In the world of public/private partnerships, checking the boxes has become the norm.

And sometimes, those boxes make about as much sense as a tree that grows "blue leaves."

So, when a public authority tells the private developers to deliver a bucket of blue leaves, in order to be successful, we don’t argue ... we don’t tell our public authority that blue leaves don’t naturally grow on trees.

We go to the local hardware store, we buy a bucket and a can of blue paint and find some leaves to paint blue after which we deliver that bucket of blue leaves to the public authority so their box can be checked.

And therein lies the dilemma.

Do we throw common sense and all things logical out with the trash as we conform to a qualified allocation plan (QAP) system that has evolved into a list of checkmarks? To be fair, the state authorities truly believe they are creating sound public policy as they draft their QAP each year. Their pressures to now adhere to Department of Housing and Urban Development (HUD) standards is enormous.

Unfortunately, trying to address all of the nation's social ills with one program has created a bucket and blue paint shortage.

QAP Evolution


Over the years, QAPs have evolved from addressing the needs of hard working families at 50% to 60% of the area median income to addressing the needs of prisoner release, migrant (and sometimes illegal immigrant) family housing, and other public policy needs far removed from Sec. 42’s original intent.

Each government program is started with a public purpose. As it evolves to include other purposes, it shortens its life span.

The low-income housing tax credit (LIHTC) program simply cannot be all things to all people.

If this program is to maintain its original mandate, agencies such as HUD need to step up with Congress to bifurcate the intended public policies for skewed very, very low income, special-purpose housing from one program; and to allow the LIHTC to do what it does best—serve hard-working families at the 50% to 60% AMI levels so they have the quality housing the program was designed to build.

That is not to say the other public purposes are not valid. It is just that these should be addressed through other social programs that are better qualified to manage those needs.


This article is the eighth 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.

Rob Hoskins is managing principal of Atlanta-based developer The NuRock Cos.