The Ohio Housing Council provides feedback on the second draft of the 9% LIHTC Qualified Allocation Plan for Program Years 2026-2027, acknowledging meaningful improvements while raising continued concerns about program implementation and flexibility.

Key recommendations include:

• Returning amenities to scoring criteria rather than mandatory threshold requirements to preserve developer flexibility
• Publishing concrete implementation examples showing how the complex regional allocation framework operates in practice
• Providing accessible census tract-level LIHTC award data to ensure equitable access to competitive information
• Refining set-aside tiebreaker procedures to apply appropriate criteria across all project types
• Conducting analysis to prevent unintended consequences from the interaction between regional distributions and set-asides

While appreciating OHFA's responsiveness to stakeholder concerns, OHC emphasizes that greater clarity and flexibility are essential for developers to make informed decisions and for the program to effectively serve Ohio's diverse housing needs.