Site sourcing and screening — Louisiana

The QAP changed under its own cycle -- and the rewrite lands squarely on site screening

LHC published the "2025 Qualified Allocation Plan, Final as of 02-14-25" in February 2025, then amended it in place roughly eleven months later. The document currently posted on LHC's own LIHTC program page at lhc.la.gov is headed, on every page's own footer, "2025 QUALIFIED ALLOCATION PLAN ... Amended QAP as of 01-13-26." This research found no evidence LHC issued a separately numbered "2026 QAP" -- the 2025-2026 cycle's governing document is this amended-in-place 2025 QAP, so a screening tool has to match on the amendment date in the footer rather than the calendar year in the title to confirm currency. This research did not find a standalone LHC memo summarizing what the amendment changed; the differences described below were found by direct line-by-line comparison of the two PDFs.

Eight parishes are Louisiana's "Urban" pools; the other fifty-six are Rural by exclusion -- and the split changes cost caps, not just competition

LHC divides its per-capita 9% housing credit ceiling into a Qualified Non-Profit/CHDO Set-Aside (at least 10% of the ceiling), a Rural Rehabilitation Pool, a Rural New Construction Pool, an Urban Rehabilitation Pool, an Urban New Construction Pool, a Choice Neighborhood Initiative (CNI) reservation capped at $3,000,000, and an opportunistic Elderly Housing allocation (one award targeted in Rural areas and one in Urban areas, funded only if a qualifying application is received). Both Urban pools are defined by naming the same eight parishes: Caddo, East Baton Rouge, Calcasieu, Jefferson, Lafayette, Orleans, Ouachita, and St. Tammany. The QAP does not define "Rural" or "Urban" as standalone glossary terms -- "Urban" is defined only by naming these eight parishes, and every other Louisiana parish is Rural by exclusion. This reading was not stated explicitly as an exclusion rule anywhere in the glossary itself; confirm it directly with LHC before treating it as settled for a parish that might be borderline.

Pool also drives the per-project and per-developer caps, and the direction is easy to get backwards: the maximum LIHTCs any single project can receive on competitive selection criteria is $1,000,000 in a Rural parish versus $1,500,000 in one of the eight Metro parishes, and the per-developer cap is $2,000,000 Rural versus $3,000,000 Metro (with an absolute $3,000,000 ceiling per developer regardless of pool). Being in a Rural parish lowers the ceiling; it does not automatically make a deal easier to fund at a given size. A developer that has never been issued a Form 8609 is eligible for only one 9% award.

Basis boost eligibility reaches beyond the federal QCT/DDA map, and a parish's own award history is its own scoring line

The federal 30% basis boost for a Qualified Census Tract (QCT) or Difficult Development Area (DDA) under 26 U.S.C. § 42(d)(5)(B) is automatic and is not separately administered by the QAP. LHC's own Basis Boost Determination section adds two more categories beyond the federal defaults: a site in a federally declared disaster area, and a site in "a Census tract where the AMI meets or exceeds 100% for the area as determined by the Federal Financial Institutions Examination Council (FFIEC)" at www.ffiec.gov -- both determined against an FFIEC dataset rather than the HUD QCT/DDA maps. This research did not independently verify the legal mechanics by which a state housing credit agency can extend basis-boost eligibility beyond the Code's own QCT/DDA/TCT categories; confirm the disaster-area and AMI-tract boost categories with LHC or counsel before underwriting to them.

Separately, Appendix A's Selection Criteria scores QCT/DDA status again, on its own terms: 2 of a possible 13 points under "Priority Development Areas and Other Preferences" go to a project in a Difficult Development Area, Qualified Census Tract, or federally/state-recognized Tribal Census Tract -- a different use of the same underlying data than the basis-boost determination, and worth keeping straight from it. The same 13-point section separately awards 2 points to a project in a parish that "has not received an award of LIHTC within the last 20 years"; the current QAP text names only four such parishes -- Grant, La Salle, St. Charles, and St. Helena. An earlier 2024 QAP workshop presentation named eight parishes in this category, so the list is shorter in the current governing document and should be reconfirmed each cycle rather than assumed static.

A third, stricter QCT-linked category sits in a different part of Appendix A entirely: the Targeted Project Type section's "Redevelopment Project" line awards up to 3 of 11 points, but only for a project in a Qualified Census Tract that is also covered by an adopted local Concerted Community Revitalization Plan -- QCT status alone does not satisfy it. A site can qualify for the plain QCT/DDA scoring line without qualifying for Redevelopment Project points, or vice versa if its revitalization plan somehow predates its QCT designation.

One glossary term is worth flagging as inactive rather than scored: the QAP defines "DELTA PARISHES" (Caldwell, Concordia, Catahoula, East Carroll, Franklin, Madison, Morehouse, Ouachita, Pointe Coupee, Richland, Tensas, and West Carroll) but this research did not find that term used anywhere else in the document's operative eligibility or scoring text. Treat it as informational only until LHC confirms otherwise.

Location Characteristics scoring is capped at 5 points and decided by LHC's own market analyst, not the applicant

Appendix A's Location Characteristics section caps at 5 points and scores ten named services -- grocery store; fresh produce market or fruit stand in a fixed structure; hospital, doctor's office, or clinic; bank/credit union with live tellers; elementary, secondary, or post-secondary school; 4-year college, university, vocational, technical, or community college; pharmacy (not counting one inside a hospital); public transportation (shuttle services excluded); a Louisiana-licensed adult/child day care or after-school care; and a public park or a police/fire station -- one point cap per service type. Urban projects earn 1 point for a qualifying service within 1 mile and 0.5 points between 1 and 2 miles; Rural projects earn 1 point only within a 5-mile radius, with nothing beyond it.

The QAP is explicit about who decides: "Applicants who propose developments in proximity to negative neighborhood characteristics ... can submit a justification," but for Location Characteristics generally, "[e]vidence may be submitted but points will be assigned by the Market Analyst," and Appendix E states plainly that "the decision of the market analyst on location characteristics (neighborhood features) will be final." LHC compounds this by ordering market studies itself, directly from its own approved roster of disinterested analysts -- Appendix E states "Market Studies will be ordered by LHC from approved disinterested market analysts" -- rather than the applicant commissioning its own study. An applicant's own pre-application amenity count is a planning tool, not a locked-in score.

A separate Negative Neighborhood Features threshold bars new construction within a half-mile of ten named incompatible uses -- junkyard/dump, processing plants, high-voltage substations, solid waste disposal, heavy industrial, pig/chicken farm, distribution facilities, airports, salvage yard, and prisons. The QAP's own text ties this specific list to the same eight parishes used for the Urban pools (East Baton Rouge, Jefferson, Orleans, St. Tammany, Caddo, Lafayette, Calcasieu, and Ouachita), carving out an exception for towns or cities with a population of 15,000 or fewer. Exactly how this threshold is meant to apply to a Rural-pool site outside those eight parishes is not stated as plainly as the rest of the item; confirm the intended scope directly with LHC rather than assume it applies, or doesn't apply, statewide.

Louisiana's hurricane-exposure geography: named Tier parishes, and a separate statutory Coastal Zone the QAP never mentions

The QAP's own glossary defines two hurricane-exposure tiers by name, independent of FEMA flood-zone mapping: Tier 1 parishes are "considered the most vulnerable to hurricanes, storm surges, and other catastrophic weather events," and Tier 2 parishes are "still exposed to hurricanes and severe weather but are slightly less at risk than Tier 1." Projects in either tier must acknowledge, in Appendix A's threshold-acknowledgment section, that they will use fortified roofs, windows, and doors -- a state resiliency-construction commitment that sits alongside, not inside, the FEMA-based elevation and floodway rules covered in Site Control and Due Diligence.

Separate from the QAP entirely, Louisiana's State and Local Coastal Resources Management Act of 1978 (La. R.S. 49:214.21 et seq.) establishes a statutory Coastal Zone administered by the Louisiana Department of Energy and Natural Resources' Office of Coastal Management. "No person shall commence a use of state or local concern" within that zone without first obtaining a Coastal Use Permit. This is a state permitting requirement layered on top of, and independent from, both FEMA's Special Flood Hazard Area mapping and the QAP's own Tier 1/Tier 2 list -- a parcel can sit outside a FEMA flood zone and still fall inside the statutory Coastal Zone, or the reverse, and the QAP's own text does not mention the Coastal Zone or Coastal Use Permit at all. A Louisiana screen should check coastal-zone status as its own, separate step rather than assume FEMA flood-zone status covers it.

That the Coastal Zone is a live issue in LHC's own practice, even though the LIHTC-only QAP threshold text is silent on it, is corroborated by LHC's own environmental-review training materials: "Coastal Zone Management" is listed as one of the specific federal "Laws & Authorities" categories (alongside floodplain management, wetlands protection, and historic preservation) that a federally funded project's environmental review must clear once HOME, CDBG, or other federal soft funds are layered onto a LIHTC deal -- covered further in Site Control and Due Diligence.