At the 2025 Texas Housing Conference, TAAHP President-Elect Kathryn Saar moderated a timely panel on the Qualified Allocation Plan (QAP), joined by TDHCA Multifamily Director Cody Campbell, QAP Committee Chair Karsten Lowe, and Past President Audrey Martin. While the conversation covered a wide range of policy topics, one issue drew extended focus: how Texas evaluates Concerted Revitalization Plans (CRPs), and what that says about the state’s evolving housing strategy.
Balancing High Opportunity and Reinvestment Areas
The discussion opened with a question that continues to shape housing policy across the country. Where should affordable housing be built and why?
TDHCA’s Cody Campbell spoke to the heart of the issue:
“It is the eternal question of affordable housing policy. Do you incentivize building in high-opportunity, good parts of town, or do you invest in parts of town that need reinvestment? There is not a definitive answer to that. It is a tightrope that we walk with every policy decision we make.”
– Cody Campbell
For years, Texas has prioritized high-opportunity sites in its scoring system. But in the 2025 cycle, CRP applications accounted for nearly half of all awards. This shift may reflect both changes in policy and the growing interest among developers in reinvestment strategies.
A More Workable CRP Standard
Kathryn Saar offered helpful context on how CRP scoring has evolved over time. Earlier versions of the rule required applicants to demonstrate specific levels of local investment tied to blight, infrastructure deficits, and dollar amounts. This made the CRP path difficult, if not impossible, in many communities.
“We’ve swung the pendulum back more toward the middle. In the past, CRP requirements were so rigid that they became unworkable. Now, if a city or county has taken real action and identified an area for reinvestment, that local voice matters and should be enough.”
– Kathryn Saar
Cody Campbell added that these changes have improved clarity and fairness for both staff and applicants. Requiring documentation from the local government rather than relying on staff interpretation has helped reduce subjectivity.
Tracking the Outcomes of Revitalization
As more applicants pursue points under the CRP scoring path, the panel raised a timely and important question: Are these investments making a meaningful difference?
Audrey Martin reminded the group that it’s important to take a step back and examine the results.
“I think it’s important to look back and see what’s the effect of what we’re doing. It sounds like in most of these areas, the CRPs our community is working within are doing some good and that’s a positive policy outcome.”
– Audrey Martin
To help explore that question, Audrey invited audience member Lora Myrick of BETCO Housing Lab to share her early findings. Lora reviewed several years of CRP developments and found promising signs. In most of the census tracts she studied, poverty rates were beginning to decline and incomes were gradually rising. While still preliminary, the data points toward real community-level impact and suggests a positive trajectory that reinforces the intent behind CRP investments.
Exploring Opportunity Zones as a CRP Pathway
Karsten Lowe, Chair of the QAP Committee, highlighted one of this year’s most forward-looking recommendations: recognizing federally designated Opportunity Zones as an eligible path under the CRP scoring category.
“A big part of the Opportunity Zones being considered going forward are heavily focused in rural areas, aiming to expand opportunities and drive investment in those key critical regions.”
– Karsten Lowe
TAAHP’s proposal builds on the growing federal momentum behind Opportunity Zones and their alignment with state revitalization goals. By allowing Opportunity Zones to count toward the 7-point CRP score without requiring traditional CRP documentation, the recommendation could ease documentation burdens for rural communities and smaller developers. It also helps safeguard scoring access for developments in the fourth quartile, reinforcing a more equitable geographic distribution of credits.
The QAP Committee reached broad consensus on the idea and urged TDHCA to incorporate it into the 2026 QAP.
What Comes Next
This year’s conversation around CRPs marks a deeper shift in how the state thinks about housing investment, balancing where we can build with where we should. Whether through high-opportunity sites or local revitalization plans, the goal is to ensure the Qualified Allocation Plan supports both community-driven strategies and measurable outcomes.
TAAHP will continue tracking TDHCA’s response to our Opportunity Zone recommendation, including how the Board engages with the idea during upcoming QAP deliberations. We’ll keep members informed as the 2026 QAP takes shape.