May 2013: It can often be difficult to determine if repairs to existing affordable housing units are an allowable use of CPA funds. The determining factor is if the work can best be described as "preservation," which is allowable, or "rehabilitation," which is generally not allowed. For the project to qualify as "preservation," it must protect real property, such as a building, from "injury, harm or destruction." Making such a determination can be a challenge!
The Massachusetts Department of Housing and Community Development (DHCD) recently issued guidance to housing authorities on exactly which tasks they consider to be allowable under the CPA legislation, and which are not. This document will be most helpful to Community Preservation Committees as they consider whether to fund work on existing affordable housing units.