"Does this town even have zoning to certify, and which of Indiana's three location pools does this site actually land in?"
What the two-week screen looks like in Indiana
IHCDA — the Indiana Housing and Community Development Authority — runs Indiana's 9% and 4% LIHTC program under its own Qualified Allocation Plan, currently the 2026-2027 QAP (Board-approved, covering both the 2026 and 2027 annual 9% competitive rounds). The screening pattern is the same shape as any other state's: an analyst has a site and spends the next one to two weeks working through a checklist before it's worth an LOI.
| Step | What it involves |
|---|---|
| Assessor/parcel record | Pull the record from the relevant County Assessor's office — Indiana's 92 counties administer this individually; this research did not surface a single consolidated, publicly REST-queryable statewide parcel API to confirm or rule one out |
| Zoning | Confirm the jurisdiction has actually adopted zoning at all, then obtain (or fail to obtain) a government official's letter certifying the current zoning allows the proposed use without a variance |
| Site-type classification | Work out whether the site is a 100%-vacant structure, an infill lot adjacent to active development, a foreclosure/condemnation, or a preservation deal — the QAP scores the first three as mutually exclusive categories, with foreclosure/condemnation as a separate category that can stack on top |
| Set-aside pool | Determine whether the site's population tier, distance from a municipal zoning jurisdiction, and water/sewer service land it in the Large City, Small City, or Rural pool |
| Flood hazard | Pull FEMA's official flood map directly — IHCDA will not accept a third-party rendering even if built from FEMA data — and check the Zone A/B funding gate |
| Environmental hazards | Screenshot the parcel against IDEM's Restricted Sites map; a covenant against residential use is an automatic disqualifier, not a scoring deduction |
| Historic status | Check IDNR's Indiana Buildings, Bridges, and Cemeteries map for Register listing or local-landmark status |
| QCT/DDA status | Check HUD's current-year Qualified Census Tract and Difficult Development Area designations against the QAP's Appendix E |
| Market characteristics | Map desirable/undesirable features within a quarter-mile to one-mile radius: grocery, civic/retail/healthcare uses, transit, and a named list of undesirable-site types |
| Income limits and rents | Pulled from HUD/IHCDA published limits later in underwriting — not scored at screening, but shapes whether the deal justifies the market study fee |
| Comparable awards | IHCDA's own scoring keys off award-recency by city/town, county, and census tract; this research did not confirm a separately published statewide award-history file comparable to some other states' |
| Construction cost anchor | No Indiana-specific public dataset found; BLS's national Producer Price Index construction-inputs series is the same free, escalation-only federal baseline available everywhere |
Two decisions come out of this phase, same as anywhere else. The first is whether to pursue the site. The second is what price goes into the option or purchase agreement — and in Indiana that number does something concrete almost immediately: if any IHCDA resource is used for acquisition, eligible basis for acquisition credits is capped at the lesser of the price actually paid or the property's 'as is' appraised value, per an Indiana-licensed appraiser's USPAP report dated within six months of the deadline. An LOI written above appraised value doesn't get scored down later — it loses eligible basis directly.
Site control: four forms, and the lease option ties to a variable Extended Use Period
IHCDA accepts exactly four forms of site control evidence, and it names them plainly rather than defining an abstract 'enforceable rights' test the way some states do.
| Form | Key condition |
|---|---|
| Purchase agreement or option | May not expire until after the anticipated LIHTC reservation date; requires title evidence via title insurance commitment, title search, or attorney's opinion |
| Executed and recorded deed | Straightforward ownership evidence |
| Long-term lease option | Lease term may not expire prior to the end of the Extended Use Period — a deal-specific, variable length, not a flat statutory number |
| Governmental acquisition package | Duly adopted resolutions identifying and authorizing the acquisition, a timetable letter from the acquiring agency, plus title evidence |
Two mechanics are easy to miss. First, site control documentation must be in the name of the Development Owner or Applicant — not an affiliate — and unlike almost every other required exhibit, it is explicitly exempted from the QAP's general six-month document-age rule, as long as the expiration date falls after the anticipated reservation date. Second, the long-term-lease option's minimum term is not a fixed number the way it is in some states' QAPs. Indiana's default Extended Use Period is 30 years (an initial 15-year Compliance Period plus 15 additional years), but an applicant can elect a 35-year term for 2 affordability-scoring points or a 40-year term for 4 points — and that election, made at application, is exactly the number a lease-option's minimum term has to clear. A lease negotiated to a 30-year floor can strand an application that later decides to chase the extra points.
Zoning is a certification you request, not a code you read — and it isn't universal
The QAP's zoning threshold item is a certification requirement: a letter from 'the appropriate authorized government official (e.g., zoning commission)' stating that current zoning allows the proposed construction, reuse, or rehabilitation and operation without a variance — required even for a straight rehab. Where the Applicant can document a failed attempt to obtain that letter, an attorney's opinion substitutes. Failing to secure either one is a threshold failure, not a scoring deduction.
What the QAP doesn't ask, because Indiana law doesn't require it, is whether the jurisdiction has zoning power to certify from at all. Indiana Code Section 36-7-4-201 frames planning and zoning as something a unit of local government elects into — 'a unit wanting to exercise planning and zoning powers in Indiana...must do so in the manner provided by this chapter' — rather than a power every city, town, or county is required to hold. In practice that means the zoning-certification threshold item can land on a jurisdiction that never adopted a zoning ordinance at all, and the QAP has no built-in fallback letter type for that scenario the way some other states' rulebooks do. It is a real, unresolved gap worth closing with local counsel before an LOI, not after.
Zoning geography also decides which funding pool the site competes in. Each 9% application competes in exactly one Development Location set-aside, and the test is more than a population lookup.
| Pool | Definition |
|---|---|
| Large City (17% of annual 9% LIHTC) | City with population 70,000+; site must be within one mile of the zoning jurisdiction and/or use city water and sewer |
| Small City (17%) | City with population 10,000–69,999; same one-mile/utility test |
| Rural (17%) | City/town of 9,999 or fewer; or an unincorporated area without a Large/Small City; or, in a county that has one, an unincorporated site at least one mile outside that city's jurisdiction and without access to its water or sewer |
The same parcel can land in a different 17%-of-allocation pool depending on exactly how far it sits from a municipal boundary and whether it's on city utilities — a genuinely load-bearing screening fact, not a formality.
Hazard and environmental screening: an official-map-only rule, and gates that hit gap funds before LIHTC
A full Phase I Environmental Site Assessment, completed by a disinterested third party and dated within 18 months of the deadline, is required before application — it must address hazardous substances, wetlands, and floodplains, with a wetlands delineation map only where wetlands actually exist. If it turns up Recognized Environmental Conditions, the Applicant must submit a mitigation narrative, timeline, and budget, and a Phase II ESA has to be completed before closing.
Floodplain documentation runs on an IHCDA-specific rule that a screening tool can silently violate: a FIRM floodplain map must come from FEMA's own website — 'third-party maps, even those created using FEMA data, will not be accepted.' A site proposing buildings in a 100-year floodplain (Zones A1-30, AE, A, AH, AO, AR, A99) has to submit a FEMA Conditional Letter of Reclassification, a licensed surveyor or civil engineer's mitigation-cost letter, and a financing narrative at application, and a final reclassification letter plus elevation certificate at completion. Separately — and easy to conflate — a site in any variation of Zone A or B is not disqualified from LIHTC itself, but it is flatly ineligible for IHCDA HOME, HTF, PBV, or Section 811 PRA funding. A screen that reduces floodplain status to one boolean either overstates the risk on a 9%-only deal or misses a hard gate on one stacking gap funds.
Environmental contamination screening is comparatively harder-edged than in some other states: for every site, the Applicant must submit a screenshot from IDEM's Restricted Sites map, and if the property is subject to an environmental restrictive covenant that prohibits residential use, the application is disqualified at the deadline — a categorical threshold failure, not a negative-points item to weigh against the rest of the score.
Historic status carries its own documentation trail: Applicants requesting Development Fund must complete a State Historic Review under Indiana Code Section 14-21-1-18, using IDNR's Indiana Buildings, Bridges, and Cemeteries (IHBBC) map to determine National or State Register listing or local-landmark status. If the site is listed, IHCDA must obtain a Certificate of Approval from the State Historic Preservation Office before a Development Fund contract can be signed — a review that takes a minimum of 30 days once SHPO receives it.
Market Characteristics runs 42 of 165 points on real public data — and the site's own history is worth up to 15
Part 6.3, Market Characteristics, is 42 of the QAP's 165 total scoring points, and almost all of it keys off named, genuinely public datasets rather than a proprietary IHCDA model: STATS Indiana (population growth, county unemployment), HUD's Comprehensive Housing Affordability Strategy data (rent burden, severe housing problems, extremely-low-income share), County Health Rankings (primary-care-physician ratio), the Indiana Department of Workforce Development's Employment Projections 2022-2032, and IHCDA's own Indiana Housing Dashboard (units by decade built, vacant-and-available-unit rate).
| Category | Points | What it measures |
|---|---|---|
| Desirable Sites (6.3(A)) | 6 | Fresh produce access, proximity to civic/retail/healthcare uses, transit access; minus 1 point per undesirable site within a quarter mile |
| Unit Production in Underserved Areas (6.3(B)) | 6 | 9% award-recency by city/town/unincorporated area (5/10/15-year lookback) and by county |
| Census Tract w/o Active LIHTC (6.3(C)) | 3 | Whether the tract already carries an active project of the same occupancy type |
| Opportunity Index (6.3(D)) | 4 (net −1 possible) | High income, low poverty, low unemployment, primary-care access; R/ECAP tracts lose 1 point |
| Housing Need Index (6.3(E)) | 8 | Population growth, rent burden, severe housing problems, low-AMI share, LIHTC-unit-to-renter ratio, pre-1940 housing stock, vacancy rate, Age-Restricted Rental Housing Desert status |
| 10-Year Projected Job Growth (6.3(F)) | 5 | Regional Employment Projections 2022-2032 |
| 5-Year Actual Job Growth (6.3(G)) | 5 | County job growth 2019-2023 |
| Jobs-to-Permits Ratio (6.3(H)) | 3 | Net jobs added per housing permit, 2014-2023 |
| Community Revitalization Plan for QCT (6.3(I)) | 2 | A qualifying local plan under IRC Section 42(m) / IRS Notice 2016-77 |
The 'Access to Fresh Produce' evidence requirement is oddly specific and worth flagging on its own: the market study must include current interior and exterior photos of any grocery store claimed for the point — stock photos are rejected outright, and only recognized grocery chains are exempt from the interior-photo requirement.
Separately, in Part 6.2 Development Characteristics, the site's own physical history is worth real points. Three of the categories — Redevelopment of Vacant Structure, Preservation of Existing Rental Housing, and Infill New Construction — are mutually exclusive with each other, so an application can claim only one of those three. Foreclosed and Condemned Properties is a separate category that can stack on top of whichever of those three also applies.
| Category | Points | Condition |
|---|---|---|
| Redevelopment of Vacant Structure (6.2(D)) | 6 | Structure(s) must be 100% vacant at application submission |
| Preservation of Existing Rental Housing (6.2(E)) | 6, plus up to 3 bonus | Expired/expiring LIHTC compliance period, HUD/USDA-assisted housing, or other affordable/market housing conversion; bonus scales with units preserved |
| Infill New Construction (6.2(F)) | 6 | At least two sides adjacent to occupied residential, commercial, or active public/community space; site has or can connect to existing utilities |
| Foreclosed and Condemned Properties (6.2(H)) | 3 | At least 50% of units on a parcel that was foreclosed or officially condemned |
Redevelopment of Vacant Structure (D), Preservation of Existing Rental Housing (E), and Infill New Construction (F) are mutually exclusive with each other — an application can claim only one. Foreclosed and Condemned Properties (6.2(H)) is a separate, stackable category, as is Historic-building status (6.2(G), up to 3 points) — neither is mutually exclusive with D/E/F or with each other.
In a program where 9% applicants need 85 of 165 points to pass threshold at all, picking the wrong site-type bucket — or one that doesn't actually qualify under the strict definitions above — is a real points swing before underwriting even starts.
Where the screen stops for Indiana today
IHCDA does not grant threshold-requirement waivers for a handful of items, and one of them is directly relevant here: a non-competitive 4% LIHTC/bond application cannot request a waiver of the requirement to submit zoning documentation or an inducement resolution. If the zoning-certification letter can't be obtained and the attorney's-opinion fallback isn't credible, there is no administrative escape hatch for a bond deal.
This research did not surface a consolidated, publicly REST-queryable statewide Indiana parcel layer comparable to what exists in some other states — ownership and assessment records live at the 92 individual County Assessor offices, and confirming county-by-county GIS coverage was out of scope for this pass. The same is true for construction cost: there is no Indiana-specific, free, unit-level affordable-housing cost dataset; the BLS Producer Price Index construction-inputs series gives escalation, not a level, and is the same federal series available in every state.
What screening can and should answer before the phone call: whether the jurisdiction has zoning to certify at all, which of the three location pools the site lands in, whether its physical history opens or forecloses the mutually-exclusive site-type points, whether it sits in a floodplain zone that specifically blocks the gap funds the deal is planning to stack, and whether an above-appraisal LOI price is about to cost eligible basis directly. None of that is available in EZFeasi for Indiana today — no Indiana parcel, zoning, hazard, market, or award data is loaded in any tool yet.
Where this goes wrong
- Treating the zoning certification letter as paperwork rather than a threshold gate. The QAP requires a government official's letter (or, after documented failed attempts, an attorney's opinion) certifying that current zoning allows the proposed use without a variance — a site that needs a variance to work fails threshold, it doesn't lose points.
- Assuming every Indiana jurisdiction has zoning to certify. Indiana Code Section 36-7-4-201 makes planning and zoning power something a unit of local government elects into, not a power every city, town, or county is required to hold, and the QAP has no defined fallback letter type for a jurisdiction with no zoning ordinance at all.
- Submitting a third-party or web-derived floodplain map. IHCDA requires the official FEMA map only — 'even those created using FEMA data' are explicitly rejected — so a screening tool serving a cached or vendor-rendered flood layer instead of linking to FEMA directly will fail a threshold review.
- Collapsing Zone A/B floodplain status into a single pass/fail flag. It does not disqualify LIHTC itself, but it does flatly disqualify IHCDA HOME, HTF, PBV, and Section 811 PRA funding — a screen needs to know which funding sources the deal is actually stacking before it can answer 'is this site eligible.'
- Missing the IDEM Restricted Sites covenant check. An environmental restrictive covenant against residential use is an automatic application disqualifier at the deadline, not a negative-points item to weigh against everything else the site has going for it.
- Picking a site-type scoring category without checking mutual exclusivity. Redevelopment of Vacant Structure, Preservation of Existing Rental Housing, and Infill New Construction cannot be claimed together — the site's actual condition (100% vacant vs. occupied-and-adjacent vs. under an existing LURA) determines which bucket is even available.
- Reducing the Large City/Small City/Rural set-aside test to a population lookup. It also runs on distance from the zoning jurisdiction and access to city water/sewer — missing either test moves the same parcel into a differently-sized, 17%-of-allocation funding pool.
- Using stock or archived photos to claim the Access to Fresh Produce point. IHCDA requires current interior and exterior photos of any grocery store claimed for the point; stock photos are rejected outright.
- Treating the LOI price as neutral until formal underwriting. Under the appraisal requirement, eligible basis for acquisition credits is capped at the lesser of the price paid or the 'as is' appraised value — an above-market LOI price is a direct, dollar-for-dollar eligible-basis loss, not a separate scoring penalty to model later.
- Letting incomplete documentation accumulate at initial submission. Five or more threshold deficiencies — including ones later resolved during the 14-day Correction Period — disqualify the application outright; a resolved deficiency still counts against that ceiling.
- Screening a site's Opportunity Index profile without checking the R/ECAP overlay. A HUD-designated Racially/Ethnically Concentrated Area of Poverty subtracts a point, which can push the whole 4-point category to a net −1 even when the site earns none of the other opportunity points.
- Assuming any qualified appraiser or market analyst can prepare the market study. The analyst must appear on IHCDA's own approved Market Study Analyst list and be pre-approved for the specific project type — general affordable housing, permanent supportive housing, or assisted living/residential care.
- Sizing a long-term-lease site-control option to the default 30-year Extended Use Period when the deal plans to chase the 35- or 40-year affordability-scoring points. A lease with a 30-year floor can strand an application that later elects the longer term for points.
- Filing the Notification of Intent to Apply (Form C) outside the required window. It must be submitted at least 30 days but no more than 60 days before a competitive application deadline — outside that window, there is no valid Form C on file at submission.
- HUD
- LIHTC
- State QAPs
- IRS § 42
- Housing Finance Agencies
