Abstract
McClure does a good job of describing the history, scope, magnitude, and significance of the Low-Income Housing Tax Credit (LIHTC) program. McClure's investigation is based on identifying the location of LIHTC units placed in service from 2000 through 2004 by census tract. From these data McClure concludes that the state Housing Finance Agencies are not directing LIHTC allocations to areas where either a shortage or small number of affordable units exists. This comment will focus on the three aspects of the affordability criteria and tract-level census data that raise some questions about whether such strong conclusions are justified: (1) Units classified as affordable that may not actually be available to low-income renters, (2) Units classified as affordable that may be physically inadequate, and (3) The limitations of census tracts as units of analysis.
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