"This parcel sits in Philadelphia and it's zoned right, but which pool does it actually compete in, and is that 25 percent carve-out going to bury it against every other Urban Pool deal in the state?"
Confirm the governing QAP and the round you're actually screening for
PHFA's Allocation Plan is adopted for two program years at a time and requires the Governor's approval after a public hearing, a two-step process the QAP states plainly: "Pursuant to federal law governing the Tax Credit Program, the Agency adopts a plan (the 'Allocation Plan') outlining the allocation priorities and procedures to be followed in distributing Federal Low Income Housing Tax Credits... Adoption of the Allocation Plan requires approval by the Governor after a public hearing." The document actually governing applications today is titled "PENNSYLVANIA HOUSING FINANCE AGENCY ALLOCATION PLAN FOR PROGRAM YEARS 2025/2026 LOW INCOME HOUSING TAX CREDIT PROGRAM," marked "FINAL PLAN AS ADOPTED BY THE BOARD OF THE PENNSYLVANIA HOUSING FINANCE AGENCY OCTOBER 10, 2024."
A successor plan is already in motion but is not yet law. PHFA's Board approved a draft 2027-2028 Qualified Allocation Plan for public release on July 13, 2026; a public hearing on that draft was held July 29, 2026, with the public comment period closing August 14, 2026. As of this research (September 2026), no final board-adopted, Governor-approved 2027-2028 QAP had been confirmed on PHFA's site -- meaning every citation and figure in this guide is drawn from the currently effective 2025/2026 QAP and its accompanying Application Guidelines, and should be re-verified against whatever plan is finally adopted for 2027-2028 before being relied on for a deal that will file under that later cycle.
| Item | What the QAP text says |
|---|---|
| 2025 competitive 9% Intent to Submit | Due December 5, 2024 (mandatory prerequisite to filing a full Application) |
| 2025 competitive 9% Application deadline | 3:00 p.m., February 11, 2025 -- the entire package, exhibits included |
| A second 2025/2026 round, or a separate 2026 deadline | "may be announced by the Agency on its website... if uncommitted resources are available or become available or if a second round is coordinated under this QAP" -- not fixed in the QAP's own text |
| 4% Tax Credits with Tax-Exempt Bonds | Accepted on a rolling basis until volume cap is depleted; Intent to Submit due at least 60 days before the desired application date |
Treat the 2025 dates above as an illustration of how the cycle runs, not as this year's actual deadline -- confirm the current round's dates on PHFA's website before building a screening calendar around them.
Two pools, not a regional map -- and a Philadelphia-specific carve-out inside the Urban Pool
Pennsylvania's current geographic allocation structure is two Set-Asides, not a multi-region apportionment system. The QAP states it directly: "The Agency has established Set-Asides and Pools for awarding Competitive 9% Tax Credits as detailed in the table below," listing an Urban Pool at approximately 50 percent and a Suburban/Rural Pool at approximately 50 percent, with a companion note: "A complete list of the applicable county designation is attached as Exhibit A. At least twenty-five percent (25%) of the Urban Pool will initially be set aside to fund developments located in municipalities other than Philadelphia." A screening tool needs Exhibit A's actual county-by-county pool assignment as its source of truth rather than an assumption about which counties count as "urban" -- and needs to model the Philadelphia carve-out as its own constraint layered on top of the Urban Pool's overall 50 percent share, not as a separate third pool.
| Pool | Share of Competitive 9% Tax Credits |
|---|---|
| Urban Pool | Approximately 50%, of which at least 25% is initially reserved for municipalities other than Philadelphia |
| Suburban/Rural Pool | Approximately 50% |
The Agency reserves the right to adjust these percentages "to ensure adequate and appropriate funding of the Applicants meeting the Program criteria" -- the split is a stated target, not a hard-coded statutory formula.
Layered inside each pool is a second structure: Preferences, each with its own minimum reservation count and, for several, its own minimum-unit-percentage set-aside. The QAP is explicit that these are floors the Agency targets, not caps, and that a single Application can qualify for more than one Preference at once: "Applicants may be considered in more than one category and will have been deemed to have met both for purposes of meeting the stated housing goals."
| Preference | Minimum reservation | Unit set-aside if applicable |
|---|---|---|
| General Occupancy | At least 3 developments per Pool | -- |
| Senior Occupancy (62+) with Services | At least 2 developments per Pool | -- |
| Preservation | At least 4 developments in the aggregate across both Pools | -- |
| Supportive Housing | At least 2 developments per Pool | 25% of units (Urban Pool) / 15% of units (Suburban/Rural Pool) |
| Innovation in Construction Technology | At least 1 development, aggregate | -- |
| Strategic Investment | At least 3, up to 8 developments, aggregate | -- |
| Community Revitalization/Mixed Income | At least 3 developments -- Urban Pool only | -- |
| Areas of Opportunity | At least 3 developments -- Suburban/Rural Pool only | -- |
| Engaging and Serving Re-Entry Populations | At least 1 development, aggregate | -- |
| Health for Housing Investments | At least 1 development, aggregate | Requires a capital contribution of at least $250,000 from a health care entity |
Community Revitalization/Mixed Income is Urban-Pool-exclusive and Areas of Opportunity is Suburban/Rural-Pool-exclusive -- the same underlying goal (site quality and neighborhood context) is scored through two differently-named, pool-specific Preferences rather than one statewide category.
Site-selection scoring sits inside a 232-point scale, and the QAP's own minimum-score text disagrees with itself
PHFA's Selection Criteria run to a maximum of 232 points across six lettered categories, and site and neighborhood characteristics are concentrated in two of them: Community and Economic Impact (37 points) and Development Characteristics (35 points, which includes a "Smart Site Selection" sub-category). A separate 93-point category, Development Team and Process, contains the Zoning item covered in Phase 3.
| Category | Maximum points |
|---|---|
| A. Community and Economic Impact | 37 |
| B. Resident Population and Services | 62 |
| C. Development Characteristics | 35 |
| D. Development Team and Process | 93 |
| E. Development Cost Savings | 10 (scoring suspended for 2025/2026 -- awarded as 0) |
| F. Complete Application Package | 5 |
232 points on paper; effectively 222 while category E is suspended.
The QAP states two different minimum scores for a competitive 9% Application in two different places, and this guide is flagging that inconsistency rather than resolving it by guessing. Section 4.3 (Selection of Applications) states: "In reserving Competitive 9% Tax Credits in the 2025/2026 cycle, the Agency has established a minimum point threshold of one hundred and twenty (120) points for all developments except for those qualifying for the Preservation Preference, which shall be one hundred ten (110) points." Section 3.2.21 (General Threshold Criteria -- Minimum Score) states instead: "For 9% LIHTC developments, the minimum score needed to meet threshold and continue through the competitive process is at least 125 points. For 4% LIHTC developments, the minimum threshold score needed is at least 110 points." The two sections agree on the Preservation and 4% figures (110 points each) but disagree on the general 9% figure -- 120 versus 125 -- and nothing else in the document reconciles the difference. Confirm the currently operative minimum with PHFA staff before using either number as a hard go/no-go screen.
Where a site actually earns points: Areas of Opportunity, transit and walkability, and Smart Site Selection
Category A's Underserved Areas sub-item (up to 15 points), scored under a QAP sub-heading actually titled "Areas of Opportunity" for the general-occupancy track, is Pennsylvania's closest analog to the opportunity-area scoring other states in this series build into their own QAPs, and it runs on two mutually exclusive tracks depending on occupancy type. For general occupancy developments, up to 13 points reward sites with "Low poverty rates," "Limited affordable housing options, both subsidized and non-subsidized," "Limited affordable housing production in past twenty (20) years," close proximity to employment, and strong, high-owner-occupancy housing markets -- with an additional 2 points available for sites in a public school district whose senior high school's combined PSSA proficiency average is 70-80% (1 point) or above 80% (2 points). For senior occupancy developments, the same 15-point ceiling instead rewards a large eligible senior population, limited existing affordable options, and proximity to health, retail and hospital amenities for seniors -- the two tracks are alternatives ("OR" in the QAP's own formatting), not additive.
| Item | Points | Test |
|---|---|---|
| Transit-Oriented Design | 2 | Within one-half mile of a completed or planned fixed-route public transportation stop, or an alternate accessible no-cost transportation option |
| Walkability -- Urban | 1-2 | Walk Score (www.walkscore.com) of 70-79 (1 pt) or 80+ (2 pts); scattered sites use a unit-weighted average across sites |
| Walkability -- Suburban/Rural | 1-2 | Walk Score of 50-69 (1 pt) or 70+ (2 pts) |
| Mixed-Income Housing | 2 | At least 15% but no more than 50% of units targeted as market-rate, with a demonstrated financial benefit |
These four items sit inside the larger Community Revitalization sub-category (up to 16 points for new construction/rehab, up to 17 for preservation), which also awards points for a documented Community Revitalization Plan (5 pts) and significant funding coordination with other community development programs (5 pts, or 3 pts for preservation).
Category C's Smart Site Selection item (up to 10 points) is where site history and adaptive reuse are directly rewarded: "up to five (5) points may be awarded to those developments located on a brownfield; up to seven (7) points may be awarded to those developments considered blight remediation or residential infill; and up to ten (10) points may be awarded to those developments consisting of an adaptive reuse of an existing building." The QAP's own text does not define "brownfield," "blight remediation," or "residential infill" anywhere in this section or elsewhere in the document made available for this research -- unlike some other states' allocation plans, which spell out a specific statutory or programmatic definition for these terms. Confirm PHFA's operative definition (likely documented in the Selection Criteria self-scoring instructions rather than the QAP body itself) before assuming a federal Brownfields program designation, an Act 2 Land Recycling Program status, or a purely narrative claim of blight is what qualifies.
Basis boost: the federal 130% is automatic, PHFA's own 130% is not
The federal basis boost works in Pennsylvania exactly as it does everywhere: "All Tax Credit developments located in a 'qualified census tract' or 'difficult development area', as established by HUD, may qualify for Tax Credits based on 130 percent (130%) of the eligible rehabilitation/new construction basis." That much requires no PHFA action beyond confirming HUD's own QCT/DDA designation for the site.
Pennsylvania's own state-designated 130% basis boost is a different, discretionary instrument layered on top, and it is not available to every deal. The QAP states: "Developments requesting Competitive 9% Tax Credits must request a Waiver (see Section 5) to receive a 130% State Designated Basis Boost. The application must demonstrate that without the basis boost, a significant funding gap will remain for the proposed development. Developments requesting 4% Tax Credits with Tax-Exempt Bonds are not eligible for the 130% State Designated Basis Boost." A screening tool should treat a QCT/DDA hit and eligibility for PHFA's own state-designated boost as two separate facts: the first is a HUD designation check, the second is a discretionary Waiver request limited to competitive 9% Applications and conditioned on a demonstrated funding gap PHFA has to accept.
Environmental and hazard screening: PA DEP's own tools, and where they stop being enough
Pennsylvania's Department of Environmental Protection (DEP) publishes two purpose-built research tools rather than a single statewide open-data portal analogous to California's. eMapPA is DEP's general GIS mapping application, covering DEP-permitted facilities alongside more than 50 map layers spanning administrative boundaries, demographics, geology, mining, water resources and transportation. DEP's Environmental Site Assessment Search Tool is narrower and squarely aimed at Phase I practitioners: it searches DEP's eFacts database for contaminated-sites information (including Act 2 Land Recycling Program cleanup records), regulated storage tanks, hazardous waste facilities, air emission points, water discharge and treatment locations, waste management facilities, and oil and gas well locations within a user-defined radius of an address, producing a DEP-letterhead summary report. A simplified public-facing version, the Environmental Search Tool, offers the same underlying eFacts lookup with less configurability.
Pennsylvania's own brownfield program is the Land Recycling and Environmental Remediation Standards Act of 1995, commonly called "Act 2" (35 P.S. § 6026.101 et seq.), which created a voluntary cleanup program letting a remediator choose the applicable cleanup standard and, on completion, obtain liability protection for the contaminants actually addressed. An Act 2 cleanup record inside DEP's Environmental Site Assessment Search Tool is the most direct, checkable link between a site's environmental history and the QAP's own Smart Site Selection brownfield points described above -- though, again, the QAP itself does not say that an Act 2 designation is what it means by "brownfield," so that connection should be confirmed with PHFA rather than assumed.
DEP's own tool disclaims exactly what a screening product should not overstate to a user: it is a records search, not a substitute for a qualified environmental professional's Phase I assessment. It tells a developer what is worth investigating before site control is locked; it does not replace the ASTM E1527-21 Phase I Environmental Site Assessment PHFA's own Application requires of every deal, covered in full in Phase 2 of this guide.
Income and rent limits: the same federal clock as every other state, published through PHFA's own chart
Pennsylvania's LIHTC income and rent limits follow the same national mechanism as every other state in this series: HUD's Multifamily Tax Subsidy Project (MTSP) income limits, published annually under the methodology HERA established for calendar years after 2008, with a uniform 45-day implementation window once HUD releases a new chart -- for 2026, that put the effective compliance date at June 15, 2026 following HUD's May 1, 2026 release. PHFA does not invent its own income-limit methodology; it publishes the calculated Tax Credit rent-and-income chart (currently distributed as the "mtxr041" chart, alongside a separate PennHOMES-plus-Tax-Credit chart) and makes it available through its Web Entry System, and the Application package's Tab labeled "Rent and Income Limits" points to that chart directly. Beyond publishing the chart itself and the accompanying online entry system, no PA-specific wrinkle to the underlying MTSP methodology (comparable to another state's HERA-special or hold-harmless carve-outs) was confirmed in this research pass -- if one exists, it should be surfaced from PHFA's own Tax Credit Program Compliance Manual before being assumed absent.
Where this goes wrong
- Modeling Pennsylvania as a multi-region geographic apportionment state. The current structure is two pools -- Urban (~50%) and Suburban/Rural (~50%) -- not a finer regional breakdown; Exhibit A's county list is the source of truth for which pool a site falls into, not an assumption based on population density alone.
- Missing the 25 percent non-Philadelphia carve-out inside the Urban Pool. A Philadelphia site isn't just competing for a share of the Urban Pool's roughly 50 percent -- every other Urban Pool municipality is separately guaranteed at least a quarter of that same pool, which changes the effective competition a Philadelphia deal faces.
- Treating the QAP's 2025 Intent to Submit and Application dates as a fixed annual calendar. The QAP's own text defers any additional 2025/2026-cycle deadline to a future website announcement; confirm the live round's actual dates before building a screening timeline.
- Relying on the 2025/2026 QAP without checking whether the 2027-2028 QAP has since been finally adopted. As of this research, the 2027-2028 QAP was still in public-comment/draft status (board-approved for release July 13, 2026; hearing July 29, 2026); a deal filing under a later cycle needs the final, Governor-approved document, not the draft.
- Picking either the 120-point or 125-point minimum score for a competitive 9% Application without flagging the conflict. The QAP states both numbers in two different sections (4.3 and 3.2.21) and never reconciles them -- confirm the operative figure with PHFA rather than assuming one section controls.
- Assuming PHFA's QAP defines "brownfield," "blight remediation," or "residential infill" the way another state's allocation plan might. The Smart Site Selection scoring item names these categories without defining them in the QAP text itself; the operative definition, if any, should be confirmed before assuming a specific federal or state designation controls the points.
- Treating a QCT/DDA hit as automatic access to Pennsylvania's own 130% state-designated basis boost. The federal 130% boost is automatic on a QCT/DDA site; PHFA's own state-designated 130% boost requires an affirmative Waiver request, a demonstrated funding gap, and is unavailable to any 4% Tax Credit with Tax-Exempt Bonds deal regardless of census-tract status.
- Using DEP's Environmental Site Assessment Search Tool as a stand-in for the Phase I Environmental Site Assessment PHFA's Application requires. DEP's tool is a records search covering its own eFacts database; it is not a substitute for the ASTM E1527-21 assessment a qualified environmental professional has to perform.
- Assuming a site's inclusion in DEP's Act 2 cleanup records automatically satisfies the QAP's undefined "brownfield" scoring category, without confirming that connection with PHFA directly.
- HUD
- LIHTC
- State QAPs
- IRS § 42
- Housing Finance Agencies