Site sourcing and screening — Rhode Island

Confirming which QAP governs, and a mid-cycle handoff between agencies

Rhode Island runs its Qualified Allocation Plan on an annual cycle, not the two-year cycle used in several other states covered in this library. The document currently in force is the State of Rhode Island 2026 Qualified Allocation Plan, approved by RIHousing's Board of Commissioners on August 21, 2025 and governing the 2026 9% and 4% LIHTC allocation year. It is published as Section 7 of RIHousing's own 2026 Developer's Handbook rather than as a freestanding document, so a screen should pull the current Section 7 file directly from rihousing.com's Developer's Handbook page rather than an older standalone "QAP" link, several of which return a 404 as RIHousing reorganizes its own site.

A more consequential change sits underneath the document itself. Rhode Island General Law § 42-55-24.1 states plainly: "effective January 1, 2026, the qualified allocation plan required by 26 U.S.C. § 42 shall be developed by the executive office of housing in consultation with the corporation." "The corporation" is RIHousing -- the Rhode Island Housing and Mortgage Finance Corporation -- which the same statutory scheme keeps in place as the sole and exclusive agent that actually allocates the federal credits. In practical terms: starting with whatever QAP first goes through this new process, the document a screen has to read is being written by a different state agency than the one issuing the award, with RIHousing now in a consulting role on its own allocating document.

That handoff produced exactly the kind of currency question this library checks for in every state. The Executive Office of Housing (EOH) held a public hearing on a draft 2027 QAP on August 12, 2026 and accepted written comment through 5:00 p.m. on August 31, 2026 -- the first QAP cycle run under the new EOH-led process. The draft document itself is watermarked "DRAFT 7.31.26 for public comment" and lays out a proposed 2027 timeline (proposals due December 2026/January 2027, reservation decisions at RIHousing's April or May 2027 Board meeting). As of this research, in late September 2026, no confirmation of final adoption of a 2027 QAP could be found in either RIHousing's or EOH's own published materials; the most recent confirmed governing document is the 2026 QAP approved August 21, 2025. A screen built today should verify directly against housing.ri.gov and rihousing.com whether a 2027 QAP has since been finalized before relying on any of the 2026-specific figures in this phase.

The draft itself is worth a brief flag precisely because it is not yet law: as posted for comment, it proposes to cut the QAP's total scoring scale from 147 points to 129, to shrink the Community category described below from up to 13 points to just 3 (dropping the Housing 2030 growth-tier scoring line entirely as drafted), and to reduce Sustainability from 14 points to 11. None of that is in force, and a public-comment draft can still change before adoption -- but a screen relying on this phase's point values for a proposal that will not actually apply until a 2027 or later cycle should confirm the live scoring table for whichever QAP year actually governs, rather than assume 2026's figures persist unchanged.

Rhode Island is not a blanket DDA -- the real ZIP-code and census-tract map

The federal 30% basis boost for a Qualified Census Tract (QCT) or Difficult Development Area (DDA) is automatic under 26 U.S.C. § 42(d)(5)(B) and requires no action by RIHousing or the QAP to administer; HUD designates both annually, with DDAs redetermined each year as income and Fair Market Rent data update. Because Rhode Island sits entirely inside HUD's Providence-Fall River, RI-MA Metro FMR Area, its DDA status is set using HUD's Small Area DDA (SADDA) method -- a ZIP Code Tabulation Area (ZCTA)-level comparison of Fair Market Rent to income, not a single determination for the whole metro area, let alone the whole state.

QCT status runs on Census tracts, not ZIP codes, and HUD's 2026 QCT list designates 37 tracts in Rhode Island -- 35 of them in Providence County, with one each in Bristol County and Washington County. RIHousing's own QAP text is notably cautious about QCT siting: the federal statute requires a QCT preference among competing applications, but the QAP states that "[b]ecause placing LIHTC projects in a QCT risks exacerbating concentrations of poverty, the QCT preference will only be given when there is an added benefit to the neighborhood in the form of the project's contribution to a concerted community revitalization plan (“CCRP”)." In the QAP's own point scoring, a QCT location is worth only 1 point on its own (bundled with CCRP status) inside the Community category's "Areas of Opportunity/Graduation Rates" line -- a modest score next to the QCT preference's outsized role in some other states' plans.

This research did not find a Rhode-Island-specific state basis boost mechanism parallel to the federal 30% QCT/DDA boost -- the kind of state-designated boost program some other states in this library administer on top of the federal one. That absence is reported here as what this research found, not as confirmation that no such program exists; a screener relying on this point should confirm directly with RIHousing rather than assume either way.

What actually gets scored at the site level: Site Design, Community, and Sustainability

RIHousing's QAP folds site suitability into its Scoring Assessment Criteria rather than a separate site-screening checklist. The Site Design criterion requires that "the proposed site, including any existing improvements, must support the intended population in terms of desirability of location; environmental quality; adequacy of utilities and transportation; proximity and connections to jobs, civic, social, commercial, recreational, and services; and appropriateness of the proposed development to the specific site." For new construction specifically, the QAP flags ledge, wetlands, subsurface contamination, grade, soil suitability, and Base Flood Elevation as the typical considerations a screen needs to check; for rehabilitation, existing structural conditions, ease of adaptation, hazardous-materials abatement, and the appropriateness of the existing building and site plan for the intended population. The QAP's flood standard is materially stricter than a simple FEMA-map pass/fail check -- that detail is developed fully in Phase 2 (Site control and due diligence), since it becomes a hard due-diligence gate rather than a scoring nuance.

A comprehensive market study is a Program-wide eligibility requirement, not just a scored item: RIHousing requires one, at the developer's expense and completed by a disinterested party it commissions, as a condition of any credit allocation, analyzing demand depth and breadth, comparable properties and rates, comparable operating expenses, absorption rates, and the needs of the prospective population. For mixed-income proposals specifically, a third-party market study must be submitted with the LIHTC application itself, not simply completed before closing the way a standard proposal's can be.

The Community category ties its top tier directly to Rhode Island's statewide Housing 2030 plan: a development in a community with less than 10% existing affordable housing that also meets that community's "Modest Growth" or "Strategic Growth" classification under Housing 2030 earns 10 points, dropping to 7 points if the community already exceeds 10% affordable housing, and to 5 points for a "Continued Growth" community with access to public water. Sustainability (up to 14 points) and a folded-in Preservation of Greenfields credit (3 of those 14 points, for a site that avoids destroying fields, forests, agricultural, or other environmentally sensitive land, or that conserves more than 50% of its land in a cluster layout) round out the site-level scoring that a screen should weigh before making the call.

Housing 2030 became binding state policy after the QAP's own text was written

The 2026 QAP's own introduction, finalized August 21, 2025, describes Housing 2030 as still a work in progress: "The Department of Housing released the draft Housing 2030 plan in April of 2025. The plan went out for public comment and will be finalized later this year." That description is now stale. Rhode Island's State Planning Council adopted Housing 2030 as a State Guide Plan element on December 11, 2025 -- after the QAP's own text was locked -- making it Rhode Island's official five-year housing policy framework and part of the state's guide for municipal planning, not a pending draft. A screener reading the QAP's own words about Housing 2030 should treat that language as dated rather than as evidence Housing 2030 is not yet in force.

As adopted, Housing 2030 sets both statewide and per-community targets: 15,000 total new homes permitted by 2030; 1,000 new homeownership units priced below $400,000; 525 accessory dwelling units; a doubling of other middle-market home permitting (against a recent baseline the plan cites of roughly 195 units per year); and 2,250 affordable rental homes financed, including at least 375 permanent supportive housing units and at least 500 units serving extremely-low-income households. Each municipality is separately assigned an annual production goal that scales with its existing concentration of jobs, transit, and infrastructure -- the same growth-tier logic (Continued Growth, Job Rich, Strategic Growth, and similar categories) that feeds directly into the QAP's Community scoring described above. This research did not independently verify which specific towns fall into which growth tier; that mapping should be confirmed against Housing 2030's own published municipal growth-category materials for a specific site rather than assumed from a town's general reputation.

The QAP's own Housing Needs section grounds all of this in current data it cites directly: as of January 2024, Rhode Island's Homeless Management Information System counted 2,442 people experiencing homelessness statewide, and the National Low-Income Housing Coalition's 2024 Out of Reach Report ranked Rhode Island 12th-highest nationally for the gap between what renters earn and what a two-bedroom apartment costs to rent. Both figures are attributed here exactly as the QAP itself cites them.