposed to rehabilitation or preservation projects, building certifications are often mirrored between the two development options. However, there are some outliers. Missouri, for instance, requires new developments to meet the current standards of Enterprise Green Communities, any LEED rating system, or NGBS; in rehabilitation projects the green building requirement is highly encouraged but optional.

 

Healthy Building Best Practices

 

Data from October 2020.

Research from the BlueGreen Alliance Foundation shows that almost 60% of states list additional health-related policies outside of building certifications in their QAPs. For the purposes of our study, states were considered to have mandatory or incentivized policies if they met at least one of six health areas—standard low/VOC paints/sealants and adhesives; low/no VOC finishes and flooring; fiberglass insulation – GREENGUARD; Green Label carpeting; formaldehyde limits; and air quality standards.

Standard low/no VOC paints/sealants and adhesives 24
Low/no VOC finishes and flooring 14
GreenLabel carpeting 10
Formaldehyde limits 10
Air quality standards 9
Fiberglass insulation – GREENGUARD 1

 

It’s worth mentioning the map only lists health provisions that are cited within a state’s QAP, as a project can still target health priorities in other ways, such as requirements or incentives in building certifications or through a state’s building code. For example, Indiana doesn’t list any health provisions but must have a third-party building certification, allowing a builder options to target a certification that includes health-related provisions.

The most frequent health initiative is limiting the use of non-toxic and/or low VOC products in affordable housing. States vary in toxicity limits for VOCs or other toxic content in products. Some QAPs do not provide a specific limit beyond specifying that low VOC products are to be used, while others reference national air quality standards.

In recent years, states have made few modifications in health provisions, and in a number of cases the growth of building certifications appears to be correlated to this stagnation. State policymakers see the benchmarks for building certifications as prescriptive criteria for preventative measures, and thus third-party certifications are the teeth in setting health provisions.

Definitions for Healthy Building Best Practices 

  • Low/no VOC paints, sealants, adhesives: Paint, sealant, and adhesive products that have no or low VOC content and/or emissions. Volatile organic compounds (VOCs) are a diverse set of chemicals, liquids and solids that can evaporate under ordinary atmospheric conditions. Products can release VOC emissions throughout their life and VOCs are highly reactive pollutants. Low VOC content is commonly based on the South Coast Air Quality Management District’s (SCAQMD) VOC content standard. Low VOC emissions standards are based on the California Department of Public Health’s (CDPH) Standard Method VOC emissions testing standard and similar 3rd-party low VOC emissions certifications, such as Cradle to Cradle, Green Seal, GREENGUARD Gold, and Indoor Advantage.
  • Fiberglass Insulation – GREENGUARD: Fiberglass insulation products that have been 3rd-party certified to have low VOC emissions by GREENGUARD.
  • Low/no VOC finishes and flooring: Flooring and flooring finishing products that have no or low VOC content and/or emissions. Low VOC content is commonly based on the South Coast Air Quality Management District’s (SCAQMD) VOC content standard. Low VOC emissions standards are based on the California Department of Public Health’s (CDPH) Standard Method VOC emissions testing standard and similar 3rd-party low VOC emissions certifications, such as FloorScore, Cradle to Cradle, GREENGUARD Gold, and Indoor Advantage.
  • Green Label carpeting: Carpet, cushion, and adhesive products that meet the low VOC emissions standard set by the Carpet and Rug Institute. QAPs cite both the Green Label and the Green Label Plus versions of the standard.
  • Formaldehyde Limits: Low-formaldehyde emission limits on certain types of products. Examples include use of formaldehyde-free insulation and sealed board products such as shelving, cabinets and countertops.
  • Air Quality Standards: Promote air quality and ventilation, such as the installation of exhaust fans, meeting ASHRAE ventilation standards, or any other efforts to enhance indoor air quality during construction or to maintain healthy air quality.

Buy Local

 

Data from October 2020.

The BlueGreen Alliance Foundation's Building Clean initiative believes that encouraging local purchasing within state procurement policies boosts the local economy and supports domestic manufacturing. Manufacturing jobs often have higher pay and better benefits than similar jobs in other sectors and are vital for rural areas within manufacturing states. Structuring policies that support the purchase of locally-made energy-efficient products not only helps maintain quality jobs, it generates local economic activity and drives economic innovation.

A handful of states use the power of procurement within state QAPs to incentivize sourcing materials in-state or within a radius of the project. Michigan—the only state that requires in-state sourcing—mandates that all projects must “demonstrate the use of products and goods that are manufactured by Michigan-based corporations and incorporate them into the proposed development.” To assist builders and developers, Michigan’s QAP also provides a list of recommended in-state suppliers.

Massachusetts, Montana, and Nevada all provide points for projects that include locally sourced materials and products. Vermont contains regional sourcing as an option for meeting state requirements for sustainable materials and products, but it is not required. While Washington’s QAP doesn’t mention local sourcing, its state specific certification—the Evergreen Sustainable Development Standard—awards points for the use of environmentally preferable materials or materials that are produced within 500 miles of the construction site.