"Which ZIP codes are already excluded, and how much of my score is locked in before I even know if I'm invited to apply?"
What the screen has to answer before January 16
Kansas runs one 9% round a year, and the preliminary application due January 16, 2026 at noon CST isn't a light-touch intake — it's where most of a new-construction site's Section VII location scoring gets submitted, sight unseen, before KHRC has even decided whether the application is competitive enough to invite to full application. The Article 10 statutory gate (K.A.R. 110-10-1 / QAP Appendix A) is assessed at the same stage: KHRC will only invite applications that "earn 310 points under the Appendix A categories" and "meet a minimum point threshold of 33 points at preliminary application." Project Location alone is worth 50 of those 310 points, all-or-nothing, and the selection criterion is specific — the application must "specifically document the exact real estate to be developed, including any necessary easements." An imprecise legal description costs the same 50 points as no description at all.
| Category | Max points | Scored at |
|---|---|---|
| B. Underserved Areas / C. Subsequent Phase (mutually exclusive) | 10 | Preliminary |
| D. Residential Character | 5 | Preliminary |
| F. Proximity to Amenities — Primary | 10 | Preliminary & Full |
| F. Proximity to Amenities — Secondary | 10 | Preliminary |
| H. CRP or I. Opportunity Sites (higher of the two) | 15 | Preliminary (CRP); Preliminary & Full (Opportunity Sites) |
| E. Quality Site | 5 | Full application only |
65 of these 70 points are submitted at preliminary application — before an applicant knows whether the site even cleared the 33-point invitation threshold to submit a full application at all.
That ordering matters for how a developer sequences the work: the site-selection analysis a shop would normally treat as preparatory has to be finished — maps, distance calculations, ZIP-code checks, adjacency documentation — before the January deadline, not spread across the months between preliminary and full application the way KHRC's own calendar might suggest.
Underserved Areas vs. Subsequent Phase — pick one, and check this year's list
QAP § VII(B) awards 10 points if the site's ZIP code has not received a LIHTC award in the past four years, using separate published exclusion lists for the Metropolitan and Rural pools — an application in Douglas, Johnson, Sedgwick, Shawnee, or Wyandotte County is checked against the Metropolitan list; everywhere else, the Rural list. These lists are republished with each year's QAP, so a ZIP that screened clear last cycle isn't guaranteed to stay clear.
| Metropolitan (33 ZIPs, excluded) | Rural (31 ZIPs, excluded) |
|---|---|
| 66012, 66018, 66025, 66030, 66044, 66046 | 64114, 66002, 66043, 66048, 66053, 66067 |
| 66049, 66061, 66062, 66101, 66102, 66104 | 66106, 66441, 66502, 66503, 66749, 66762 |
| 66106, 66109, 66111, 66112, 66213, 66217 | 66801, 67002, 67010, 67042, 67063, 67114 |
| 66227, 66602, 66604, 66605, 66615, 67037 | 67119, 67156, 67301, 67337, 67357, 67401 |
| 67052, 67202, 67206, 67208, 67209, 67212 | 67410, 67665, 67701, 67801, 67846, 67871 |
| 67216, 67219, 67220 | 67901 |
ZIP 66106 appears on both the Metropolitan and Rural exclusion lists as published in the 2026 QAP text — the document doesn't explain the overlap, and this content doesn't attempt to resolve it. Confirm against the then-current year's QAP before relying on any of these lists; they are not static.
Underserved Areas and Subsequent Phase are explicitly mutually exclusive — an application may not earn points in both (QAP § VII(B)). Subsequent Phase is the alternative 10 points for a second or third phase within .25 miles of a prior phase, but it comes with real conditions: the earlier phase(s) must show less than 5% physical vacancy for the six months before preliminary application, a waitlist covering at least 50% of the proposed phase's units, the same original Applicant on both awards, and no prior qualified-contract request. For a developer choosing between a fresh site and a phased expansion of an existing property, this is the first fork — a strong existing waitlist can be worth more than a clean ZIP code, but only if the vacancy and waitlist evidence actually holds up six months back from January 16.
Residential Character, Quality Site, and Proximity to Amenities test three different things about the same parcel
Residential Character (QAP § VII(D)) awards 5 points if the site is in or adjacent to existing residential development compatible in density and architectural style — but "adjacent" is defined narrowly, as sharing a lot line with, or sitting across the street from, structures containing at least 25% of the proposed development's unit count. It also carries a location test independent of adjacency: the site must sit within city limits, on land that is in or committed to urban development as defined by the Farmland Protection Policy Act at 7 C.F.R. § 658.2(a). A rural or unincorporated agricultural-zoned parcel can't earn these 5 points no matter how compatible its surroundings look, until it's inside a city's limits.
Quality Site (QAP § VII(E)) is the one category that isn't formula-driven at all: KHRC staff rate proposals on street appeal, natural features, walkability, traffic and noise, buildability, green space, safety, and neighborhood stability, and award 5 points each to only the top two Metropolitan and top two Rural proposals per round — a hard cap, not a threshold. A developer can't self-score this one; it's scored at full application, and being genuinely scarce, it shouldn't be budgeted into a preliminary competitive-standing estimate.
Proximity to Amenities (QAP § VII(F)) is worth up to 20 points and works differently depending on credit type. Primary amenities (up to 10 points) measure Google Maps driving distance to grocery (weighted ×0.5), shopping (×0.75), and pharmacy (×1.0), with distances under .3 miles rounded up to .3. For 9%, KHRC separates Metropolitan from Rural applicants, sums the weighted distances, and awards full points only to the single lowest-total applicant in that round's pool — everyone else is pro-rated down by percentage of the lowest. That's a relative ranking against whoever else applied that cycle, not an absolute distance target. 4% new construction instead uses a flat 0.4-mile comparable-scoring benchmark — an absolute standard, since there's no competing round to rank against. Secondary amenities (up to 10 points) award 1 point each for up to 10 of 16 listed types within 3 miles (½ point per amenity between 3 and 20 miles for Rural sites only), with a single establishment capped at one point and unable to double as a primary amenity for more than two of the three primary categories.
The county math constrains where a well-scored site can even compete
Two counties pools govern 9%: Douglas, Johnson, Sedgwick, Shawnee, and Wyandotte are Metropolitan; every other county is Rural. Each pool gets at least 25% of available LIHTC targeted to it (QAP § III(C)), but a separate, harder constraint sits underneath the set-asides — KHRC generally makes no more than two new-construction awards per Rural County and three per Metropolitan County per round (QAP § III(A)(3)). A site can clear every point category and still lose purely because its county already has its allotment filled that round; the QAP gives KHRC discretion to award an additional application in a full county only through the separate Unique Opportunities set-aside.
Opportunity Sites (QAP § VII(I), up to 15 points, Appendix D) is the one dataset in this phase that's genuinely queryable today: KHRC publishes a numeric score for every census tract in the state, built from four weighted categories — Affordable Housing Need, Growth Demand, Quality of Life, and Economic Opportunities — grounded in the 2021 Kansas Statewide Housing Needs Assessment. But the scoring mechanic differs by credit type the same way Primary Amenities does: for 9%, KHRC ranks applicants within the Metropolitan or Rural pool and gives full points only to the highest final percentile that round (relative); for 4%, full points go to any site scoring above a flat benchmark of 70 (absolute). The same census tract's Opportunity Site score means something different depending which program a developer is chasing. It's also mutually exclusive with Community Revitalization Plans (§VII(H)) — an application eligible under both gets whichever is higher, not both.
What's actually queryable today, and what EZFeasi doesn't have loaded yet
The Kansas Data Access and Support Center (DASC), the state's GIS clearinghouse since 1991, hosts statewide layers including parcels through collaboration with county assessors, and its ORKA tool integrates county appraiser CAMA data with parcel boundaries and imagery. Whether that adds up to a single normalized, machine-queryable statewide parcel-and-zoning layer — the way SCAG's does for six Southern California counties — isn't something I could confirm from DASC's own publicly fetchable pages; the Geoportal's data catalog is JavaScript-rendered and describes itself only in general terms. Confirming per-county coverage, vintage, and access terms would take a direct inquiry to DASC, not a page read. EZFeasi has not loaded any Kansas parcel, zoning, or DASC data yet.
FEMA flood data covers the floodplain and wetland tests in QAP § V(C)(1)'s SITE bullets, the same open national layer used everywhere. But the broader incompatible-uses screen in that same subsection — a half-mile check for chemical or hazardous-materials storage, junk or salvage yards, industrial or agricultural odor/pollution sources, active landfills, and wastewater treatment facilities, plus a separate adjacency check for adult entertainment establishments, trucking distribution facilities, electrical substations, factories, jails or prisons, and sources of excessive noise or environmental-justice concern — has no single queryable KHRC or state layer behind it. It's determined narratively at preliminary application, meaning a developer builds this checklist site by site today, by hand.
Where this goes wrong
- Treating site screening as a step that happens before scoring begins. Up to 65 of Section VII's location points are submitted — and effectively locked — at the January 16 preliminary deadline, before KHRC even confirms the site cleared the 33-point invitation threshold.
- Checking last year's Underserved Areas ZIP-code exclusion list instead of the current year's. KHRC republishes the Metropolitan and Rural lists with each QAP cycle (QAP § VII(B)); a ZIP that was clear last year may have received an award since.
- Claiming both Underserved Areas and Subsequent Phase points on one application. The two are explicitly mutually exclusive (QAP § VII(B)-(C)).
- Assuming Residential Character is available to any well-integrated site. It categorically requires the site to sit within city limits, on land in or committed to urban development under the Farmland Protection Policy Act (7 C.F.R. § 658.2(a)) — an unincorporated or agricultural rural parcel can't earn it regardless of how compatible its surroundings look.
- Budgeting on Quality Site points as if they were formula-based. Only four proposals statewide (two Metropolitan, two Rural) receive them each round, on KHRC staff's own subjective rating, and they aren't scored until full application.
- Treating Primary Proximity to Amenities as a fixed mileage threshold. For 9%, it's a relative ranking within that round's Metropolitan or Rural applicant pool — full points go only to the single lowest-weighted-distance site. Only 4% new construction uses a flat 0.4-mile absolute benchmark.
- Assuming a strong site guarantees an award regardless of geography. County award caps (2 per Rural County, 3 per Metropolitan County per round) can shut out an otherwise well-scored application simply because its county is already full that round.
- Skipping precision on the Article 10 Project Location documentation because it "isn't the real scoring." It's a 50-point all-or-nothing category inside KHRC's separate 310-point statutory gate, requiring the exact real estate — including easements — to be documented.
- HUD
- LIHTC
- State QAPs
- IRS § 42
- Housing Finance Agencies
