The title of this series is appropriate, as qualified allocation plans (QAPs) often involve debate. Differences of opinion are not only OK but to be expected: All forms of resource allocation are political, at least to a certain degree.
One of the main venues for how the debate takes place is through submitting comments. Although allocating agencies carefully consider all of what they receive, some of this input is ineffective—for avoidable reasons.
The purpose of this article is to give advice on how to make more of an impact in submitting feedback. In addition to hopefully benefiting stakeholders, an important motivation is to help allocators themselves.
Agency staff need hear from you. To a certain extent, every QAP must reflect a consensus of the state’s industry participants. Doing so is only possible with widespread, diverse, and actionable feedback.
Also, very few states have personnel dedicated to conducting research and analysis. As such, their partners are the main source of policy guidance. Therefore, comments need to be presented in a useful manner.
The matrix below contains “Do”s and “Don’t"s for how to comment. Some points may not necessarily work in every state, but they represent best practices for each state to consider.
Lastly, anyone reading this article and not planning on submitting comments themselves has missed the most important point entirely. Developers, some local governments, and a few advocates make up almost all of what an agency receives.
Conversely, lenders and equity providers rarely have anything to say, which is a real shame. Their extensive knowledge and neutrality on many controversial topics lends great credence to their views.
The ideal conclusion would be a combination of the WWII Uncle Sam “I Want You” poster and Nike’s “Just Do It” slogan. We are all in this program together and have a shared responsibility to help it improve.
The Do's and Don'ts
|Be specific! This suggestion is listed first because it is by far the most important. Ideally, write out proposed text word for word.||Don’t make general or vague requests, they usually have little impact. Don’t assume the agency understands what you want to happen or has the same knowledge.|
|Comment before the first draft. Doing so is especially important for
At a minimum you need to comment early on. Set a deadline of no later than 10 days after a formal period opens.
|Don’t feel limited by official comment periods. Most agencies at
least informally accept input year-round.|
|Make submissions more than once, particularly when there are multiple drafts. Your subsequent comments should move the discussion forward.||Don’t simply repeat the same statements.|
|Mention what you like about the current policies. Others may be critical, and so you could lose something beneficial by being silent.||Don’t think that everyone agrees with you. No matter how confident in
your position, almost nothing is universally popular.|
|Focus on the substance of your ideas.|
Assume all communications will be public, either by being posted to a website or a public records request.
|Don’t worry about style of presentation and grammar. An email is as
good as a letter, and allows easy forwarding. You don’t have to be an expert.
Knowledge of the program is helpful, but not required.|
|Pay attention to others’ perspectives. You may be able to respond to their arguments, and/or even change your mind.||Don’t ignore other stakeholders’ perspectives. The allocating agency
will listen to them just as much as they listen to you.|
|Be realistic and fair. Remember examples and results are more
convincing than opinions. Recognize the program’s limitations.||Don’t try to use “spin”; it won’t gain support with knowledgeable
decision-makers. Tell it straight, including any aspect which isn’t helpful
to your case.|
|Be patient. QAPs can be like battleships: powerful tools which
require time and space to change course.||Don’t think you’ve wasted time if the QAP doesn’t reflect your
comments. The idea may be ahead of its time and need longer to evolve.|
This article is the seventh installment of "The Great QAP Debate," a series exploring multiple perspectives about qualified allocation plans, culminating in a panel session at AHF Live! Housing Developers Forum.
Mark Shelburne is a policy consultant with Novogradac & Co., based in Raleigh, N.C. His work includes advising state agencies, financial institutions, and developers on topics including allocation policy, fair housing, compliance, program innovation, and permanent supportive housing. Previously he was counsel & policy coordinator for the North Carolina Housing Finance Agency.