The Ohio Housing Council provided feedback on OHFA's second draft of the 2027 Design and Architectural Standards (DAS) and Design and Architectural Process Manual (DAPM), finding the revised drafts a substantial improvement with fewer provisions, better organization, and a demonstrated willingness to reconsider requirements rather than defend them.

Key points include:

• Provisions OHFA removed or improved. OHC specifically credited the deletion of the common area cap, the elimination of minimum bedroom sizes, the cleanup of duplicative energy provisions, the narrowing of the moisture-resistant gypsum requirement to an enumerated list, and the removal of the rocker switch requirement from rehabilitation.
• New guidance on rehabilitation exception requests. The second draft identified seven considerations OHFA will weigh when existing units fall below minimum sizes, which OHC described as the kind of transparency that makes the exception process work as intended.
• ENERGY STAR Version 7 windows. OHC questioned tightening the window standard on the premise that the cost premium has closed, and asked OHFA to publish supporting pricing analysis, retain Version 6 until it exists, or allow Version 6 compliance for projects meeting a green building certification.
• No-step entry and code restatements. OHC sought clarification that the no-step entry provision does not extend to every unit door, which would foreclose garden-style walk-up construction, and renewed its request to remove provisions that restate building code.
• Kitchen landing zones. OHC asked OHFA to add an alternative compliance path based on total usable countertop, an approach raised during the Columbus stakeholder session.
• Scope in mixed-income developments. The draft inconsistently removed "affordable" as a modifier of "units," and OHC recommended a single statement of applicability in the General section.
• Leasing and occupancy obligations. OHC renewed its request for guidance on marketing and occupancy obligations where accessible units remain vacant despite good-faith efforts.
• Process Manual improvements and refinements. OHC supported the six-week review commitment, the required meeting in place of exchanged letters, and the new Exception Inquiry process, while asking that reviewers cite the specific provision being applied, that blower door test failures be addressed, and that Exception Inquiries be supported by information reasonably available at the time of submission.

OHC's letter closed by recognizing the seriousness with which OHFA has approached this rewrite, noting that a few relatively small but meaningful changes would produce a document that ensures safe, decent, affordable housing without imposing unnecessary and costly requirements.

OHC's Letter to OHFA