consider rehabilitation and preservation when analyzing the location of LIHTC properties

[Ellen Lurie Hoffman]

As HUD has noted on several occasions, we can and should be investing in wealthier communities while simultaneously preserving existing affordable housing wherever it may be. Indeed, HUD’s AFFH final rule “recognizes the role of place-based strategies… to improve conditions in high poverty neighborhoods, as well as preservation of the existing affordable housing stock, including HUD-assisted housing, to help respond to the overwhelming need for affordable housing.” However, PD&R’s report, “Effects of QAP Incentives on the Location of LIHTC Properties,” does not distinguish between new construction and preservation when analyzing the deployment of LIHTC. PD&R should conduct a follow-up study on LIHTC and QAPs, distinguishing between rehabilitation and new construction.