September 4, 2026
Housing New Mexico | MFA
Attn: Jeanne Redondo
7425 Jefferson St NE
Albuquerque, NM 87109
Sent electronically to jredondo@housingnm.org
RE: Public Comment on the Draft 2027 Qualified Allocation Plan (QAP)
To Whom it May Concern:
The Poverty & Race Research Action Council (PRRAC) respectfully submits these comments regarding the Draft 2027 Qualified Allocation Plan (QAP). PRRAC has extensively researched
how federal programs, particularly the Low-Income Housing Tax Credit (LIHTC) program, can be leveraged to support social and collective ownership models. New Mexico has a strong
history of land stewardship and Community Land Trusts (CLTs) that could be better supported by the QAP. PRRAC is a national civil rights organization bridging law, policy, social science, and grassroots
organizing to advance racial and economic justice. PRRAC brings deep expertise on housing justice and educational equity to grassroots movement organizations and coalitions, through legal analysis, policy design, and research translation. Our work is grounded in empirical research, legal analysis, and demonstrated solutions to ensure that federal housing programs advance equity, inclusion, and opportunity.
1. Background on Community Land Trusts in New Mexico
The Community Land Trust model ensures permanent affordability by separating the ownership of land from its structures. Land trusts effectively remove the underlying land off of the speculative market and allow topside improvements such as homes to be sold or rented for much lower costs while the trust preserves perpetual affordability.
