Cost, construction type, and the labor package — Louisiana

Total Development Cost is capped by reference to HUD's own schedule, not an LHC dollar figure

Rather than publishing its own per-unit cost ceiling, LHC ties Total Development Cost directly to a federal benchmark: "The maximum unit development cost is based on the design building type (i.e., elevator, walk up, row house, detached/semi-detached), number of bedrooms, and geographic location of the proposed property. All projects developed with LIHTCs must use the latest applicable cost limits for properties located in the HUD 2024 Unit Total Development Cost Limits document" (Section IV.D.25). A project that comes in over that limit is not automatically disqualified: LHC staff "may approve cost increases identified in the Cost Containment Template related exclusively to Extraordinary Site Costs, Threshold Mandated Costs, and/or Complex Layered Financing Costs up to 30% above the per unit maximum Total Development Costs," while "the LHC Board must approve all costs greater than 30% above" that limit for the same defined categories. For any project that initially exceeds the HUD TDC limit, LHC Construction staff independently verifies the documented costs using RS Means industry cost-index software as part of its own cost containment review.

The QAP lists specific carve-outs that do not count toward the HUD TDC comparison in the first place: extraordinary site costs (environmental hazard abatement, extensive rock/soil removal, hazardous underground tank removal, flood-plain remediation, and similar items -- each requiring qualified-professional documentation and industry cost-index support such as RS Means); community facility and community service facility costs; Single Room Occupancy project costs (subject to their own limits, waivable with a local government resolution tied to homeless services or Stewart-McKinney Act funding); and cost increases tied to a project delayed by housing discrimination and reallocated credits.

Fee caps: developer, architect, builder profit/overhead, general requirements, syndication

LHC also disallows builder profit and overhead altogether under a specific concentration test: "LHC will not allow overhead and builder profit when (a) more than fifty percent (50%) of the contract sum in the construction contract is subcontracted to one subcontractor, material supplier or equipment leaser, or (b) seventy-five percent (75%) or more of the contract sum in the construction contract is sub-contracted with three or fewer subcontractors, material suppliers or equipment lessors" (Section IV.D.22) -- a real constraint on how a general contractor structures its subcontractor base, not just a cap on the fee amount.

The January 2026 amendment rewrote Louisiana's hurricane/flood construction rules mid-cycle

The original 2025 QAP (Final as of 02.14.25) required, as a mandatory Project Threshold Requirement, that "all LIHTC projects located in Tier 1 and Tier 2 parishes must incorporate the following fortified construction measures: (a) Roofing -- Must meet IBHS FORTIFIED Roof™ standards, including sealed roof decks and wind-rated shingles[;] (b) Windows & Doors -- Must be impact-resistant or have hurricane-rated shutters that meet ASTM standards; garage doors, if applicable, must meet wind-load requirements[;] (c) Verification -- A licensed architect or engineer must certify compliance" (original Section IV.A.1), layered on top of a separate set of flood-elevation rules for new construction.

The amendment adopted January 13, 2026 replaced that entire Tier-specific mandate with a single, parish-tier-independent flood-elevation standard: structures "designed principally for residential use, and located in the one percent annual chance (or 100-year) floodplain, that receive assistance for new construction, reconstruction, rehabilitation of substantial damage, or rehabilitation that results in substantial improvement... must be elevated with the lowest floor, including the basement, at least two feet above the one percent annual chance floodplain elevation (base flood elevation)," with mixed-use structures floodproofed to the same standard and an absolute rule that "no residential buildings or structures of any kind may be located in a floodway" (amended Section IV.A.1, referencing definitions at 44 CFR 59.1 and 24 CFR 55.2(b)(10)).

Two things did not change. First, the twelve Tier 1 parishes ("the most vulnerable to hurricanes, storm surges, and other catastrophic weather events": Cameron, Iberia, Jefferson, Lafourche, Orleans, Plaquemines, St. Bernard, St. Martin, St. Mary, St. Tammany, Terrebonne, and Vermilion) and fourteen Tier 2 parishes (Acadia, Ascension, Assumption, Calcasieu, Iberville, Jefferson Davis, Lafayette, St. Charles, St. James, St. John, Tangipahoa, Washington, East Baton Rouge, and West Baton Rouge) remain defined in the QAP's Glossary. Second, a separate, statewide Design Features mandate -- unaffected by the resiliency rewrite -- still requires every project to obtain "certification by IBHS or a qualified Architect for ‘Fortified Roof,'" carry at least a 25-year roof warranty, use at least double-paned insulated windows, and use exterior materials rated for 15 years or more maintenance-free; vinyl siding, if used, must carry a wind rating of 186-210 mph, stay clear of the bottom 6 feet of finished grade (except protected recessed porches), and cannot exceed 20% of any building's total wall area (Section IV.A.11).

One inconsistency this research could not resolve: LHC's own Appendix A Selection Criteria checklist -- the self-certification form applicants complete -- still lists, verbatim, "RESILIENCY STANDARDS - PROJECTS LOCATED IN TIER 1 OR TIER 2 PARISHES" with the single line "Fortified Roofs, windows, and doors" as a threshold checkbox item (Appendix A, Section VI.I), even though the underlying Tier-specific threshold requirement it appears to reference was replaced by the elevation-only standard described above. Whether that checklist line survives as an independent, still-binding requirement, or is simply an unupdated artifact of the amendment, is not something this research could determine from the QAP text alone. Confirm directly with LHC which version governs before finalizing a Tier 1/Tier 2 site's construction scope.

Green building: not a scored category in Louisiana

A direct search of the full Appendix A Selection Criteria -- covering Targeted Project Type, Targeted Population, Priority Development Areas, Location Characteristics, Community Facilities, Project Amenities, and On-Site Security -- found no green-building or energy-efficiency scoring category anywhere in the point structure. Energy-related requirements in this QAP are baseline mandatory minimums rather than competitive points: rehabilitation projects must meet minimum energy-efficiency standards only when a Capital Needs Assessment requires replacing the relevant item, an applicant chooses to replace it, or LHC's underwriter determines an early replacement is warranted (Section IV.A.10); new construction and adaptive re-use projects must use Energy Star-labeled water heaters (Appendix B, Minimum Design Standards) and double-paned insulated windows (Section IV.A.11.iii). A developer used to scoring points for green certification in another state should not expect an equivalent scoring path in Louisiana's current QAP.

Labor: no Louisiana prevailing wage law -- Davis-Bacon triggers only through other federal money

Louisiana has had no state prevailing wage law since 1988. Louisiana Revised Statutes 38:2301 -- the state's former "Little Davis-Bacon" statute covering public works -- was repealed by Acts 1988, No. 18 §1 and Acts 1988, No. 90 §1, effective June 27, 1988. The U.S. Department of Labor's own current state-by-state list of prevailing wage laws confirms Louisiana has none today. Neither the QAP nor the LIHTC Program Compliance Manual contains any reference to a state prevailing-wage or labor-standards requirement, consistent with that repeal.

The Low-Income Housing Tax Credit itself does not trigger federal Davis-Bacon wage rates -- that trigger comes from other federal funding layered onto the same construction contract, independent of the LIHTC allocation. The clearest example: under 24 CFR 92.354, "every contract for the construction... of housing that includes 12 or more units assisted with HOME funds must contain a provision requiring the payment of not less than the wages prevailing in the locality, as predetermined by the Secretary of Labor pursuant to the Davis-Bacon Act" -- and once triggered, that requirement applies to the construction of the entire project, not just the HOME-assisted units. A Louisiana LIHTC deal that layers in HOME funds for 12 or more assisted units, National Housing Trust Fund dollars, or another federally assisted source with its own labor-standards trigger should budget for Davis-Bacon wages on that basis -- not because of the LIHTC award itself. This research did not independently confirm the National Housing Trust Fund's own exact unit-count Davis-Bacon threshold; confirm directly against 24 CFR Part 93 before assuming it mirrors HOME's 12-unit rule.