Site sourcing and screening — Montana

What the Pre-Application checklist doesn't ask for — and why that's a trap

Montana Board of Housing (MBOH) is, as Phase 4 of this guide covers, the sole agency for both 9% and 4% Credits — there is no separate site-screening body to coordinate with. What is easy to miss is how little the Pre-Application itself demands: a fee, a narrative, an Attachment (Excel), and — for 9% Credit Projects only — a Mini-Market Study and Summary Sheet (2027 QAP Section VI.A.1). There is no site control document, no zoning documentation, and no appraisal required at Pre-Application; those all arrive later, at Full-Application (2027 QAP Section VI.A.2, Items 4–5, 16).

That thin checklist is not permission to screen lightly. The QAP states plainly that Pre-Applications "generally should reflect Projects that will meet all QAP requirements," and that full Applications will not be Awarded if they "change the general project location (city/town), type (e.g., family or elderly), or Applicant and Developer specified in the Pre-Application," except by Board waiver (2027 QAP Section III.F.1). Combined with the fact that Pre-Applications receive no formal scoring — only a Threshold Requirements check — before the Board decides which of them to invite to Full-Application (2027 QAP Section III.F.1, as covered in Phase 4), the practical effect is that most of a site's real screening work has to happen before the April Pre-Application deadline, not after it. A site that looks promising in March but turns out to have a fatal zoning or market problem in June is a much harder position to be in Montana than in a state where site control and zoning documentation are due at the same early stage as everything else.

Site characteristics that actually move the outcome — because there's no point table to game

Phase 4 of this guide covers Montana's Development Evaluation Criteria as a whole: five categories an Application must satisfy through qualifying facts, not a scored table. Three of those five categories are decided almost entirely by where the site sits, which makes them a screening question, not just an application-drafting one.

The other lever tied to location is size-based rather than amenity-based: a Small Rural Project — a ten-year Credit request of $5,000,000 or less, sited outside the city limits of Billings, Bozeman, Butte, Great Falls, Helena, Kalispell, or Missoula (2027 QAP Appendix A) — gets grouped separately from other Projects when Board staff present Applications for Award, and the Board may (but is not required to) consider Tribal or Small Rural Projects first (2027 QAP Section III.F.2). Screening a rural site should include checking whether it clears that $5,000,000 ceiling, since exceeding it forfeits the grouping without buying anything in return.

Hazard and environmental screening: thinner than CTCAC or CHFA, and split across two agencies the QAP doesn't name

This is a genuine finding worth stating plainly: the 2027 QAP contains no Threshold Requirement for a Phase I Environmental Site Assessment, no floodplain or wetlands screening item, and no site-hazard scoring category — a real structural difference from California's CTCAC or Colorado's CHFA, both of which mandate a Phase I on every application. That does not mean hazards are irrelevant to a Montana deal; it means MBOH's own checklist does not screen for them, and a lender, syndicator, or USDA Rural Development co-funder will still expect the standard diligence package. Treat the absence of a QAP-level environmental threshold as a gap between what MBOH requires and what the capital stack requires — not as evidence the site doesn't need it.

Where the QAP does reach environmental compliance, it does so as a construction-standard requirement in the Design Requirements Appendix, not as a site-screening gate, and it involves two different state and federal regimes that are easy to conflate. Floodplain jurisdiction in Montana sits with the Department of Natural Resources and Conservation (DNRC), not the Department of Environmental Quality — DNRC designates Regulated Flood Hazard Areas and coordinates the National Flood Insurance Program under the Flood Plain and Floodway Management Act (Mont. Code Ann. Title 76, Chapter 5) and its implementing rules (Admin. R. Mont. Title 36, Chapter 15), with permitting typically administered by the county or city floodplain administrator. The Montana Department of Environmental Quality's (DEQ) role that actually appears in the QAP is narrower and construction-focused: asbestos control, where the QAP directs compliance with the most restrictive of NESHAP (40 CFR Part 61, Subparts A and M), DEQ's own administrative rules (Admin. R. Mont. Title 17, Chapter 74, Subchapter 3), and state statute (Mont. Code Ann. Title 75, Chapter 2, Part 5).

The passive radon mandate is worth calling out on its own: it applies to every Project regardless of what any hazard layer says about the specific parcel, which makes it a fixed cost of screening-in a Montana site rather than something a screen can rule in or out.

Rent and income limits: no MBOH-published table, pull Novogradac's calculator directly

Unlike agencies that publish their own county-by-county rent-and-income-limit PDF, MBOH's Full-Application checklist requires Applicants to "[p]rovide Novogradac Rent and Income Calculator results for the project," with the calculator itself linked from MBOH's website (2027 QAP Section VI.A.2, Item 9). There is no separate MBOH-authored limits table to screen against before that — the lookup happens directly against the third-party (but MBOH-endorsed) Novogradac tool, keyed to HUD's underlying Multifamily Tax Subsidy Income Limits for the county. Phase 4 of this guide covers the income-targeting math itself (53% AMI weighted average for 9% Projects, 60% for 4%); this phase is only about where the underlying numbers come from.

Utility allowances follow a similar pattern of picking from a fixed menu rather than reading a state-published table: MBOH accepts the Montana Department of Commerce Section 8 Utility Allowances, USDA Rural Development's own schedule, the HUD Utility Schedule Model (HUSM), or an Energy Consumption Model (ECM) — but explicitly will not accept a utility allowance a utility provider supplies directly (2027 QAP Section VIII, Item 6). A screen that assumes a single achievable-rent number without checking which utility-allowance source applies to the specific unit mix and heating type will overstate or understate net rent.

Rurality, tribal geography, and a comparable-awards dataset that couldn't be confirmed

Montana is one of the most rural states in the LIHTC program, and that shows up directly in the QAP's structure: the Small Rural Project definition excludes only seven named cities, meaning every other incorporated place and every unincorporated county in the state qualifies as rural for that purpose (2027 QAP Appendix A). Montana also contains seven Indian reservations — Blackfeet, Crow, Flathead (home to the Confederated Salish and Kootenai Tribes), Fort Belknap, Fort Peck, Northern Cheyenne, and Rocky Boy's — plus the Little Shell Band of Chippewa, a federally recognized tribe (since 2019) with no reservation land base of its own. The QAP's "Tribal" defined term turns on sponsorship, not geography — an Application sponsored by a Tribally Designated Housing Entity (TDHE) or other tribally sponsored entity qualifies as "Tribal" regardless of where the site sits — while the separate "Tribal Area" scoring item under Small Town/Tribal Designated Area turns on the site actually sitting within a reservation's exterior boundaries (2027 QAP Appendix A; Section VII.A). A TDHE-sponsored Application on a site outside any reservation qualifies as a "Tribal" Applicant without qualifying for the Tribal Area scoring item — the two tests are independent and a screen should check both.

A site inside a reservation's exterior boundaries carries one concrete Full-Application benefit: the appraisal/CMA requirement is waived outright, provided the Application documents that the property sits within the reservation (2027 QAP Section VI.A.2, Item 16.d). That is a real, citable exception — not a general statement that reservation land is easier to underwrite.

What this research could not confirm is whether MBOH publishes a structured, parcel-joinable dataset of past awards comparable to CTCAC's List_of_Projects spreadsheet. MBOH's Board meeting packets and minutes, posted on commerce.mt.gov, appear to be the primary public record of past Reservations and Awards, but this pass did not catalog their format closely enough to say whether they support systematic screening the way a structured award list would. A Montana screening tool should verify this directly with MBOH (multifamily program contact: Jason Hanson) rather than assume a CTCAC-equivalent dataset exists.