Site control and due diligence — Georgia

Site control: two runways, one instrument list, and a 45-year lease floor

DCA's Site Control threshold accepts a narrow, specific set of instruments. Every Application needs a settlement statement or warranty deed conveying title to the property's current owner. If that current owner is not the General Partner or proposed Limited Partnership, the Applicant needs either a legally binding contract to purchase the site -- executed in the name of the General Partner or proposed LP, with an assignment if the contract was signed by an affiliate -- or a binding long-term ground lease (or an option for one) with a minimum term of forty-five years that clearly gives the Applicant the right to execute a binding agreement at closing. Every contract must be executed before the Application Submission deadline, carry a discernible price, be signed by both purchaser and seller, and include a legal description of the property.

Two exceptions round out the threshold. An Applicant selected through a federal government RFP process can show site control by documenting reasonable certainty that final site-control documents will be finalized within a reasonable time after award, without yet holding an executed contract. And for Scattered Site Projects, DCA requires separate evidence of site control for every non-contiguous parcel -- there is no single blanket showing that covers the whole assemblage.

Access, water/sewer, and zoning documentation: three more all-or-nothing gates

Site Access requires either a specified entrance legally accessible by paved roads, or -- if that doesn't already exist -- documentation covering the existing-conditions site plan, evidence of Local Government approval to pave the necessary roads, a funding commitment, and a completion timetable. A private drive requires documented proof of ownership or an easement, plus the paving plan and its cost.

Public Water/Sanitary Sewer is one of the sharpest-edged thresholds in the QAP: service must already be available to every parcel of the proposed site at Application Submission, meaning all necessary easements are secured at that time, and a utility's commitment letter "cannot be contingent on the construction of a water/sewer system, annexation of the property, or funding to the utility provider from an outside source." An otherwise-complete commitment letter carrying any of those three conditions does not satisfy the threshold -- DCA's own text warns that any unclear or unresolved issue here "may result in Threshold failure."

Site Zoning documentation (required for any Application proposing new construction, including added units to an existing property) needs a letter from a named Local Government official, on official letterhead, dated within six months of Application Submission, stating the project's zoning and land use classification, attaching the applicable ordinance sections, and confirming the site's conformance with any moratoria, density, or setback requirements -- shown graphically or in writing on the Conceptual Site Development Plan (CSDP). The one alternative path: an affirmation that the jurisdiction "does not have or enforce a zoning ordinance," which matters given how many rural Georgia counties fall into that category (discussed further under Entitlement Pathway Election). The QAP places responsibility for resolving any ambiguity squarely on the Applicant: "any unclear or unresolved issues could result in Threshold failure."

Market study and appraisal: NCAHMA, not USPAP -- and a real anti-inflation rule on related-party deals

The market study must be completed no more than six months before Application Submission, by an analyst on DCA's own approved Market Analyst list, and DCA's 2026 Market Study Manual states that "[u]nless stated specifically in the manual, all processes and practices used by the analyst must conform to the National Council of Affordable Housing Market Analysts' (NCAHMA) standards" -- not the Uniform Standards of Professional Appraisal Practice (USPAP), and the Manual does not require the analyst to hold a state appraiser certification. DCA is explicit that it is not bound by the analyst's own conclusions: "DCA is not bound by the opinion or conclusions reached by the market analyst and determine[s] whether the project will be able to achieve the desired lease up and maintain feasibility" itself, and may require an update mid-review if a competing project surfaces in an overlapping market area.

Appraisals are required for every single development under the QAP -- not only acquisitions or identity-of-interest transactions. Total hard costs cannot exceed 90% of the as-completed, unencumbered appraised value, on penalty of DCA revoking the project's funding; the appraisal's effective date (the inspection date) cannot be more than six months before Application Submission, DCA must be named an intended user, and separate building and land values are required if the Application claims acquisition credits. DCA reserves the right to commission its own appraisal on any development, and will always do so -- billing the cost back to the Applicant -- for developments using DCA-administered federal funding.

The Identity-of-Interest valuation rule is the sharpest anti-basis-inflation provision in this section, and it was newly added -- along with its one exception -- during this QAP cycle's drafting. Where an Identity of Interest exists between buyer and seller, DCA values a property that has been under the control of the Applicant or a Related Party for five years or less at the acquisition cost the Related Party paid when it originally obtained site control -- not a fresh appraised value reflecting subsequent market appreciation. The sole carve-out: properties purchased during the one-year Qualified Contract sale period.

Environmental due diligence: DCA's ASTM-plus checklist, and a Physical Needs Assessment for every rehab

Every Application must include a signed Phase I Environmental Site Assessment conducted to the ASTM E1527-21 standard, dated within six months of Application Submission, with the Phase I report itself issued no more than 60 days after the site reconnaissance. If the Phase I recommends a Phase II, Georgia requires all Phase II testing to be completed before Application Submission -- there is no post-award path to satisfy an outstanding Phase II recommendation the way some other agencies' processes allow.

Any property using HOME funds as a source must separately meet HUD's Site and Neighborhood Standards under 24 CFR § 92.202 and § 983.6, documented with a HOME Site and Neighborhood Standards Certification alongside the Phase I/II reports and an Environmental Transmittal. After an Application is submitted, Owners and Developers of federally funded proposed projects must refrain from any activity with potential adverse environmental impact -- acquiring, rehabilitating, converting, leasing, repairing, or constructing -- until DCA issues an environmental clearance letter, and cannot commit or expend HUD or non-federal funds before that review completes.

For rehabilitation or Adaptive Reuse Applications, a Physical Needs Assessment (PNA) and a Capital Reserve Study -- both prepared by a DCA-qualified consultant, both no more than six months old, both per the Rehabilitation Guide in DCA's Architectural Manual -- are mandatory. The rehabilitation scope itself must budget a minimum of $35,000 per dwelling unit in hard costs, replace any building or site component with less than fifteen years of Effective Remaining Useful Life under the Fannie Mae Expected Useful Life Table, and be certified as adequate by the project's architect (and, where applicable, a licensed engineer) at Application -- with that same certification reconfirmed at construction completion before DCA will release IRS Forms 8609.

The Conceptual Site Development Plan carries its own, comparatively light survey standard: DCA does not require an ALTA survey to prepare the CSDP, and will only require a boundary survey if the precise location of the subject property is genuinely in question. What the CSDP does require is ground-level color photographs and aerial imagery no more than six months old, plus a written and graphic accounting of adjacent land uses within 100 feet, all existing easements, and any wetlands, floodplains, or state waters (with buffer zones) affecting the site.

Readiness to Proceed scoring mostly restates what Threshold already required

The Scoring Criteria's Readiness to Proceed section (up to 15 points) is worth understanding precisely because much of it duplicates, rather than adds to, the due-diligence work already described above. Five of the fifteen points require nothing more than the Minimum Documentation already listed under the mandatory Site Control threshold and, for new construction, the mandatory Site Zoning threshold -- meaning most Applications that clear Threshold at all will also collect these five points essentially automatically. The remaining points are one apiece for Public Water/Sanitary Sewer documentation, Operating Utilities documentation, Site Information/CSDP documentation, preliminary financing commitments, a general contractor's cost estimate, the market study, and (for rehabilitation) the PNA -- again, all items an Application generally has to produce for Threshold anyway. The one place this section's own standard is actually looser than Threshold's: it accepts a Phase I Environmental Site Assessment dated within 18 months of the Competitive Application deadline for scoring purposes, versus the six-month freshness window Threshold itself requires -- though DCA notes the Phase I must still be updated to meet full Environmental Manual requirements if the Application is selected and proceeds to Threshold review.