QAP Report

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Scorecard on QAPs: How States Can Integrate Health, Energy Efficiency, Working Conditions, and Racial Equity into Qualified Allocation Plans

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The BlueGreen Alliance Foundation (BGAF) researched state Qualified Allocation Plans (QAPs) and developed this report to encourage states to learn from each other and improve efficiency, health, and equity in housing and create good jobs. Our findings show that while some states continue to make strides in considering energy efficiency and the health of occupants, others minimize their importance by not requiring LIHTC-financed properties to include these provisions or prioritize other housing needs. On racial equity, our research shows a majority of states address only a portion of areas that can reduce disparities and increase housing opportunities. Almost no states require or incentivize labor standards in their QAP and only encourage local sourcing or local-hiring provisions.

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State and City Scoring Summaries


Alaska does not include any provisions relating to indoor health or chemical exposures in their QAP. It does incentivize all construction projects to use the Building Energy Efficiency Standard (BEES), a state standard that sets building energy standards for thermal resistance, air leakage, moisture protection and ventilation. Alaska scored a D in the report’s Racial Equity section, having only met multiple criteria in the “Depth of Affordability” sub-section.


Alabama has minimal standards relating to the health of occupants, as the Alabama Housing Finance Authority only mandates radon-resistant new construction and radon testing for rehabilitation projects and incentivizes low-VOC wall and flooring finishes. While not comprehensively addressing racial equity issues, Alabama’s QAP does target location and environmental health exposures and incentivizes applicants that are minority or women-owned entities or projects which promise to award 10% of building costs to minority or women-owned businesses.


Arkansas is one of three states that didn’t meet any criteria in either the Healthy Building Practices or Energy Efficiency section, and the primary reason for receiving an overall D grade. It did receive an above-average score nationally in the Racial Equity section, as it includes a handful of incentives for high-opportunity areas and offers right of first refusal contract for  eventual tenant ownership.


Arizona met nationwide average scores in the Healthy Building Practices and Energy Efficiency sections. It supplements their incentive of green building certifications for new construction by mandating low-VOC adhesives/caulks/sealants and requiring carpets to be Green Label Plus certified. To address energy efficiency, Arizona’s QAP awards points for applicants with a HERS Index score of 55 or better for new construction while rehabilitation projects must improve building energy performance by at least 15%. While Arizona’s QAP incentivizes applicants to include a comprehensive plan for conversion to ownership by tenants after 15 years and projects built within ten miles of eligible amenities, it otherwise offers little to address racial disparities.


California no longer requires or incentivizes green building certifications and for this reason scores poorly in the report. It is one of only a handful of states who require all fiberglass-based insulation provided or replaced to be GREENGUARD Gold certified. Rehabilitated projects must document at least a 10% post-rehabilitation improvement for energy efficiency. The California Tax Credit Allocation Committee—which allocates federal tax credits—has minimal racial equity provisions aside from additional benefits for projects partnered by a Person of Color, incentivizes for universal design and local amenities. It is, however, one of the few states that encourages developers to offer health and wellness services to tenants.



Colorado requires all projects to obtain a green building certification, listing Enterprise Green Communities, LEED, and the National Green Building Standards as certification options for developers. Given the competitive nature of LIHTC funding, Colorado also encourages applicants to align with the state’s climate action goals and obtain an additional certification through Zero Energy Ready Homes or Passive House. Colorado is unique in that it requires applicants to show “in measurable terms” how a neighborhood will be improved through community revitalization efforts.


Connecticut is the lone state to require a green building certification for rehabilitation projects but not for new construction, listing Enterprise Green Communities, LEED and NGBS as options for developers. A similar dichotomy exists for energy reduction measures within Connecticut’s QAP, as a reduced HERS Index score is incentivized for new construction projects and required for rehabilitation projects.

The District of Columbia

The District of Columbia received an A-, one of the highest grades in the scorecard. D.C. received As in the Healthy Building Practices and Energy Efficiency sections partly due to its requirement that all LIHTC projects with at least 50,000 square feet of gross floor area must be certified by Enterprise Green Communities or a “substantially similar standard.” D.C’s QAP met all criteria within the report’s “Unit Size and Design” Racial Equity sub-section, as it prioritizes projects with at least 30% of units to have three or more bedrooms and incentivizes housing for seniors and people with disabilities.


Delaware was consistent and received Bs across the board in the scorecard. It incentivizes green building certifications for all projects and requires all interior paints and primers to meet low or no VOC levels. Energy conservation measures encourage efficiency-targeted certifications and HERS Index scores. Delaware received high marks for ‘depth of affordability’ in the Racial Equity section, and is one of a handful of states who award points to LIHTC-applicants who offer documents to rental applicants in Spanish and other languages for non-english speaking applicants.


Florida has its own green building certification from the Florida Green Building Coalition. Housing developers must choose to use this standard or a similar certification framework to receive federal tax credits for new construction projects. Rehabilitation projects are incentivized to use Green Label carpeting and limit formaldehyde in cabinetry. Florida met all the criteria in the QAP in the tenant screening category, as they prohibit screening for any arrests and previous evictions in a household’s application for tenancy.



Georgia lists “health outcomes for residents” as one of the state's priorities in its QAP, noting that “safe, quality affordable housing provides the foundation and central location for encouraging healthy lifestyles.” Georgia requires a green building certification for all projects, with five certifications listed as options for developers, including Southface EarthCraft and the Green Building Initiative’s Green Globes certification. Georgia has several incentives that encourage community engagement. To receive points in the state’s “Community Transformation” category, applicants must make efforts to get feedback from the low-income population that will benefit from the housing development and have partnered with community organizations in the area of the proposed property.



Hawaii incentivizes certifications of Enterprise Green Communities, LEED and NGBS, along with EPA’s ENERGY STAR under its “Sustainable Building Practices” criteria. Requiring these certifications would raise Hawaii’s overall grade considerably. Despite offering points for project applicants targeting high opportunity areas and incentivizing tenant ownership, Hawaii’s QAP has limited provisions related to racial equity.



Iowa received a score just above the national median. It offers several routes to address health and energy efficiency. For example, if a project doesn’t meet the prescriptive standards of ENERGY STAR Certified Homes, a project must then adhere to the requirements of Iowa Green Streets, a state program to promote public health, energy efficiency, water conservation and sustainable building practices. 



To meet Idaho’s green building requirement, a proposed development must either incorporate one of six green building certified program standards or include a combination of individual green building and energy efficiency components. The latter criteria includes Green Label certified low-emission carpeting, “no added urea-formaldehyde” cabinets, and HERS scores of 100 or less for rehabilitation developments or 70 or less for new construction developments. Aside from encouraging developments located in close proximity to selective criteria and affordability measures, Idaho doesn’t include many racial equity objectives.



Illinois received the highest overall score in the report. While it does not require a green building certification, it does mandate all projects to meet specific criteria within Enterprise Green Communities—such as its building performance standard and healthier material selection sections. Projects can receive additional points if they are certified from  either the International Living Future Institute’s Core Green standard or the Living Building Challenge. Illinois received one of the highest scores in the nation in the QAP report’s Racial Equity section, meeting all criteria in both the “Unit Size and Design” and “Outreach and Affirmative Marketing” categories.


The City of Chicago

The City of Chicago is unique in that it is one of the few non-states that receives housing tax credits to allocate each year and has a QAP separate from the state of Illinois. Chicago received a low score as its QAP lacks provisions relating to occupancy health and it doesn’t detail energy efficiency requirements. In 2021, the Chicago Department of Housing released a Racial Equity Impact Assessment aimed at examining its QAP through a racial equity lens and how to incorporate racial equity into its design, but it is not yet implemented.



As part of its “Minimum Design Requirements,” Indiana’s QAP mandates all new construction and rehabilitation projects to achieve energy efficiency by meeting the minimum standards set by Enterprise Green Communities, LEED, NGBS or an equivalent certification accredited by the American National Standards Institute. Indiana scored highly in the Racial Equity section relative to other states, meeting a majority of the criteria in affordability, tenant screening, amenities and services.



Kansas has limited healthy building components and only includes an incentive for ENERGY STAR of new construction projects.. As part of receiving a grade of B for racial equity, Kansas’ QAP offers ownership for tenants after 15 years for single-family structures and offers integrated supportive housing to aid populations with a particular vulnerability to housing instability.



Kentucky is one of a handful of states who met no criteria in the Healthy Building Practices and Energy Efficiency sections, and had one of the lowest scores in the Racial Equity section. In the latter category, Kentucky awards points for households below 60% AMI and Minority or Women Business Enterprise (MBE/WBE) developers.



Louisiana requires a third-party certification from either Enterprise Green Communities, LEED, NGBS or EarthCraft for new construction projects, and incentivizes a green building certification for rehabilitation projects. It is also one of the only states with local sourcing and local hiring provisions within its QAP, as project developers must detail efforts to maximize the use of regional material, labor and services.



Massachusetts scored highly in the Healthy Building Practices section, but low scores in other sections reduced its overall score to a C+. Along with incentivizing green building certifications, Massachusetts mandates no-VOC paints and formaldehyde-free countertops. In an effort to expand opportunities for individuals and entities that have not historically been able to participate in affordable housing development, Massachusetts awards points for developments with project sponsors or general contractors as a Minority or Women Business Enterprise (MBE/WBE).



Maryland received B’s across the board, receiving one of the top ten scores nationally. Its QAP mandates several healthy building provisions in its base level green standards for all projects. For energy efficiency, Maryland requires an ENERGY STAR certification for new construction and minimum energy savings for rehabilitation buildings.



Maine requires a Green Label certification for carpeting and ASHRAE ventilation for indoor air quality, but otherwise doesn’t include green building or energy reduction measures. Aside from enhanced affordability policies, Maine offers little other provisions related to racial equity.



All projects in Michigan receiving Low-Income Housing Tax Credits are required to incorporate either Enterprise Green Communities, LEED, or NGBS, which led to high scores in the QAP report’s Healthy Building Practices and Energy Efficiency sections. Michigan is also one of several states that encourages the use of in-state products, as it requires all projects “to demonstrate the use of products and goods that are manufactured by Michigan-based corporations and incorporate them into the proposed development.” Meeting a majority of the criteria in the “Access” and “Location and Siting” categories helped Michigan receive one of the higher grades in the Racial Equity section.



Minnesota received the highest score in the report, having high marks in all three sections. It mandates all completed developments to comply with an “overlay”—or a modification—of the Enterprise Green Communities Criteria and the state’s design and construction standards. For enhanced sustainability and energy conservation, projects can target certifications such as the Department of Energy’s Zero Energy Ready Home and Passive House. Minnesota also met all the criteria for the scorecard’s “Data Accountability and Transparency” racial equity category.



All new construction projects in Missouri must meet certification standards for either Enterprise Green Communities, LEED or NGBS, but otherwise there are minimal energy efficiency or occupant-health related provisions. Missouri’s QAP includes a target for approved applicants from MBE/WBE developers, development amenities and tenant ownership.



Mississippi awards points for developments that build or rehabilitate projects that meet the standards of either Enterprise Green Communities or NGBS and requires low/no VOC interior paints and the use of formaldehyde-free insulation. While not scoring highly in the Racial Equity section, Mississippi incentivizes developments that set aside 15% of the total units to individuals or families that do not exceed 30% of the area median gross income.



Montana has one of the lowest overall scores and is one of the few states who scored poorly in both the Healthy Building Practices and Energy Efficiency sections. It cites the Passive House building standard, energy efficiency and water conservation, and material and resource efficiency  but only mentions them as voluntary initiatives.


North Carolina

North Carolina has no language in their QAP that meets the Healthy Building Practices criteria. It does require new construction projects to achieve an ENERGY STAR certification, while adaptive re-use and rehabilitation projects “must comply to the extent doing so is economically feasible.” North Carolina tied for the lowest overall score in the Racial Equity section.


North Dakota

North Dakota’s “Green Communities” category incentivizes projects to meet mandatory criteria within Enterprise Green Communities, with maximum points awarded to projects certifying an Enterprise certification (or LEED/NGBS). No other health-related or energy efficiency-related criteria are mentioned. North Dakota received a C in the report’s Racial Equity section, with universal design and tenant demographic reporting among  several of the criteria the state met.



Nebraska received an F in both the Healthy Building Practices and Energy Efficiency sections, only including policies to limit VOCs in paints and water conservation. Nebraska also incentivizes proximity to amenities and developments in high-opportunity areas.


New Hampshire

Incentivizing green building certifications and requiring ENERGY STAR certifications for all projects is the reason New Hampshire received B grades in the Healthy Building Practices and Energy Efficiency sections. Unfortunately, the state didn’t score as well in the Racial Equity section and didn’t meet any of the criteria in a majority of the categories, including Outreach and Affirmative Marketing, Unit Size and Design, and Tenant Screening.


New Jersey

New Jersey received an above average score nationally, as its QAP cites six green building certifications as options for all projects to receive 3-4 points within the state’s QAP. ENERGY STAR certification and energy benchmarking are required for all tax credit projects. New Jersey encourages owners and developers to affirmatively market their projects and requires all multifamily projects to perform Phase I environmental assessment and follow-up Phase II, if necessary, along with any required remediation.


New Mexico

New Mexico does not reference building certifications, and only requires low-VOC paints/sealants and carpet to be Green Label Plus certified for all projects. For energy conservation, all newly constructed projects must obtain a HERS score of at least 55 and rehabilitation projects must obtain a score of 65 or better. New Mexico only met minimal racial equity criteria, but incentivizes women and/or minorities to participate in the ownership, development or management of the project.



While not encouraging the use of green building certifications, Nevada does require low-VOC paints, ASHRAE standards for indoor air quality, and radon-resistant features. For energy efficiency, energy performance for new construction projects must be equal or greater than the ENERGY STAR Home Program Version 3.1. For local sourcing and hiring, applicants must submit “a list of products and goods by Nevada-based corporations that will be incorporated into the development” and employ at least two “third-party Nevada-based companies” into the development.


New York

New York had the highest score in the Healthy Building Practices section, as it requires a “certification from a responsible green and/or energy professional” and requires spray foam insulation to limit residual off-gassing. New York scored poorly in the Racial Equity section, although it does incentivize minority, women and service-disabled business participation and the  participation of non-profit applicant organizations.


New York City

New York City uses an “overlay” of the Enterprise Green Communities and requires all projects to be certified or pursue LEED’s gold or platinum certification. The overlay is a version of Enterprise Green Communities that is modified to meet New York City’s needs and priorities. Similar to its state QAP, New York City’s Housing Preservation and Development’s (HPD) QAP received a low score in the Racial Equity section.



Ohio garnered one of the highest scores nationwide, receiving A grades in the Healthy Building Practices and Energy Efficiency sections and a B in Racial Equity. The Buckeye state mandates all multifamily developments to obtain either an Enterprise Green Communities, LEED, or NGBS certification and offers several paths to meet the ENERGY STAR requirement. Ohio’s QAP makes owners of developments adopt Tenant Selection Plans, which “prohibits the denial of admission, termination of assistance or eviction on the basis of arrest records alone,” among other provisions.



Oklahoma scored poorly in each category, only incentivizing the use of low-VOC paints and a reduced HERS score in the Healthy Building Practices and Energy Efficiency sections, respectively. Oklahoma did meet several of the criteria within the ‘Amenities and Services’ subsection of Racial Equity, partly due to the state’s  incentivizing onsite health clinics or wellness suites with a service coordinator on-site at least 10 hours a week.



Oregon tied for the 2nd highest score overall. It mandates housing developers to integrate a ‘Sustainable Building Path’ and select either Enterprise Green Communities, LEED, or Earth Advantage certification, the latter of which specializes in low-income housing. Oregon tied with Illinois in receiving the highest score in the Racial Equity section. Devised by Oregon Housing and Community Services, the state’s QAP requires applicants to identify strategies for contracting with MBE/WBE contractors and subcontractors, incentivizes tenant ownership, and disincentivizes projects sited on tracts with greater health risks due to environmental factors, as determined by EPA’s Environmental Justice Screening and Mapping Tool.



Pennsylvania requires multifamily projects to comply with the building performance standards within the Enterprise Green Communities criteria, criteria that mandates an ENERGY STAR certification for new construction projects and energy reduction measures for rehabilitation projects. The Keystone State achieved the same score as the national median in the Racial Equity section, highlighted by comprehensive affordability criteria for very low-income units.


Rhode Island

Rhode Island incentivizes the use of net zero or Passive House standards and has their own residential construction standards, which can combine with ENERGY STAR standards to obtain a higher level of energy efficiency. It would score higher in the Healthy Building Practices section, but Rhode Island’s QAP merely encourages, rather than requires or incentivizes, low-VOC finishes and paints. Rhode Island does ban the use of formaldehyde for cabinetry.


South Carolina

For new construction projects, South Carolina incentivizes the application of a handful of green building certifications – including an in-state building performance standard - and requires an ENERGY STAR certification. While not meeting a majority of the criteria in the Racial Equity section, South Carolina does disqualify projects that pose environmental health risks, such as disposal facilities for hazardous wastes.


South Dakota

South Dakota does not reference green building certifications, and instead just requires formaldehyde free insulation and the use of low-VOC paints/stains/adhesives and sealants for all projects. For energy conservation measures, South Dakota offers points to projects that become ENERGY STAR certified or have a HERS score of 60 or better. While the state QAP does incentivize participation by minority or women owned or operated business enterprises, it otherwise offers minimal racial equity provisions.



Tennessee had one of the lowest scores nationwide, as their QAP offers no health-related or energy reduction measures that met the criteria of BGAF’s report. Besides having affordability and location policies, Tennessee offered almost no other targeted goals for applicants to address racial inequities.



In the “Green Buildings Features” section of its QAP, Texas aims to “promote energy and water conservation, operational savings and sustainable building practices.” It incentivizes projects to incorporate applicable criteria to the type of construction (new or rehabilitation) for Enterprise Green Communities, LEED or NGBS. While encouraging  the use of ENERGY STAR appliances, it does not incentivize an ENERGY STAR certification or energy reduction measure, but does offer a point for EPA WaterSense toilets, showerheads, and faucets.



Utah achieved the national median score, receiving an overall C grade. It incentivizes the use of green building certifications—offering Enterprise Green Communities, LEED, and NGBS as options—and requires new construction and rehabilitation projects to be ENERGY STAR certified (rehabilitation projects can be ENERGY STAR “enhanced” if certification cannot be feasibly met). As part of Utah’s “Project Amenities” category, it incentivizes ‘life skills classes’ and lists 14 examples, such as employment, computer literacy, and medical and childcare resources.



Virginia offers no specific building material-related health provisions in their QAP, but the state QAP does incentivize LIHTC applicants to obtain either an EarthCraft, LEED, NGBS or Enterprise Green Communities certification. Each applicant must also meet all requirements for an ENERGY STAR certification for new construction projects and rehabilitation projects must result in a 30% HERS score decrease or achieve a score of 80 or lower.



As part of its evaluation criteria, Vermont incentivizes a Passive House certification and requires a handful of health-related provisions, such as low-VOC paints and radon-resistant construction. It doesn’t reference an ENERGY STAR certification but rather requires all new construction to comply with Efficiency Vermont’s (EVT) 2020 High-Performance Track standards. Vermont mandates all projects to meet the state’s Universal Design Policy and encourages developers to target deeper affordability than minimum requirements, but meets only a handful of other racial equity criteria.


Washington has one of the highest scores in the QAP report and received an overall B+ grade. The Evergreen state requires all projects to comply with the state’s Evergreen Sustainable Development criteria, a detailed building performance standards designed for affordable housing projects. Washington met all the criteria in the ‘Community Engagement’ and ‘Amenities and Services’ subsections of the report’s Racial Equity section.



As a minimum threshold requirement, Wisconsin requires all projects to be built to the Wisconsin Green Built Home Standard or the Enterprise Green Communities Criteria. Compared to the other two sections, Wisconsin did not score highly in the Racial Equity section. One of Wisconsin’s unique provisions is encouraging developers to meet the state’s Emerging Business program criteria, which aims to boost the development of economically disadvantaged businesses.

West Virginia

West Virginia has the second lowest overall score, as its “Energy Efficiency and Quality Housing” section doesn’t target occupant-health or performance-related energy reduction provisions. Despite earning  a D in the Racial Equity section, West Virginia does incentivize minority and women business enterprises and development in high-opportunity areas.



Wyoming’s QAP has no reference to green building certifications or measures aiming to reduce worker or occupant exposure to toxic chemicals. It does incentivize an ENERGY STAR certification and energy reduction through HERS Index score for both new construction and rehabilitation projects. Wyoming is one of a handful of states to collect and report vacancies at LIHTC projects.