Site sourcing and screening — Georgia

The QAP changed under its own cycle -- confirming which document actually governs

DCA's Board approved the 2026-2027 Qualified Allocation Plan on November 20, 2025. Nine months into that two-year cycle, DCA amended it: the Board-Approved Amended 2026-2027 QAP is dated August 12, 2026, and DCA's own amendment memorandum states the reason plainly. The Georgia General Assembly passed House Bill 1199 in its 2026 session, amending O.C.G.A. § 48-7-29.6 to cap the aggregate annual amount of 9% and 4% Georgia Housing Tax Credits at $100 million per year for taxable years 2026 through 2028. DCA's memo describes the amendment's purpose as producing "broader geographic distribution" under that new cap by limiting resources going to the city of Atlanta specifically. This is the exact failure mode a Georgia build-out has to guard against: a QAP that was genuinely current in November 2025 was superseded, in a materially substantive way, before the same two-year cycle it governs even reached its midpoint. Any Georgia screen, application, or underwriting model still citing the November 2025 board-approved document -- including copies mirrored by third-party aggregators -- is working from a document DCA itself no longer treats as controlling.

One more currency detail worth stating plainly: the Cost Limits threshold section discussed below is itself new to this QAP cycle -- it did not exist in the 2024-2025 QAP and was added during this cycle's own drafting process, with the Rural Pool's adjustment factor revised again between drafts. A site screen built by carrying forward assumptions from an older Georgia QAP would miss this threshold entirely.

Three pools, nine cost-limit metros, and a scoring table that resets by pool

Every Georgia site falls into exactly one of three geographic pools, and the QAP defines them by reference to federal USDA rural-eligibility data rather than by any state-drawn boundary. The "Atlanta Metro Pool" is Fulton, DeKalb, Gwinnett, and Cobb counties -- full stop, regardless of whether a given parcel inside those counties would also qualify as USDA-eligible rural land. The "Rural Pool" is every USDA-eligible rural area outside the Atlanta Metro Pool (checked against USDA's own eligibility lookup at eligibility.sc.egov.usda.gov, a determination that can shift between screening and application as USDA updates its maps). The "Other Metro Pool" is everything left over. A screener has to keep these straight from three OTHER Georgia geographies that share the word "Atlanta" or "metro": the city of Atlanta itself (the August 2026 amendment's specific target, discussed above), and the Atlanta MSA used for cost limits (a roughly 40-county HUD metropolitan statistical area that reaches well into the exurbs and is unrelated to the four-county Atlanta Metro Pool used for set-asides and scoring).

Pool also drives Total Development Cost limits. DCA applies HUD's own published Total Development Cost Limits (by MSA and unit size) and then adds a DCA-specific percentage on top -- and that add-on is larger for Metro Pool sites than Rural Pool sites at every bedroom size, which is a real, if counterintuitive, screening fact: a Metro Pool efficiency unit gets a 60% add-on over the HUD baseline where a Rural Pool efficiency unit gets only 30%.

Location scoring runs through five separate, only partly compatible tracks

Georgia's Desirable/Undesirable Activities section (up to 20 points) is the closest thing to a fixed amenity table, and it is genuinely fine-grained: eighteen named amenity categories (big-box retail, grocery stores, restaurants, hospitals, pharmacies, licensed childcare, colleges, K-12 schools, a rural-only "traditional town square" category, community centers, parks of two different size bands, libraries, fire/police stations, banks, places of worship, post offices), each assigned to a two-tier point group, scored on Google-Maps driving-or-walking distance bands that are themselves different for the Metro Pools versus the Rural Pool (a Group 1 amenity is worth 2.5 points at 0.5 miles but only 1.5 points at 3 miles in the Rural Pool, versus 2 miles in the Metro Pools). Undesirable characteristics -- junkyards, chemical/heavy manufacturing, gas stations with leaking-tank history, abandoned or deteriorated structures, extensive floodplain/wetland mitigation needs, and USDA-defined food deserts -- each deduct 2 points if within a 0.25-mile radius, with a documented-mitigation exception.

Community Transportation Options (up to 6 points) rewards transit access on a scale that differs meaningfully by pool: Metro Pool sites can earn up to 6 points for a transit-agency-owned strategic site or up to 5 points for walking distance to a real transit hub (three or more routes/modes), while Rural Pool sites earn only up to 2 points, tied to a publicly operated fixed-route or on-call service. One rule is easy to miss and site-specific: on-call transportation service is explicitly not eligible for points anywhere in the Atlanta Metro Pool, even though it is eligible in the Other Metro Pool (1 point) and the Rural Pool (2 points).

Quality Education Areas (up to 3 points) scores nearby schools against Georgia's own College and Career Readiness Performance Index (CCRPI, at or above the 50th percentile) or a 2024-or-later "Beating the Odds" designation from the Governor's Office of Student Achievement -- both Georgia-specific, DCA-published data sources rather than a national school-rating service.

The remaining four sections -- Revitalization/Redevelopment Plans (up to 7 points for a qualifying Community Revitalization Plan plus a QCT bonus, plus up to 3 more for Community Transformation and Community Investment activity), Stable Communities (up to 10 points, scored against Census Bureau and Agency for Toxic Substances and Disease Registry environmental-justice indicators), Housing Needs Characteristics (up to 10 points, not applicable to the Atlanta Metro Pool at all), and Community Designations (up to 13 points, for a HUD Choice Neighborhood Implementation grant area or a Purpose Built Communities nomination) -- are framed by the QAP as competing tracks: each section's own text states that only one of the four will count toward the Application's total score. That framing is not perfectly consistent across the four sections' own cross-references, however -- Housing Needs Characteristics contains an explicit stacking mechanism awarding a further 5 points if a site that already qualifies for "Housing Need and Growth" also separately qualifies for 5+ points under Stable Communities or Revitalization, while Stable Communities' and Community Designations' own lists of competing sections do not mention Housing Needs Characteristics at all. This inconsistency was not resolved in this research pass; a specific site's true location-scoring ceiling across these four sections should be confirmed directly with DCA rather than assumed from the QAP text alone.

Previous Projects (up to 5 points) and Phased Development (up to 4 points) round out the location-adjacent scoring by rewarding under-served geography on two different tests: Metro Pool sites are scored on whether recent 9%/4% awards exist within a one-mile (9% Round) or half-mile (4% Round) radius, while Rural Pool sites are scored on restricted units as a percentage of county population -- a genuinely different statistical test for the same underlying idea of avoiding market saturation.

The state basis boost is not the federal QCT/DDA boost, and hazard data still lives at the county level

Two separate basis-boost mechanisms apply in Georgia, and a screen has to keep them apart. The federal 30% basis boost for sites in a Qualified Census Tract (QCT) or Difficult Development Area (DDA) is automatic under 26 U.S.C. § 42(d)(5)(B) -- it requires no DCA action and the QAP does not need to (and does not) separately administer it. Georgia's own "state-designated basis boost" is a distinct, DCA-administered program: 9% Credit projects can request an allocation based on 110% to 130% of eligible basis (in whole percentage points), but only in one of three categories -- a multifamily Rural Pool project without DCA-administered federal funding, a project qualifying for points under Stable Communities, or "extraordinary circumstances" that the QAP explicitly defines to exclude low rents, high utility costs, and proximity to a QCT. The boost is not free: DCA requires the project to defer 1% of total Developer Fee for every 1% of state boost granted, unless the project brings in a new source equal to at least 30% of the Developer Fee from an unrelated party.

Georgia's Environmental Protection Division (EPD) publishes the state's Hazardous Site Inventory (HSI) at least once a year, every July, as a statewide list (by HSI number, site name, county, and hazard class) with an accompanying Google-Maps-based interactive viewer -- a real, current, usable source, but not a queryable GIS/REST layer the way some other states publish their equivalent inventories. EPD's underground storage tank program was not found, in this pass, to publish an equivalent open dataset at all; a screen needing UST history should expect to work through EPD's technical assistance line or a GEOS records request rather than a public map. Georgia's own environmental-buffer statute is worth building into any wetlands/waters check directly: the Erosion and Sedimentation Act establishes a 25-foot buffer along the banks of all state waters, extended to 50 feet for trout streams, under O.C.G.A. § 12-7-6 -- a state-law setback independent of federal wetlands regulation, and one of the specific items (alongside floodplains, endangered species, noise, radon, asbestos, lead, mold, and vapor intrusion) that DCA's Environmental Manual requires on top of the ASTM Phase I baseline.

Parcel and zoning data remain fragmented across Georgia's 159 counties -- more counties than any state except Texas -- and this research did not confirm a normalized, statewide, parcel-keyed zoning dataset. The Georgia Geospatial Information Office's data hub advertises GeoServices/WMS/WFS API access to its holdings, and at least one third-party clearinghouse reports usable parcel data for only "more than 20%" of Georgia's counties, organized county by county rather than as one schema. A Georgia screening tool should verify DCA's and GIO's actual current holdings directly rather than assume a SCAG- or DRCOG-style unified layer exists.

Income and rent limits are published on DCA's own site, refreshed annually on a fixed schedule that trails HUD's own publication -- the 2026 limits, for example, took effect May 1, 2026 with a required local implementation date of June 16, 2026 -- so a screen should check DCA's Rent and Income Limits page for the current implementation date rather than assume HUD's national release date controls.

Two more Georgia-specific screening flags belong at this stage rather than later. First, a Community Revitalization Plan can only carry Revitalization scoring points if it was adopted (or re-adopted) by a "Qualified Local Government" as defined at O.C.G.A. § 50-8-2 -- a jurisdiction that has fallen out of QLG status (a real possibility under the Georgia Planning Act's ongoing compliance requirements) can lose access to those points even with an otherwise-perfect plan. Second, a large, rural, or multi-phase site should be checked against Georgia's Development of Regional Impact (DRI) threshold at screening, not later: DCA's own rules (Rule Chapter 110-12-3, adopted November 20, 2025 and effective December 15, 2025) trigger mandatory Regional Commission review for any housing development exceeding 400 new units in a Metropolitan Tier county (population 50,000+) or 125 new units in a Non-Metropolitan Tier county -- a threshold within easy reach of a scattered-site or portfolio Rural Pool deal even though it is well above a typical single-phase 60-to-120-unit LIHTC development.