Site sourcing and screening — Arizona

What screening actually looks like in Arizona

The Arizona Department of Housing (ADOH) is the state's designated housing credit agency under A.R.S. § 35-728(B), administering both the federal 9%/4% Low-Income Housing Tax Credit and a smaller state credit under its Qualified Allocation Plan (QAP). The document governing the phase covered here is ADOH's 2026 and 2027 Qualified Allocation Plan, which the agency states it "has adopted... for 2026 and 2027 to administer LIHTCs and state tax credits (STC)." In the two weeks after a site surfaces, a real Arizona screen works through the same rough list as any other state, with two Arizona-specific items added at the top.

Three commitments come out of this phase. The first is whether to pursue the site at all. The second is site control: it has to hold, unbroken, all the way to the April 1 application deadline — and, under QAP Section IV.A.7, for at least one month past the anticipated award date after that. The only mandatory pre-filing formality is procedural rather than substantive: Section IV.A.1 requires at least one representative of the Applicant to attend ADOH's Application Workshop before the round closes. The third, quieter one is price: under QAP Section VI.B.7, an application may include no more than the lesser of the purchase price or an as-is appraisal dated within six months of the application deadline — every dollar paid above appraised value simply never enters eligible basis. A developer who locks site control on a promising but unentitled parcel, only to find weeks before April 1 that the rezoning hearing has been continued past the deadline, has no fallback parcel to substitute before filing.

Zoning: entitled before you file, and the state cannot make a city say yes

Arizona's structural fact here is a statute, not a data gap. A.R.S. § 35-728(C) requires ADOH to notify the local city, town, county, or tribal government of a planned project and obtain written consent before proceeding, and states plainly: "The department shall not interfere with or attempt to override the local jurisdiction's planning, zoning or land use regulations." There is no Arizona counterpart to California's SB 35 or AB 2011 ministerial, by-right density-override pathway. Whatever zoning and land-use approvals a project needs, it gets them from the city, town, or county alone, on that jurisdiction's own calendar.

The QAP then converts that statutory deference into a hard filing gate. Section IV.C.3 (Zoning) requires applications to include documentation that all necessary legislative land-use authorizations (rezoning), quasi-judicial approvals (conditional or special-use permits), and all known variances from administrative requirements "are in place" for the proposed property — not applied for, not scheduled for hearing, in place. Section IV.C.4 adds that utility connections must already be available or their availability documented, and that the site must have or will have access to a publicly maintained road.

That combination — no state override, full entitlement required at filing — means a raw, unzoned parcel with real development potential still cannot be screened as a near-term 9% LIHTC site; it has to clear the entire local rezoning and permitting calendar first, on its own timeline, with no state-law shortcut and no ability to file with entitlements pending.

On the parcel side, this guide verified that Maricopa County's assessor runs a live, public parcel-records system (mcassessor.maricopa.gov) and that Pima County's government site is reachable — the state's two Metro counties, together holding most of Arizona's population and most 9% New Construction competition. It did not independently test live GIS endpoints for the other 13 counties the way the California research corpus tested each of that state's county ArcGIS services; treat any specific rural-county endpoint claim as unverified until it is actually queried, and expect the same kind of per-county breakage California's screen documented — stale hosts, undocumented pagination limits, inconsistent coordinate systems — to show up here too.

Site suitability is a threshold test, not a score

Where California's amenity and hazard rules mostly award or withhold points, Arizona's QAP Section IV.C (New Construction Threshold) makes site suitability a pass/fail eligibility question that ADOH applies at its own discretion — the operative verb throughout is "may be deemed ineligible," not "loses points."

A site within the 0.5-mile ring is not automatically dead: the QAP provides a safe harbor. An application "will not be deemed ineligible solely due to its proximity to an incompatible use" if the applicant demonstrates that a multifamily market-rate project or multiple single-family homes sit within one mile of that same incompatible use — evidence the market already treats the area as residentially viable.

Floodplain and wetland exposure is a separate, similarly blunt gate under Section IV.C.2: an application may be ineligible if any portion of an improvement sits in a 100-year floodplain and the 8-step process has not been completed or a Conditional Letter/Letter of Map Revision has not been obtained, or if the site is in, or has an "un-mitigatable effect" on, a wetland.

QCT, DDA, and Arizona's own basis boost

The federal layer works the same in Arizona as everywhere else: under 26 U.S.C. § 42(d)(5)(B)(i)-(iii), a building located in a HUD-designated Qualified Census Tract or Difficult Development Area gets eligible basis increased to 130% of what it would otherwise be. Arizona's QAP scores this inside a single ten-point category ("Community Revitalization Plans, Qualified Census Tracts, Difficult Development Areas, and Opportunity Zones"): 5 points for a qualifying Community Revitalization Plan, 5 points for at least one building in a QCT, 5 points if every building in the project sits in a DDA, and 5 points if every building sits in a federal Opportunity Zone — capped at a 10-point maximum for the category as a whole, so at most two of the four components can actually pay out (QAP Sections V.B.4 and V.C.4). The QCT and DDA standards are not symmetric: QCT points need only one building in the tract, while DDA points require every building in the project to sit inside the designated area — a scattered-site project can clear one and miss the other.

Arizona layers a second, entirely separate basis-boost mechanism on top of the federal one. Under 26 U.S.C. § 42(d)(5)(B)(v), a state housing credit agency may itself designate a building as needing the increase in order to be financially feasible, without regard to whether it sits in a federally designated QCT or DDA. ADOH's QAP (Section VI.B.6) exercises exactly that authority: "ADOH will allow for a statewide thirty percent (30%) increase in the eligible basis for 9% LIHTC projects that demonstrate a financial need," approved only to the level ADOH determines is actually needed for feasibility — a discretionary, project-by-project, financial-need test that can in principle reach any site in the state, not a geography-locked gate like California's Opportunity Area/threshold-basis-limit rule. The QAP text limits this specific boost to 9% projects; it does not describe it as available to 4% LIHTC applications.

Site control, market study, and the disqualification net

QAP Section IV.A.7 sets the acceptable forms of site control: a deed, purchase agreement, purchase option, lease agreement, or lease option, in writing, signed by both sides, in the name of the Applicant, a Principal, or an affiliated entity, and valid through at least one month past the anticipated award date. Tribal-land projects follow a separate path — either a lease agreement with all Tribal, Bureau of Indian Affairs, and other approvals secured, or, where no lease exists yet, an agreement to enter into a lease of at least 25 years with a 25-year renewal option, paired with a Tribal or TDHE resolution authorizing it.

Section IV.A.8 requires a market study from an analyst on ADOH's own approved list, unaffiliated with any Principal, meeting the most recent Model Content Standards of the National Council of Housing Market Analysts, and dated within one year of application submission — not the deal-team's own consultant of choice, and not a study that can quietly age past its filing date.

Underneath the site sits the Development Team. Section IV.A.5 lists roughly a dozen grounds on which ADOH may disqualify an entire application based on "substantive evidence" connecting any Principal to any one of them — among them: a bankruptcy within the past five years; having allowed an affordable rental property to enter foreclosure; removal from an LIHTC ownership entity by an equity investor or ADOH; an adverse fair-housing, civil-rights, or other housing-related judgment within the past five years; uncorrected noncompliance on another project within the past five years; unpaid ADOH fees or loan payments as of the application deadline; and debarment from any federal housing program. This is a binary kill tied to a person, not a points deduction tied to the project — closer in effect to California's negative-points regime, but structured as outright disqualification rather than a point penalty.

New Construction applications must clear a minimum total score of 160 points to even proceed to formal scoring (Section IV.C.6) — and only the highest self-scored applications in each set-aside are formally scored at all, so a marginal self-score can mean the application is never substantively reviewed. Where more than one application ties on points and credits run out, ADOH's tiebreaker (Sections V.B.6 and V.C.10) runs, in order: greatest total LIHTC units, then lowest average AMI of the rent-restricted units, then longest extended-use period — a materially different mechanism from California's leveraged-soft-resources tiebreaker percentage.

Where the screen stops, and what it cannot tell you

Construction cost is the clearest gap. Arizona publishes no CTCAC-style threshold basis limit table by county or bedroom count. Instead, QAP Section VI.D says ADOH will "determine whether applications show development budget amounts outside the standard deviation among applications submitted, and require all such Applicants to provide explanations," adding that an inability to explain the cost "may result in disqualification of the application." There is no number to look up before filing — only a comparison ADOH runs after everyone has already filed, against whatever the rest of that round's applicant pool happened to submit.

Arizona also runs a state-level tax credit alongside the federal LIHTC, easy to screen right past because it lives outside the QAP's own point system. Under A.R.S. §§ 43-1075 and 43-1163, the state Affordable Housing Tax Credit is a nonrefundable credit equal to at least 50% of the federal LIHTC amount for the taxable year, capped statewide at $4,000,000 per calendar year with any unused balance rolling to the next year, for projects placed in service after June 30, 2022. One honest caveat: the only primary-source copy of the claiming form this research reached — the Arizona Department of Revenue's 2024 Form 354 instructions — describes the credit as available for interests acquired "from and after December 31, 2021 and before January 1, 2026." The 2026-2027 QAP itself still references "state tax credits (STC)" as an active part of the program, so the window has likely been extended or replaced by a newer form, but that specific date should be confirmed directly with ADOH or AZDOR before a project counts on the state credit stacking.

Entitlement duration — how long a given city actually takes to move a rezoning or conditional-use permit from filing to approval — is no more centrally tracked in Arizona than in California or Texas; it lives in city permit portals with no public API, in staff memory, and in local land-use counsel's heads. The difference is that Arizona's QAP forces the question to be fully resolved before an application can even be filed, so guessing wrong at the screening stage is more expensive here than in a state that allows entitlements to run concurrently with the application.

The honest limit, same as anywhere: whether a rural county's staff will actually champion a Rehabilitation-set-aside project, whether a Tribal council will move its resolution before the deadline, whether a competing Metro New Construction application in the same county will out-self-score this one — none of that is a dataset, and none of it should be synthesized. What screening can and should do in Arizona is confirm, before the phone call, that the site already clears — or can clear before the deadline — the threshold gates covered here: entitlement status, the incompatible-use ring, floodplain exposure, site control that will survive from pre-application to filing, and which set-aside it actually competes in. EZFeasi's own Arizona coverage today is zero: no Arizona parcel layer, no Arizona zoning normalization, no QCT/DDA overlay, and no Arizona-specific market-study, income-limit, or compliance tooling has been built. This guide is the research base, not the product.