"Is this parcel worth a call to the town office?"
One round a year, one fixed date
New Hampshire Housing (New Hampshire Housing Finance Authority, established under RSA 204-C) runs one 9% LIHTC round per calendar year, statewide — not a rolling calendar, not multiple regions with independent apportionments the way a bigger state might. Every general-occupancy and age-restricted project in the state competes in the same pool against the same date. That changes what "screening" means in practice: there isn't a queue of upcoming deadlines to pick from, there's one, and NH Housing's own application schedule carries the caveat "dates subject to change."
| Date | Milestone |
|---|---|
| May 8, 2026 | Financing application and exhibit list posted |
| May 13, 2026 | QAP and round information session |
| June 3, 2026 | Pre-application period opens |
| July 10, 2026, 5:00 PM | Preliminary applications due |
| August 21, 2026 | Staff distribute preliminary review memos |
| September 25, 2026, 5:00 PM | Final applications due |
| December 17, 2026 | Board of Directors votes reservations |
Unlike an informal analyst checklist, NH Housing spells out exactly what a screened site has to produce in writing before the preliminary application is even considered complete. Four of the eleven required preliminary exhibits are pure site-screening artifacts.
| Exhibit | What it requires |
|---|---|
| Exhibit 2 | Site Information Map — an aerial photograph with the site identified |
| Exhibit 3 | Floodplain Map, pulled from FEMA.gov |
| Exhibit 4 | Evidence of site control — an executed Option to Purchase, Agreement to Enter into a Lease, or other legal form; if not yet secured, a narrative plan and timeline to get it |
| Exhibit 6 | Status and Timetable of Zoning Local Approvals — a narrative on every pending Planning Board and Zoning Board of Adjustment approval |
The quiet arithmetic decision in New Hampshire isn't the LOI price the way it is in California — it's which town. Scoring item 7.a awards 15 points to a general-occupancy project sited in a city or town with no other previously approved affordable general-occupancy housing, full stop, versus 0-8 points from the NH Housing Opportunity Index if the town doesn't qualify. Against a minimum scoring threshold of 106 points to receive a reservation at all (Hfa 109.06(N)), a 15-point swing tied to nothing but the town on the deed is close to a seventh of the entire bar — bigger than most individual categories in the point schedule — and it's checkable before a phone call is ever made, against a list NH Housing already publishes.
The parcel record lives at the town, not the county
New Hampshire has no county-level assessing or zoning function to speak of. RSA 674:16 grants the power to zone to "any city, town, or county in which there are located unincorporated towns or unorganized places" — and because virtually all of New Hampshire's land area sits inside one of its 234 incorporated cities and towns, that county carve-out applies almost nowhere. Every one of those 234 municipalities assesses its own parcels, sets its own zoning (if it has any), and keeps its own records, independently.
The fragmentation is therefore by vendor, not by geography. Most town assessing and GIS pages run on one of a small number of commercial CAMA platforms — Vision Government Solutions, Avitar Associates, and Axis GIS are the names that turn up most often — and each town's own contract, not a shared state standard, determines the record format, the parcel ID scheme, and whether the data is queryable at all versus scanned card images.
NH GRANIT, the statewide geographic information clearinghouse housed at the University of New Hampshire, publishes a stitched-together statewide parcel layer built from those town submissions — a real answer to the fragmentation, in principle. What this review could not confirm from a primary source is how current or complete that mosaic is as of any given year; GRANIT's own site advertises the parcel product but its underlying catalog and download pages did not render enough content to verify a coverage percentage or update cadence. That gap belongs in the data model as an open question, not a silently assumed 100%.
Several of New Hampshire's own state-agency web properties returned HTTP 403 to a scripted client during this review — the Department of Revenue Administration's municipal/equalization pages, the Department of Environmental Services' site, and the Division of Historical Resources' site among them. That's a genuine access constraint on building an automated screen against New Hampshire's own government data, distinct from — but structurally similar to — the DTSC/SWRCB blocks the California guide documents.
Zoning is optional here, and hostile zoning has a state-level remedy
RSA 674:16 doesn't require a New Hampshire municipality to zone at all — it "authorizes" the local legislative body to adopt or amend an ordinance. A screen built on the assumption that every parcel sits inside some zone code will, on a real slice of New Hampshire sites, find nothing to look up.
Where a town does zone, and zones restrictively, New Hampshire gives a qualifying project a statutory lever California doesn't have in quite this form. RSA 674:58 defines "workforce housing" — for-sale housing affordable to a household at or below 100% of the 4-person area median income, or rental housing affordable at or below 60% of the 3-person area median income; the income tests themselves carry no unit-count floor. The statute separately defines "multi-family housing," for workforce-housing purposes, as a building of 5 or more units — a term RSA 674:59 invokes when it directs municipalities to make reasonable and realistic room for "workforce housing, including rental multi-family housing," allowing it on a majority (not necessarily all) of the land zoned residential — subject to an existing-housing-stock safe harbor and carve-outs for genuine environmental, water, sanitary, traffic, and life-safety standards.
A denial or an economically crippling set of conditions on a qualifying workforce housing project isn't just a bad screening signal in New Hampshire — it's an appealable statutory violation, and there are two different paths to appeal it, with very different clocks.
| Path | Timing | Who hears it |
|---|---|---|
| RSA 674:61 — superior court | Hearing on the merits within 6 months of filing (or a court-appointed referee if the court can't meet that) | A superior court judge, or an appointed referee experienced in planning and zoning law |
| RSA 679 — Housing Appeals Board | File within 30 days of the final municipal decision; hearing within 90 days of the appeal notice; decision within 60 days after the hearing | A 2-member state board (one NH-licensed attorney, one professional engineer or land surveyor), created 2019, effective July 1, 2020 |
The Housing Appeals Board's jurisdiction under RSA 679:5 isn't limited to workforce housing — it reaches planning board subdivision and site plan decisions, ZBA variances and special exceptions, and historic/heritage/conservation commission decisions on any housing matter, with the power to award any remedy a superior court could, including permission to develop. But both appeal paths share the same precondition: RSA 674:60 requires the applicant to file a written statement of intent to build workforce housing with the original local application. Skip that filing, and RSA 674:60, I says the applicant's rights under RSA 674:61 (and, by extension, the RSA 679 route to workforce-housing claims) are waived — an appeal under other laws may still be possible, but not this one.
The environmental and historic screen — half of it NH Housing runs for you
Flood screening at the preliminary stage is self-sourced and federal: Exhibit 3 is a floodplain map pulled straight from FEMA.gov, the same National Flood Hazard Layer used everywhere else in the country.
What's distinctly New Hampshire is what happens next. Filing a Letter of Intent and preliminary application automatically triggers NH Housing to commission an abbreviated HUD Environmental Checklist from a third-party professional NH Housing selects — at the applicant's expense, paid directly to the vendor. Any issue the checklist raises has to be discussed with NH Housing staff, and follow-up work can carry additional fees (Hfa 109.05(A)). The agency runs the first environmental pass, not the applicant — which is a genuinely different workflow from a self-serve GIS screen, and one worth representing accurately rather than skipped over.
Historic and archaeological review runs through a single state system: the NH Division of Historical Resources' EMMIT database. The QAP awards points for documenting progress through it directly — 3 points for submitting Historic Project Review materials, 5 more for a completed State Historic Review — each substantiated by an EMMIT printout, not a narrative (Hfa 109.07(A), scoring item 9.a).
Brownfield status is a cost lever here, not just a hazard flag. It's one of seven paths to the higher $425,000 TDC Weighted Average cost cap instead of the $397,000 standard cap, and NH Housing requires documentation demonstrating the site meets the EPA definition of a brownfield — a hazard-layer hit is not, by itself, that documentation (Hfa 109.04(C)).
Wetlands and endangered species show up narrowly but concretely, in the 811 Project Rental Assistance scoring criteria: a project seeking those points cannot sit in the FEMA 100- or 500-year floodplain, cannot impact a wetland, and cannot cause the "taking" of an endangered species under the federal Endangered Species regulations. Real gating language, and nothing EZFeasi models today.
Where the screen stops, and the honest limit
Comparable-award data exists and is genuinely usable — NH Housing publishes Current LIHTC Reservations, Final Scores by Category, and Past LIHTC Applications and Reservations back to 2000 — but only as PDFs. There's no equivalent to CTCAC's List_of_Projects.xlsx: no single bulk file with a parcel or census-tract key that joins directly to a GIS layer. Where the California data problem is one enormous file with real extraction gotchas, New Hampshire's is a handful of small, clean, but manually-transcribed tables.
Rent and income limits are federal, not state-specific: HUD's Multifamily Tax Subsidy Project income limits set the ceiling that determines LIHTC rents in New Hampshire the same way they do in every other state. NH Housing does not publish a separate state income-limit schedule for the program.
Construction cost has the same structural hole it has everywhere. There is no free, authoritative, New Hampshire-specific, unit-level affordable-housing construction cost dataset. BLS's national Producer Price Index for construction inputs gives escalation, not a level. The QAP's own TDC Weighted Average figures — $397,000 standard, $425,000 high-cost, $464,000 as a hard per-unit ceiling — are regulatory caps on eligible cost, not cost estimates, and conflating the two is the same classic and expensive error the California guide flags for threshold basis limits.
Finally, the honest limit. Whether a planning board will actually cooperate regardless of what RSA 674:59 requires on paper, whether a Housing Appeals Board appeal will land inside its statutory 90-day/60-day clock in real practice, whether a competing application is quietly being assembled for the same town this round — none of that is a dataset, and none of it should be synthesized as one. Give the user a place to record their own judgment and its date.
What EZFeasi actually has for New Hampshire today is none of the above, automated. There is no New Hampshire parcel layer, no zoning normalization, no QAP scoring model, and no rent calculator built for this state yet. Screening a New Hampshire site today means doing this by hand — one town website, one PDF, one phone call at a time.
Where this goes wrong
- Assuming every NH parcel sits inside a zoned jurisdiction. RSA 674:16 only authorizes a city or town to adopt a zoning ordinance — it doesn't require one — so a screen that treats a missing zone code as a data gap rather than a possible fact about the town will misread some sites.
- Treating restrictive local zoning as a flat no without checking whether the project meets RSA 674:58's definition of workforce housing. A qualifying project gets the RSA 674:59 'reasonable and realistic opportunity' mandate and two possible appeal paths that a non-qualifying project does not.
- Skipping the RSA 674:60 written notice of intent to build workforce housing at the original local application. RSA 674:60, I says failing to file it waives the applicant's rights under RSA 674:61 — foreclosing the superior court appeal and, with it, the practical basis for a Housing Appeals Board claim on the same grounds.
- Reading the Housing Appeals Board's statutory clock (RSA 679:6 — 30 days to file, hearing within 90 days, decision within 60 days after) as a track record rather than a procedural deadline. No public dataset reports how appeals have actually resolved in practice.
- Treating the 'Qualified Locations for Points' list (185 of New Hampshire's 234 cities and towns, currently) as permanent. A town drops off the moment a project is approved there, which can happen mid-cycle, and the list itself is something NH Housing maintains and updates, not a fixed rule.
- Assuming the Rural Towns for Basis Boost list is current for the 2027-2028 QAP. The version linked from NH Housing's live LIHTC page is dated 01/24 and was published for the 2025-2026 QAP; nothing on the page indicates a refresh for the current plan.
- Confusing the QAP's TDC Weighted Average limits ($397,000 standard / $425,000 high-cost) with an actual construction cost estimate. They are regulatory ceilings on eligible cost, not a market cost projection.
- Assuming brownfield status for the higher $425,000 high-cost TDC cap follows automatically from a hazard-layer hit. NH Housing requires documentation demonstrating the site meets the EPA brownfield definition; a screen can flag a likely brownfield, it cannot certify one.
- Not checking the one-application-per-principal and no-more-than-two-uncompleted-projects caps (Hfa 109.04(B)) before screening a third site tied to the same development team. A site can be disqualified from the round for reasons that have nothing to do with the site itself.
- Missing that 106 points (general occupancy), 80 (age-restricted), or 110 (preservation) is a hard minimum to receive any reservation at all (Hfa 109.06(N)) — not just a competitive target. Losing the single largest location bonus (15 points) is close to a seventh of that threshold gone before any other category is scored.
- Parsing the QAP's own table of contents as an authoritative list of threshold-criteria letters. The current (March 16, 2026) QAP's table of contents lists threshold criterion K as 'Environment'; the body of Hfa 109.06 has no separate lettered Environment section — K in the body is 'Smoke Free Requirement.' A parser keyed on the table of contents will look for a section that isn't there.
- Using HUD's Multifamily Tax Subsidy Project income limits as though they were New Hampshire-specific. They're the same federal dataset used to set LIHTC rents in every state; New Hampshire publishes no separate state schedule.
- Treating NH Housing's own abbreviated HUD Environmental Checklist (automatically commissioned at preliminary application under Hfa 109.05(A)) as a substitute for independent Phase I diligence. It's a paid, agency-triggered first pass — not the Phase I Environmental Site Assessment the QAP separately scores and later requires at progress phase (Appendix A, Exhibit A.2).
- HUD
- LIHTC
- State QAPs
- IRS § 42
- Housing Finance Agencies
