Comment on Kirk McClure's "Are low-income housing tax credit developments locating where there is a shortage of affordable units?"

Kirk McClure's article makes important contributions to our understanding of the way in which state allocating agencies are using the Low-Income Housing Tax Credit (LIHTC). However, one of the premises of his analysis - that allocating agencies should encourage the location housing developments in census tracts with a osurpluso of low-income renters - is mistaken. Census tracts are too small to be considered closed-system housing markets. Additionally, the LIHTC program does not exist in isolation, but instead as part of a combined national rental housing policy that includes both supply-side programs (LIHTC) and demand-side programs (housing vouchers). A final flaw in the notion that LIHTC units should be built in census tracts with a surplus of renter households in the 30% to 60% of AMI range compared with the units affordable to them is that increasing the amount of affordable housing in those tracts could have the effect of further concentrating households by income and race.