"Is this Guam parcel even reachable given how much of the island the military controls -- and does GHURA's scoring table actually check for that, or do I have to?"
A one-round, small-dollar program running on its own calendar
The Guam Housing and Urban Renewal Authority (GHURA) is Guam's designated housing finance agency for LIHTC under Section 42(m)(1)(A) of the Internal Revenue Code. Its 2025 Qualified Allocation Plan -- the document actually governing awards as of this research -- was approved by the GHURA Board of Commissioners on October 21, 2025, following a public comment period that ran October 1-16, 2025. GHURA's own website (ghura.org) still lists the 2025 QAP as its current LIHTC document, with no 2026 QAP, draft, or in-cycle amendment found anywhere on GHURA's site, its public notices on notices.guam.gov, or its board meeting packets through mid-2026. Unlike several mainland QAPs in this library that were amended mid-cycle without being renamed, nothing in this research turned up a Guam amendment of that kind -- but because GHURA's QAP explicitly states it "is subject to amendment by the GHURA Board of Commissioners" at any time, a screen still owes itself a direct check of ghura.org before relying on any cached copy, including this one.
The 2025 cycle itself is unusual on its own terms: GHURA describes it as an "abbreviated QAP Application Process," run in 2025 specifically because Guam's CY2024 credits were never awarded, and federal rules require CY2024 credits to be allocated by December 31, 2025. That gave the 2025 round a genuinely compressed timetable -- comment period October 1-16, board approval October 21, application window October 22-November 26, evaluation panel review November 28-December 7, board award decision December 11, and a final December 31, 2025 deadline for carryover allocation paperwork. A screener assuming Guam runs on a predictable annual calendar the way most mainland agencies do would be wrong about this cycle specifically, and should not assume the next cycle will look identical.
Guam's total 2025 allocation is $6,815,000, made up of $3,360,000 in CY2024 credits (issued under Rev. Proc. 2023-34) and $3,455,000 in CY2025 credits (issued under Rev. Proc. 2024-40). The GHURA Board had already approved an allocation reservation of up to $1,793,120 to Flores Rosa Gardens LLC before the round even opened, leaving $5,021,880 in credits available for competitive award -- a figure the QAP states directly. Applicants requesting more than that net amount must show the project can be scaled to fit it; forward commitments of future-year allocations are not entertained except to break a tie. A minimum score of 77 out of 111 total points is required just to be considered for an award at all, regardless of how the $5,021,880 pool ultimately gets split.
| Criteria | Points |
|---|---|
| 1. Project Location and Proximity | 20 |
| 2. Project Financial Feasibility/Viability | 18 |
| 3. Project Characteristics | 12 |
| 4. Populations Served by the Project | 15 |
| 5. Developer, Owner, and Management Team Experience and Capacity | 12 |
| 6. Community Support and Involvement / Neighborhood Impact | 5 |
| 7. Affordability of Rents and Length of Affordability Period | 8 |
| 8. Increase in Extended Use Period / Conversion to Homeownership | 6 |
| 9. Local/Federal Government Support | 2 |
| 10. Qualified Non-Profit Organization | 1 |
| 11. Qualified Census Tract | 2 |
| 12. Public Housing Waiting Lists | 1 |
| 13. Project-Based Rental Assistance | 1 |
| 14. Historic Nature of the Project | 1 |
| 15. Developer Fee | 7 |
Criteria 1 (Project Location and Proximity) is the largest single scoring category and the one most directly tied to site screening -- see below.
Criteria 1: four proximity tests, all measured on an island where nothing is far away
Project Location and Proximity is worth 20 of the 111 total points and splits evenly into four subcategories -- public transportation, grocery store/shopping, health care facilities, and employment hubs -- each worth up to 5 points on identical distance bands, measured by driving distance on Google Maps or a similar service and documented through the required market study.
| Driving distance | Points |
|---|---|
| Less than 5 miles | 5 |
| 5 - 10 miles | 4 |
| 10 - 15 miles | 3 |
| More than 15 miles | 0 |
Because Guam is roughly 30 miles long and 4 to 12 miles wide, a "more than 15 miles" site would have to sit at one of the island's extreme ends relative to the amenity in question -- the QAP's own distance bands are calibrated to island scale, not mainland scale, and a mainland analyst's intuition about what counts as "close" will read every Guam site as more central than it would look on a mainland map of the same mileage.
The Qualified Census Tract criterion is worth only 2 points -- and GHURA's own basis-boost language is easy to misread
Criteria 11, Qualified Census Tract, is worth up to 2 points: 1 point if the project site is located in a Qualified Census Tract (QCT), and a separate, independent 1 point if the project will redevelop existing housing as part of a documented community revitalization plan (with a copy of that plan, and a letter of interest or binding agreement with the administering government agency, required at application). These two points are unrelated to whether a project receives the much larger federal basis boost discussed below -- Criteria 11 is a scored competitive point, not the boost itself.
Separately, in its compliance-monitoring section, the QAP states: "High-Cost Area Designation. Newly constructed buildings located outside of designated Difficult to Develop Areas or Qualified Census Tracts qualify as a high-cost area. The additional LIHTC available from the 'basis boost' will be used to offset the high cost of construction and land throughout the island." Read on its own, this sentence is easy to misparse as reversed -- ordinarily it is a site inside a QCT/DDA that earns the federal 30% basis boost. What the QAP is actually invoking is a separate, real statutory mechanism: 26 U.S.C. § 42(d)(5)(B)(v) lets a state (or territorial) housing credit agency independently designate a building as located in a difficult development area, without waiting for a HUD DDA designation, whenever the agency determines the increase is necessary for the building's financial feasibility. GHURA's sentence reads as an exercise of that agency-designation authority -- functionally extending high-cost-area treatment to new construction anywhere on Guam that HUD's own QCT/DDA maps don't already cover, rather than a description of the ordinary federal QCT/DDA mechanism running in reverse.
This research could not independently confirm, from HUD's own current-year QCT/DDA dataset, exactly which Guam census tracts (if any) HUD has designated as QCTs or DDAs for the applicable allocation year -- HUD's DDA/QCT lookup and GIS data are updated annually and are the authoritative source. A screen should check huduser.gov's QCT/DDA lookup tool directly for the specific tract before assuming either the federal designation or GHURA's own high-cost-area language applies to a given parcel.
What the QAP never asks about: military land, and typhoon/seismic geography
Guam's Housing Needs Assessment section attributes the island's "strong" rental market partly to "the driven presence of military personnel," and Criteria 4 (Populations Served) gives preference to organizations providing housing for military veterans. Beyond that, the QAP never once mentions the U.S. Department of Defense's landholdings on Guam -- a real and material constraint on developable land supply that a screen has to bring in from outside the QAP entirely. The U.S. Government Accountability Office reported in 2008 and again in 2010 that DOD controls about 29% of Guam's land, roughly 62 square miles. The Congressional Research Service's 2023 report on Guam defense infrastructure states DOD "owns about 25% of the land on Guam." The two figures come from different vintages and methodologies and this research did not find a single authoritative current percentage reconciling them -- but both agree the share is large, in the range of one-quarter to one-third of the island, and that it is concentrated in specific installations (Andersen Air Force Base in the north, Naval Base Guam and the new Marine Corps Base Camp Blaz, which opened in 2020) rather than spread evenly across all 19 villages. A parcel's proximity to, or history of association with, an active or former military installation is a real screening question the QAP itself never raises.
The QAP is equally silent on Guam's hazard geography. Guam sits in the Pacific typhoon belt and in a seismically active zone (a regional research resource cites roughly 471 earthquakes per year in the area, with monthly magnitude-5-plus events); Guam has adopted the International Building Code and International Residential Code with wind-load provisions built for sustained winds in excess of 150 mph. None of this appears anywhere in GHURA's QAP -- no flood, FEMA, or wetlands reference of any kind was found in either the 2025 or the 2024 QAP text. A screen cannot rely on the QAP to flag flood zone, storm surge, or seismic siting risk; that work has to be done independently, and belongs in the market study GHURA requires (which does ask, separately, for "analysis of impacts of development to the area's existing education, public safety, and utilities infrastructure") rather than in anything GHURA itself screens for.
Where this goes wrong
- Assuming Guam runs a predictable annual QAP calendar -- the 2025 cycle was explicitly an "abbreviated" one-off process triggered by unawarded CY2024 credits, with a five-week application window; the next cycle's timing should not be assumed to match it.
- Treating the $6,815,000 total 2025 allocation as the competitive pool -- $1,793,120 was already reserved to Flores Rosa Gardens LLC before the round opened, leaving $5,021,880 actually available for competitive award.
- Misreading the QAP's "High-Cost Area Designation" sentence as the ordinary federal QCT/DDA boost running as usual -- it reads instead as GHURA exercising its own independent state/territorial agency-designation authority under 26 U.S.C. § 42(d)(5)(B)(v) to extend high-cost treatment to new construction outside HUD's own QCT/DDA maps.
- Assuming a specific Guam parcel's current-year federal QCT or DDA status without checking HUD's own huduser.gov lookup tool directly -- this research could not confirm Guam's current tract-level designations from a live, queryable source.
- Screening a site without checking its proximity to, or history with, an active or former DOD installation -- DOD control of Guam's land is estimated at roughly 25% (CRS, 2023) to 29% (GAO, 2008/2010) of the island, and the QAP itself never raises this as a screening factor.
- Assuming GHURA's QAP will flag flood, wetlands, or seismic siting risk the way some mainland QAPs' location-scoring tables do -- no flood, FEMA, or wetlands reference of any kind appears in either the 2025 or 2024 GHURA QAP text; that diligence sits entirely outside the QAP.
- Using mainland driving-distance intuition to judge Criteria 1 -- the QAP's own bands (5/10/15-mile) are calibrated to an island roughly 30 miles long, so "far" on Guam looks nothing like "far" on a mainland map.
- Relying on a cached or third-party copy of the QAP rather than confirming directly with ghura.org that the 2025 QAP (Board-Approved 10-21-2025) has not since been amended -- the QAP itself states it is subject to Board amendment at any time.
- Conflating the 2-point Qualified Census Tract scoring criterion (Criteria 11) with the much larger federal or state-designated basis boost -- they are governed by different QAP sections and are not the same mechanism.
- HUD
- LIHTC
- State QAPs
- IRS § 42
- Housing Finance Agencies