Site sourcing and screening — Illinois

The Preliminary Project Assessment: the gate before there's an Application at all

IHDA requires every 4% and 9% Tax Credit applicant to complete a Preliminary Project Assessment (PPA) before it will accept a full Application. Sponsors request a Project ID ("PID") and an IHDA Connect account at ppa.ihda.org, then submit the current Universal PPA Workbook electronically — paper submissions are not accepted. The PPA is evaluated across five categories, and each one receives its own outcome (Approval, Conditional Approval, or Denial) that rolls up into one overall PPA determination. An overall Denial means the Authority will not accept an Application for that Project at all — this is the first real screening decision Illinois forces on a site, well before anything resembling a scored Application exists.

Fees are due at PPA submission and are retained by IHDA even if a Project never moves forward. PPA validity is asymmetric by credit type: an overall PPA notification letter for a 4% Tax Credit Project is valid for 12 months or until the QAP expires, whichever comes first, while a 9% PPA letter is valid for both years covered by the 2027-2028 QAP's competitive rounds. Critically, a PPA evaluation and notification letter issued under a prior QAP is not valid under the current one — a Sponsor who received a PPA approval but no award under the 2026 QAP has to resubmit a fresh PPA under the 2027-2028 QAP before applying again.

The screening judgment made at PPA is close to final. IHDA states plainly that it will not approve an Application for a Project with changes to Site(s), population served, or construction type relative to what was approved at PPA, with a narrow list of permitted post-PPA adjustments (unit-count swings of up to 10%, AMI-mix changes that preserve proportions, and similar). A Project Site can move to an adjacent parcel only at IHDA's sole discretion; any other Site change requires submitting an entirely new PPA. That means the parcel decided on at the PPA stage is, in practice, the parcel the deal is stuck with.

Four Set-Asides, percentage goals, and no fixed minimum score

9% Tax Credit Applications compete only against other Applications filed in the same annual round within the same geographic Set-Aside. IHDA defines four: Chicago Metro (Cook County's five adjacent counties — DuPage, Kane, Lake, McHenry, and Will — excluding the city of Chicago itself), City of Chicago (the municipal boundary of Chicago), Other Metro (smaller metro areas with contiguous development, such as Springfield, Peoria, and Rockford), and Non-Metro (regions outside any contiguous metro area, including every county under 50,000 population). A fifth, Statewide, is not something a Sponsor can apply into directly — IHDA may draw from it at its own discretion for Projects that advance its policy priorities, that would not otherwise win an award within their own geographic Set-Aside, or that sit in a Set-Aside where requested credits exceed what's available. A scattered-site Project is assigned to whichever Set-Aside holds the largest share of its units, and IHDA's own Set-Aside Lookup tool tells a Sponsor which bucket a given parcel falls into before a PPA is even filed.

Unlike states that enforce a published minimum score to compete at all, Illinois runs a purely comparative process. The maximum possible score for any Application is 100 points — 80 from General Scoring Criteria plus up to 20 more from a single elected Policy Track (Creative Solutions, Permanent Supportive Housing, or Targeted Markets; a Sponsor may pursue only one) — but there is no floor an Application has to clear before IHDA will consider it. Ties are broken through a defined five-step sequence: highest unit count, then lowest per-unit construction cost, then lowest average AMI targeting across all units, then eventual-tenant-ownership intent with a credible plan, then historic significance.

Community Characteristics and the Quality of Life Index

Of the 80 General Scoring Criteria points, 18 sit inside a single "Community Characteristics" category: up to 10 for the Quality of Life Index ("QOLI"), up to 5 for Access to Transportation, and a swing of plus-or-minus 3 for Market Characteristics. IHDA maintains the QOLI as a standing, tract-level index covering every census tract in Illinois, built from five categories — education, prosperity, health, housing, and connectivity — each worth up to two points, for a possible range of one to ten. A Project simply receives the QOLI score assigned to its tract; the QAP states plainly that "QOLI scores cannot be adjusted," so a low-scoring tract's ceiling on this category is fixed by geography, not by anything a Sponsor submits.

Access to Transportation awards up to four points for Sites within a half-mile of a public transportation station (or an eighth-mile of a qualifying bus stop) with weekday service running roughly 8 a.m. to 6 p.m., or served by a Demand Responsive Transit service open to the general public; a further point is available for proximity to a set number of jobs that scales by Set-Aside (for example, 10,700 jobs within one mile in the City of Chicago versus 3,500 jobs within five miles in a Non-Metro Set-Aside, verified through the U.S. Census Bureau's "On the Map" tool). Market Characteristics works differently from every other scoring line: an Application "will only be permitted to self-score a zero," and IHDA alone assigns the actual score, from negative three to positive three, based on the Site and Market Study and factors like tenant targeting, unit mix and rents relative to the comparable set, and penetration and capture rates.

Separately from all of this scoring, IHDA imposes a mandatory Food Access requirement at the PPA stage — a pass/fail item, not a points category. Each Site must be within a set radius of a NAICS-coded qualifying grocery, supermarket, or produce-market business (one mile in Chicago Metro, City of Chicago, and Other Metro; five miles in Non-Metro), verified through Esri Business Analyst. Convenience stores are explicitly disqualified from satisfying this requirement in any Set-Aside.

QCT and R/ECAP: a planning mandate, not a scoring bonus — and where the Basis Boost actually comes from

Illinois's QAP does not award scoring points for a Site simply sitting inside a Qualified Census Tract (QCT) or a Racially or Ethnically Concentrated Area of Poverty (R/ECAP, HUD's term for a tract that is 50% or more non-white with a poverty rate of 40% or higher). Instead, that geography triggers a Mandatory obligation: any Project with a Site in a QCT and/or R/ECAP must submit a Community Revitalization Strategy meeting IHDA's own Community Revitalization Strategy Thresholds and Scoring Criteria, evaluated first at PPA and required again at Application, and must complete a technical assistance call with IHDA's Community Revitalization staff. This is due-diligence homework triggered by geography, not a scoring credit — the scoring credit for a Community Revitalization Strategy sits instead inside the optional Targeted Markets policy track (up to five points), and only counts if a Sponsor separately elects that track.

The Basis Boost mechanism is narrower than in some other states. A Code Provided Basis Boost of up to 30% is available to any Project in the most recent published HUD list or map of QCTs or Difficult Development Areas (DDAs), but the QAP treats it as something IHDA has to grant rather than something an Applicant self-certifies: "Projects may not apply with a Basis Boost. Requests for a Basis Boost will be considered as an Authority resource request." A Discretionary Basis Boost exists only for 9% Tax Credit Projects, at IHDA's discretion, tied either to the Authority's own Policy Priorities or to managing its resources or making a Project financially feasible — and the QAP states outright that "the Authority may not provide a discretionary Boost to 4% Tax Credit Projects."

Illinois does not otherwise run a separate state-statutory basis-boost mechanism parallel to what some other states' housing finance agencies offer. Illinois's other Authority-administered credit, the Illinois Affordable Housing Tax Credit (IAHTC), is a donation tax credit for individuals or entities that contribute money, materials, or land to a Project — a different transaction serving a different purpose, not a per-project increase to eligible basis. The two should not be conflated when sizing a deal's credit stack.

The Targeted Markets policy track, and the hazard and parcel-data floor underneath every screen

A Sponsor who elects the Targeted Markets policy track in lieu of Creative Solutions or Permanent Supportive Housing can reach up to 20 additional points across six sub-categories: the Affordability Risk Index (ARI, a non-adjustable, tract-level census score from zero to five); Communities Lacking Affordability, worth up to five points and tied directly to the Affordable Housing Planning and Appeal Act's own affordability-share calculation (five points if the municipality's share is 10% or less — a "Non-Exempt Local Government" under that Act — three points at 10.1%-17%, two points at 17%-20%); Community Revitalization Strategies (up to five, the same Strategy that's Mandatory for QCT/R/ECAP Sites); Neighborhood Assets (up to two, based on walking-distance proximity to categories like food access, health and wellness, education and culture, mobility, civic facilities, retail, and services); Opportunity Zones (two flat points for a Site in a census tract the Illinois Department of Commerce and Economic Development designates under the federal Opportunity Zone 2.0 program, effective January 1, 2027); and Transit Oriented Development (one point for a Site inside a Northern Illinois Transit Authority TOD planning area or a qualifying local TOD plan).

On top of scoring, every Application has to clear a fixed set of environmental and hazard layers regardless of Set-Aside or policy track: a FEMA floodplain map (new-construction buildings must sit entirely outside the 1% floodplain or floodway), a U.S. Fish and Wildlife Service National Wetlands Inventory map, an Illinois State Geological Survey (ISGS) mining map, and a USGS seismic zone map. The mining requirement carries a distinctly Illinois wrinkle: any Project in a county the Illinois Mine Subsidence Insurance Fund Map identifies as requiring subsidence coverage must budget for that insurance in the Application, a legacy of the coal-mining geology under parts of the state that most other states' screens simply don't have to account for.

What this research could not confirm is whether Illinois has a single, state- or IHDA-published, parcel-level zoning dataset comparable to what some other states maintain. The state's own Illinois Geospatial Data Clearinghouse, hosted through the University of Illinois's Prairie Research Institute (ISGS), aggregates statewide non-parcel layers — geology, land use, political boundaries, and similar — and commercial aggregators claim county-by-county parcel coverage across all 102 Illinois counties, each of which runs its own assessor. But this research did not locate a normalized, parcel-keyed zoning schema published by the state or by IHDA itself; that gap should be verified directly rather than assumed to exist or assumed not to.

IHDA publishes its own current-year income and rent limits as an annual Excel workbook, broken out by county, timed to follow HUD's Multifamily Tax Subsidy Project income-limit release each year — a different publication format from a single standalone PDF, but serving the same purpose: turning a county's median income into the specific dollar rents a Project can charge at each AMI tier under 26 U.S.C. § 42(g).