The Ohio Housing Council provides detailed feedback on the first drafts of the 2027 Design and Architectural Standards and Design and Architectural Process Manual. The letter credits OHFA for a genuine, responsive process while making clear that this draft falls well short of the ground-up rewrite OHFA promised and OHC supported.

Key findings and recommendations include:

• Burden of Justification: Provisions throughout the draft lack stated rationale. No requirement should appear in the second draft without answers to three questions: what problem does it solve, what does it cost, and is the benefit worth that cost? OHC identifies N3.5.5 (PLAM countertop corners) as a model provision that names the problem, leaves the means to the professional, and disclaims any single prescription.
• Compare to the Market: Several provisions exceed what comparable market-rate housing requires without explanation, including five-foot sidewalk widths (N3.1.4), solid-core interior doors (N3.7.1.2), and Energy Star V6 window specifications (N3.9.2.5). Where OHFA exceeds market practice, it should state the Ohio-specific reason that market standard is insufficient.
• Prevent a Race to the Bottom: OHC is not asking OHFA to abandon all floors. It asks OHFA to keep floors that prevent a genuine race to the bottom — such as the solution-dyed nylon carpet requirement — and remove those that do not.
• Give Historic Rehabilitation a Home: The draft's two-track structure (new construction and rehabilitation) leaves historic rehabilitation with no workable path. OHC recommends either a dedicated historic track or a document-wide carve-out, an expanded SHPO materials exemption, a written OHFA commitment to coordinate with SHPO with all parties at the table, and a predictable exception process keyed on a project's pursuit of historic tax credits.
• OHC Supports: OHC affirmatively supports the removal of the paperless gypsum requirement, the sustainability section's shift to performance-verified certification, reduced efficiency-unit minimums, and several rehab-specific tailoring provisions that demonstrate OHFA can and does differentiate by project type.
• Process Manual: OHC requests substantive criteria for evaluating exception requests and public publication of exception outcomes with brief rationale, so that approved exceptions can function as de facto guidance and the process becomes predictable and equitably accessible.

OHC asks OHFA to build the second draft from the floor up, justifying each retained requirement, relocating preferences to the QAP, preserving flexibility already provided by code and federal law, and giving historic rehabilitation a real home. 

OHC's Letter to OHFA