Site sourcing and screening — Oregon

A thin QAP that hands almost everything to the ORCA

The currently effective plan is the 2025 State of Oregon Qualified Allocation Plan, Version 2025.1, which Governor Tina Kotek approved for implementation on February 25, 2025, under Executive Order EO-87-06 and Oregon Administrative Rule (OAR) Chapter 813, Division 90. OHCS's own QAP webpage confirms this is still the current, controlling document as of this research, and separately states that OHCS is preparing updates for the 2027-2028 award cycles, with a public hearing and comment period anticipated in fall 2026 -- meaning a newer QAP could already be in public draft by the time a specific site is being scored. A screen should pull the QAP directly from oregon.gov/ohcs's own Qualified Allocation Plan page rather than a cached or mirrored copy, and check whether a fall-2026-or-later draft has since superseded it.

One QAP-currency detail this research could not fully resolve: OHCS's own search-indexed materials describe the QAP as updated "every other year," but the plan immediately preceding the 2025 version, on OHCS's own QAP page, is dated 2022 -- a three-year gap, not two. This research did not confirm what interim guidance, if any, governed 2023 and 2024 award cycles under a still-active 2022 QAP; a sponsor working from that period's files should confirm the applicable plan year directly with OHCS rather than assume a strict two-year cadence.

Rather than scoring an application against a points table the way most states' QAPs do, Oregon evaluates every LIHTC project -- 9% and 4% alike -- through the Oregon Centralized Application (ORCA), a single intake system covering nearly all of OHCS's rental-housing-development resources, not LIHTC alone. The QAP itself says so directly: "All set-asides, prioritizations, and performance standards within the ORCA will remain applicable and required," and "[a]ll definitions in the ORCA Manual are incorporated by reference." The ORCA Manual, in turn, is updated far more often than the QAP -- its own version history shows five revisions between May 2024 and July 2026 alone -- so a screen has to treat the ORCA Manual as a live document, not something to save a copy of and reuse.

No points table -- 9% Credits run on mandatory criteria, three-of-eight supplemental criteria, and ordered tiebreakers

To move a new-construction 9% LIHTC project forward into Impact Assessment, OHCS requires an applicant to meet all mandatory criteria and at least three of eight supplemental criteria -- there is no cumulative point total, and the QAP is explicit that meeting more than three supplemental criteria earns no additional priority. The three mandatory criteria are: (1) the project's design, services, site location, or other considerations are tailored to the population being served; (2) the project demonstrates alignment with the Oregon Housing Needs Analysis (OHNA) and the local jurisdiction's housing production strategy, showing a need for the AMI level proposed -- with small cities under 10,000 population exempt from this requirement because they carry no OHNA obligation in the first place; and (3) the project has supporting documentation from a local Housing Authority showing either a waitlist-marketing commitment or reliance on coordinated entry for tenant referrals.

Only if the total resources requested by threshold-qualifying projects exceed what's available does OHCS apply an ordered tiebreaker sequence -- and it is genuinely ordered, not weighted: criterion (a) is decided first, and only projects still tied after (a) move to (b), and so on.

Two hard project caps apply to every 9% LIHTC applicant regardless of how well it scores: no sponsor or ultimate project owner may receive more than $2 million of any single year's annual state 9% LIHTC allocation, and no sponsor may receive more than an average of 15% of the annual 9% LIHTC allocation across any two sequential years.

Four geographic set-asides administered through the ORCA -- not scored in the QAP text itself

The QAP states only that "65% of the annual credit ceiling should be allocated consistent with the percentages outlined in the ORCA," alongside two fixed carve-outs stated directly in the QAP: 25% of the annual credit ceiling for preservation projects, and 10% for developments serving Native Nations on tribal trust land. The QAP separately states that 10% of the annual credit ceiling must go to qualified nonprofits under IRC §42(h)(5) -- a federally mandated set-aside that the QAP does not explicitly reconcile, arithmetically, against the 25%/10%/65% breakdown; this research treats the nonprofit set-aside as a requirement that cuts across the other categories rather than a fourth additive geographic slice, but a sponsor should confirm the current mechanics with OHCS rather than assume the numbers simply add to 100%.

The actual geographic split lives on OHCS's own "Oregon Centralized Application Set-Asides" webpage (last updated January 14, 2026), which the QAP incorporates by reference. It applies to the 65% general share of 9% Credits and, separately, to several other ORCA-administered gap resources (including LIFT bond proceeds and Permanent Supportive Housing bond proceeds). A Culturally Specific Organization (CSO) set-aside comes off the top at 20% of available funding; the remaining 80% is split across four regions defined by census tract, not by city or county boundary outside the three-county Metro core.

This ORCA-administered framework is adopted by the Housing Stability Council, not written into statute or the QAP text itself, and a public comment preserved in the QAP's own Appendix B shows exactly why that distinction matters in practice: a commenter asked OHCS to clarify "whether LIHTC resources do or do not count towards the three geographic set-asides," and OHCS's own written response states plainly that "LIHTC resources do not count toward the three geographic set asides in the ORCA" the way other gap resources do -- only the 65% general share described above uses the same 20%/80% CSO-and-regional formula. Because this is administrative guidance rather than a rule, a screener should re-check the live ORCA Set-Asides webpage before relying on any of these percentages, rather than treating them as fixed for the life of a deal.

No QCT/DDA scoring rubric -- Oregon's own opportunity signal runs through a discretionary basis boost

The federal 30% basis boost for Qualified Census Tracts (QCTs) and Difficult Development Areas (DDAs) is automatic under 26 U.S.C. §42(d)(5)(B) and requires no OHCS action. Outside of a single boilerplate reference to "qualified census tracts" in the QAP's recitation of the federal selection criteria the Code itself requires a QAP to list, Oregon's 2025 QAP does not build any independent QCT/DDA scoring mechanism, opportunity-area index, or location-scoring table of the kind many other states' QAPs run -- there is simply no points category tied to census-tract status to chase.

Oregon's own state-administered lever is the discretionary Housing and Economic Recovery Act (HERA) basis boost: OHCS may increase a 9% LIHTC project's eligible basis from 100% up to 130% when it determines, at its sole discretion, that a project's financial feasibility requires it. This is a project-by-project underwriting judgment, not a scored entitlement -- meeting one of the nine listed categories makes a project eligible to be considered, not automatically boosted.

Oregon's statewide land-use system is the real site filter

Oregon layers a mandatory statewide land-use planning system on top of ordinary local zoning, administered by the Department of Land Conservation and Development (DLCD) and the Land Conservation and Development Commission (LCDC) under ORS Chapter 197. Every Oregon city and county must adopt a comprehensive plan and implementing land-use regulations -- including its zoning ordinance -- that comply with 19 Statewide Planning Goals (ORS 197.175). Two of those goals do most of the work for a LIHTC screen: Goal 10 (Housing) requires a jurisdiction to plan for the housing needs of citizens at all income levels, and Goal 14 (Urbanization) requires every city to be surrounded by an urban growth boundary (UGB) separating land available for urban-density development from farm, forest, and other rural land outside it.

A parcel outside an acknowledged UGB is a fundamentally different, and far slower, problem than a parcel inside one that simply needs a rezoning -- expanding a UGB is itself a multi-year process reviewed by DLCD and LCDC, not a routine local land-use action, so a real Oregon screen has to confirm UGB status before spending time on anything else about the site. Inside the three-county Portland region, UGB authority runs through a different body entirely: Metro, a directly elected regional government created under ORS Chapter 268, manages a single UGB spanning Multnomah, Clackamas, and Washington counties -- the identical three counties that define the "Metro" geographic set-aside described above. Metro's UGB is reviewed roughly every six years and expanded, when it is expanded, by act of the Metro Council rather than by any individual city inside the boundary.

The QAP's own mandatory criterion requiring alignment with "the Oregon Housing Needs Analysis (OHNA) and local jurisdiction housing production strategies" is not a stand-alone LIHTC requirement -- it plugs directly into a separate DLCD-led process created by House Bill 2003 (2019). Cities over 10,000 population must periodically study future housing need and adopt a Housing Production Strategy describing the actions (regulatory changes, incentives, etc.) they will take to meet it; cities inside the Portland Metro boundary update this analysis every six years, and cities outside it update every eight years. The QAP's own exemption for small cities under 10,000 population tracks this framework exactly, since those cities carry no OHNA obligation to align with in the first place.

Hazard and contamination data: DEQ's 2024 database migration, and a separate state wetlands regulator

The Oregon Department of Environmental Quality's (DEQ) long-standing Environmental Cleanup Site Information (ECSI) database -- the electronic system DEQ had used since 1989 to track known, suspected, or cleaned-up hazardous-substance contamination -- was formally retired on April 16, 2024, with its records migrated to a replacement system, Your DEQ Online, as part of an agency modernization effort. A screen still pulling from a cached ECSI export or an old bookmark is working from stale data; current cleanup-site records and an accompanying map view are available through Your DEQ Online's public records portal, and DEQ cleanup-site layers are also published through the state's Oregon Explorer GIS mapping tools.

DEQ is not Oregon's only environmental gatekeeper relevant to site screening. Wetlands and waterway fill-and-removal activity is regulated by a separate agency, the Department of State Lands (DSL), under Oregon's Removal-Fill Law (ORS Chapter 196). A permit is generally required for any project that would add, remove, or move more than 50 cubic yards of material in most wetlands or waters, but the threshold drops to any amount of material at all in three categories: streams designated Essential Salmonid Habitat, State Scenic Waterways (and adjacent land within a quarter mile), and designated mitigation sites. DSL maintains its own Statewide Wetlands Inventory (SWI) as the primary screening layer for this purpose -- a distinct dataset from anything DEQ or the federal Army Corps of Engineers publishes.

Income and rent limits follow OHCS's own implementation clock, not HUD's national release date. For the 2026 cycle, HUD published its Multifamily Tax Subsidy Program (MTSP) limits on May 1, 2026, but OHCS's own required local implementation date was June 14, 2026 -- roughly six weeks later. A screen should confirm the current figures and effective date on OHCS's own Income and Rent Limits Dashboard rather than assume HUD's publication date controls Oregon underwriting.