Tab 7 Written Comments from the Public

Tab 7

Written Comments from the Public

Written Comments Received for Modifications Made to the Low Income Housing Tax Credit FY2018 Qualified Allocation Plan December 4, 2017

Aumann, Shirah Miriam “Mimi” Beacon Village Resident Springfield, MO 65802

I am a resident of Beacon Village in Springfield, MO, low income level residence. My rent is $475/Mo, and I really struggle to make that rent payment but have never been late. I am 78 years old and live alone with no family checking on me. If I did not have this apartment, I would definitely be either out on the street or living in sub-standard conditions which exist all over Springfield, MO.

Before I got on the waiting list for this apartment while it was being built, I was living in a 20-year old trailer and driving a 20-year old car. By a miracle, I was able to sell that trailer and got enough money to pay for a used car so I would not have to have a car note monthly. There was a little left that I have been living on in the 4 years I have lived in Beacon Village.

I am VERY thrifty- I do not smoke or drink, have a lot of medications or eat out a lot. I spend any money very carefully and do not abuse "the system" by trying to get all I can out of it. Until now, I have made it barely. Recently I had to cash in a couple of CO's I had been saving for years to leave to two nieces who have been kind to me but live at a great distance in other states. Recently, because of my need, I have had to apply for help and qualify for Medicare monthly payment to be paid for me. It hasn't happened yet but I am hoping it will as I need some kind of assistance it would appear...

I would repeat, if it were not for this housing I am currently in, I would end up on the street or in very dire conditions. I have lived a good life of service and character, being a volunteer most of my life and in leadership roles. I have been a teacher and worked in Christian environments by choice, rather than the worldly roles I could have filled at higher pay. I am one of those who has slipped through the cracks through no fault of my own but by the circumstances of my life. I know others in this situation as well. We tend to commiserate together about how we would have come to this condition in our golden years when we are supposed to at last get a little rest and leisure activities when we have been "good citizens" and lived exemplary lives...

Please make a way that low income housing would still be available- especially to deserving members of the population. Not those simply using "the system" and continuing in a lifestyle of entitlement and addictions and abuses ...

Sincerely,

Shirah Miriam "Mimi" Aumann Beacon Village 3936-B West Maple Street Springfield, MO 65802 [email protected] 417.230.0114

Braunage, Toni Highland Ridge Senior Complex Resident

Carpentry and Exteriors, LLC Lana McPartlin Kansas City, MO

City of Columbia – City Council Matt Pitzer, City Council 701 E. Broadway, Columbia, MO 65205

I write as a representative of Columbia to urge you restore funding for the state low-income housing tax credit program. We in Columbia know the dramatic positive effect this funding has on our community and fear that a decision to end the program would cause irreparable harm to those in most need.

Here in Columbia, state LIHTC funding recently has helped renovate 360 public housing units, construct 25 new apartments for homeless veterans and hundreds more units for Missouri seniors. We have plans to renovate more than 200 additional public units in future years, helping to restore our aging public housing property. These affordable housing opportunities provide a critical "hand up" to families who simply need the dignity of a roof over their heads to stabilize their lives.

The state LIHTC program, with private market oversight, has served as an efficient alternative to the old, bloated government-run bureaucracies that rightfully earned scorn. Here in Missouri, we have done it better, cheaper and with less government involvement. We have entrusted the private market to deliver efficiency where government cannot. Missouri spending on state LIHTCs is a fraction of the $1 billion in rent subsidies spent by New York City alone. Further, mandates elsewhere require developers to set aside a percentage of all new units as affordable. Missouri's LIHTC program keeps taxes down and reduces costs for all citizens.

And with an aging population, veterans who struggle to stay out of the cold and the serious challenges facing the disabled, the need for affordable housing is acute. More than ¼ of all renters spend more than half their income on rent, and waitlists for rental assistance in Missouri are often so long they are closed to new applicants. A recent study counted 16,000 homeless schoolchildren, each of whom is less likely to complete high school and more likely to require state support throughout their lives.

The Missouri low-income housing tax credit program has delivered countless benefits to thousands of Missourians at low cost to taxpayers. I implore you to reconsider your vote to end this valuable funding.

City of Columbia – City Council Ian Thomas, Fourth Ward Councilman 701 E. Broadway, Columbia, MO 65205

I am writing to you in support of Missouri's Low-Income Housing Tax Credit (LlHTC) program, which utilized Federal and State funds to develop affordable housing throughout the state.

As a member of the Columbia City Council, I am aware of a serious shortage of affordable homes in our community. More than 12,000 rental households ln Columbia (about 57% of all renters) and about 3,500 owner-occupied households (23%) are cost-burdened by 30% or more. In spending 30% or more of their income on housing and utilities, these families and individuals are in a fragile economic situation and at high risk of becoming homeless. This inability of the market to provide affordable housing is replicated across the state, and the UHTC program is an essential tool for Missouri communities to mitigate the problem. , ·

The following remarks provide support and justification for the LIHTC program, and respond to criticism that has been articulated.

1. The federal government's old way of financing affordable housing was broken; Missouri has helped fill the gap for decades ...until now.

LIHTCs .are preferable to the old public housing system which suffered from tremendous waste and mismanagement, and which saw taxpayers spending money to tear down structures just 2-3 decades after they were built. Compared to that, a tax credit with private market oversight, as originally crafted and enacted by Ronald Reagan and Jack Kemp, is a very efficient alternative.

2. The need for affordable housing is more acute than ever.

A recent state study counted 16,000 homeless schoolchildren, excluding kids age 0-5. Research shows that homeless children are less likely to complete high school and more likely to cost the state money throughout their lives.

3. Missouri's program isn't unusually large ... we just meet housing needs differently.

Our LlHTC program is larger than that pf many other states but other states spend far more money to subsidize affordable housing using programs Missouri lacks. For instance, while Missouri spent $144 million on state LIHTCs last year, New York City alone spends $1 billion annually to subsidize rents and requires developers to set aside 20% of all new units as affordable. During the past decade; California has spent an average of a half million dollars a year on state housing bonds.

And LIHTC spending is not, as opponents claim, out of control. LIHTC spending has grown by $144M since 1992.Since 1992, K-12 education has risen over $2B from $1.3 billion to $3.5B; Medicaid spending has increased similarly. Thus, the actual spending increase on education and Medicaid has been 15-20 times as large as that on affordable housing.

4. A recent audit of the state LJHTC program contains significant errors; LIHTC is the most efficient way to inject capital into affordable housing development.

The audit suggests using state grants as a more efficient way to build affordable housing. But tax credits are more efficient as they're less taxable than grants. Grants or forgivable loans would cost the state up-front, creating a huge short term fiscal note. Also, the state would incur 100% of the risk. Currently, the state incurs no risk b/c investors provide upfront money and additional capital if the project becomes distressed. Credits don't flow until units are leased according to stringent guidelines, and are recaptured if projects fallout of compliance. Since roughly 40% of approved projects are not built or fall out of compliance, the state would lose a lot of money- a risk currently borne by investors who provide private oversight, ensuring compliance so they don't lose their stake. Because of this market discipline, 1/3 of all LIHTCs awarded are never redeemed.

It's inaccurate to say that 42 cents goes into project and the rest is profit. This excludes 1) federal taxes; and 2) decreased value of credits in years 2-10 due to inflation (ie, time value of money). That is, before investors receive a return, typically concluding 13-14 years after the award, inflation has eaten up about 30-35 cents of the dollar.

Put simply: if you asked a bank for $1000 and off red to pay back $100/yr for 10 years, starting in 3 years and ending in 13 years, would they accept? No, but they may loan you $600 in exchange for that promise. That’s the time value of money.

5. LUITC developments create cost savings elsewhere in the budget.

LlHTC developments are a hand up, not a handout. They are not free but do reduce rents by an average of $288 month for elderly and disabled people who would otherwise be unable to afford an apartment. Given local governments’ cost providing emergency care for feeble seniors and disable people in dilapidated homes, many expenses are never incurred, and lives are saved when emergencies are spotted earlier in a large community with onsite support services.

Senior projects are an especially wise use of tax dollars because of Medicaid savings from reduced nursing home use. Over the past decade, LIHTCs have helped build 300+ new senior units annually. Of those, 43% of residents are detoured from nursing homes; thanks to specia1 services provided in tax credit units. An average of 332 units annually utilize LIHTC vs; a Medicaid funded nursing home unit. The average annual nursing home costs the state $29,871 per unit, while the annual LIHTC allocation per elderly resident is $7,773, which multiplied by 332 units costs the state $2.5M Thus, tax-credit senior housing brings $7.4M of annual savings to the state, and a 10•year savings of $74M.

Homeless vets are another key constituency LIHTC supports. Returning vets who may suffer from PTSD and substance abuse issues- face challenges finding affordable housing. LIHTC allows groups like The Salvation Army to build affordable housing that includes on-site support, sparing government from delivering costly mental health and medical services. Non-profit organizations provide services at veteran focused developments in St Louis, Kansas City, Columbia, Mexico, and elsewhere across Missouri.

City of Columbia – City Manager Mike Matthes, City Manager 701 E. Broadway, Columbia, MO 65205

In 2015, the City of Columbia launched a three-year strategic plan to address social equity issues with a strong focus on income inequities in our community. Now in our second year of the plan we have had great success in addressing these issues and reducing poverty in our community.

As you know, affordable housing is a necessary and critical resource for helping to break the cycle of poverty. It impacts the lives of low-income families, seniors, persons with disabilities, and our Veterans.

The state of Missouri's contribution to the Low-Income Housing Tax Credit program has provided critical resources to our community to address our shortage of affordable housing.

The City of Columbia's Consolidated Plan documents a significant number of renters who are rent burdened and paying more the 50% of their income for rent. State low-Income Housing Tax Credit funding is an essential resource in eliminating rent burdens on families and individuals which in turn helps to support them in their efforts to break the cycle of poverty and become self-sufficient.

The State Low-Income Housing Tax Credit program, with private market oversight, has served as an efficient and effective alternative to previous government operated housing programs. In Missouri the low-Income Housing Tax Credit program has done a better job of producing quality affordable housing in a more cost effective manner than government operated housing programs.

In Columbia, State Low-Income Housing Tax Credits were critical to the construction of the Patriot Place Apartments which provides 25 apartments for homeless Veterans.

In addition, our partner, the Columbia Housing Authority, has undertaken the monumental task of renovating and preserving their 719 units of public housing stock. To date the Columbia Housing Authority has renovated 360 public housing units with another 147 units at Oak Towers currently being renovated. In January the Columbia Housing Authority will start renovating 90 more public housing units. State low-Income Housing Tax Credits have been critical to this process and represents the largest investment in our public housing properties since urban renewal.

As the first and only housing authority in Missouri to be approved for the HUD Rental Assistance Demonstration (RAD) program, State low-Income Housing Tax Credits will be necessary for the Columbia Housing Authority to complete the process of renovating and preserving all 719 units of their public housing stock.

I urge you to please reconsider your decision not to allocate State Low-Income Housing Tax Credit funding for the 2018 funding cycle. These funds represent a critical investment in our state and our community.

City of Kansas City – Mayor Sly James Sly James, Mayor Kansas City, MO

Remarks made Friday, December 1, 2017

Thank you for this opportunity to speak. I am Mayor Sly James of Kansas City, Missouri. I know firsthand that we as policy makers have to make difficult decisions every day in allotting scarce dollars and resources. And, I understand that state policymakers face similar challenges. But the move to completely eliminate the State Low Income Housing Tax Credits from annual funding was misguided.

Thousands of people on affordable housing waiting lists across Missouri will pay the price. In Kansas City, we have an estimated 24,000 low-income households in need of affordable housing. These are our most vulnerable Kansas Citizens• veterans, persons with disabilities, seniors, and children who are in need of safe and reliable housing.

We know that housing stability leads to better health outcomes, improves children's school performance, promotes employment and economic wealth. Over the past ten years, the MHDC and the City have worked to address this need, creating 1,846 units of affordable housing.

Missouri Housing Tax Credits have been integral to these efforts, providing $112 million in equity. An average of $11.2 million per year. In Kansas City we've found great success thanks to these tax credits, resulting in the new St. Michael's Center and Housing development, which provides our veterans with social services and housing.

Elderly units throughout the metropolitan area that provide low income rents for the growing senior population units that permanently house our disabled and homeless families and individuals while the MHDC, City, and nonprofits have partnered to alleviate the growing need, there is still a need for affordable housing and limited resources available. There are still over 10,000 households on the waitlist for the affordable housing through the Kansas City Housing Authority. That's 10,000 Kansas City families who are still without a safe place to live. Without the state's low income housing tax credits, that number will be much worse.

Opponents of the state's Low Income Housing Tax Credits argue that the program is inefficient. But in Kansas City and other places across the state, we know that this program is working. And, it's generated jobs ... In Kansas City's East Side, developments utilizing low income housing tax credits have created more jobs in any area of the City in dire need of economic opportunities.

And, most importantly, state low income housing tax credits have resulted in more affordable housing across the state. So if those opponents still find inefficiencies, then find ways to make the program more efficient. Fix it.

Leaders solve difficult problems. But I don't see much leadership in completely eliminating a program that helps thousands of Missourians survive without offering any true replacement. Grants and forgivable loans are more burdensome to the state, requiring the state to provide the money up front, rather than gradually reimbursing developers through tax credits. They are also subject to higher tax rates for the beneficiaries, ultimately lessening their impact.

Eliminating these state credits will undo critical work by the State, the City, as well as the development, labor and nonprofits communities serving Kansas City's most vulnerable residents.

I'd like to defer the rest of my time to the many others representing affected stakeholders also here to speak about the impacts on Kansas City: representatives from Restart, LISC, St. Michael's Veterans Center, and the Kansas City Housing Authority, residents of our low income housing developments, educators, health officials, and many more.

Columbia Housing Authority Phil Steinhaus, CEO 201 Switzler Street, Columbia, MO 65203

The Columbia Housing Authority (CHA) is the first and only housing authority approved to participate in the HUD Rental Assistance Demonstration (RAD) program and has undertaken the monumental task of renovating and preserving our 719 units of public housing stock. The RAD program allows the CHA to convert our unstable operating subsidies to a stable 20 year contract rent using Project-Based Vouchers.

For the Columbia Housing Authority, the loss of the state LIHTC funding puts our plan to complete the renovation and preservation of our aging public housing properties in jeopardy. To date we have renovated 360 public housing units and constructed the Patriot Place Apartments. Oak Towers is currently under construction (147 units) and we are getting ready to renovate the Bryant Walkway Apartments (54 units) and Bryant Walkway II Apartments (36 units) in January. Once these are complete the CHA will have renovated 597 public housing units and created 25 new apartments for homeless Veterans. All of these projects would not have been possible without state and federal LIHTC funding. Removing the state LIHTC funding from the equation will result in less affordable housing in our community and across the state. The following is a chart of our RAD renovation phases.

Public Housing RAD Renovation Phases

Rehab Submission Construct Complete Phase Public Housing Sites Type & # of Units LIHTC Level Date(s) Start Date

Stuart Parker Apartments 84 Townhomes Major 1 4% 05-2014* 01-2016 10-2017

Paquin Tower 200 High Rise Units Minor

2 Bear Creek Apartments 76 Town homes Modest 4% 09-2014* 06-2016 10-2017

3 Oak Towers 147 High Rise Units Modest 4% 09-2015* 01-2017 05-2018**

4 Bryant Walkway Apartments 54 Townhomes Major 9% 09-2016* 01-2018 07-2019**

5 Bryant Walkway II Apartments 36 Town homes Major 4% 09-2016* 01-2018 07-2019**

6 Providence Walkway Apartments 50 Townhomes Major 9% 03-2018 01-2019 07-2020

7 East Park Avenue Apartments 40 Townhomes Major 9% 09-2019 01-2021 07-2021 t

8 Fisher Walkway Apartments 30 Town homes Major 9% 09-2020 01-2022 07-2023

* Proposals were funded. ** Estimated completion date.

The Federal and State Low-Income Housing Tax Credit programs, with private market oversight, have proven to be an efficient and effective alternative to previous government operated housing programs. In Missouri the Low-Income Housing Tax Credit program has done a better job of producing quality affordable housing in a more cost effective manner than government operated housing programs.

In 2015, the City of Columbia launched a three-year strategic plan to address social equity issues with a strong focus on income inequities in our community. Now in the second year of the plan our community has had great success in addressing these issues and reducing poverty in our community. Affordable housing is a necessary and critical resource for helping people break the cycle of poverty.

The City of Columbia’s Consolidated Plan documents a significant number of renters who are rent burdened and paying more the 50% of their income for rent. State Low-Income Housing Tax Credit funding is an essential resource in eliminating rent burdens on families and individuals which in turn helps to' support them in their efforts to break the cycle of poverty and become self-sufficient.

The Columbia Housing Authority has made significant investments in renovating our public housing stock as well as providing numerous resources that support our families as they work toward Family Self• Sufficiency and independent living. With an annual budget of over $1,000,000, our 501(c}3 nonprofit, CHA Low-Income Services, Inc. provides supportive services with three overarching goals:

• Helping Children and Youth Succeed in School and in Life • Supporting Families Working Toward Self-Sufficiency; and • Enabling Seniors and Persons with Disabilities to Live Independently

As you can see, the investment of State Low-Income Housing Tax Credit funding in our community is complements by a significant investment in supportive services by the Columbia Housing Authority and our greater community.

Columbia Love INC Kelli Van Doren, Extra Mile Coordinator 1516 Business Loop 70W, Columbia, MO 65202

I am unable to attend the public hearing on December 1but I want to request your support for state LIHTC funding to create affordable housing.

Love INC, our organization works with people in poverty in Columbia. Affordable housing is one of the main things that we assist people in obtaining and remaining in. Many of our clients are spending half of their income or more on housing and utilities. It creates such a challenge for them to be sustainable and independent.

I oversee a four month budgeting program called Extra Mile that matches volunteers with clients. I have seen several Extra Mile families obtain affordable housing through the Columbia Housing Authority. Two of them were placed in the newly renovated Bear Creek housing. These families are really thankful to have a safe, affordable, pleasant and inviting place to live. Tax credits have helped the Columbia Housing Authority make much needed improvements to their aging facilities.

Con-Tech Carpentry Craig McPartlin 366 W. Fourth Street, Eureka, MO 63025

Dear Governor Greitens:

My name is Craig McPartlin and I have lived in the St. Louis community for twenty years. I am the President of a locally owned Construction company that has partnered with tax credit developments in our community. These developments are very desirable to Missouri communities due to the economic activity that is stimulated by the creation of construction jobs and the generation of tax dollars from labor and material.

Our company, Con-Tech Carpentry LLC, sub-contracted with Fairway Construction and are proud to have helped provide homes for low to moderate income seniors and families.

As an important part of our local economy, I urge you to move forward with the State Low Income Housing Tax Credit program as adopted by the Missouri legislature many years ago.

For every 100 units built in a typical tax credit development, 122 local jobs are created in the community. Since 1986, the State Low Income Housing Tax Credit program has provided roughly 7 million homes to low-income families, seniors, veterans and people with disabilities who could otherwise not afford quality housing.

Over 18o,ooo Missouri households spend more than half of their monthly income on rent. What remains of their income is not enough for other expenses, such as health care, transportation and nutritious food.

Thank you for your consideration.

Craig McPartlin Con-Tech Carpentry LLC

Con-Tech Foundations Ronald Behrmann 366 W. Fourth Street, Eureka, MO 63025

Dear Governor Greitens:

My name is Ronald Behrmann and I have lived in the St. Louis community for 45 plus years. I am a Partner of a locally owned Foundation company that has partnered with tax credit developments in our community. These developments are very desirable to Missouri communities due to the economic activity that is stimulated by the creation of construct i on jobs and the generation of tax dollars from labor and material.

Our company, Con-Tech Foundations LLC, sub-contracted with E.M. Harris and Rubicon Corporation just to name a few on the Fairview Estates, Hillsdale Manor and Hillsdale Homes projects and are proud to have helped provide homes for low to moderate income seniors and families.

As an important part of our local economy, I urge you to move forward with the State Low Income Housing Tax Credit program as adopted by the Missouri legislature many years ago.

For every 100 units built in a typical tax credit development, 122 local jobs are created in the community. Since 1986 the State Low Income Housing Tax Credit program has provided roughly 7 million homes to low-income famil ies, seniors, veterans and people with disabilities who could otherwise not afford quality housing.

Over 180,000 Missouri households spend more than half of their monthly income on rent. What remains of the i r 1 income is not enough for other expenses care, transportation and nutritious food.

Thank you for your consideration. Sincerely,

Ronald Beh rmann Con-Tech Foundations LLC

Con-Tech Insulation Harrell Henson 366 W. Fourth Street, Eureka, MO 63025

My name is Harrell Henson and I have l lived in the St. Louis community for 40 plus years. I am a Partner of a locally owned Insulation company that has partnered with tax credit developments in our community. These developments are very desirable to Missouri communities due to the economic activity that is stimulated by the creation of construction jobs and the generation of tax dollars from labor and material.

Our company, Con-Tech Insulation LLC, sub-contracted with several Contractors in the area and are proud to have helped provide homes for low to moderate income seniors and families.

As an important part of our local economy, I urge you to move forward with the State Low Income Housing Tax Credit program as adopted by the Missouri legislature many years ago.

For every 100 units built in a typical tax credit development, 22 local jobs are created in the community. Since 1986, the State Low Income Housing Tax Credit program has provided roughly 7 million homes to low-income families, seniors, veterans and people with disabilities who could otherwise not afford quality housing .

Over 8o,ooo Missouri households spend more than half of their monthly income on rent. What remains of their income is not enough for other expenses, such as health care, transportation and nutritious food.

Thank you for your consideration,

Harrell Henson Con-Tech Insulation LLC

Boone County Family Resources Robyn Kaufman, Executive Director 1209 East Walnut, Columbia, MO 65201

Boone County Family Resources supports over 1600 individuals with developmental disabilities to thrive in the community, connect with others and achieve their personal goals-including the goal of having a home of their own. However, many struggle to meet this goal due to the shortage of affordable, accessible housing in our community.

A national report on the Housing Crisis for People with Disabilities stated the average rent for a one-bedroom apartment in Missouri cost 81% of the monthly SSI income of a person with a disability. Bringing it to a local level, the City of Columbia's Consolidated Plan stated that over 5,000 single persons in our community spend over 50°/o of their income on housing costs. The wait list for an affordable 1-bedroom apartment in Columbia can be as long as 5 years and accessible apartments are even more limited. While these statistics alone were a call to action, knowing the personal stories of persons with disabilities in our community gave Boone County Family Resources the passion to be part of the solution.

We were very fortunate to be awarded state and federal Low Income Housing Tax Credits from MHDC, which made the development of Boone County Special Needs Affordable Housing, known as Boone Point Apartments, possible. Boone Point Apartments include two new apartment buildings, located on sites in Central and Southwest Columbia that provide 28 affordable, universally designed, energy-efficient apartments for people with disabilities or others with special needs. 24 of the apartments are 1-bedroom units.

The new apartments are fully occupied and the positive impact Boone Point Apartments have made in the lives of our tenants has been heartwarming.

Fleming, Glenna LIHTC Resident Springfield, MO

Heaslet, Alice Beacon Village Resident

Heidgen, Rebecca LIHTC Resident

Hocker, Tierney LIHTC Resident

My name is Tierney Hocker. I am the single mother of 2 boys. 9 yrs. and 12 yrs. We live in a low income housing complex. Without this place to live we would be homeless. I do not get child support. I barely get help of any kind. I do have a full time job but I do not get paid by the hour. I work off of commission. Without low income housing, my son’s and I would be homeless. We need the low income housing because not everyone can pay $500 plus a month.

Please do not get rid of low income housing.

Hodges, Annete Property Manager Sedalia, MO

To Whom It May Concern:

As a property manager for an LIHTC property, I take phone calls every day from Missourians looking for affordable housing. I have to turn these people away as I have a waiting list with over 30 people on it. This is one year after we opened up 36 more apartment units, where we had 130 on our waiting list.

These Missourians are senior citizens and veterans, some whom have shown up at my office while living in their car.

The need for affordable housing in my area alone (Sedalia MO) is great. Every LIHTC property in town has a waiting list.

I have had these Missourians set at my desk and cry because they can-not afford market rent, which in our area is an average of $800 a month. Some of these people only receive a social security check of $800. They are not asking for handouts. These are people who worked all their lives, our elderly and our most vulnerable and who served our country and are known as the "greatest generation". We owe it to them to take care of them, like they did us.

LIHTC has a rippling effect. The jobs it creates helps our economy from the construction workers to the vendors we hire to help keep up our properties. LIHTC is a needed program in our state.

Sincerely,

Annette Hodges 2608 Highland Sedalia, MO 65301

Housing Authority of Kansas City Kansas City, MO

Transcript of Comments Provided at the MHDC KCMO Public Hearing on the 2018 LIHTC QAP

The mission of the Housing Authority of KCMO (HAKC) is to revitalize and increase affordable housing in Kansas City, Missouri. In order to expand housing choice and opportunities for families, HAKC has reduced the concentration of public housing in the central city and created housing in all nine school districts that serve KCMO.

HAKC has utilized a variety of public and private financing tools, and partnerships with private developers to create new housing. Over 2100 units of new or rehabilitated housing have been completed over the last 20 years with a total investment of over $200 million.

Mixed-income housing has proven to be a successful model. These sites include public housing, LIHTC qualified, and market rate units. Unlike public housing, these sites are privately owned and managed. And unlike public housing, they look like and include the same features as market rate apartments.

To date, HAKC and its private development partners have been awarded LIHTC for eleven sites. LIHTC has helped these sites leverage a total investment of $87,000,000 in private investment.

Some of HAKC's LIHTC developments address special populations like the elderly, grand-families, and formerly homeless households. The State and Federal LIHTC program has been an essential tool for our redevelopment of the Paseo Gateway District. It helped leverage our $30,000,000 HUD Choice Neighborhoods grant.

State LIHTC has been a critical tool in filling the financing gaps. Affordable housing development poses unique financing challenges due to low rental income, federal construction requirements, and environmental issues. The LIHTC program is a proven model for addressing these challenges.

With millions invested in each LIHTC development, developers and private investors have a substantial stake in the success of each site. If a State grant or low interest loan program is substituted, the State will be taking back a large portion of risk currently born by the private sector.

The National Association of Home Builders (NAHB) found that every 100 units of apartments created under the LITC program supports 113 jobs for a year in a broad variety of services and small businesses.

Unintended consequence - eliminating the State LIHTC program will likely result in fewer proposed sites in suburban areas with greater employment and educational opportunities. Developers will seek to stretch the federal credits to make up the gap, and will be more likely to select sites in Qualified Census Tracts (QCT) which provide an extra 30% in LIHTC basis. QCT's are concentrated in inner cities.

The great need for affordable housing for the poor and special needs populations has certainly not lessened during the recovery as rents continue to increase. The HAKC combined waiting list for public housing and Housing Choice Vouchers currently stands at over 12,000 households.

We respectfully urge the Commission to reconsider the proven track record of the State LIHTC program, and to carefully consider the impact its elimination will have on the development of affordable housing in Missouri.

Hudson, Pamela St. Louis, MO

MHDC

My name is Pamela Hudson. We are clearly in need of “affordable” homes. It is very hard to pay high rent plus utilities, food, clothing, etc. I have worked all my life paying “high” rent to live in a nice home but eventually the bills began to overwhelm me. Now that I’m a Senior I personally NEED Affordable Housing (Rent) as well as others.

The State Tax Credit Program Should Not be cancelled. WE also need more affordable homes built throughout St. Louis City and County. I am comfortable and feel safe being in an affordable home.

Today in more at peace and happier.

Thank You

Pamela Hudson

James, Amanda

To Whom It May Concern:

I am writing today to urge the Missouri State Legislature and our executives to increase funding for low-income housing in Missouri.

As a tenant in a residential area which receives government assistance; I have seen firsthand the need for available housing for lower income families. In today's world, most families can only survive on more than one income. However, this most often is not sufficient to provide safe, stable housing for their children. In areas lacking available, cost-efficient homes, parents are forced to make choices they’d likely rater not make. Food over medicine over warm clothing; and unfortunately other needs over proper housing. I ask our politicians to please give weight to the choices that the hard-working citizens of Missouri face every day. Please help provide a viable option in housing for families who live at, or below, the poverty level in our state.

I thank you for your time and consideration in this matter, and hope that one day the great “Show Me’ State will be an example to other areas of our nation as to how best to provide for and nurture our citizens.

With Sincerest Regards,

Amanda James

Kelley, Ruthie Property Manager Springfield, MO

MHDC:

I currently manage three properties that fall under the Tax Credit program in Springfield. I was very disheartened to learn that, along with Governor Greitens, have voted to stop utilizing these tax credits to fund affordable housing. I spoke to my residents regarding this decision and the first question each asked was, "why?"

I didn't have a ready answer for the why of this, nor do I now even after thinking about it for a couple of days. What I have thought about in trying to come to a decisive answer was the faces of my resident's ' when I first showed them their new homes. The look of sheer joy on their faces when they turned the key to their new home and got their first look inside is simply indescribable. The bear-tight hugs that I received in return to show their happiness and gratitude for now having a home that they felt secure in are priceless.

I did a lease up this year on a new 55+ community in Springfield. I met every resident that was going to live on that property and had conversations at length with each person. I can tell you everything about each person that now resides there. None of those stories started very pretty. One story in particular stays with me, a Mom and her adult disabled son that were living in a trailer with very little exist ing floor making the ground visible through much of their home . There was mold everywhere and more safety issues than they could count. The Mom was very nervous through the entire application process as she stated over and over that she just didn’t want to get her hopes up that something this good could happen to them. This good. This good meaning a nice home with a floor, a working kitchen and bathroom, and the feeling of security. This family had not been afforded that luxury in many years as they simply did not have the means to afford it. When I called to tell her they were approved to move in, she cried and cried on the phone. When I handed her the keys to let her unlock her new home, she fell to her knees and thanked God upon walking through the door.

I've watched homeless persons weep walking through their new apartment just happy to have a stable, secure roof over their heads, single mothers hug their babies tight and whisper "we're okay now" into their tiny heads, formerly homeless women telling me the horror stories of living on the streets and how grateful they are for their home, low income families being able to buy their kids school supplies and new shoes instead of feeling ashamed that they could not, that they had failed their children.

These properties make these events possible. They make people feel secure, it gives them safety and most importantly, it brings hope. Do not take this hope away as any answer to the question of "why" cannot be better than the feeling of being able to provide for yourself and your family. Tax Credit make this possible.

Thank you for your consideration,

Kirksville Gardens LIHTC Resident Kirksville, MO

To Whom It May Concern

I am writing to explain how beneficial Low Income Housing has been to me.

6 years ago, my husband left me. I had been doing in home daycare in our home for 7 years and was not out in the work force. Due to this change in my life, I was forced to find work outside the home and because of my being out of the work force so long, could only find part-time work. This left me in a huge hole because I was left to cover a house payment and all of the utilities on a part-time income. I was struggling and I knew that I needed to find an alternative to our situation to keep a roof over my childrens’ head.

I was told about low income housing, specifically the Kirksville Gardens units. I was hesitant at first because of what people think when they know you live in low income housing but I didn't have a choice. I was relieved to find out that it is based on your income and not a set amount like a house payment or a normal rental unit would require. I was able to lower my burden of a house payment that I couldn't afford and sleep better at night knowing that I was able to provide my kids with a nice, safe environment that I could afford and still be able to pay for all the extras like utilities, food and clothing.

It was truly a life saver for me. My children were able to have their own rooms like before and although we downsized quite a bit, I was able to try to keep some kind of normalcy like before in their lives. I don't think that I could of kept a roof over my childrens’ heads without this housing opportunity. I currently live in a 3 bedroom 2 bathroom unit...without the availability of low income housing, to find something comparable to that would cost me $900-$1200 dollars a month and may not even be in a safe neighborhood.

I think that this opportunity should stay available to those who truly need it. So many people struggle for different reasons and people like me who were struggling and clearly didn't know what the next day was going to bring them, had a door opened to them when this option became available. It is not a hand out or something to be ashamed of...it is clearly a solution to help those who need the help no matter what the reason.

LISC Greater Kansas City Stephen Samuels, Executive Director 600 Broadway, Suite 280, Kansas City, MO 64105

Local Initiatives Support Corporation (USC) has been investing in the state of Missouri since 1981. We are one of the largest and most prominent community development support organizations in the country. It is because of affordable housing tax credit programs that we are able to leverage public and private capital to house thousands of families who deserve the right to a quality home and a life of economic opportunities.

USC has invested nearly $164 million in Missouri, a combination of grants, loans and equity investments. 4,270 homes and apartments were constructed as a result of these investments, and nearly all of them were financed using state and federal low Income Housing Tax Credits and Historic Tax Credits. If it weren't for tools like these, I am certain these projects could not afford to have been built.

Missouri has long assisted seniors, veterans, low-income families and the disabled with safe, quality affordable housing to remain productive and independent. Between 1986 and 2015, over 167,000 households were provided housing with this incentive program. The program has provided rents that are reduced by an average of $288 month for elderly and disabled people, and the demand only grows. Today, the St. Louis City, St. Louis County, and Kansas City Housing Authorities waitlists range from 4,000-15,000 people. In Missouri, a minimum wage worker has to work 76 hours per week in order to afford a modest one-bedroom apartment.

On behalf of USC's staff, Board, and the communities we serve, I strongly urge you to continue the low income housing tax credit program. Families across the state will be healthier and more productive, neighborhoods will be safer, and our local economies more resilient.

LRG Consulting and Development Inc. Lela Gruebel Kanas City

If the QAP as revised under the Crowell QAP is approved later this month, it will destroy a program that has provided housing to many of Missouri's most vulnerable citizens. The number of affordable housing units built and preserved will collapse and rents will skyrocket. This goes against the mission of MHDC to strengthen communities and the lives of Missourians through the financing 1 development and preservation of affordable housing.

According to the 2016 Poverty Report there were just under 950,000 Missourians living at or below 100% of the poverty level and over 400,000 living at the extreme poverty level (30% AMI). To put this into perspective an individual earning $11,490 in 2016 was living at the poverty level. With many disabled and seniors on fixed incomes of $788 per month or $9,456 annually they fall into this category. Based upon these income levels an individual paying 30% of his income in rent could pay no more than $236 per month. When you consider that it costs us over $350 per month just to operate these units with taxes, insurance, repairs, maintenance and salaries with no debt on the property we are fighting a losing battle.

To lose the State Credit would cause the number of units built to decrease, the rents to skyrocket, and the extremely poor would be left out in the cold as developers would be forced to target those at the highest LIHTC income levels just to make the deals work. The special needs supportive services would be eliminated ending the ability to serve these individuals. Without access to affordable housing and the stability it provides, it becomes increasingly difficult to introduce a system of home and community based supports to families in the community.

While Missouri's LIHTC program may need some modifications, it would be better than totally doing away with the program. These modifications while supported by the Commissioners should be made by the legislative body that created the program to begin with. The LIHTC program is a hand up, not a handout. They are not free, but do reduce rents for the elderly and disabled people who would otherwise be unable to afford an apartment.

Furthermore, it is a misconception to say that 42 cents goes to the project and the rest is profit. The pricing for the State Credit has continually increased over the last ten years. For example: On a current development if you take 15 cents for overhead (Governor Greiten's Non-profit uses 13 cents) you would be at 85 cents pricing. Based upon the equity, if you calculated the interest rate on the 85 cents with a repayment schedule of 13 years, it would equate to 6.25% return on investment (interest if this were a loan). However the notion of the state granting or loaning the money is not an efficient strategy. As a grant if the state substituted $140 million annually for the credits, they would have to come up with this money up front creating a huge short term fiscal note. In addition, the existing outstanding credits would only be reduced by $14 million annually over the next 13 years.

I personally know of at least one individual who came out of a nursing home to live in a LIHTC property. She is paying her LIHTC rent and saving the state over $27,000 in nursing home costs. Without this program she would have to stay in the nursing home.

I urge the commissioners to reconsider this move to eliminate the state credit and instead work with the legislature to improve the credit.

Locke, Paula Senior Resident

My Name is Paula Locke....l am writing this, as I would like to make my thoughts about LIHTC be known. I think it is a wonderful program, and yes I live in a UHTC property. My husband and are both disabled, and make very little on disability and 551. Between the two of us, we make less than $1500 a month. That is supposed to be for rent, food, medicine, Dr. appointments, utilities, and transportation. That isn’t very much for two individuals to live on and try to find a decent place to live, without having to turn to scum lords. That is where the LIHTC properties come into view. If it were not for this wonderful program, my husband and 1 would have to live out on the streets and be homeless. That is another factor for the LIHTC program, as they make rent affordable for some of the homeless people to be able to have a decent life. Some place warm and to be able to call home.

From my understanding, the reason this was voted on and turned down, is that the government seems to think they are getting ripped off by this program. I say it is to the contrary ....Lots of taxes coming in....from the person who decides to build....from the person who is contracted to build.....from the construction crew who builds.....and from the plumbers and electricians who also work on the services for the project. You are getting taxes from the materials that are being bought, you are getting taxes from each and every person working, and you are also getting taxes from the companies involved. And of course you are also getting taxes from some of the citizens that live in the communities that the UHTC has made possible.

You may not think this program is perfect, but that is no reason to just scratch it completely. Come up with a few different ideas of how to improve it. And if you can’t come up with anything, maybe a suggestion would be, take a month or so and live in our shoes. No big check to line your pockets....no fancy car....no fancy clothes....no Red Lobster every other night...... no thousands of dollars, maybe even millions of dollar houses...... just a nice place in a LIHTC property. A place where you can have a roof over your head, have nice appliances, and utilities like heat and air, and running water. Try to make ends meet with very little money.

Feel the full experience. Heck, maybe work your way up....maybe Jive out on the streets for a while, while having very little income. Maybe even stand on the street corners asking for money just so you can have a meal for the night, and be sure that you can maybe get into some kind of shelter for the night, but be sure to have a cardboard box or a tent just In case.....see how that is for the homeless people...Then work your way up, try to find affordable housing with a very limited income....try to stay away from the scum lords though. Then try to live in a LIHTC property. Live there for a bit. Then maybe, just maybe, you will understand what the LIHTC program means to those that are low income, disabled and elderly.

LIHTC program is not all about drugs users and drunks. We have lived in LIHTC properties for the last 5 1/2 years, in that time I have experienced possibly one or two families that would fall into that category. We are talking about very nice properties that are being built for the good of the lower income families. These places aren't ridden with scummy lower income fa miles either. Most have worked for what they have now....not sat on their butts taking handouts. I don't see the LIHTC program as a handout....but a hand up!!!

There may be some flaws that you might be able to see.....if that's the case.....don't nix it....fix it!!!!! And I am sure, until you are truly in someone's position, like myself, then I believe you should leave well enough alone, and let those that are trying to do a wonderful thing, to continue with what they are doing!!!!! Take a step back, look at those that are reaping the rewards of this program before you decide to ruin the future of those that truly need the help of the LIHTC program.

A truly low income, disabled individual who truly appreciates the UHTC program,

Paula Locke

Martin, Malu and Donald Senior Resident

McCamon, Rose Faith Beacon Village Resident

Dear Governor Greitens,

The City of Springfield, MO and general area has a great need for low rent residences, i.e., apartments. We have had a large number of homeless people, and still have; people who lost their homes in the last few years due to the economy, and a lot of families and seniors who do not have enough income to afford pricey residences.

I found myself, a disabled senior, no longer able to obtain the level of employment that could help me pay to live in a clean, reasonably priced residence in a safe area of the city. I now live in one of several duplexes built in Springfield by those people who represent The Kitchen, called Beacon Village. I am very thankful for this opportunity; especially because I was unable to find a reasonably priced senior living residence that I could afford the rent. As it is, my financial situation is such that should I encounter a temporary financial hardship I could lose the apartment I have come to call home.

Governor Greitens, eliminating the Tax Credit for these companies who help Missourians be self-sufficient, especially those who are non• profits, is a bad move for Missouri. We need to have more concern for the poor. Yes, we will always have the poor with us. For many reasons not everyone can become well-to-do or rich during their productive years.

Please help those companies who are building rental facilities so that the people I have mentioned above can obtain a decent, reasonably priced, rental residence and keep themselves and their families off the streets.

I do not know if you are a believing Christian man, but I have noticed that in scripture when Israel's wealthy and powerful turned their hearts away from the poor, the very young, and the elderly- it appears to be the breaking point at which they then fell into the hands of those who brought about their destruction. God intends those who He blesses with much should in return bless others with mercy.

Everyone deserves an affordable place to live in our America. Please re-think removing the Tax Credit from Missouri.

Thank you for your kind attention to this matter,

Rose Faith McCamon [email protected]

I am a voting Republican

Missouri Mayors

Missouri Senate - 19th District Caleb Rowden, Senator State Capitol Office Room 433, 201 W. Capitol Ave., Jefferson City, MO 65101

As you consider the future of Missouri's Low Income Housing Tax Credit (LIHTC) program; I ask that you consider the incredible benefit LIHTC credits have brought to my community, Columbia.

The Columbia Housing Authority (CHA), of which I have been a strong advocate, serves nearly 2.000 families in Boone County and operates over 700 public housing units. Missouri's LIHTC program has empowered CHA to repair and renovate over 600 of those units-some of which have been occupied since the 1960s. These critical upgrades have created safe, accessible, energy-efficient homes for our most needy neighbors while delivering long-term value for taxpayers.

Missouri's LIHTC has been an invaluable resource that allows my community to keep families in stable housing and keep seniors and individuals with disabilities living independently. Stable, affordable housing keeps families together, keeps kids in school, improves educational outcomes, keeps seniors healthy and active, offers an independent life, of dignity and purpose, and drives economic growth.

In addition to traditional public housing stock, Missouri's LIHTC made it possible for the development of Patriot Place- a community for low-income veterans. As the home of the Truman V.A. Medical Center, Columbia has seen an increase in veterans struggling to avoid homelessness. Patriot Place was a joint venture between CHA, Welcome Home Inc., the Veterans Administration, and numerous private donors-this project brought low income housing, temporary homeless housing, a V.A. service center, and other services together to serve our veterans Patriot Place is indicative of a community that is thinking outside the box to deliver the most value to taxpayers and to those in need.

Missouri's LIHTC program is not without flaws-improvement must be a continuous process and is in the best interest of all Missourians. However to scrap the program entirely, and without consideration of the human cost, would be detrimental to my community and thousands of families who are looking to us for a helping hand.

I appreciate your time and your consideration on this very serious matter.

Scherrie Mones LIHTC Resident

People First of Boone County Jeff Johnson, President 1209 E. Walnut, Columbia, MO 65201

People First of Boone County is a self-advocacy group for people with disabilities. We were saddened to hear of the decision to eliminate the state portion of Low-Income Housing Tax Credits. The need for affordable, accessible housing in our community is severe, especially for people with disabilities. Also, there are public housing units in our community that are aged, needing renovation. LIHTC funds would help meet those needs.

We have seen lives change when affordable housing becomes available to people with disabilities. People we know who were used to spending most of their income on housing recently moved into LIHTC-supported apartments in Columbia. They can now afford not only their housing, but also things others take for granted, like getting a haircut, or buying a birthday card for their mother.

We do not feel LIHTC is a failed program. We do feel that eliminating it hurts those who do not otherwise have access to decent, affordable, accessible housing. We support the Columbia Housing Authority's plan to renovate aged housing units in our community, and we applaud them and agencies like Boone County Family Resources for their new housing projects for people with disabilities, including disable veterans. LIHTC helps make good things like that happen.

Perry, Claudia LIHTC Resident

Putmon, Randy and Linda Beacon Village Resident

reStart Evelyn E. Craig, MA, CFRE, President and CEO 918 E. 9th Street, Kansas City, MO 64106

Thank you for the opportunity to participate in the Public Hearings and to provide Written Comments on the Modifications to the 2018 Qualified Allocation Plan for administration of low Income Housing Tax Credits . reStart. Inc. hereby submits the following comments in response to the proposed modifications:

1. We believe that the Commission's decision NOT to allocate state low-income tax credits is not only short- sighted but potentially tragic. State low-income tax credits have been a primary source of gap funding for housing developments in Jackson County's most distressed neighborhoods for our most vulnerable populations- seniors, the disabled, Veterans, working poor families and young adults transitioning out of the foster care or other systems.

2. Twenty-eight LIHTC projects in Kansas City alone over the past ten years have accounted for 1,846 units of permanent housing- the foundation of individual and community development and stability. reStart is grateful to the Commission for support of two LIHTC developments Rose Hill Townhomes and Woodbridge Apartments for which we are the lead referral agency. Thanks to the utilization of state tax credits as well as federal, more than 50 formerly homeless families are creating better futures for their children- who will, in turn, create a better future for our State.

I appreciate the opportunity to submit comments. I welcome visits at any time from anyone associated with MHDC to witness first-hand the good that state tax credits have accomplished for our fellow citizens.

Please feel free to call me at 816.472 .5664 ext. 252 should you wish to discuss this further. Thank you for your time and consideration.

River City Drywall and Painting, Inc.. Nick Flinn 1011 Cool Springs Industrial Drive, O’Fallon, MO 63366

Dear Governor Greitens:

My name is Nick Flinn and I have lived in the St Louis area all my life. I am a senior estimator with River City Drywall and Painting, which is a small family-owned business with roughly 80 employees. River City was established in 1993 in St. Charles, MO. We focus mainly on residential construction.

I am writing you to stress the importance of the State Low Income Housing Tax Credit. I, like many young men and women, started my construction career right out of high school. I put myself through college as a drywall finisher, and eventually worked myself into management. I have seen both sides of construction since I began my career, spending many years working in the field and now ten years in the office . I have worked first hand on many of the projects that the Tax Credit helped fund. These projects have been extremely impactful on the communities in which we live on many different levels. For our field employees, these projects provide steady paychecks, allowing them to support and grow their families. For people like me in management, they provide a revenue stream to help our small business grow. Our most recent project, Hillmann Place was near our office in O'Fallon, MO. It is a multi- resident community for low income seniors. This project alone generated close to 4,000 hours for our employees and their families.

I urge you, Governor Greitens, to consider both the communities that benefit from the construction of these projects as well as the working families who are supported by them.

Please allow the Tax Credit Program to continue. Allow our senior citizens the housing they need. Allow small businesses like ours to grow. Allow our employees to continue to work and support their families.

Sincerely, Nick Flinn

SCIL Karen Burnell Ruff, Director of Policy and Advocacy 2864 S. Nettleton Ave., Springfield, MO 65807

As a Center for Independent Living (CIL) in Southwest Missouri, SCIL provides services and supports to individuals with disabilities that help them to live and thrive independently in our community. Our mission to promote a barrier- free environment for all individuals with disabilities through public education and advocacy for social change, while providing independent living services to assist in meeting their goals for independence.

As a CIL we are federally mandated to offer the following five core services: • Information and Referral • Independent Living Skills Training • Peer Support • Advocacy o Individual o Systems • Transitions o From high school to work force or higher education o From Institutional care back into community

Quality, affordable, and accessible housing is fundamental need for all, regardless of your ability. However, barriers may be higher for those friends with disabilities that often have lower incomes and lack resources for support. SCIL staff report that they receive on average 15-20 calls per week from individuals seeking assistance to identify affordable housing. Our Independent Living Specialists connect them to the resources and assist them through the application process as-needed. This demonstrates a clear and absolute need for the housing projects developed through LIHTC's. We urge this commission to reconsider the value and benefits this program brings to ensure access to vital, quality housing that is not out of reach. We suggest that there are alternative ways to reform without an all or nothing approach. We ask that you listen to consider and refrain from zeroing out the state portion of the LTHTC.

The need for the disability community for housing that is universally designed to include ground floor units and roll- in showers that is affordable is non-existent outside of the Missouri LIHTC program. The 5% Fair Housing accessible minimum requirement are not filling the need for this type of housing.

Transition services often are slowed down due to lack of housing available. SCIL averages around 12 transitions from institutional care back into the community a year. In 2017, we assisted I3 individuals to gain their independence back.

SCIL is fortunate to work with several developers that build quality housing that is more affordable than market rate rental housing. Many citizens receiving Social Security Disability Income (SSDI), who have worked and paid into the system that do not rely on government assistance cannot even afford market rate rents. According to the U.S. Census Bureau American Community Survey 2010-2015 estimates, more than 60 percent of rental homes in Greene County are not affordable, meaning more than 30% of household income is spent on housing and utility costs. Families in this situation will have difficulty paying for necessities such as food, clothing, transportation and medical care. A single person working 40 hours per week at a minimum wage job in Missouri should spend no more than $400 per month on rent and utilities for a home to be considered affordable. Unfortunately, without the state tax credit, the rents would probably double, making it out of reach for those that need it the most. Many of the units at lower rents in this range outside LITCH developments are substandard and often less efficient with higher utility costs and unsafe dwellings;

We were pleased when MHDC adopted implementation of the MHDC requirements for Universal Design of housing for elderly and single family dwellings in 2015. It has played a significant role in removing barriers and expanding housing options for anyone regardless of their abilities. Market rate multi-family housing units include the minimal standards for accessibility, excluding and discriminating those that have physical disabilities that prohibit them from access. This is an achievement in housing that Missouri can be proud of to demonstrate forward thinking and innovations that leaves no one out.

Another important and vital benefit for consideration is the need for quality housing for our veterans. According to the U.S. Census, there are 24,000 veterans in Greene County, Missouri. Of those, 3,200 have a service connected disability at 13.3%. As we plan for a new Veterans Medical Center here in Springfield we are only going to grow in need for housing units for employees, veterans and their families that may choose to move to Southwest Missouri.

The need is apparent, and is not decreasing, but increasing with the retiring baby-boomer population at a rate of 10,000 per day. MHDC has done an outstanding job selecting and awarding quality projects that promote independence and inclusion that are affordable for seniors, veterans, and individuals with disabilities. It is not necessary to take an all or nothing approach to attempt to improve efficiencies in our state programs. More appropriately, may we suggest to look at what is working and what is not and make calculated changes to make the program better without eliminating the key components that add value to our communities.

We urge the Commission to reconsider taking an alternative approach and preserve what is working in the affordable housing program that rely on the state tax credits to maintain affordability.

Salvation Army Mark E. Abels, Chairman St. Louis Regional Advisory Board St. Louis, MO

Dear Commissioners:

I am writing in my capacity as Chairman of the St. Louis Regional Advisory Board of The Salvation Army to urge retention of the State Low Income Housing Tax Credit in the Commission's 2017 funding plan. Elimination of this program will bring to an end the most efficient and most effective mechanism for providing decent, affordable housing in our state. It will hurt thousands in our state in need of a helping hand to rebuild their lives.

Here in St. Louis in recent years, this program has enabled the Army to gut rehab our downtown Railton Residence to create more than 100 units of clean, affordable workforce housing ; to build our Veterans Residence on Locust Street, with 48 apartments that affords homeless vets the opportunity they need to restart and successfully rebuild their lives; and to build our 3010 Apartments on Washington Avenue, a gut rehab of the old Harbor Light shelter that exemplifies the "housing first" model of helping the homeless regain their footing and build news lives. None of these outstanding facilities would exist without the LIHTC funding program.

LIHTC is the realization of the dream of private sector solutions to societal problems that inspired President Ronald Reagan and Secretary Jack Kemp to create this approach 30 years ago. Those who criticize this program as a "welfare handout" would do well to remember that bit of history, and to recognize that this program is not a handout but a hand-up that provides benefits in exchange for the beneficiaries' commitment to live responsibly and pay the rent on time.

Please don't simply discard this important and effective program; to do so would be tantamount to discarding the lives of thousands.

Thank you,

Mark E. Abels, Chairman St. Louis Regional Advisory Board, The Salvation Army

Salvation Army – Finance Chairperson Bryan Lundstrom, CPA St. Louis, MO

Re: Support for MO Low-Income Housing Credits Dear Commissioners, I am writing as a Very concerned MO citizen to voice my opposition and alarm over the recent vote by the MO Housing Development Commission (MHDC) to eliminate low-income housing tax credits (LIHTC) for many in need of housing solutions in our community.

Our most vulnerable citizens including veterans, seniors, disabled, children and low-income families will be dramatically affected. This decision comes at a time when our population is aging, our veteran community size is rising, and disabled and low-income disadvantaged families and children living day-to-day on the margins of life continue to face a reduction of resources to give them a chance to be productive and independent.

For all of the vulnerable, housing represents the first and most important step toward a path towards dignity of life that all deserve. Many who benefit from the affordable housing these developments provide also have other significant challenges in their lives. Affordable housing, often times with on-site support from not-for• profit groups such as The Salvation Army allows for a total approach to helping those in need and reduces the government's costly delivery of services in other areas. Some of these successful projects include: 3010 Apartments for the disabled and low-income families, Veterans Residence for men and women vets, Railton for low-income persons and Booth Manor Senior Housing.

LIHTC is by far a much more efficient and risk averse way to build and maintain affordable housing than grants or forgivable loans. Grants have an up-front and immediate cost which has an extreme short-term fiscal effect along with 100% of the associated risk. Under LIHTC, the investors provide up-front and additional capital for the project. Credits don't flow if the units aren't built or leased under strict guidelines. Also they are recaptured if the project fails to be in compliance. Thus, the risk is held by the investors. This is significant given the fact that about 40% of projects that are approved do not get built or fall out of compliance.

I strongly ask you to please reconsider your decision and preserve the Missouri's Low-Income Housing Tax Credit for the good of the vulnerable in our State.

Sincerely,

Bryan Lundstrom, CPA [email protected] 314-401-9537 cell 10033 Harwich Drive St. Louis, MO 63126

Volunteer and Finance Chairperson of The Salvation Army

Salvation Army – Midland Divisional Headquarters Gary Busiek, Divisional Social Services Director 1130 Hampton Ave., St. Louis, MO 63139

Missouri Housing Development Commission:

First, thank you for the acceptance of my comments regarding the removal of State low Income Housing Tax Credits from the 2018 Qualified Allocation Plan. My name is Mr. Gary Busiek, Divisional Social Services Director of The Salvation Army Midland Division. We provide denominational and human services in 104 counties and City of St. Louis in the state of Missouri. I have directly and professionally overseen the development of affordable housing units for the populations we serve; since 2009 we have developed three successful permanent supportive housing projects. These developments would not have occurred without Missouri LIHTC.

To accomplish these developments I, along with the organization I represent, had to compete for the best project cost, the best project design, and the best project impact with the allowed Missouri LIHTC. To accomplish these developments we had to show evidence of habitability, marketability, and sustainability with the allowed Missouri LIHTC. And I, and the not-for-profit church and human service organization I represent, accomplished these developments without pocketing fees or project profiteering. Instead, we succeeded in using the Missouri LIHTC to develop affordable, decent housing for persons who are elderly, persons who have been homeless, persons with disabilities- medical and behavioral, persons who have served in the military, persons with low wage employment, and young persons aging out of foster care- persons who otherwise without LIHTC housing would cost Missouri and our society far more in other financial supports.

I, and the organization I represent, have used LIHTC to employ a higher than require number MBE/WBE businesses utilizing the Missouri LIHTC to pay small businesses transferring LIHTC into meaningful wages for hourly, non- exempt workers throughout the region. I, and the organization I represent, have used LIHTC to transform decaying buildings and vacant land into contributing and functional uses where none existed without the Missouri LIHTC. Moreover, the UHTC financed developments created with The Salvation Army and State of Missouri will continue for an affordable, common good use in perpetuity.

I am asking this Commission to reconsider your position to eliminate State low Income Tax Credits. I, and The Salvation Army, have worked in the area of LIHTC with Missouri Housing Development Commission since 2009 and Ihave worked with MHDC for most of my thirty-five years of human services in Missouri. During all that time I have long admired MHDC and taken Missouri pride in the leading role that MHDC has provided in ensuring housing affordability and availability for Missouri citizens. The Commission action to eliminate LIHTC from the plan is an unnecessary and harmful blow to this pride and to Missouri's successes in housing. As a lifelong Missouri resident and social service and housing developer, I urge you to reinstate LIHTC. We can work together to improve it but do not eliminate it. Missouri will fall backward without LIHTC.

Salvation Army – Midland Divisional Headquarters Lt. Colonel Dan Jennings, Divisional Commander 1130 Hampton Ave., St. Louis, MO 63139

Missouri Housing Development Commission:

Thank you for the opportunity to provide public comment for the record regarding the removal of State Low Income Housing Tax Credits from the 2018 Qualified Allocation Plan. I am Lt. Colonel Dan Jennings, Divisional Commander (denominational and organizational head) of The Salvation Army Midland Division. The Salvation Army provides denominational and human services in 104 counties and the City of St. Louis in the state of Missouri. Since 2009, when we first began use of LIHTC to develop affordable housing units for the populations we serve, we have developed three successful permanent supportive housing projects in Saint Louis City. Our current stock of affordable housing projects serves low-wage workers who would otherwise be cost burdened to live in safe modest housing, veterans of various comorbidities that had resulted in chronic homelessness and institutionalization, and individuals with special needs, including youth aged out of foster care, an often overlooked segment of our society.

I am concerned about the misrepresentation and criticism of whom low-income housing tax credits benefit. When you consider that 1) the current waiting list for housing vouchers in Saint Louis alone has over 23,000 names of individuals and families waiting for affordable housing units; 2) the average annual cost to Missouri and Medicaid for a senior in a nursing home is over $61,000 per senior and; 3) the annual cost to the state for corrections and hospitalization of individuals with mental illness exceeds $200 million, due to the relatively long length of stay, as these individuals are often homeless and/or lack access to community-based treatments, Isee an opportunity to provide stable and affordable housing for these, often fixed- or low-income, individuals in a community where they can thrive and live with dignity . It also seems to me that there is a long term benefit to the state, as the economic burden of mental illness is over $2 billion; meanwhile, LIHTC spending has only grown by $144 million over 25 years.

The Salvation Army, as a non-profit developer, reinvests and reserves its developer fees for the long-term viability of our projects and to keep rents affordable for our residents because we are committed to maintaining the affordability of our LIHTC developments in perpetuity, beyond the usual 30 year compliance period. Families are able to live in a safe, decent, clean environment and access community-based services to prepare the next generation to prosper. Through collaboration with Veterans Administration we have created a supportive housing program for formerly homeless Veterans who would otherwise be hospitalized or incarcerated due to various treatable conditions. Youth aged out of foster care are provided a safe and decent place to live while they attend an educational institution to become contributing members of society. LIHTC made all this possible and the benefits far exceed short term savings.

I am asking you to reconsider the elimination of Missouri LIHTC. As our population ages, our veteran community grows, and individuals with special needs continue to face serious challenges, the need for affordable housing will continue to increase. Please do not leave hard working low-wage workers, seniors, veterans, disabled, and motherless out in the cold.

St. Louis Equity Fund John F. Kennedy, President & CEO 707 N. 2nd Street, Ste 308, St. Louis, MO 63102

Attn: Executive Director Stetzler, Commissioner Parson, Commissioner Schmitt, Commissioner Crowell, Commissioner Simpson, Commissioner Bay, Commissioner Miller Commissioner Hawley

Re: Removal of the Missouri 9% and 4% Low Income Housing Tax Credit (State LIHTC) from the 2018 Qualified Allocation Plan

As an advocate for the affordable housing program, I am shocked that Governor Greitens has gone around the state legislature to unilaterally kill the State LIHTC by placing commissioners at MHDC to vote for a Qualified Allocation Plan that excludes the State LIHTC. The legislature's intent in creating MHDC was for an agency whose mission is " working to provide quality, safe, affordable housing for low and moderate income citizens of Missouri" and to "...help increase the supply of housing for low and moderate income persons."

That decision will, in and of itself on an annual basis without the state providing another viable source of financing for these developments, result in approximately 40% less affordable rental housing units being created. Counter intuitive for the agencies mission, wouldn't you agree? The investors shoulder the burden of risk of loss of credits, having to repay credits if developments fail (which is an extremely rare occasion).

At a time when the production of affordable rental housing is not sufficient to meet the current needs, this is not the time to scale the program back. In St. Louis alone, there are approximately 23,000 households in need of affordable rental housing. With the 2017 allocation, the competitive (9%) Missouri affordable housing tax credit will assist in the production of 1,362 units (again, a mere 6% of those needing affordable units in St. Louis alone) in 30 developments, of which more than half are outside of KC/STL, with some of those rural areas in dire need of affordable rental housing. Of those 30 developments, a majority will support housing for seniors. The program makes rental housing available to those in low to very low-income brackets and to keep those qualifying individuals and families from having to pay a substantial portion of their incomes just on housing- in many cases more than 50% of their disposable income in non-assisted developments. I shudder to think of that kind of financial burden for those families and individuals.

So instead of finding a way to make the program more efficient and the opportunity to create even more affordable rental housing, the current recommendations will further stymie the needs of those whom the program is intended to benefit.

Please, at the December 19th Commission meeting, do not vote for the draft 2018 QAP as recommended at the November 17, 2017 meeting. Instead, please reconsider full inclusion of the State LIHTC.

John F. Kennedy

President & CEO

Star Residences Tenants St. Louis, MO

Letters as follows:

Maggie Boyd 6367 Lalite Ave Apt 313 St. Louis, MO 63136

December 1, 2017

To Whom It May Concern: MHDC

I want you to know I am very grateful for the State Tax Credit Program. Because of this program Iam able to have a safe and affordable place to live.

Our apartment building provides all kinds of services to help us feel connected to the community and each other. The rent is reasonable and this means I don't have to worry about paying my other bills or buying food or medication.

The State Tax Credit program has helped many other low-income individuals in Missouri and it should not be stopped.

Sincerely, Maggie Boyd

Roscoe Cannon 6367 Lalite Ave APT 302 St. Louis, MO 63136

December 1, 2017

To Whom It May Concern:

I am writing to let you know why I value the State Tax Credit Program this program has allowed me to live independently in a safe and affordable apartment home.

My rent is reasonable which mea11sIcan pay my doctor bills, get my prescriptions filled and buy food on my limited income.

This program has had a positive impact on my life and many other seniors who could not afford to pay their rent without assistance from this program.

Sincerely, Roscoe Cannon

Sauda Carr 6367 Lalite Ave Apt 210 St. Louis, MO 63136

To Whom It May Concern: MHDC

I want you to know I am very grateful for the State Tax Credit Program. Because of this program I am able to have a safe and affordable place to live. As you age you want to continue to have a your own place and not move in with your children or other family members

The State Tax Credit program has helped many other low-income individuals in Missouri and it should not be stopped.

Sincerely,

Sauda S. Carr

Patricia Clark 6367 Lalite Ave. Apt 113 St. Louis, MO 63 136

To Whom It May Concern: MHDC

I am writing to express my concern about the potential for Missouri to end the State Tax Credit Program. I am a senior and I live on a fix income. Right now I live in a safe and affordable apartment that cost $495.00 per month. The state tax credit program has made this possible. Like many low-income seniors we need programs like this to help ensure we have a safe affordable place to live.

This program has made it possible for me to provide for myself and Iam asking the Governor to please not eliminate this program.

Sincerely,

Patricia Clark

Annie Hill 6367 Lalite Ave. Apt 212 St. Louis, MO 63 136

To Whom It May Concern: MHDC

I want you to know I am very grateful for the State Tax Credit Program. Because of this program I am able to have a safe and affordable place to live.

The State Tax Credit program has helped many other low-income individuals in Missouri and it should not be stopped.

Julia Hudson 6367 Lalite Ave. Apt 214 St. Louis, MO 63136

Julia Hudson 6367 Lalite Ave. St. Louis, MO 63136

To Whom It May Concern: MHDC

I am writing to let you know why I value the State Tax Credit Program. This program has allowed me to live independently in a safe and affordable apartment home.

My rent is reasonable which means I can pay my doctor bills, get my prescriptions filled and buy food on my limited income.

This program has had a positive impact on my life and many other seniors who could not afford to pay their rent without assistance from this program.

Sincerely,

Julia Hudson

Gail Jackson 6367 Lalite Ave. Apt 206 St. Louis, MO 63136

To Whom It May Concern: MHDC

I am writing to let you know why I value the State Tax Credit Program. This program has allowed me to live independently in a safe and affordable apartment home.

My rent is reasonable which means I can pay my doctor bills, get my prescriptions filled and buy food on my limited income.

This program has had a positive impact on my life and many other seniors who could not afford to pay their rent without assistance from this program.

Sincerely

Linda Jackson 6367 Lalite Ave. St. Louis, MO 63136

I am writing to let you know why I value the State Tax Credit Program. This program has allowed me to live independently in a safe and affordable apartment home.

My rent is reasonable which means I can pay my doctor bills, get my prescriptions filled and buy food on my limited income.

This program has had a positive impact on my life and many other seniors who could not afford to pay their rent without assistance from this program.

Sincerely, Linda Jackson

Ethel Perkins 6367 Lalite Ave. Apt. 110 St. Louis, MO 63136

I am writing to let you know I love my 2 bedroom apartment for the following reasons: It is safe and affordable. I have some health challenges and the ·way it is designed it is very easy for me to come and go. The rent is affordable because of the Missouri State Tax Credit program. If this State Tax Credit program ends this is going to have a negative impact on seniors like me who live on a fixed income.

When you have affordable: rent it allows you to afford the many unexpected things that happen as you age.

This program has helped rnany citizens in Missouri and it should be continued.

Sincerely, Ethel Perkins

Glenda Powers 6367 Lalite Ave. Apt. 108 St. Louis, MO 63136

To Whom It May Concern : MHDC

I live in an apartment that is: supported by the State Tax Credit Program. This program has made it possible for me to have a safe and affordable place to live.

I have numerous health challenges and the money I receive for being disabled would not allow me to have such a nice home if the State Tax Credit Program did not help with the cost.

This program has helped many struggling families in Missouri have a safe and affordable place to live and it should be continued.

Doris Scales 6367 Lalite Ave. Apt. 112 St. Louis, MO 63136

To Whom It May Concern: MHDC

I am writing to let you know I love my 2 bedroom apartment for the following reasons: It is safe and affordable. I have some health challenges and the way it is designed it is very easy for me to come and go. The rent is affordable because of the Missouri State Tax Credit program. If this State Tax Credit program ends this is going to have a negative impact on seniors like me who live on a fixed income. When you have affordable rent it allows you to afford the many unexpected things that happen as you age. This program has helped many citizens in Missouri and it should be continued.

Sincerely,

Doris Scales

Relda Stewart 6367 Lalite Ave. Apt. 304 St. Louis, MO 63136

To Whom It May Concern: MHDC

I am writing to let you know why I value the State Tax Credit Program. This program has allowed me to live independently in a safe and affordable apartment home.

My rent is reasonable which means I can pay my doctor bills, get my prescriptions filled and buy food on my limited income.

This program has had a positive impact on my life and many other seniors who could not afford to pay their rent without assistance from this program.

Sincerely,

Relda Stewart

Ella Stokes 6367 Lalite Ave. Apt. 209 St. Louis, MO 63136

To Whom It May Concern: MHDC Please do not discontinue the State Tax Credit Program. What do you expect seniors to do about affordable housing? This program has made it possible for me to have a safe and affordable place to live.

We have social activities and we all work together to build a strong sense of community. This opportunity to live with dignity has been supported by the State Tax Credit Program and I feel this program should be continued.

Sincerely,

Ella Stokes

Ward, Nancy Oak Grove Villas Resident Oak Grove, MO

We need the aid we get based on our income. I am disabled and I live in Oak Grove Villas Apt. I only get about $1000 a month. I can’t afford $700-900 a month. I couldn’t even afford $440-$700 a month and my other bills.

If you do this, where are we going to live? You all keep taking stuff away from us. There is people worse off than me.

Maybe we will all come and move in with you or we will be on the streets.

If you all do this, this is going to hurt lots of people.

Nancy Ward

Westchester Village of St. Joseph Employees (2) St. Joseph, MO

Letters as follows:

Westchester Village of St. Joseph Residents (43) Joseph, MO

Young, David and Rhonda Kirksville, MO

To whom this may concern:

In light of the recent news regarding the potential abolishment of the state housing tax credit, we wish for you to please consider another method for balancing the budget other than cutting stable housing opportunities for low income families, seniors, and veterans. These developments transform communities and provide a respectable place for seniors to live who are living on a fixed income as well creating economic opportunity and investment in small communities of $6-10 million dollars each.

The project here in Kirksville awarded credits last year which is currently under construction, Baltimore Meadows, already has a waiting list beyond the number of units being provided. We have been waiting for a quality project like this for years and are so fortunate to have been selected for a funded project. We know that we were one of about 30 projects selected among about 120 applicants. To think that all future proposed projects will be competing for even less funding is devastating for other towns in rural Missouri. The way we understand it, without the state housing credits, rents would be hundreds of dollars more per month which is just not feasible for people on low or fixed income.

We understand the overall effort to cut costs but to cut housing opportunities to an already underserved population of seniors, veterans, and families is tough to justify in any situation. Please consider any other options on the table than to end a program providing low income housing which is a cornerstone to positive, healthy living.

Sincerely,

*Concerned Residents*

David & Rhonda Young 1106 E Northtown Road Kirksville, MO 65301 Emailed Comments Received for Modifications Made to the Low Income Housing Tax Credit FY2018 Qualified Allocation Plan December 4, 2017

Adams, Emily [email protected] St. Louis, MO “Comment on LIHTC”

I believe that Governor Greiten's actions to remove the state LIHTC program are highly inappropriate and I applaud Lt. Governor Parson and State Treasurer Schmitt for voting "no" to remove LIHTC from the 2018 LIHTC application under the QAP.

There is a clear need for affordable housing here in Missouri and LIHTC is currently the only state program available to provide affordable housing to veterans, seniors, the disabled, and low-income Missourians.

The old government public housing system prior to LIHTC suffered from waste and mismanagement. Taxpayer money was being spent on tearing down poorly constructed government sponsored housing only 2-3 decades after they were originally built. To fix this issue, President Ronald Reagan and Congress created a tax credit to allow private and public developers to be incentivized to develop affordable housing across the country.

A recent study found that 25% of all renters spend over half of their income on rent. However, less than 20% of them receive aid, because current waitlists for rental assistance in Missouri are years long.

Today, St. Louis City, St. Louis County, and Kansas City Housing Authorities have waitlists ranging from 4,000-15,000 people. However, this problem is not unique to big cities as smaller counties have waitlists that often exceed 1,000 people. Nearly all of the state's waitlists are so full that they are closed to new applicants and only open the application window for 3-4 weeks, every few years.

I am concerned with the efforts to remove state LIHTC outside of our General Assembly. The Legislature allocated our tax dollars to fund the State LIHTC program for 2018. It is not appropriate for the Governor, a few state elected officials, and three unelected commissioners to take away our voice on this issue. I would prefer for my elected representative and state senator to have the opportunity to discuss changes to the LIHTC program and to discuss alternative solutions in the 2018 legislative session, instead of this current proposal.

Thank you for this opportunity to comment.

Sincerely, Emily Adams 4101 Shaw Blvd. St. Louis, MO 63110

Albright, Sharon [email protected] “State LIHTC Program”

Thank you for this opportunity to comment.

Sincerely, Sharon Albright

Barnes, Cheryl [email protected] Blue Hills Neighborhood Association Kansas City, MO “State Low Income Housing Tax Credits (LIHTC)”

I am writing on behalf of the Blue Hills Neighborhood Association, an area that can be characterized by less than ideal, modest housing stock providing homes for low to moderate income families.

The neighborhood boundaries are Paseo to Prospect, Cleaver Blvd. to 63rd Street, zip codes 64130, on the east side and noted for the number of murders in the area and 64110 on the west side.

That said, the neighborhood association is looking for ways to improve the housing stock and to make affordable homes available for families. We have an aging urban population and are looking for ways to pull the neighborhood up by its bootstraps: decent, affordable housing for younger families is among the top priorities.

We are at a time when we need our government resources to support those at the bottom of the income levels, at the bottom of the opportunity chain. Eliminating the state tax credits diminishes the opportunity to make significant changes in Kansas City, including the Blue Hills neighborhood.

We have solid housing stock that needs basic upgrades, vacant lots that that with new homes could help re-populate the city. Although we are speaking from an urban perspective, the problem also is acute in rural areas.

We believe that the elected officials in the General Assembly are close to local issues such as the need for affordable housing and understand the importance of improving blighted areas. We believe they should be responsible for the LIHTC program, not an appointed commission with no connection or real affinity to housing issues and neighborhoods.

We hope that in the spirit of the season the program will be funded to provide communities and Missouri families with a hand up and not close the door on this important program.

Thank you for the opportunity to share our concern.

Belcher, Jonathan [email protected] St. Louis, MO

First Name Jonathan

Last Name Belcher

Phone 314-802-0709

Email Address [email protected]

Home Address 800 North Tucker St. Louis, MO 63101

Subject Other

Message I am responding to the proposed changes to MHDC 2018 Qualified Allocation plan for MHDC Multifamily programs. I serve homeless individuals and families and this would greatly affect the future of affordable housing in St. Louis. This program allows low income individuals and families afford safe, dignified, and affordable housing. Not only does this benefit our current clients we serve but future clients as well. St. Patrick Center does not develop property but we do partner with LIHTC developers to find our clients safe affordable and dignified housing. This program has assisted countless individuals and families with maintaining their housing in safe neighborhoods. Without current and new stocks of affordable housing our clients could be priced out of the market. This could increase homelessness and push more individuals and families into poverty. It makes little sense to eliminate this funding. Thank you for your time and I hope the commission reconsiders their vote to eliminate this funding.

Bowman, Christopher [email protected] St. Louis, MO “LIHTC Comment”

Hello,

I am writing to encourage the MHDC to continue funding the LIHTC. I am a recipient of one of your first-time home buyer grants, without which I would not have been able to purchase a home. The home I purchased was a duplex, previously vacant after being foreclosed over 5 years ago.

The neighborhood I live in has done significant renovation via the LIHTC. See this article for an enumeration of their most recent project: https://nextstl.com/2014/09/fox-park-2/

45 apartments were added to the neighborhood, creating a multitude of construction jobs and providing an extended property tax base to the city and state, as these were all formerly vacant (and uninhabitable) properties.

Without the LIHTC these buildings would have been demolished, as the cost to rehab via a private developer would not be cost efficient. A demolished building produces no tax revenue for the state, ending the LIHTC would quite literally be cutting off the nose to spite one’s face.

Thank you for your time, Chris Bowman St. Louis, MO

City of St. Louis - Mayor Lyda Krewson

Sent By: [email protected]

Letter as attached:

LYDA KREWSON

MAYOR

OFFICE OF THE MAYOR

CITY OF ST. LOUIS MISSOURI CITY HALL - ROOM 200 1200 MARKET STREET SAINT LOUIS, MISSOURI 63103-2877 PHONE: (314) 622-3201 FAX: (314) 622-4061 [email protected]

December 4, 2017

Chairman Jeffrey S. Bay Missouri Housing Development Commission 920 Main Street, Suite 1400 Kansas City, MO 64105

RE: Support for Low Income Housing Tax Credit

Dear Chairman Bay:

I am writing to support the retention of the State Low Income Housing Tax Credit (LIHTC) program. The elimination of the State LIHTCs reduces the already small number of housing units built each year by at least 33%. The housing, built by the credit program, provides the state's hard working families, seniors and individuals with disabilities with affordable, quality housing.

The program has a very low administrative cost since both State and Federal Credits are extensively monitored by the investors and MHDC- properties are inspected by both annually. With grants, the agency has cost to disburse and review on a constant and ongoing basis.

There is an unfortunate misperception that LIHTC developers are mostly private firms whose sole motivation is to make as much money as they can while meeting the minimum requirements of the program. That has certainly not been our experience.

In the City of St. Louis, many of our leading LIHTC developers have been non-profit and community- based organizations. These include Rise, DeSales Community Development, Northside Community Housing, The Salvation Army and Places for People. These groups share a long-term, mission-based commitment to their neighborhoods and the populations they serve. They develop high quality projects and maintain affordability beyond the required period. They are most definitely not doing LIHTC development just for the money.

In fact, LIHTC investments have been catalytic in stabilizing and improving several neighborhoods in St. Louis. Examples include Fox Park, Old North St. Louis, The Ville and Hyde Park. LIHTC developments- both new construction and rehabs- in these neighborhoods provide quality, stable homes for working families. Numerous studies have demonstrated that a stable home in a safe neighborhood is the foundation for helping children learn and grow to be healthy, productive citizens. The Missouri LIHTC has been a powerful tool in this effort.

I understand from our Housing Authority that we have almost 23,000 families on the waiting list for housing and I am concerned that the State LIHTC program is being eliminated without any alternative. I am requesting that MHDC reverse their decision and to put the LIHTC back into the QAP at the December 19th meeting in Jefferson City.

Sincerely,

Lyda Krewson Mayor, City of St. Louis

CC: Governor Greitens

Cook, Mike [email protected] PLS Builders Callao, MO

Letter as attached:

PLS Builders, LLC

20417 Fathom Place Callao, MO 63534 314-660-1812 Email: [email protected]

12/1/2017 Dear Governor Greitens:

My name is Michael Cook and I have lived in the Macon community for over 10 years. I am the owner of a locally owned construction company that has partnered with tax credit developments in our community. These developments are desirable to Missouri communities due to the economic activity that is stimulated by the creation of construction jobs and the generation of tax dollars from labor and material.

Our company, PLS Builders, LLC, sub-contracted with Fairway Construction Co., Inc. and are proud to have helped provide homes for low to moderate income seniors and families. I live in the country of a small town in Macon County Missouri with my wife and our 3 sons. I have been a residential and commercial carpenter for over 25 years. My wife and I are both veterans of our great country and are very appreciative and grateful for those that have given the ultimate sacrifice. According to the U.S. Department of Housing and Urban Development, over 39,000 veterans are homeless on any given night. The State Low Income Housing Tax Credit program has helped hundreds of veterans find safe, affordable homes.

I am currently involved in the Baltimore Meadows housing development in Kirksville, MO which will provide safe and efficient living for many residents. Being a part of these projects has improved job security for my employees and has provided local businesses with income from purchasing supplies and materials for these projects.

As an important part of my local economy, I urge you to move forward with the State Low Income Housing Tax Credit program as adopted by the Missouri Legislature many years ago. Since 1986, the State Low Income Housing Tax Credit program has provided roughly 7 million homes to low-income families, seniors, veterans and people with disabilities who could otherwise not afford quality housing.

Sincerely,

Michael Cook

Courtney Cushard [email protected] St. Louis “Save the Low-Income Housing Tax Credit in Missouri”

Good Afternoon,

I'm writing today to encourage you to keep keep the Low-Income Housing tax credit in Missouri. It has a great and positive impact on our communities and helps struggling families find quality, safe, places to live. It is also a great economic driver! 81,000 jobs a year are supported with the LIHTC, $7.7 billion has been generated in local income, and $3 billion in tax revenue has been generated.

Please save the LIHTC!

Thank you,

Courtney Cushard 2758 Accomac St. St. Louis, Missouri 63104

Gershman Mortgage Adam Hendin [email protected] St. Louis, MO

Gershman Mortgage

To Whom It May Concern

Gershman Mortgage is a proud supporter of the Missouri Low Income Tax Credit (LIHTC) program, and we have financed affordable housing communities in Missouri and across the United States. We believe the LIHTC program is a socially responsible program that has a positive effect on the seniors, veterans and family tenants who make up these housing communities, and whom may not otherwise have access to quality housing.

As a lender actively involved in the HUD-insured programs for financing multifamily, we finance all types of rental housing, including market-rate, affordable, elderly, and family-oriented projects alike. We firmly believe that without state LIHTC, Missouri's affordable housing product will be severely cut in the state, and it will directly impact some of the state's most vulnerable residents.

Missouri should keep supporting its LIHTC properties! Don't let the state affordable housing tax credit go away.

The following list represents a few of the dozens of housing communities financed with LIHTC that Gershman Mortgage has helped develop or preserve:

• Laurel Park (Ventura Village), 352 units in Florissant, MO. Rehabbed in 2006 with LIHTC. This 352 unit property in North County suffered from an abundance of crime and high vacancy (60% occupied) prior to undergoing a significant rehab in 2006 with tax credits. Now, in 2017 crime is non-existent and occupancy is near 100%. This property is a great indicator of the positive change the LIHTC program is capable of having on a troubled community and hundreds of residents.

• Council Tower Senior Apartments, 227 units designed for the elderly in the City of St. Louis, MO. Originally developed in 1968, this project was financed under the HUD direct-loan, (Section 202). In 2011 the owner redeveloped this 27- story high rise using State and Federal LIHTC and historic credits. This full-scale renovation was a necessity for the city of St. Louis and the hundreds of tenants occupying the large and highly-visible building located off the I-64 Interstate in midtown St. Louis.

• Rolla Apartments, a 150 unit former HUD 202 built in 1979 and designed for the elderly. Located at 1101 McCutchen in Rolla, MO. This project is currently being renovated using the State 4% tax credit in 2017. This is a great example of the impact our state tax credit has on a rural property that houses our elderly. The property had not been renovated since it was originally developed almost 40 years ago.

• Wendell Apartments, 76 units in Sikeston, MO. Rehabbed in 2006 with LIHTC. Wendell Apartments caters to 62+ affordable seniors, and provides quality housing for some of Sikeston's most vulnerable elderly residents

• Glendale at the Mansions, Independence, MO, 200 units, originally developed using LIHTC. Provides quality housing to elderly residents over the age of 62

• Eureka Apartments, 50 Units in Chafee, MO. Rehabbed 2006 with LIHTC. Located in rural Missouri, this one of the few affordable housing developments in the area.

• Thunderbird, 50 units in Harrisonville, MO. Rehabbed in 2004 with LIHTC.

• Westminster Place Phase I, II, and III, 337 units in St. Louis, MO. Built with LIHTC between 1986- 1993.

Several other key projects we financed using the state and federal LITCH program include: • Alpha Terrace Apartments, St. Louis, MO • Blumeyer Associates, 4 phases, St. Louis, MO • Covenant Place, 2 phases, St. Louis, MO • Hanley Crossing, St. Louis, MO • O'Fallon Place apartments, St. Louis, MO • Paul Brown Lofts, St. Louis, MO • Wendell Apartments,- Sikeston, MO • 1110 Lofts - Washington Avenue, St. Louis redevelopment of former warehouse • Vaughn Place- St. Louis City

Without the state low-income tax credit any developments or rehab projects above would not have been built or otherwise preserved. We have firsthand experience with these projects, and most of the tenants would otherwise be homeless if forced to pay much more for quality housing.

With the reduction in the HUD Budget for grants and loans to affordable projects it makes it more important that ever to keep the state LIHTC to help subsidize the cost of the preservation of affordable housing. These programs make a positive impact on the people of Missouri and their lives.

Sincerely, GERSHMAN MORTGAGE

Chris Will Vice President

· Adam Hendin Vice President

Hafner, Colleen [email protected] St. Louis, MO “Comments on State LIHTC”

Good afternoon.

I'm writing in opposition to the revised QAP which removes the state LIHTC from the FY 2018 program. It is short sighted to believe removing the program is "progress", with no plan in place to fund the hundreds of housing units that will no longer be possible without a state LIHTC program.

The tax credit program has been the most successful public private partnership in our country. It has been a critical source of private dollars to fund the creation of much-needed housing for individuals, families, seniors, those living with disability, children at risk of homelessness, etc. The government does not have to come up with cash out of pocket - the private sector makes the equity investments, and government provides oversight. It is a model that has seen much success and brought billions of dollars of private investment to bear for a public good.

Certainly there are ways the program could be improved. There are inefficiencies that could be addressed, and I believe that working closely with those who are most familiar with providing low income housing is the way forward towards these improvements. Unfortunately, the Governor does not agree and wishes to push away anyone who may be considered an "expert" in this field.

Not once in the history of our State, or our Country, has there ever been an adequate amount of safe and decent housing for all citizens. If the State LIHTC is removed from the affordable housing development toolbox in Missouri, we will be that much further away from ever achieving this goal.

Regards,

Colleen Hafner 4164 Hartford St. St. Louis, MO 63116

Hannah, Brent [email protected] Monarch Private Capital St. Louis, MO “Comments to FY2018 Draft QAP”

Letter as attached

December 1, 2017

Missouri Housing Development Commission 920 Main Street, Suite 1400 Kansas City, MO 63105

Dear Commissioners,

I am writing to urge you to reconsider and vote against adopting the QAP as currently proposed. Elimination of the State Low Income Housing Tax Credit will have very real and dramatic unintended consequences. Has MHDC calculated how many units will no longer be developed or rehabbed annually if the state LIHTC credit is not available? Conservatively, it has to be more than 500 units annually.

The need for affordable housing is greater than ever. Preventing these additional units from being developed will keep at least 500 families or seniors on perpetual waitlists and living in substandard housing situations. Contrary to recent criticism, the LIHTC program has been the most efficient public policy created to build affordable housing.

I am very proud to have worked in the LIHTC industry for more than a decade. I have worked on projects in many states throughout the country and the impact of having a state credit program that accompanies the federal program is tremendous. The two most obvious benefits of the state credit program are 1. Additional units developed and 2. The ability to set aside- units for the groups that need them the most.

Missouri has had the ability, primarily due to the funds available through the state credit program, to build units that are targeted for the "special needs" and "vulnerable populations" that are noted in the QAP- the homeless, veterans, physically or mentally disabled, youths transitioning from foster care, etc. Without the state credit the ability of projects to provide the supportive services required by these groups are nearly impossible as funds are simply not available. In short, these groups that are the most in need of affordable housing will be the ones most impacted by this decision to withhold state credits.

In addition to the two issues above, there are additional consequences that I would like to point out related to jobs and other costs that arise from reducing the number of LIHTC units that are developed each year. Employment in the construction industry is an area that is often overlooked when discussing affordable housing. How many jobs will be lost if more than 500 units that would have otherwise been built each year are no longer built? How many subcontractors that work in this industry will be laid off?

The last impact that I would like to mention is other inadvertent costs that the state will incur by reducing the amount of affordable rental housing available. A significant portion of LIHTC units developed are targeted for seniors. Many of these are on fixed incomes and cannot afford quality housing outside of this program. Some of these would-be residents will enviably end up in nursing homes funded by Medicaid. Additionally, it is hard to quantify the economic and social cost of homelessness on our healthcare and justice systems. Lastly, the number one most important factor for a child's education is secure and stable housing. It is also hard to quantify the impact of denying these additional families that stable housing.

I would like to also note that the inefficiency of the Missouri LIHTC program has been grossly exaggerated. The $0.42 cent on the dollar reference that I have heard repeatedly is outdated and also completely disregards the economics of the state credits being a 12+ year investment by the private sector. Currently projects will receive pricing in the $0.58-$0.59 range which is very efficient return for the state with credits coming over such a long term.

I would welcome the opportunity to speak with you about this in more detail.

Sincerely,

Brent Hannah

Holman, James [email protected] JT Holman Construction LLC “Tax Letter”

Dear Governor Greitens:

My name is James Holman and I have lived in the Macon community for over 30 years. I am the owner of a locally owned construction company that has partnered with tax credit developments in our community. These developments are desirable to Missouri communities due to the economic activity that is stimulated by the creation of construction jobs and the generation of tax dollars from labor and material.

My company, JT Holman General Construction and Excavating, LLC, contracted with Fairway Construction Co., Inc. and are proud to have helped provide homes for low to moderate income seniors and families.

As a veteran myself, small business owner and living in a low income community in Northern Missouri these types of housing developments and the need for them are at an all time high. I have been a contractor in Macon, MO for over 20 years, I have built several duplexes and housing apartments in this community. Being involved in these types of projects has provided steady employment and income for my company, other contractors and suppliers in the local area.

Iman, Kyna [email protected] Bridgeton, MO “Save LIHTC credits!!”

I am writing to voice my concerns on the removal of Low Income Housing Tax Credit program.I believe that Governor Greiten's actions to remove the state LIHTC program are highly inappropriate and I applaud Lt. Governor Parson and State Treasurer Schmitt for voting "no" to remove LIHTC from the 2018 LIHTC application under the QAP.

Thank you for this opportunity to comment.

Sincerely,

Kyna Iman 3819 Harmony Lane Bridgeton, MO 63044

314-651-1185 [email protected]

Jaegers, Martha [email protected] “Continue funding for LIHTC”

I am an Adult Education teacher in the city of St. Louis. One elder student has recently moved because of her difficulty in paying her rent. Today another student talked about how her rent was keeping her from having enough food on a regular basis. These are only two of the ones I know personally who would be even worse off if LIHTC were decreased or closed.

Thank you for this opportunity to comment.

Sincerely yours

Kansas City Equity Fund Dobreff, Erica [email protected] Kansas City, MO “Letter attached”

Letter as attached:

Kansas City Public Schools Jaax, Shannon [email protected] “Letter Re: FY2018 QAP from KCPS”

Attached letter as follows:

November 4, 2017

Missouri Housing Development Commission c/o Frank Quagraine Director of Rental Production

Missouri Housing Development Corporation 920 Main Street, Suite 1400 Kansas City, MO 64105

Dear Commissioners:

On behalf of the team at Kansas City Public Schools (KCPS), I would like to express our concerns about the draft FY2018 Qualified Allocation Plan which eliminates the state allocation of 9% and 4% Low Income Housing Tax Credits (LIHTC).

The LIHTC program is critical to providing safe, affordable and stable housing for many of our students and their families. At KCPS, we serve many at-risk students whose families struggle with housing instability, which is closely tied to student mobility. Last year, our mobility rate was 41% (students who change schools during the school year), and it is common to see many students change schools multiple times per year. In addition, this year, we have already served more than 800 homeless students. It is critical that we address housing instability and student mobility as it is impacts our students’ success in the classroom. Based on our Fall 2017 NWEA testing of 1,500 2nd graders, we know that our students with no mobility between Kindergarten and 2nd grade are 81% more likely to score in the top quartile in Math (41% more likely in English Language Arts) than those who have moved schools. Eliminating the State LIHTC program will likely decrease our students’ access to affordable housing resources and increase student mobility within our schools, which will have a detrimental effect on academic achievement.

In addition, we have seen firsthand the impact that LIHTC-funded projects have made in our neighborhoods. Several former school buildings have been converted into affordable housing, including Bancroft School, Seven Oaks Elementary and Faxon School. All of these projects have not only provided much-needed affordable housing, but they have provided a means for seniors to remain in their neighborhoods as they age out of their homes, which is especially important for those who are no longer able to take on the upkeep of their homes. The LIHTC projects are also serving as a stabilizing investment in neighborhoods that has prompted private investment in the rehabilitation of single family homes nearby.

2901 Troost Ave. Kansas City, MO 64109 (816) 418-7000

www.kcpublicschools.org

We understand that there are inefficiencies in Missouri’s LIHTC program. Rather than eliminating this much-needed program, we strongly urge you to reinstate the State LIHTC for FY2018 and work with the legislature and affordable housing experts to improve the program for FY2019.

Thank you for your consideration of this request.

Yours in Education,

Dr. Mark T. Bedell

Superintendent of Schools

Cc: Senator S. Kiki Curls Senator Jason Holsman Senator John Rizzo Representative Gail McCann Beatty

Klug, Bethany [email protected] Kansas City, MO “Keep LIHTC Program”

"I believe that Governor Greiten's actions to remove the state LIHTC program are highly inappropriate and I applaud Lt. Governor Parson and State Treasurer Schmitt for voting "no" to remove LIHTC from the 2018 LIHTC application under the QAP.

Thank you for this opportunity to comment.

Sincerely,

Bethany Klug, DO 625 E 71st Ter Kansas City, MO 64131

Lang, Sara [email protected] Columbia, MO “Don't take LIHTC out of Legislative jurisdiction”

I oppose the Governor's high handed power grab that will take the LIHTC out of the hands of our Legislative body.

Sincerely, Registered voter Sara Lang Columbia, Missouri

Larm, Valerie [email protected] “The Recent Vote”

Please read my opinion. This affects people I know.

Thank you for this opportunity to comment.

Sincerely, Valerie K. Larm

Linhares, Karen [email protected]

“Tax credit elimination”

I am very disappointed and concerned that the state low income housing tax credits were eliminated in Congress. Just wanted to voice my opinion I am a preschool teacher on a limited income. The elimination of these tax credits will hurt many people who rely on these tax credits to help pay their monthly heating bills. Please reconsider bringing back the tax credits. Stop and think. Please put yourself in a person situation who due to their work situation (income) can’t afford their electric bill and need the tax credits to help them get by with other monthly bills.

Lord of Love Lutheran Church [email protected] Meggan Prosser-Gebhardt – Pastor Belton, MO “LIHTC Program”

Hi Sarah,

Attached is a letter in response to the recent MHDC's vote to zero out the LIHTC Program. I will also mail in a copy, but wanted to be sure our letter was received.

Thanks so much!

Meggan Prosser-Gebhardt

Pastor Lord of Love Lutheran Church 8306 E. 171st St. Belton, MO 913.749.3869

Letter as attached:

Cass County Non-Profits Coalition

Serving Cass County, MO

MO Housing Development Commission 920 Main St., Suite 1400 Kansas City MO 64105

4 December 2017

We are submitting this letter on behalf of the Cass County Non-Profit Coalition. Our Coalition is comprised of over 30 service agencies, government representatives and business leaders that serve those in need throughout the county. Representatives of our coalition attended the December 1st public hearing on the 2018 MHDC QAP held in Kansas City.

The decision to zero out funding for LIHTC is unacceptable and will devastate the work to end homelessness in our community and throughout MO.

The following points support the need for and success of the UHTC in MO over the past ten years:

The federal government's old way of financing affordable housing was broken; Missouri has helped fill the gap for decades...until now.

LIHTCs are preferable to the old public housing system which suffered from tremendous waste and mismanagement, and which saw taxpayers' spending money to tear down structures just 2- 3 decades after they were built. Compared to that, a tax credit with private market oversight, as originally crafted and enacted by Ronald Reagan and Jack Kemp, is a very efficient alternative.

The need for affordable housing is more acute than ever.

A recent study found that 1/4 of all renters spend over half their income on rent. Less than 20% of them receive aid, because resources are scarce- waitlists for rental assistance in Missouri are years long. Today, the St. Louis City, St. Louis County, and Kansas City Housing Authorities waitlists range from 4,000-15,000 people; lists in smaller counties often exceed 1,000. Nearly all of the state's waitlists are so full that they are closed to new applicants. Another study counted 16,000 homeless schoolchildren, excluding kids age 0-5. Research shows that homeless children are less likely to complete high school and more likely to cost the state throughout their lives.

Missouri's program isn't unusually large- we just meet housing needs differently.

Our LIHTC program is larger than that of many states, but other states spend far more money to subsidize affordable housing using programs Missouri lacks. For instance,while Missouri spent $144 million on state LIHTCs last year, New York City alone spends $1billion annually to subsidize rents, and requires developers to set aside 20% of all new units as affordable. During the past decade, California has spent an average of a half million dollars a year on state housing bonds.

And LIHTC spending is not, as opponents claim, out of control. LIHTC spending has grown by $144M since 1992. Since 1992, K-12 education spending has risen over $2B from $1.3 billion to $3.5B; Medicaid spending has increased similarly. Thus, the actual spending increase on education and Medicaid has been 15-20 times as large as that on affordable housing.

A recent audit of the state LIHTC program contains significant errors; LIHTC is the most efficient way to inject capital into affordable housing development.

Also, the state would incur 100% of the risk. Currently, the state incurs no risk b/c investors provide up-front money and additional capital if the project becomes distressed. Credits don't flow until units are leased according to stringent guidelines, and are recaptured if projects fail to comply.Since roughly 40% of approved projects are not built or fall out of compliance, the state would lose money- a risk now borne by investors who provide oversight, ensuring compliance to preserve their stake.

It's inaccurate to say that 42-55 cents (the price range of credits during past state audits; pricing is currently 58-59 cents) of each dollar goes into the project.This excludes 1)federal taxes; and

2) decreased value of credits in years 2-10 due to inflation (i.e., time value of money). That is, by the time investors receive their full credit stream 13-14 years after the award, inflation has eaten up 30-35 cents of the dollar. Thus,the fact that the credits sell for 58-59 cents is a sign of efficiency, not waste.

Put simply: if you asked a bank for $1000 and offered to pay back $100/yr for 10 years, starting in 3 years and ending in 13 years, would they accept? Of course not. After 13 years, assuming 5% interest, you'd have paid the bank about $1500 on a secured loan. That's the time value of money.

Viewed from a different perspective, investors paying 58-59 cents for a 10-year stream of credits that don't begin paying out until 3 years after purchase (once a development is built and fully leased) are making a pre-tax 8.6% return on an unsecured loan. Historically, an investor would fare much better with less hassle and worry investing in the S&P 500, or nearly as well with worry-free U.S. Treasuries.

LIHTC developments create cost savings elsewhe re in the budget.

UHTC developments are a hand up, not a handout. They are not free but do reduce rents by an average of $288 month for elderly and disabled people who would otherwise be unable to afford an apartment. Given local governments' cost providing emergency care for feeble seniors and disabled people in dilapidated homes, many expenses are never incurred, and lives are saved, when emergencies are spotted earlier in a large community with on-site support services.

Senior projects are an especially wise use of tax dollars because of Medicaid savings from reduced nursing home use. Over the past decade, LIHTCs have helped build 800+ new senior units annually. Of those, 43% of residents are detoured from nursing homes thanks to special services provided in LIHTC units. An average of 332 units annually utilize LIHTC vs. a Medicaid funded nursing home unit. Annual nursing home costs run the state $29,871per unit,while the annualliHTC allocation per senior is $7,773, which multiplied by 332 units costs the state $2.SM. Thus,tax-credit senior housing saves the state $7.4M annually, and $74M over 10-years.

Homeless veterans are another key constituency LIHTC supports. Vets- who may suffer from PTSD and other issues- face challenges finding affordable housing. LIHTC helps groups like The Salvation Army to build affordable housing with on-site support, sparing government from delivering costly mental health and medical services. Non-profit organizations provide services at veteran-focused developments in St. Louis, Kansas City, Columbia, Mexico, and elsewhere across Missouri.

We believe that the MHDC Commissioners must reconsider this decision and continue the LIHTC program; with modifications if necessary but this crucial program must not be ended.

Sincerely,

Reverend Meggan Prosser-Gebhardt, Chair

Matt Adam Development Co. Tull, Ryan [email protected] Overland Park, KS

I would like to submit a comment regarding the 2018 QAP. I appreciate the concern for wanting state LIHTC pricing to be higher. It has increased in recent years and can probably go up a little further. I think the Commission members that made the decision to eliminate MO LIHTCs haven't fully taken into account why the state credits are discounted (how they work with Federal taxes) or what an investor's return actually looks like when the timing of the investment and credits are taken into account. My simple math shows something like this:

Investment Tax Credits IRR

$(570,000) $100,000 $100,000 $100,000 $100,000 $100,000 $100,000 $100,000 $100,000 $100,000 $100,000 12%

Cutting the MO State LIHTC will mean fewer affordable units, higher rents to make projects work financially, fewer construction and management jobs, fewer property taxes paid and fewer projects to create catalytic impacts in small town and urban Missouri. I would urge the Commission to reconsider eliminating the MO State LIHTCs.

-Ryan

Ryan Tull Director of Multifamily Development Matt Adam Development Co 15050 Antioch Rd # 101 Overland Park, KS 66221 785-550-1683

McClintic, Kathy [email protected] Hunnewell, MO “Public Comment: Missouri Housing Development Commission Vote”

I am a citizen of rural Missouri, I vote, and I am concerned about the direction Gov. Greiten is taking our state. Where’s the compassion and common sense? As a rural Missourian now, and a former St Louis County resident it breaks my heart to see the horrible places in which many rural folks are forced to live because there are no other options.

Thank you for this opportunity to comment.

McCormack Baron Salazar, Inc. Kozminske, Mandy [email protected] “MHDC 2018 QAP and AHAP NOFA Comments”

Letter as attached

M E M O R A N D U M TO: MHDC FROM: McCormack Baron Salazar

RE: 2018 Qualified Allocation Plan (QAP) Comments and Affordable Housing Assistance Program (AHAP) Notice of Funding Availability (NOFA) Comments

DATE: 12/4/17

We have received and reviewed the 2018 MHDC QAP and offer the following comments and questions for consideration:

1. Funding Resources: Traditionally, State LIHTCs have been critical resources in larger projects that are part of major community transformation plans. Are there other resources proposed to help these types of developments achieve the necessary scale and level of community investment level for transformation to occur? We recommend that large-scale community transformation projects including those that have leveraged significant non-MHDC resources with expenditure deadlines, such as the Choice Neighborhoods Initiative Implementation Grant, are prioritized for MHDC resources that allow them to proceed with a comparable scale and economic impact.

2. Underwriting Standards: Service Escrows According to this language, at least 50% of the Developer Fee must fund this Service Escrow to the extent it is not separately funded by a grant. These Service Escrows/Reserves are often required by the investor and lender(s) for projects that have committed to being “Service-Enriched” under the LURA. In many cases the LIHTC equity or first mortgage loan proceeds are the only funds that can be used to fund these Service Escrows/Reserves, as federal funds are strictly prohibited from funding reserves. We recommend that the requirement is modified to allow the reserve to be funded by LIHTC equity and/or loan proceeds so long as evidence of the investor or lender(s) reserve requirement is provided to MHDC.

3. Underwriting Standards: Development Cost Minimums The increase in minimum construction costs for 4% acquisition/rehabilitation developments jumped from 20% of Total Replacement Costs to 40% Total Replacement Costs and will likely impact the feasibility of many of these types of developments. Without significant “gap” resources, many 4% tax exempt bond developments will not be feasible.

We recommend that MHDC use a 20% of Total Replacement Costs threshold for 4% acquisition/rehabilitation developments.

AHAP NOFA Comments:

We have also reviewed the AHAP NOFA which now expressly disallows AHAP-eligible donations to developments with LIHTCs. For many years AHAP credits have proven to be an extremely valuable affordable housing resource for LIHTC developments and units serving residents earning 50% AMI and below. AHAP credits are very efficient, with each $1.00 of AHAP tax credit generating $1.82 in additional private investment into Missouri’s affordable housing and economy. The impact is even larger when leveraged with other private and local funding sources. We recommend that AHAP donations and credits remain permitted in LIHTC developments as a tool to leverage significant private donations and to serve very low income Missourians.

McKinney, Lori [email protected] Missouri Valley Community Action Agency Lafayette County Housing Authority “LIHTC Public Comment”

To Whom It May Concern:

Missouri Valley Community Action Agency is concerned with the efforts to remove state LIHTC. There is a clear need for affordable housing here in Missouri and LIHTC is currently the only state program available to provide affordable housing to veterans, seniors, the disabled, and the low-income Missourians.

Some of the bigger cities like St. Louis, and Kansas City housing Authorities have waitlist ranging from 4,000-15,000 people. Smaller counties have anywhere from 200-1,000 people waiting to be helped. These waitlists are so full that they are only open a few weeks a year to take more applications.

Please consider these comments when deciding on the future of LIHTC’s. Without this program, there will not be a state incentive to create affordable housing. As you can see, from the above statistics that it is defiantly needed in Missouri.

Thanks so much for your consideration,

Lori McKinney Housing/Weatherization Director Missouri Valley Community Action Agency Lafayette County Housing Authority P 660-886-7476 X841 F 660-886-3398 [email protected]

Metropolitan St. Louis Equal Housing and Opportunity Council Risch, Elisabeth [email protected] St. Louis, MO “EHOC Comments on 2018 QAP”

Dear Mr. Quagraine and Mr. Metz-

Please see attached for comments from the Metropolitan St. Louis Equal Housing and Opportunity Council on MHDC's draft 2018 QAP.

Thank you for your consideration, and please feel free to let us know if you have any questions about any of our comments.

Best, Elisabeth

-- Elisabeth Risch Assistant Director Metropolitan St. Louis Equal Housing and Opportunity Council 1027 South Vandeventer Avenue, 6th Floor St. Louis, Missouri 63110 www.ehocstl.org [email protected] 314.534.5800 ext. 7012 Fax: 888.636.4412

Letter as attached:

December 4, 2017 Kip Stetzler Executive Director Missouri Housing Development Commission 920 Main Street, Suite 1400 Kansas City, MO 64105

RE: Draft 2018 Qualified Allocation Plan (QAP) Dear Mr. Stetzler:

The Metropolitan St. Louis Equal Housing and Opportunity Council (EHOC) thanks you for the opportunity to comment on the 2018 Qualified Allocation Plan (QAP) for Low Income Housing Tax Credits (LIHTC). EHOC is a private fair housing organization working to ensure equal access to housing for all people through education, counseling, investigation, and enforcement. We appreciate the efforts of Missouri Housing Development Commission (MHDC) in recent years to address fair housing issues and ensure that all programs are Affirmatively Furthering Fair Housing. As part of this obligation to Affirmatively Further Fair Housing, MHDC must proactively work to promote residential racial integration and increase meaningful access to opportunity for all people.

We first wish to express concern regarding the elimination of the State LIHTC funds, as documented in the draft 2018 QAP.1 We are concerned that the reduction of funds will exacerbate the affordable housing needs in the state of Missouri, particularly affecting the housing needs for seniors, people with disabilities, and low- and moderate-income families. Developing affordable housing, particularly in ways that meet housing needs and provide access to opportunity for members of protected classes, is a critical way that the state of Missouri meets their affirmatively furthering fair housing obligation. By eliminating the State LIHTC through a last minute process with limited public input and no clear replacement proposal for the future, MHDC threatens how they are meeting fair housing obligations and addressing critical housing needs for vulnerable populations throughout the state of Missouri. Additionally, we wish to comment on the QAP related to how MHDC is fulfilling their obligation to affirmatively further fair housing.2 Although encouraging changes have been made to the QAP, LIHTC proposals are still

11 MISSOURI HOUSING DEVELOPMENT COMMISSION, Draft 2018 Qualified Allocation Plan for MHDC Multifamily Programs. Accessed http://www.mhdc.com/notices/ph/FY2018-D2/FY2018_LIHTC_QAP.pdf 2 Id.

predominantly locating in high-poverty, disproportionately or majority minority neighborhoods. For example, in the Kansas City region, the 2017 round one proposals included eleven developments in high-poverty neighborhoods (>20% on a per capita basis) and eleven developments in majority non-white neighborhoods out of twenty-one proposals with street addresses. Said plainly, about half of Missouri LIHTC proposals in the Kansas City region were in high-poverty and majority non-white neighborhoods. These proportions are similar when broken out into family and senior developments: 58% (7 of 12) and 50% (6 of 12) of proposed family developments are located in high-poverty and majority non-white census tracts, while 44% (4 of 9) and 56% (5 of 9) of proposed senior developments are located in high- poverty and majority non-white census tracts, respectively. Only three proposed developments are located in census tracts where the individual poverty rate is less than 10%. These proportions are about the same as those found for the St. Louis area in 2016.3 These high- poverty neighborhoods often represent areas of lesser opportunity for the low-income families that are eligible to live in LIHTC developments. Missouri can do better. Its QAP and Developers Guide offer opportunities for improvement as we recommend below. Specifically, the main obstacles include QAP provisions (or lack thereof) related to 1) concerted community revitalization plans, 2) a transparent scoring system, 3) set-asides for development in high opportunity areas, 4) Section 8 voucher holders’ access to LIHTC, 5) information on tenant recruitment and selection, 6) compliance with fair housing rules and regulations, 7) collection of demographic information, 8) standards for relocation and rehabilitation, and 9) Affirmative Fair Housing Marketing Plans. Our comments and recommendations related to each provision are detailed below.

1. DEFINE CONCERTED COMMUNITY REVITALIZATION PLAN

Consistent with the Code,4 Missouri’s QAP gives preference to projects located in a Qualified Census Tract (QCT) for which a concerted community revitalization plan (CCRP) exists. However, neither Missouri’s QAP nor its Developers Guide define what constitutes a CCRP. Without a definition, the CCRP requirement is largely meaningless. The QAP does describe three criteria analogous to CCRP. To the extent these criteria relate to the goals of the CCRP requirement, MHDC should adapt them. More fundamentally, MHDC should provide an explicit

______3 METROPOLITAN ST. LOUIS EQUAL HOUSING AND OPPORTUNITY COUNCIL to Kip Stetzler, Executive Director, Missouri Housing Development Commission (Oct. 21, 2016). (Noting that of the 21 St. Louis region LIHTC applications submitted under the 2016 QAP, “11 would be in Census Tracts that are majority African American according to the 2009-2013 American Community Survey 5-Year Estimates. Eight would be in Census Tracts with poverty rates of 20% or more.”).

4 26 U.S. Code § 42(m)(1)(B). (“(B) Qualified allocation plan For purposes of this paragraph, the term “qualified allocation plan” means any plan— … (ii) which also gives preference in allocating housing credit dollar amounts among selected projects to— (III) projects which are located in qualified census tracts (as defined in subsection (d)(5)(C)) and the development of which contributes to a concerted community revitalization plan, …

definition of CCRP so that LIHTC residents benefit from legitimately revitalizing neighborhoods. “Concerted community revitalization plans” or “community revitalization plans” are referenced in three locations in the 2018 QAP, while “municipal redevelopment plans” or “redevelopment plans” are referenced in two locations. The three CCRP references are contained under “Selection Criteria,” “Market Characteristics,” and “Community Impact.”1 In these instances, the QAP repeats the code and does not elaborate on what a CCRP entails. Contextual information under “Market Characteristics” is helpful. This section indicates a preference for projects located “in a community with demonstrated new employment opportunities and a proven need for workforce housing.” Such a preference represents a rational selection criteria: affordable housing should be located near employment opportunities, an important non-housing component of revitalization. The QAP’s language on “redevelopment plans” likewise offers some guidance. However, we are concerned that these redevelopment plans are only authorized by elected officials or municipal governments that may exercise unnecessary veto power over plans. When seeking preference based on such a plan, Missouri LIHTC developers must “include a letter from the local authorizing official that the proposed development is part of a redevelopment plan.”2 We suggest the QAP allow “redevelopment plans” to be authored by non-profits, community groups, and other social institutions. In that circumstance, local approval (i.e., local veto) can be substituted with the approval from engaged, community-focused groups as well.

These limited references should be supplemented with a complete definition of CCRP that encompasses the current references to “community revitalization plans” and the “redevelopment plans.” Creating a standard definition of CCRP would provide greater certainty for developers. More importantly, it would better meet the needs of neighborhoods, communities, and LIHTC residents seeking to revitalize or live in revitalized neighborhoods.

We recommend that Missouri adopt a definition of CCRP in its “Selection Criteria” section that details minimum criteria for any CCRP. We provide example text in the box below. Whether adopted in the form recommended below or in another form, this definition should include reference to 1) resources committed to revitalization, 2) a well-defined geographic area, 3) housing and non-housing development, and 4) goals, metrics, and follow-up tasks. These recommendations line up directly with each word in the phrase CCRP. Specifically, a “concerted” plan should include committed resources for private and public development; a “community” plan should pertain to a well-defined geographic and cultural area; a “revitalization” plan must address housing and non-housing development; and a “plan” itself should select measurable outcomes and achievable tasks.

1 MHDC Draft 2018 QAP, at 19, 22, 23. 2 Id, at 18

B. Selection Criteria … The selection criteria incorporate both the federal preferences and selection criteria as described in §42(m)(1)(B)(ii) and §42(m)(1)(C) of the Code. The selection criteria must include: … iv. Project characteristics, including whether the project involves the use of existing housing as part of a concerted community revitalization plan (CCRP); … The Code does not explicitly define what constitutes a CCRP, but many states have developed their own definitions. Missouri has developed a definition of CCRP consistent with the goals of LIHTC in revitalizing neighborhoods and serving communities. Specifically, any CCRP should do the following: i. Identify planned public and private development in the community; ii. Identify any resources committed to development; iii. Set clear geographic boundaries for the community; iv. Describe the community itself; v. Address housing and non-housing development; vi. Coordinate with other state and federal standards; vii. Identify barriers to revitalization; viii. Set goals; ix. Delineate actions to be taken; and x. Engage community partners.

This framework closely follows the recommendations of fair and affordable housing organizations,3 and the practices of other states. For example, the “concerted” aspect of CCRP is demonstrated by the 2016 Texas QAP, which gives preference to projects in CCRPs with “sufficient, documented and committed funding” already “flowing in accordance with the plan.”4 The “community” aspect of CCRP is demonstrated by Georgia’s QAP, which requires that CCRPs “clearly delineate a target area that includes the proposed project site.”9 The “revitalization” aspect of CCRP is demonstrated by Pennsylvania’s requirement that CCRPs address access to public transportation, health care choices, community serving enterprises, and other non-housing aspects of development.5 Finally, the “plan” aspect of CCRP is demonstrated

3 POVERTY AND RACE RESEARCH ACTION COUNCIL, Guidance and Best Practices for “Concerted Community Revitalization Plans” (Mar. 2, 2017), http://www.prrac.org/pdf/PRRAC_CCRP_recommendations_3_14_17.pdf. 4 Id. at 3; see also TEX. DEP’T OF HOUS. AND COMM. AFFAIRS, MULTIFAMILY HOUSING RENTAL PROGRAMS, 2016 QUALIFIED ALLOCATION PLAN 28 (2015), https://www.tdhca.state.tx.us/multifamily/docs/16-QAP.pdf. 9 GA. DEP’T OF COMM. AFFAIRS, 2016 QUALIFIED ACTION PLAN, APP. II, SCORING CRITERIA 14 (2015), http://www.dca.state.ga.us/housing/housingdevelopment/programs/downloads/2016QAPDocs/QAP/2016Qualified AllocationPlan.pdf. 5 PA. HOUS. FIN. AGENCY, ALLOCATION PLAN FOR YEAR 2017/2018 7 (2017), http://www.phfa.org/forms/multifamily_program_notices/qap/2017/2017_2018_qap_final.pdf

by Indiana and Georgia’s requirements that CCRPs identify “implementation measures along with specific, current, and ongoing time frames for the achievement of such policies and housing activities.”6 Other states’ CCRP definitions are succinctly summarized by the Poverty and Race Research Council in Guidance and Best Practices for “Concerted Community Revitalization Plans.7

2. CONSIDER ESTABLISHING A QUANTITATIVE SCORING SYSTEM

The vast majority of states use a scoring system to determine which projects will receive 9% credits.8 In contrast, the Missouri QAP lists several selection criteria and priority areas in its QAP, but does not quantify the extent to which a project will benefit from meeting these criteria. Instead, the QAP “encourages” or “strongly encourages” projects to fulfill certain criteria or apply for certain set-asides. All other states, except Florida and (arguably Vermont) provide a quantitative scoring system.9 In doing so, these states explicitly identify their priorities and guide developers to create proposals that serve the needs of their people. This necessarily means that MHDC decisions regarding which projects do and do not receive credits are less transparent than in other states with scoring systems.

To remedy this lack of transparency, we recommend that Missouri adopt a scoring system in line with other states. Such a change would lead to proposals more in line with MHDC priorities and would serve the needs of many developers and fair housing advocates. Many developers would likely prefer clear instructions on how their projects will be scored so that they can develop truly competitive proposals. Fair housing advocates in turn would like to know precisely how much weight MHDC places on various fair housing provisions, in order to inform future advocacy. Finally, the people of Missouri would benefit from a more competitive application process, as supported by quantitative scoring information.

6 IND. HOUS. AND COMM. DEV. AUTH., 2016-2017 QUALIFIED ACTION PLAN 60 (2016), http://www.in.gov/myihcda/files/Final_2016-2017_QAP.pdf; GA. DEP’T OF COMM. AFFAIRS, supra note 27, at 14. 7 POVERTY AND RACE RESEARCH ACTION COUNCIL, supra note 23. 8 This includes each of the states bordering Missouri: Arkansas, Illinois, Iowa, Kansas, Kentucky, Nebraska, Oklahoma, and Tennessee. For a full list of state QAPs, see https://www.novoco.com/resource- centers/affordablehousing-tax-credits/application-allocation/qaps-and-applications/2016-qaps-and-applications. 9 The Florida QAP, which is only five pages long, allocates percentages of its tax credits to projects falling under certain broad categories. It does not indicate how “the Board” distinguishes between projects within these categories. See FLA. HOUS. FIN. CORP., 2016 QUALIFIED ALLOCATION PLAN LOW INCOME HOUSING TAX CREDITS PROGRAM 4-5 (2016), https://www.novoco.com/sites/default/files/atoms/files/florida_2016_final_qap_101816.pdf. The Vermont QAP differentiates between “top tier” priorities and “second tier priorities,” with projects in the top tier receiving “twice the weight” of second tier priorities. The Vermont QAP therefore allows for basic quantitative analysis in the sense that a project fulfilling a top tier priority has twice the “points” of a project that does not. When differentiating between projects in the same tier, however, the QAP states only that preference will be given to projects that (1) serve the lowest income tenants, (2) serve qualified tenants for the longest period, and/or (3) rehabilitate existing projects that are federally subsidized and “at-risk.” See JOINT COMM. ON TAX CREDITS, VERMONT AFFORDABLE HOUSING CREDIT PROGRAM 26-27 (2015), https://www.novoco.com/sites/default/files/atoms/files/vermont_2016_final_qap_100715.pdf.

We recognize that MHDC may have legitimate reasons why it has not adopted a scoring system. MHDC may wish to reserve the authority to make qualitative decisions about which projects will do the most good, without having its hands tied by a rigid scoring system. We believe that the benefits of a transparent scoring system are compelling, however, and would give the MHDC the ability to more clearly articulate its preferences to developers at the outset of the process.

3. CREATE 10% SET ASIDES FOR DEVELOPMENT IN HIGH-OPPORTUNITY AREAS

We strongly approve of the QAP’s existing preference for LIHTC projects in high-opportunity areas. Specifically, the QAP prioritizes family developments in lower poverty census tracts (<15% poverty rate) that would provide access to “high-performing school systems, transportation and employment.”10 The QAP also requires an affirmative marketing plan and a Special Marketing Reserve to assist in recruiting and relocating families from high poverty census tracts (>40%).11 These provisions are vitally important to creating opportunity through the LIHTC program. They may, however, lose out against other forces that steer LIHTC projects toward low-income, low-opportunity neighborhoods. These trends may be compounded by obligations of family developments in opportunity areas to have an affirmative marketing plan and a Special Marketing Reserve,17 which require additional time and resources of developers. Such requirements are essential to the goals of LIHTC. However, they also provide an advantage to applications in lower-opportunity areas that do not have to incorporate such a plan or reserve.

The QAP and the Code have a ready-made solution to this challenge. Both give set aside priority to LIHTC applications with other desirable but challenging features. Specifically, non-profit housing has a set aside of 10% of available LIHTC credits.

To ensure that at least some credits are going to high opportunity areas in each year, we recommend an additional 10% set aside priority for development in these areas. In making these changes, MHDC can help overcome barriers to development in high opportunity areas, development that it otherwise preferences. If it can overcome these barriers, MHDC should realize better outcomes for children and families, as demonstrated in recent scholarly research on mobility.12

10 MHDC DRAFT 2018 QAP, at 18 11 Id. 17 Id. 12 Raj Chetty et al., Where is the Land of Opportunity? The Geography of Intergenerational Mobility in the United States, (Jun. 2014), https://www.rajchetty.com/chettyfiles/mobility_geo.pdf (analyzing records of more than 40 million children to conclude that “[h]igh mobility areas have (1) less residential segregation, (2) less income inequality, (3) better primary schools, (4) greater social capital, and (5) greater family stability.”)

4. MONITOR TO ENSURE ACCESS BY SECTION 8 VOUCHER HOLDERS

Section 8 voucher holders routinely face discrimination from housing providers. Indeed, EHOC recently found that despite a recent City of St. Louis ordinance protecting voucher holders, landlords in St. Louis continue to discriminate based on source of income.13 The Code requires that owners of LIHTC properties agree not to discriminate against Section 8 voucher holders based on source of income.20 But, as seen in the case of the City of St. Louis ordinance, the existence of a prohibition does not necessarily ensure compliance. Some states ensure that project owners comply with this mandate by monitoring their behavior. For example, the Georgia QAP states that recipients of tax credits will be monitored as follows:

No project may deny a unit to Applicants possessing a Section 8 Rental Assistance certificate or voucher unless those applicants fail to meet the minimum requirements for all leaseholders. Federal statutes prohibit discrimination against Section 8 certificate and voucher holders. The number of Section 8 tenants residing at a property cannot be limited under the IRS program regulations at any property receiving [Department of Community Affairs (DCA)] Tax Credits and/or HOME [Investment Partnerships Program] funding. DCA will closely monitor whether the tenant application process is structured to avoid such discrimination or whether any actions are taken to discourage Section 8 Rental Assistance certificate or voucher holders from applying. Likewise, all lease provisions must be compatible and not in conflict with Section 8 leases.14

The Tennessee QAP takes a different approach, placing an affirmative duty on owners of LIHTC properties to actively market to Section 8 applicants:

As a part of the on-site inspection, a review will be conducted of the owner’s marketing efforts to attract special needs populations and Section 8 applicants as outlined in the extended low-income housing commitment.15

We recommend that MHDC adopt a monitoring provision to ensure that owners of LIHTC properties do not discriminate against Section 8 voucher holders in violation of the Code. The Missouri QAP already indicates that MHDC will monitor developments for compliance with the Code, which prohibits discrimination against Section 8 voucher holders. We recommend, however, that MHDC include a more explicit statement affirming that the prohibition against

13 Kameel Stanley, Housing council says local landlord discriminated against Section 8 voucher-holders in St. Louis, ST. LOUIS PUBLIC RADIO (2016), http://news.stlpublicradio.org/post/housing-council-says-local- landlorddiscriminated-against-section-8-voucher-holders-st-louis#stream/0. 20 26 U.S.C. § 42(h)(6)(B)(iv). 14 GA. DEP’T OF COMM. AFFAIRS, 2017 QUALIFIED ALLOCATION PLAN (2017), http://www.dca.state.ga.us/housing/housingdevelopment/programs/downloads/A_HFDMain/FdgRd/2017/QAP/Fin a l/2017QualifiedAllocationPlan.pdf. 15 TENN. HOUS. DEV. AGENCY, LOW-INCOME HOUSING TAX CREDIT 2017 QUALIFIED ALLOCATION PLAN (2016), https://www.novoco.com/sites/default/files/atoms/files/tennessee_2017_final_qap_121216.pdf.

Section 8 voucher holders will be strictly enforced. As such, we recommend the inclusion of the following language, modifying the existing “Compliance Monitoring” provision.16

MHDC will closely monitor whether the tenant application process is structured to avoid discrimination against Section 8 voucher holders or whether any actions are taken to discourage Section 8 Rental Assistance certificate or voucher holders from applying. Likewise, all lease provisions must be compatible and not in conflict with Section 8 leases.

Alternatively, or in addition to the above recommendation, MHDC could require that project owners affirmatively market to Section 8 voucher holders. We note that MHDC requires applications seeking the “Set-aside Preferences” basis boost to include a marketing plan demonstrating that the project will be affirmatively marketed to individuals with special needs and to vulnerable populations.17 Missouri could require a similar marketing plan designed to attract Section 8 voucher holders in its “Secondary Documentation Review” section. For example it could require a marketing plan, per the following:

i. Marketing Plan. A Marketing Plan signed by the owner/developer detailing how the applicant intends to attract Section 8 applicants.

5. REQUIRE INFORMATION ON TENANT RECRUITMENT AND SELECTION

Tenant recruitment and selection procedures can dramatically impact how well LIHTC serves vulnerable residents and the community. Missouri requires information on tenant recruitment on a post-hoc basis: The annual occupancy reports include lines for tenant income and ethnicity.18 Awardees must also submit an Affirmative Fair Housing Marketing Plan, according to the Developer’s Guide.19 These post-hoc measures are important to fulfilling the fair housing potential of LIHTC-supported projects. However, they provide no basis to select among the proposed projects: the relevant data and marketing plans do not exist until after the projects have been selected. In Missouri, before-the-fact tenant recruitment information is only required if special priority is sought. For example, developers seeking a “Special Needs Priority” or “Vulnerable Persons Priority” basis boost must submit a “draft referral and support agreement with the Lead Referral Agency,” a “Special Needs/Vulnerable Persons Marketing Plan,” and “rental assistance commitment letters” from the local public housing agency.20 Similar requirements exist for projects seeking priority based on their location in high opportunity areas which must have an affirmative marketing plan and a special marketing reserve.21 These means of

16 MHDC DRAFT 2018 QAP, at 30. 17 MHDC DRAFT 2018 QAP, at 13. 18 MO. HOUS. DEV. COMM’N, Annual Occupancy Reports for Non-Internet Reporting, http://www.mhdc.com/program_compliance/tax_credit/2004_02_19_Ex-H-NewEthnicityData.doc. 19 MO. HOUS. DEV. COMM’N, MHDC DEVELOPER’S GUIDE FOR MULTIFAMILY PROGRAMS 41 (2017), http://www.mhdc.com/rental_production/2017_fy_items/FY2017_Developers_Guide.pdf. 20 MHDC DRAFT 2018 QAP, at 12 -13. 21 MHDC DRAFT 2018 QAP, at 18. recruiting and selecting tenants need not be exclusive to special needs populations and high opportunity areas, however. All LIHTC developers should be cognizant of their tenant recruitment and selection processes, and they should describe that process in their LIHTC application. Some analogous means of identifying, recruiting, selecting, and appropriately serving all members of a LIHTC development should be employed at other buildings as well. This imperative applies to low opportunity areas, high opportunity areas, and everything in between.

To fulfill this promise, the Missouri QAP should at a minimum, require applicants to describe their tenant recruitment and selection strategies. Currently, the QAP uses tenant population as a selection criterion. It appropriately notes that “it is important MHDC fund developments offering quality affordable housing to the populations that need it in the locations where it is needed.” MHDC will be better able to evaluate applications along these lines if it also requires applicants to describe any relationships with referral agencies, marketing plans for different types of units, and any rental assistance commitment letters that would make the property accessible to specific populations. These suggestions mirror the requirements for applicants seeking a special needs priority basis boost and are provided below.

Development Characteristics. It is important the development’s characteristics are appropriate for the intended tenant population. It is also important that the intended population has access to the development, and that the development serves the needs of those who actually live there. Accordingly, the following characteristics will be reviewed closely:

a. Tenant Population It is important MHDC fund developments offering quality affordable housing to the populations that need it in the locations where it is needed. Items given consideration with regard to the intended tenants include: i. Tenant populations with special housing needs, such as persons with physical and/or developmental disabilities, homeless individuals and families, the senior, and other underserved and/or at risk populations; ii. Individuals diagnosed with mental illness; iii. Individuals on public housing waiting lists; iv. Individuals with children; v. Youth transitioning from foster care; vi. Developments serving the lowest income tenants; and vii. The quantity, quality, and suitability of services provided or offered to the tenants.

b. Tenant Recruitment and Selection

It is important to attract residents who can benefit from the proposed development and to meet the needs of actual residents. For this reason, all applicants should describe their plans for tenant recruitment and selection. Such plans should include: i. any relationships with referral agencies and whether one will serve as a lead referral agency; ii. the building’s marketing plan for different types of units; and iii. any rental assistance commitment letters that will ensure access for specific populations.

Furthermore, for projects that are seeking a special needs or vulnerable person’s priority basis boost, more detail should be provided on what constitutes a “Special Needs/Vulnerable Persons Marketing Plan.” This requirement is not defined in the QAP or the Developer’s Guide. At a minimum, such a plan should include a description of 1) the forms of media that will be used for marketing, 2) the vendors, partners, or platforms that will be used for marketing, 3) the location of such marketing, 4) the proposed content of such marketing, and 5) the intended audience and population for that marketing. We recommend including those points in the QAP as part of the Special Needs/Vulnerable Persons Marketing Plan requirement.

6. COMPLY WITH FAIR HOUSING RULES AND REGULATIONS

MHDC requires that all applications be “consistent with fair housing requirements,”22 but does not require that owners/developers certify to MHDC that they understand the requirements of the Fair Housing Act and other relevant federal statutes. We believe that requiring certification at the outset would benefit both MHDC and applicants. Applicants would have clear guidance on the standards with which they must comply. MHDC, in turn, may spend less on monitoring if applicants have a better grasp of relevant federal statutes and certify compliance to that effect.

An example of this kind of certification can be found in Nebraska’s 2016 QAP, which includes a form “Fair Housing Accessibility Certification” that must be submitted to the Authority after conditional reservation is granted.23 While the certification form is primarily intended to ensure compliance with accessibility standards (sufficient handicapped parking, accessibility ramps, etc.), MHDC could adopt a certification form that also clearly delineates groups that cannot be discriminated against under the Code, the Fair Housing Act, the Americans with Disabilities Act, and other applicable statutes.

22 MHDC DRAFT 2018 QAP, at 24. 23 NEB. INV. FIN. AUTH., LOW INCOME HOUSING TAX CREDIT PROGRAM 2016 LIHTC ALLOCATION PLAN 30 (2016), https://www.novoco.com/sites/default/files/atoms/files/nebraska_2016_final_qap_101215.pdf.

7. COLLECT AND REPORT DEMOGRAPHIC DATA ON TENANT POPULATIONS

Under the Housing and Economic Recovery Act of 2008, every state housing credit agency must annually provide information concerning the “race, ethnicity, family composition, age, income, use of rental assistance …, disability status, and monthly rental payments of households residing in each property receiving [LIHTC] credits.”31 MHDC collects this information through its tenant income certification form.32 However, Missouri’s QAP and Developer’s Guide do not provide indication of this requirement, although other states do.33 The benefits of collecting and providing these data are similar to those regarding tenant recruitment and selection. Information on recruitment and selection is essential to ensure that individual buildings serve the intended population. Likewise information on the actual tenant population is essential to ensure that LIHTC is operating to the full benefit of Missouri’s communities and residents.

In keeping with its current format, we recommend that the QAP incorporate these information- gathering requirements in both section II.B, “Development Standards,” and in section VI, “Compliance Monitoring.” As the act requires, information on the above categories should be collected “through existing reporting processes and in a manner that minimizes burdens on property owners submitted with other compliance reporting requirements.” 34 Stating this requirement may better prepare developers to provide this data in a timely and accurate manner.

B. Development Standards All MHDC-financed developments (defined as a development receiving one or more of the following: Federal LIHTC, State LIHTC, an MHDC loan, or an MHDC grant) are required to: 1. Comply with the MHDC Design/Construction Compliance Guidelines (MHDC Form 1200), as may be amended from time-to-time. 2. Comply with all applicable local, state and federal ordinances and laws …

31 42 USC § 1437z–8. In full, the rental assistance information includes: “use of rental assistance under section 1437f (o) of this title or other similar assistance.” 32 http://www.mhdc.com/program_compliance/LIHTC/documents/EXHIBIT_B_vi.docx 33 At least seventeen housing authorities provide indication of this information requirement. See POVERTY AND RACE RESEARCH ACTION COUNCIL, BUILDING OPPORTUNITY II 14 (2015), www.prrac.org/pdf/BuildingOpportunityII.pdf (Listing as “strong positive” for these reporting requirements Alaska, Connecticut, Massachusetts, Maryland, Maine, Montana, Hawaii, Idaho, Ohio, New Hampshire, New Jersey, Oregon, Pennsylvania, Rhode Island, Tennessee, Texas, Utah, Washington, Wyoming, and New York City). Many of these states do not indicate the means by which they collect this data. For example, Tennessee’s QAP states that “[o]wners shall submit, not less than annually during the compliance period and the extended use period, information concerning the race, ethnicity, family composition, age, income, use of rental assistance under Section 8(o) of the United States Housing Act of 1937 or other similar assistance, disability status, and monthly rental payments of households residing in the development in a form and with substance as THDA may require.” (emphasis added). Pennsylvania and Connecticut’s QAPs make very similar statements. 34 42 USC § 1437z–8.

3. Submit with every tenant income certification form, information concerning the race, ethnicity, family composition, age, income, use of rental assistance, disability status, and monthly rental payments of households residing in each property receiving credits. Missouri is required to collect this information and furnish it to HUD pursuant to 42 USC § 1437z–8.

V. COMPLIANCE MONITORING Section 42(m)(1)(B)(iii) of the Code mandates that MHDC, as the State Housing Agency, monitor all placed in service tax credit developments for compliance with the provisions of the Code. …

MHDC is also required by 42 USC § 1437z–8 to report to HUD annually information concerning the race, ethnicity, family composition, age, income, use of rental assistance, disability status, and monthly rental payments of households residing in each property receiving credits. MHDC will collect this information via tenant income certifications.

8. REFERENCE REHABILITATION AND RELOCATION STANDARDS

Rehabilitation projects can cause significant disruption in the lives of tenants. As such, the MHDC requires that any project that will result in the temporary or permanent relocation of tenants submit a relocation plan detailing expected expenses and services provided. While requiring a relocation plan is important, we recommend that the MHDC further protect tenants by discouraging permanent displacement and by making clear that developers should maximize the amount of time that tenants may remain in their homes.

Several other states’ QAPs seek to limit or foreclose unnecessary displacement. Maine’s 2017 QAP, for example, states that “The Applicant must take all reasonable steps to minimize the displacement of existing tenants at the Project site.”24 The District of Columbia’s 2017 Draft QAP requires that projects involving relocation submit a “Relocation and Anti-Displacement Strategy” prior to project approval.25 And for several years New Hampshire’s QAP contained the following language:

Permanent displacement of tenants is strongly discouraged. The Authority reserves the right to reject any applications that fail to minimize permanent displacement of tenants.

35 ME. STATE HOUS. AUTH., 2017 LOW INCOME HOUSING TAX CREDIT QUALIFIED ALLOCATION PLAN 21 (2017), https://www.novoco.com/sites/default/files/atoms/files/maine_2017_final_qap_080216.pdf. 36 DEP’T OF HOUS. AND COMM. DEV., 2017 DRAFT LOW INCOME HOUSING TAX CREDIT QUALIFIED ALLOCATION PLAN 19 (2017), https://dhcd.dc.gov/sites/default/files/dc/sites/dhcd/publication/attachments/DHCD_2017%20QAP%20FINAL%20d raft.pdf

Any proposed temporary or permanent relocation of tenants should generally meet standards equivalent to the federal Uniform Relocation Act (URA).26

We recommend that MHDC similarly discourage permanent displacement and make clear that temporary displacement should be minimized whenever possible. Such language could be included in the “Housing Needs” section of the QAP, which already specifies that the MHDC will not approve applications proposing the delivery of new units under certain conditions. We have included proposed language below.

a. Housing Needs

Developments must address the affordable housing needs of the state, region, and locality where they will be located. Important considerations regarding market need include: … No application proposing the delivery of new units will be approved if it is deemed by MHDC to adversely impact any existing MHDC development(s), exist in a questionable market, or create excessive concentration of multifamily units.

For applications proposing the rehabilitation of existing housing, permanent displacement of tenants is strongly discouraged. The applicant must take all reasonable steps to minimize the displacement of existing tenants.

The MHDC could also require that the “relocation plan,” which is described in greater detail in the Developer’s Guide,38 include as part of its “narrative” a strategy for minimizing the displacement of residents.

9. REQUIRE AN AFFIRMATIVE FAIR HOUSING MARKETING PLAN

Missouri’s 2018 QAP makes clear that, pursuant to its obligations under the Fair Housing Act,

MHDC is fully committed to affirmatively furthering fair housing by taking meaningful actions to promote fair housing choice, overcome patterns of segregation, and eliminate disparities in access to opportunity, and consequently, MHDC will consider the extent to which a certain development affirmatively furthers fair housing when deciding which developments should be recommended for funding.

37 N.H. HOUS. FIN. AUTH., 2013 QUALIFIED ALLOCATION PLAN FOR THE LOW INCOME HOUSING TAX CREDIT PROGRAM 13 (2012), https://www.novoco.com/sites/default/files/atoms/files/newhampshire_final_13_082912.pdf 38 MHDC DEVELOPER’S GUIDE, at 46.

In accordance with HUD guidance, MHDC requires that developers submit an Affirmative Fair Housing Marketing Plan as part of the compliance process detailed in the Developer’s Guide.39 We believe that MHDC should go one step further to state this requirement in the text of the QAP itself. Doing so would communicate MHDC’s commitment to effectuating the fair housing mission underlying the LIHTC program, and encourage developers to think about the AFHMP during the application process and not just during compliance. Iowa and Illinois present excellent examples of how to implement an AFHMP provision in a QAP.27 Their respective provisions specify that developers must affirmatively reach out to underserved populations when soliciting tenants. We include a model provision below, largely adapted from Illinois’s version of the AFHMP provision. We recommend that this provision be included in the “Primary Documentation Review” section of the Missouri QAP. Affirmative Fair Housing Marketing Plan. It is the policy of MHDC to administer the Tax Credit program affirmatively, so as to achieve a condition in which individuals of similar income levels in the same housing market area have a like range of housing choices available to them regardless of their race, color, religion, sex, disability, familial status or national origin. Each applicant shall pursue affirmative fair housing marketing policies in soliciting tenants and outreaching to underserved populations and those least likely apply to reside in completed tax credit units. Each project receiving an allocation of Tax Credits will be required to submit an Affirmative Fair Housing Marketing Plan outlining how the Project will market units to underserved tenants, including tenants with special needs.

In conclusion, we applaud MHDC’s recent actions to prioritize developments that seek to deconcentrate poverty and racially segregated areas. We urge MHDC to consider our comments and recommendations as part of the review of proposed multifamily rental production programs for 2018 and future years. Thank you for the opportunity to provide comments.

Sincerely,

Will Jordan

Executive Director

39 MO. HOUS. DEV. COMM’N, LOW-INCOME HOUSING TAX CREDIT PROGRAM COMPLIANCE MONITORING MANUAL 13 (2006), http://www.mhdc.com/program_compliance/tax_credit/Tax_Credit_Manual_FINAL_Posted_112006.pdf

40 See IOWA FIN. AUTH., LOW-INCOME HOUSING TAX CREDIT PROGRAM 2017 9% QUALIFIED ALLOCATION PLAN 52 (2017), https://www.novoco.com/sites/default/files/atoms/files/iowa_2017_final_qap_030117.pdf; ILL. HOUS. DEV. AUTH., 2016-2017 LOW INCOME HOUSING TAX CREDIT QUALIFIED ALLOCATION PLAN 34 (2016), https://www.novoco.com/sites/default/files/atoms/files/illinois_2016_final_qap_032816.pdf.

Mid-City Lumber Co. LTD Gene Sadner [email protected]

Dear Housing Development Commission,

Thank you for giving me the opportunity see send you this email regarding the proposed changes on the QFY2018 Qualified Allocation Plan. My name is Gene Sandner and I am the general manager for Mid-City Lumber, a locally owned building supply company with four locations in headquartered in Columbia Mo. We have partnered with various tax credit developments in Missouri over the years and I know that these projects are benefit to our communities and to our business. They have had a significant impact by the creation of jobs and the generation of tax dollars from both labor and materials.

Our company, Mid-city Lumber has supplied and worked with various developers on many projects and we are very proud to have helped provide homes for low to moderate income seniors and families. There is little in life of anymore importance than for people to have a home and for them to have a place to call their own! We employ over 100 people here in central Missouri and we want you to know that those tax credits have helped us to do that. As an important part of our community I ask you to move forward and continue the Low Income Housing Authority Tax credit program as was adopted by the Missouri Legislature.

Thank You.

Gene Sandner MID-CITY LUMBER CO., LTD. 4709 Paris Rd. Columbia, MO 65202 417-474-9531 Office

Missouri Workforce Housing Association Smith, Jeff [email protected]

To whom it may concern:

Please see the Missouri Workforce Housing Association's feedback on the draft QAP, attached. Many thanks for your consideration,

Jeff Smith Executive Director Missouri Workforce Housing Association www.moworkforcehousing.com (314) 323-0915 (c)

Letter as attached:

To: MHDC Leadership From: Missouri Workforce Housing Association Contact: Jeff Smith, MOWHA (314) 323-0915 (m) Date: December 4, 2017 Re: QAP feedback I. First and foremost, MOWHA would like to express vehement disagreement with the proposed “federal credits only” Qualified Allocation Plan. The rhetoric of those backing this proposal has distressed the entire affordable housing community – from developers to advocates and residents. Below are some reasons for the distress:

A. A QAP without state credits will reduce the number of units built by at least one-third at a time when the need for affordable housing is more acute than ever.

Missouri has long assisted seniors, veterans, low-income families and the disabled secure safe, quality affordable housing to remain productive and independent. For 25 years, we have achieved this policy goal via the state low- income housing tax credit. As baby boomers age (and Missouri’s population is aging even faster than the rest of the nation), our veteran community grows, and the disabled face serious challenges, the need for affordable housing will continue to increase. Current affordable housing waitlists in St. Louis City, St. Louis County, and Kansas City Housing Authorities waitlists range from 4,000-25,000 people; lists in smaller counties often exceed 1,000. Nearly all of the county waitlists are so full that they are closed to new applicants. Another study counted 16,000 homeless schoolchildren, excluding kids age 0-5. B. Without state credits, most rural deals will not work without substantially higher rents. This will not only deny thousands of people a safe, decent, affordable home, but will deepen the state’s already stark urban- rural divide. While urban developers may be able to access additional resources such as municipal government loans, rural developers will be unable to make deals work.

C. Contrary to the rhetoric of those proposing to eliminate state credits, LIHTCs are the most efficient way to finance affordable housing development.

The Governor’s Tax Committee proposed using forgivable loans to finance affordable housing. But tax credits are more efficient as they're less taxable. Forgivable loans would cost the state up-front, creating a huge short term fiscal note.

Proponents of “federal credits only” make outdated, misleading statements like “only 42 cents of each dollar goes into housing” and suggest that their magic wands can make federal taxes disappear. First of all, market pricing is currently 56-58 cents. Second, pricing takes into account 1) federal taxes; and 2) decreased value of credits in years 2-10 due to inflation (i.e., time value of money). That the credits sell for 58-59 cents is a sign of efficiency, not waste.

D. Again, contrary to the overblown rhetoric, investors are making reasonable returns.

Investors paying 58 cents for a 10-year stream of credits that don’t begin paying out until 3 years after purchase are making a pre-tax 8.6% return on an unsecured loan. Historically, an investor would fare much better with less hassle and worry investing in the S&P 500, or nearly as well with worry-free U.S. Treasuries.

E. LIHTCs minimize risk to state taxpayers; state loans load risk onto taxpayers

If the state substituted forgivable loans for state credits as proponents of the “federal credits only” regime have proposed, taxpayers would incur 100% of the risk. Currently, the state incurs no risk because investors provide up- front money and additional capital if the project becomes distressed. Credits don't flow until units are leased according to stringent guidelines, and are recaptured if projects fail to comply. There would be no way to “recapture” a state loan to a developer whose project fails.

F. LIHTC developments create unrecognized cost savings elsewhere in the budget.

Given local governments’ cost providing emergency care for feeble seniors and disabled people in dilapidated homes, many expenses are never incurred, and lives are saved, when emergencies are spotted earlier in a large community with on-site support services.

Senior projects are an especially wise use of tax dollars because of Medicaid savings from reduced nursing home use. LIHTCs helped build an average of 800 new senior units annually. Of those, over 40% of residents can avoid nursing homes thanks to special services provided in LIHTC units. Nursing home units costs the state $29,871 per unit annual, while the annual LIHTC allocation per senior unit is $7,773. Multiplying this difference by the number of seniors diverted demonstrates that tax-credit senior housing saves the state $7.4M annually.

Homeless veterans are another key constituency LIHTC supports. LIHTC helps groups like The Salvation Army to build affordable housing with on-site support, sparing government from delivering costly mental health and medical services to veterans struggling with PTSD and substance use issues.

II. AHAP

We are perplexed by the Commission’s proposed prohibition on the use of Affordable Housing Assistance Program (“AHAP”) tax credits for housing production purposes. AHAP provides donors with $0.55 in Missouri tax credits for every dollar of charitable contribution donors make to eligible tax exempt organizations. The contributions are then used in the financing of affordable housing. This translates into the State receiving $1.82 in affordable housing investment for each tax credit dollar spent, which is a great deal for the State.

And, if the State LIHTC is disallowed under the 2018 QAP, there would be no “layering” of State tax credits when using AHAP credits with Federal LIHTCs. Does MHDC want to give up $1.82 in affordable housing investment for each dollar it spends in tax credits and stop encouraging charitable contributions for affordable housing?

Proponents of the “federal credits only” regime have argued that not enough of each dollar goes into housing construction. It is certainly difficult to square that claim with the new AHAP rule which eliminates arguably the most efficient tool available to leverage private investment.

III. Other specific issues

(QAP language is highlighted in yellow; MOWHA feedback is boldfaced.)

In section II. Standards – Development Standards Added a section: “All applications for MHDC funding must establish the development will include sufficient broadband infrastructure in accordance with Narrowing the Digital Divide. Through Installation of Broadband Infrastructure in New Construction and Substantial Rehabilitation of Multifamily Rental Housing, 81 FR 92626 (the "HUD Broadband Rule"). By not limiting the new broadband standard to projects that receive HUD funding, MHDC appears to exceed the scope of the HUD rule. – Underwriting Standards Revised the guidelines on maximum consultant fees to read: “If the consultant is not providing development guarantees, whether to any lender or any other partner or member of the ownership entity, then the maximum allowable consultant fee cannot exceed thirty percent (30%) of the total developer fee.” We do not understand the rationale for this. If the proposal doesn't change the total developer fee, what is MHDC’s impetus to intervene? In other words, why should MHDC concern itself with the division of the fee between development partners? That some nonprofits doing LIHTC deals lack the financial wherewithal to either (a) have lenders and investors accept a guaranty from them, or (b) that lenders and investors are accepting guaranties from nonprofits who lack sufficient assets to back them up, is problematic from a safety and soundness perspective. It is unusual to expect a consultant to provide guaranties for its clients or limit its fees to an arbitrary amount. In fact, in some cases nonprofits with very limited capacity rely on the consultant for most (if not all) of the work even as the nonprofit receives most of the fee. If they truly lack the assets to back up a guaranty, then they are taking little risk, because no one will sue them. Added: “Service Escrow - If the developer proposes an escrow for services, and that escrow is not funded by a grant specific to the development services, the developer must contribute at least 50% of the escrow amount from the developer fee. Developments requesting priority status will be reviewed on a case by case basis and extent of services will be taken into consideration. Developments offering services, but not selecting the priority and not receiving a services grant, will be one hundred percent (100%) developer funded and should be deducted from the Developer’s Fee.” If an applicant is not applying under the "service priority" and wants a service escrow, it must be funded entirely from the developer fee. This discourages building a service escrow into the project. If MHDC is concerned that some have proposed overly high service escrows, why not limit the amount allowed without developer fee contribution? III. Reservation Process

--Housing Priorities In the Special Needs section, “Rents should be as affordable as possible to special needs households. Affordability can be accomplished through project-based or tenant-based subsidies. The Lead Referral Agency is responsible for coordinating tenant-based rental assistance with service providers or governmental agencies, whenever necessary and possible. In the absence of project- based or tenant-based assistance, the owner should consider other methods to ensure rents are affordable to special needs households. If proposed rents for special needs units are above 30% AMI rents, the applicant must provide evidence that special needs tenants will qualify at 30% of their income for the special needs unit proposed rents. In no circumstance should special needs tenants pay more than the greater of 30% AMI rents, or 30% of their income towards rents.” The QAP reads: "Affordability can be accomplished through project-based or tenant-based subsidies." However, receiving a project-based subsidy is very rare. Assuming the tenant-based subsidies are not vouchers, which all LIHTC properties must accept under all circumstances, then are developers expected to fund the tenant-based subsidies out of developer fees? This could be a potential use for NHTF money, but lenders and investors will be skittish about appropriation risk. In the Service Enriched Section, Added “Veterans” to the list of targeted populations. Added a priority: Independence Enabling Housing Units Added a Veteran’s Housing Priority

This now adds up to 14 Priorities in the QAP: 1. Nonprofit Involvement Set-aside (required by IRS Code) 2. Special Needs (eligible for up to 30% basis boost) 3. Service-Enriched Housing (eligible for up to 30% basis boost) 4. Preservation (eligible for up to 30% basis boost) 5. MBE/WBE 6. Property Disposition 7. Compliance Period and Affordability (agree in advance to waive opt out of LIHTC LURA) 8. 50% AMI (at least 15% of total units at 50% AMI, as revised by 2018 QAP) 9. Workforce Housing (eligible for up to 30% basis boost)—15-25% of total units are at 60-80% AMI, as revised by 2018 QAP 10. Transit Oriented Development (eligible for up to 30% basis boost) 11. Redevelopment Plan 12. Opportunity Areas 13. Independence Enabling Housing Units (eligible for up to 30% basis boost)—NEW for 2018. 14. Veteran’s Housing (eligible for up to 30% basis boost)—NEW for 2018.

Mo Citizen [email protected] “Tax Credit Reform”

These state housing tax credits are not efficient as they could be, and they are putting a mortgage on the future 10 years of budgets every time they're issued. How is that fair to future generations? Spending their money, now? That's not being talked about, it seems.

And wow, these reports that people in affordable housing are going to be kicked out of their housing certainly must be false, and the media is creating a scare, to sensationalize the story. As I understand it, it is for the new construction of affordable housing. Let’s not forget the state tax credit is just a portion of the overall funding involved in financing of these developments. This sounds like it would just be possible reduction in the amount of new housing created. Affordable housing can still be built in Missouri, but the state tax credit portion of it needs to be done in a more cost-effective manner.

Lawmakers; here's an idea -- simply eliminate the State Tax Credit and create a yearly appropriation that is dollar- for-dollar, that we account for more efficiently. No more of this 'here's 40 cents, I'd like a full dollar for that please'. Even if is a reduction in tax liability, it's still the same. Please don't put campaign contributions and special interests in front of what is best $ for the state.

The majority of other states have no state housing tax credit, and seem to do okay. Don't forget the Federal Tax Credit is still in place, and while it isn't as dysfunctional as the state tax credit, it is more efficient. The method the MHDC is taking to cut them at the board level seems unprecedented, but I'm in favor of the Commission moving forward with a plan that doesn't include state tax credits this year, and force the legislative bodies to reform the program.

Time to tighten the belt on wasteful spending in Missouri, and this is a great opportunity to do so – while continuing to provide affordable housing subsidies.

Respectfully, Concerned Citizen

National Housing Trust Fund Abernathy, Laura [email protected] “MO State LIHTC Program”

Dear Commissioners,

Thanks to the Missouri State LIHTC program, Missouri has financed significantly more projects each year than similarly sized states receiving comparable allocations of the federal Low Income Housing Tax Credit (Housing Credit). In 2015, Arizona and Indiana received an allocation of competitive Federal Housing Credits comparable to that received by MHDC, with Arizona receiving $14,879,832, Indiana receiving $15,801, 908, and Missouri receiving $14,436,500. Yet while Arizona and Indiana were only able to finance 944 and 1,043 affordable apartments with the competitive Housing Credit that year respectively, Missouri was able to finance 1,415 affordable rental homes with their comparable allocation of competitive federal Housing Credits. Unfortunately, even the additional units MHDC is able to finance each year are not enough to keep pace with the growing need for affordable housing. Waitlists for rental assistance in Missouri are years long, and the St. Louis, St. Louis County and Kansas City Housing Authorities waitlists range from 4,000-15,000 people. In Missouri, a minimum age worked has to work 76 hours per week in order to afford a modest one-bedroom apartment. The state LIHTC program is a critical piece of meeting Missouri’s affordable housing needs.

As Missouri’s population ages, the veteran community grows, and the disabled face serious challenges, the need for affordable housing will continue to increase. Now is not the time to move away from a dedicated, cost-effective, and trusted program to create and preserve affordable housing.

The National Housing Trust and the Natural Resources Defense Council strongly urge MHDC to continue its commitment to providing affordable housing options and serving the state’s most vulnerable by maintaining the State Low Income Housing Tax Credit. Attached, please find NHT’s formal letter in support of the MO State LIHTC program.

Thanks, Laura. ______Laura Abernathy State and Local Housing Policy Director | National Housing Trust 202-333-8931 x 137

Attached letter as follows:

December 4, 2017

Missouri Housing Development Commission 920 Main Street, Suite 1400 Kansas City, MO 64105

Re: Missouri State Low Income Housing Tax Credit Program

Dear Commissioners:

The National Housing Trust is a national nonprofit organization formed to preserve and revitalize affordable homes to better the quality of life for families, veterans, and elderly who live there. The National Housing Trust engages in housing preservation through real estate development, lending and public policy. Since its inception, NHT and our affiliate, NHT-

Enterprise Preservation Corporation, have preserved more than 36,000 affordable apartments in all types of communities, leveraging more than $1.2 billion in financing.

The Natural Resources Defense Council (NRDC) is an international nonprofit environmental organization with more than 2 million members and online activists. Since 1970, NRDC's lawyers, scientists, and other environmental specialists have worked to protect the world's natural resources, public health, and the environment. NRDC focuses on a variety of environmental issue areas including energy, health, communities, water, food, and wildlife.

Together, NHT, the Natural Resources Defense Council and Missouri-based partners have been working together since 2013 on an initiative titled Energy Efficiency for All to scale-up efficiency investments in the multifamily affordable housing sector in Missouri.

NHT strongly urges MHDC to continue its commitment to providing affordable housing options and serving the state’s most vulnerable by maintaining the State Low Income Housing Tax Credit.

Sincerely,

RISE Community Development Stroker, Mark [email protected] St. Louis “Comments to the November 17th MHDC Qualified Allocation Plan “

I would strongly encourage the Missouri Housing Development Commission to restore the Missouri state low-income housing tax to the allocation plan. It is an invaluable resource that likely all projects statewide in the development pipeline are contemplating as a source. Refusing to allocate the state credit will certainly make many projects unworkable, greatly reduce the number of new affordable units able to be built or rehabilitated, seriously blunt the economic impact typically associated with affordable projects and greatly limit the scope and impact of community development initiatives.

I would recommend that the Commission add a discretionary basis boost for financial feasibility. It will be imperative for many planned projects if the state credit is otherwise unavailable.

Respectfully submitted,

Mark Stroker, Director of Real Estate Development Rise Community Development

Rosenblum Goldenhersh Beck, Brian J. [email protected] St. Louis “Public Comments to Draft 2018 Qualified Allocation Plan”

Dear Mr. Metz- Attached please find public comments to the Draft 2018 Qualified Allocation Plan. Respectfully submitted,

Brian J. Beck, Esq.

ROSENBLUM GOLDENHERSH

7733 Forsyth Boulevard, Suite 400

St. Louis, MO 63105

tel: 314.726.6868 | dir: 314.854.0424

fax: 314.726.6786

www.rosenblumgoldenhersh.com

Letter as attached:

M E M O R A N D U M

TO: Missouri Housing Development Commission (“MHDC”) 920 Main Street, Suite 1400 Kansas City, MO 64105

FROM: Below Listed Members of the Missouri Affordable Housing Legal Community

DATE: December 4, 2017

RE: Comments to Draft 2018 Qualified Allocation Plan submitted to MHDC by Senator Jason Crowell

======We have reviewed the Draft 2018 Qualified Allocation Plan submitted to MHDC by Senator Jason Crowell (the “Crowell Draft QAP”), and urge you not to adopt it. It is our opinion that the Crowell Draft QAP ‘s intentional omission of an allocation process for the Missouri LIHTC is in direct violation of MHDC’s statutory duties and responsibilities set forth in the Section 135.350 et. seq. RSMO (the “State LIHTC Act”).

Specifically, Section 135.352.4 of the State LIHTC Act provides:

For qualified Missouri projects placed in service after January 1, 1997, the Missouri low-income housing tax credit available to a project shall be such amount as the commission shall determine is necessary to ensure the feasibility of the project, up to an amount equal to the federal low-income housing tax credit for a qualified Missouri project, for a federal tax period, and such amount shall be subtracted from the amount of state tax otherwise due for the same tax period. (emphasis added).

MHDC’s statutory duty to “ensure the feasibility of each project” requires MHDC to individually consider each project’s need for an allocation of State LIHTC. The Crowell Draft QAP violates this statutory duty by failing to allow State LIHTC to be approved for any project. Further, as the Missouri Legislature acknowledged by enactment of the State LIHTC Act in

1990 and as MHDC’s own 25 plus years of prior faithful administration of the program undeniably demonstrates, an allocation of State LIHTC is necessary to ensure the feasibility of most, if not, all Missouri projects, so any assertion that the Commission could uniformly withhold State LIHTC from all 2018 projects is without any basis in law or fact.

The Crowell Draft QAP further violates MHDC’s statutory obligations set forth in other provisions of the MO LIHTC Act in a similar manner. For example, Section 135.350(3) of the State LIHTC Act provides:

The commission shall promulgate rules establishing criteria upon which the eligibility statements will be issued. The eligibility statement shall specify the amount of the Missouri low-income housing tax credit allowed. The commission shall only authorize the tax credits to qualified projects which begin after June 18, 1991. (emphasis added)

Again, the State LIHTC Act makes clear that MHDC must establish “criteria upon which the eligibility statements will be issued” to allow projects to be considered on an individual basis. MHDC cannot indiscriminately and arbitrarily deny all 2018 projects the right and opportunity to receive State LIHTCs.

Together the undersigned members of Missouri’s affordable housing legal community urge MHDC’s Commissioners to refuse to adopt the Crowell Draft QAP, and adopt the original 2018 Draft QAP proposed at the November 17, 2017 MHDC meeting by Frank Quagraine, Director of Rental Production meeting, which includes the normal allocation process for both Federal LIHTC and State LIHTC.

Thank you.

Brian J. Beck, St. Louis, MO, Rosenblum Goldenhersh, P.C. David T. Woods, St. Louis, MO, Rosenblum Goldenhersh, P.C. Jennifer A. Merlo, St. Louis, MO, Rosenblum Goldenhersh, P.C. David S. Lang, St. Louis, MO, Rosenblum Goldenhersh, P.C. Carl C. Lang, St. Louis, MO, Rosenblum Goldenhersh, P.C. Michael A. Markenson, St. Louis, MO, Rosenblum Goldenhersh, P.C. Alexander H. Kuehling, St. Louis, MO, Rosenblum Goldenhersh, P.C. Matthew W. Potter, St. Louis, MO, Rosenblum Goldenhersh, P.C. Thomas A. Duda, St. Louis, MO, Rosenblum Goldenhersh, P.C. Kelly C. Rock, St. Louis, MO, Rosenblum Goldenhersh, P.C. Roger M. Herman, St. Louis, MO, Rosenblum Goldenhersh, P.C. Sean P. Clancy, St. Louis, MO, Rosenblum Goldenhersh, P.C. S. Shawn Whitney, Springfield, MO Spencer Fane LLP Richard Walters, Springfield, MO Spencer Fane LLP Adlai Groves, Springfield, MO Spencer Fane LLP Nick Irmen, Springfield, MO Spencer Fane LLP Elizabeth Fast, Kansas City, MO Spencer Fane LLP Nate Orr, Kansas City, MO Spencer Fane LLP Allison Tanner, Kansas City, MO Spencer Fane LLP Matthew Wine, Kansas City, MO Spencer Fane LLP Tom Jerry, St. Louis, MO Spencer Fane LLP Roger Denny, St. Louis, MO Spencer Fane LLP Carl Desenberg, St. Louis, MO Spencer Fane LLP Jim Loranger, St. Louis, MO Spencer Fane LLP Jack Coater, St. Louis, MO Spencer Fane LLP Francis Slay St. Louis, MO Spencer Fane LLP

Simmons, Ian [email protected] Law office of Ian C. Simmons, LLC St. Louis “Please Save the LIHTC”

I personally witnessed the power and importance of the LIHTC in the last 10 years in the neighborhood of Fox Park, in the City of St. Louis. The credit allowed investment into that and surrounding neighborhoods, which also allowed hundreds of people to find affordable housing in a safe community. Taking away this tool will have immediate and long lasting effects, and will stop the forward momentum that is now present in so many places where this credit has been utilized. For those reasons, I urge you to save MO’s LIHTC. Thank you for your consideration.

Skelton, Kelly [email protected] St. Louis, MO “State LIHTC program”

Hello,

Thank you for this opportunity to comment.

Sincerely,

Kelly Skelton St. Louis, 63109

Zimmerman, Paulette [email protected] “LIHTC”

I feel strongly that Governor Greiten's actions to remove the state LIHTC program are highly inappropriate and I thank Lt. Governor Parson and State Treasurer Schmitt for voting "no" to remove LIHTC from the 2018 LIHTC application under the QAP.

I am further concerned with the efforts to remove state LIHTC outside of our General Assembly. The Legislature allocated our tax dollars to fund the State LIHTC program for 2018. It is not appropriate for the Governor, a few state elected officials, and three unelected commissioners to take away our voice on this issue. I want my elected representative and state senator to have the opportunity to discuss changes to the LIHTC program and to discuss alternative solutions in the 2018 legislative session, instead of this current proposal.

Thank you.

Paulette Zimmerman, SSND