Advocate for Sustainable Design in the Connecticut Low-Income Housing Tax Credit program

One of our ongoing advocacy initiatives is to ensure Sustainable Design tax incentives are available for developers through the Low Income Housing Tax Credit (LIHTC) program. These tax credits have a powerful impact on a developer’s decision to build healthy, comfortable, low energy buildings for affordable housing while also helping to meet the state’s goals of reducing greenhouse gas emissions and increasing the resiliency of our building stock.

The Qualified Allocation Plan (QAP) designates these tax credits in the form of points for meeting various qualifications. Competition among developers is fierce, so the allocation of points in the QAP for specific high-performance criteria determines the type of projects that are pursued and approved for funding.

Public Hearing on Tuesday, July 7 at 10:00am

See #2 below

Written statements due Friday, 7/10

See #3 below for three simple steps

1. What you need to know:

Connecticut Housing Finance Authority (CHFA) is inviting comments on their proposed Low Income Housing Tax Credit (LIHTC) Qualified Allocation Plan (QAP) which sets priorities and criteria for awarding federal tax credits to housing properties.

This is an opportunity for the green building community to promote and advocate for sustainable design in publicly funded housing.

See the proposed, redlined 2027-28 QAP. “Sustainable Design Measures” are in Exhibits A-1 & A-2 on pages 30-32.

BuildGreenCT is advocating to reinstate the framework from the 2024-2025 QAP and enhance the Preservation section.

Some history:

Sustainability Measures have weakened since the 2024-25 QAP which had 13 maximum sustainable design points (pp 32-37) .

The current 2026 QAP has 9 points (pp 28-30) and removed prerequisites (benchmarking, balanced ventilation, DOE certification), commissioning, the Renewables, Electrification and Resiliency section, the Operations and Resiliency section, and ILFI.

Removed from Preservation (Exhibit A-1)

  • Expectation for benchmarking, backup power for critical systems, and commissioning.

Removed from New Construction (Exhibit A-2)

  • Prerequisites for benchmarking, DOE Zero Energy Ready Home (now “Efficient New Homes”), and balanced ventilation,
  • A point from Energy Conservation and a tier,
  • International Living Future Institute (ILFI) Zero Energy Ready from Energy Conservation,
  • Renewables, Electrification and Resiliency section of New Construction which included points for multi-level targets for PVs, all-electric buildings, backup power, and battery storage for critical systems,
  • Operations and Resiliency section of New Construction including points for owner paid utilities, commissioning, and backup power.

The proposed 2027-28 QAP has 11 points (pp 30-32), adding back the balanced ventilation prerequisite and commissioning points.

We need to do better

BuildGreenCT’s suggested goals:

A.

Reinstate the framework from the 2024-2025 QAP which was developed by a working group of diverse stakeholders with hours of volunteer effort to arrive at a robust and flexible point framework which allowed developers to get points in a variety of different ways and in different categories. Restore:

  • DOE Efficient New Homes program (formerly Zero Energy Ready Home) prerequisite. Any publicly funded building projects should have to meet this minimum energy conservation level.
  • Benchmarking requirements for Preservation and New Construction sections. These tools help buildings run optimally, helping to reduce operating costs and meet sustainability goals.
  • Commissioning and backup power for critical systems for Preservation section. Renovations require the same attention to these areas as new construction.
  • Tiers and points with four possible Energy Conservation points.
  • The full “Renewables, Electrification and Resiliency” category with specific PV offset targets, all-electric buildings, backup power, and battery storage.
  • The full “Operations and Resiliency” category with tiers including owner paid utilities giving them extra incentive to build for low energy.

B.

Enhance Exhibit A-1 Preservation. Connecticut’s existing building stock should be embraced as part of the solution to our housing crisis, not overlooked. Treating the Preservation category in the same manner as New Construction reinforces the importance of renovating for energy efficiency and sustainable design and should be rewarded for meeting retrofit energy standards.

Add an “Energy Conservation” category with criteria tiers with increasing points for meeting, shown with WUFI Passive or Pass­ive House Plan­ning Pack­age (PHPP):

  • Tier 1: PHI Low Energy Building Standard benchmark
  • Tier 2: PHI EnerPHit Classic
  • Tier 3: PHI EnerPHit Plus OR Phius CORE REVIVE
  • Tier 4: PHI EnerPHit Premium OR Phius REVIVE ZERO
  • An additional point can be earned with Passive House Certification.

Talking points:

Thank CHFA for including points for Sustainable Design Measures for many cycles. Acknowledge their leadership with their continued push to ensure the creation of high-quality affordable housing.

Thank CHFA for adding the balanced ventilation prerequisite and commissioning point back into the proposed 2027-28 QAP.

It’s time to raise the bar on behalf of low-income residents and climate goals. Sustainability Measures have weakened since the 2024-25 QAP. We must move forward, not backwards.

Additional benefits to sustainable design are low energy costs, health, comfort, durability, resilience, and the ability to shelter-in-place. All factors important to Connecticut’s most vulnerable residents.

Public funds should be used to better Connecticut’s communities and environment, and help to address the climate crisis. Using sustainable design for affordable housing works in lockstep with Connecticut’s ambitious climate goals.

Escalate Connecticut’s momentum towards energy and sustainability goals, and continue to use tax incentives to promote high quality buildings for that sector of the population who would most benefit.

Why Passive House?
Passive House recognizes that housing affordability is about the total cost of living — not simply the cost of construction. By reducing energy use, improving durability, supporting occupant health, increasing resilience, and lowering long-term operating costs, Passive House helps create homes that remain affordable and livable throughout their lifespan. This combination of social, economic, and environmental benefits makes it one of the most comprehensive strategies available for delivering high-quality affordable housing.

Passive House shifts spending from ongoing utility bills and maintenance into a durable, high-performance building envelope that pays dividends over decades. Residents benefit from lower monthly costs, healthier indoor environments, and greater comfort, while owners benefit from reduced maintenance, predictable operating expenses, and more resilient buildings.

The increased cost of construction is minimal, especially considering the higher quality product. This is evident by the many Passive House affordable housing projects in our state, and the soaring implementation of Passive House in Massachusetts where over 30,000 Passive House units are coming in the next few years. All the more reason to offer more points to gain incentives — offset the initial cost to get a better result.

See the written statement template below for more.

Background:

Learn more about the Federal Low-Income Housing Tax Credit (LIHTC) Program.
See the current 2026 QAP, approved by Governor Lamont on October 1, 2025. 
See the 2024-2025 LIHTC QAP, approved by Governor Lamont on August 17, 2023.

2. How to attend the hearing TUESDAY, JULY 7 at 10:00am

Notice of Public Hearing

“The public is hereby notified that CHFA will hold a public hearing on July 7, 2026 at 10:00 am to receive data, views and comments with respect to its 2027 and 2028 Low-Income Housing Tax Credit (LIHTC) Qualified Allocation Plan (QAP).
All interested persons may attend.” 

Be on the call by 10:00 to get in the comment queue. 
You just need to stay on long enough to say your piece.


Meeting chat link https://us02web.zoom.us/launch/jc/83755345795
Meeting ID: 837 5534 5795
Passcode: 572394

Dial-in by phone:
646 931 3860 or 929 205 6099
Meeting ID: 837 5534 5795
Passcode: 572394

3. Tips for written statements due FRIDAY, JULY 10

“Written statements, in place of or in addition to oral statements, may be submitted by email to PublicComment@chfa.org or by mail to attention Terry Nash Giovannucci, CHFA, 999 West Street, Rocky Hill, CT 06067 from date of this notice to no later than close of business July 10, 2026.”

It can be a short and simple email, or spend a few more minutes writing a quick letter in three simple steps…

STEP 1: DOWNLOAD OUR TEMPLATE LETTER


STEP 2: FILL IN THE BLANKS
Customize the letter with your info. Here’s a portion of what you’ll see: 

“I am a resident of ______________ and am involved in my community as a ______________ (environmental steward, business owner, developer, contractor, parent, teacher, health care professional etc.). I care about this issue because ______________.”

If you have the time, add more information.  
Need some ideas? Use some of the above talking points. Here are some links for inspiration:
CT DEEP’s Climate Action Timeline for Connecticut
CT DEEP’s Comprehensive Energy Strategy
Connecticut’s 2018 SB 7: An Act Concerning Climate Change Planning & Resiliency

STEP 3: SUBMIT YOUR WRITTEN STATEMENT TO CHFA
Save your document and send it to:
Ms. Terry Nash Giovannucci
Community Engagement Officer
PublicComment@chfa.org
No later than close of business FRIDAY, July 10

Have more a few more minutes?  Also send it to:

Ms. Seila Mosquera- Bruno,
CHFA Board Chair & Commissioner of the Department of Housing 
seila.mosquera-bruno@ct.gov

Governor Ned Lamont:  
governor.lamont@ct.gov
or via web form

Ms. Catherine MacKinnon
CHFA Board Vice Chair & Exec. Dir., Mutual Housing Association of Greater Hartford
catherine.mackinnon@chfa.org

Ms. Nandini Natarajan
CHFA CEO
nandini.natarajan@chfa.org

Mr. Pasquale “Pat” Guliano
CHFA Managing Director of Multifamily
pat.guliano@chfa.org

Ms. Emma Cimino
DEEP Acting Commissioner
emma.cimino@ct.gov
(Katie Dykes has left the DEEP Commissioner position)

THANK YOU! THIS SIMPLE ACT CONTRIBUTES TO POSITIVE CHANGE IN OUR COMMUNITIES.