Site sourcing and screening — South Carolina

SC Housing, the 2026 QAP, and a plan built to be amended mid-year

South Carolina's allocating agency is the South Carolina State Housing Finance and Development Authority, doing business as SC Housing, and its governing document is the 2026 Qualified Allocation Plan. This research directly confirmed, by OCR'ing the Authority's own scanned Certification of Approval, that Governor Henry Dargan McMaster signed the 2026 QAP on December 30, 2025 -- a document that also grants SC Housing express authority "to amend or waive any requirements of this QAP as described herein without the necessity of further approval." That grant is not a formality: SC Housing published clarifications and amendments to the 2026 QAP on at least January 9, January 27, February 23, and March 31, 2026, covering everything from bond-ceiling request minimums to internet-access design requirements, all without a second governor signature. A screening tool that snapshots the QAP once at the start of a cycle will silently drift out of date; the QAP itself should be treated as a living document for the entire plan year.

As of this research (September 2026), the 2026 QAP is the only currently adopted, governor-approved plan. SC Housing has already published a 2027 QAP process -- an initial draft posted by June 12, 2026, a workshop held June 23, 2026, and a revised draft dated August 25, 2026 -- but no Certification of Approval for a 2027 QAP was found in this pass, and the 2026 QAP's own full-application-to-award cycle was still running through the third quarter of 2026 (initial full-application scores posted June 26, 2026; final scores in July; reservation notifications in September). A 2027 draft is worth tracking for what might change, but it is not yet governing law and should not be cited as such. Where checked, the 2027 revised draft's county groupings and 9% set-aside percentages were unchanged from the 2026 QAP -- a sign of structural continuity, not a guarantee it will stay that way once adopted.

South Carolina's federal LIHTC program and its own state credit share one statute base: 26 U.S.C. Section 42 governs the federal credit, and South Carolina Code of Laws Section 12-6-3795, as amended, governs what the QAP itself calls the "STC" -- the South Carolina housing tax credit. The QAP states this relationship in its own introduction. The state credit's mechanics are covered in depth under Entitlement Pathway Election, but its existence already shapes site screening: a site's USDA Rural eligibility, for instance, is not just a federal-program data point in South Carolina -- it is also the gate for at least half of the state credit dollars set aside for 9% LIHTC deals.

Urban, Suburban, Rural: the geography that replaces regional pools

South Carolina does not run California-style regional apportionment, and it does not run a Colorado-style single statewide pool with no geographic mechanism at all. Instead, Appendix C1 of the QAP sorts every one of the state's 46 counties into exactly one of three groups -- Urban, Suburban, or Rural -- and that group assignment is fixed in the QAP text, not derived from a Census designation or a formula. The three major metro anchors land in different places relative to each other than a newcomer might expect: Charleston, Berkeley, and Dorchester (the three-county Charleston metro), Richland (Columbia), and Greenville are all Urban, but so are Aiken, Anderson, Beaufort, Horry, Lancaster, Lexington, Spartanburg, and York -- thirteen counties in total. Greenwood, Pickens, Sumter, and nine others sit in Suburban; the remaining twenty counties, mostly the Pee Dee, Lowcountry interior, and Piedmont's smaller counties, are Rural.

The group assignment cascades into almost every other number in the program. Each 9% award is capped by group -- $1,450,000 in federal LIHTC for an Urban application, $1,350,000 for Suburban, $1,250,000 for Rural (a Public Housing Authority award is capped instead by the county's own maximum). Unit count is capped by group too: a new-construction development may not exceed 80 affordable units in an Urban county or 60 in a Suburban or Rural county, with a 40-unit floor statewide regardless of group. And the group defines the 9% set-asides themselves: Urban New Construction (35-40% of the year's 9% ceiling after the PHA award), Rehabilitation (15-20%), Suburban New Construction (25-30%), and Rural New Construction (5-10%), plus the single Public Housing Authority award, which does not count against any county's per-county limit.

Per-county award limits add a second layer on top of the set-asides: the Authority will not award more than two new-construction applications per county in an Urban county, or more than one per county in a Suburban or Rural county -- and an Urban county that receives two awards in one cycle is limited to a single award in the next year's cycle. A site in a county that already picked up two Urban awards this year is not disqualified, but it is now competing for one slot instead of two in the following cycle, which is worth knowing before spending money on an application a screening tool could have flagged as structurally throttled.

The 4% tax-exempt bond program (Appendix C2) does not use the same three-way grouping for its own per-county caps. It collapses the geography to two groups instead: the same thirteen-county Urban list, and "Rural: all other counties" -- meaning a county that is Suburban for 9% purposes (Greenwood, Sumter, Pickens, and the rest) is treated as Rural for 4% bond per-county-award-limit purposes. A screening tool that hard-codes one Urban/Suburban/Rural table and applies it to both programs will misstate the bond program's per-county caps for every Suburban county in the state.

What actually gets scored on location -- and what is conspicuously not

South Carolina's 9% new-construction scoring criteria (Appendix C1, Section III) put real, sizable point values on location, but the mileage bands widen by group in a way a national screening tool cannot hard-code once and reuse. Distance to Amenities is worth up to 70 points total, split across six categories -- grocery, shopping, pharmacy, retail, healthcare, and public facility -- each scored on driving distance measured via Google Maps as of the preliminary application deadline, with a maximum of two amenities per category and a single establishment eligible for points in at most two categories.

Area Employment is worth up to 10 points, based on the number of jobs paying between $1,251 and $3,333 per month within a radius that -- like the amenity bands -- scales by group: two miles for Urban, five miles for Suburban, ten miles for Rural, all measured against the U.S. Census Bureau's OnTheMap tool for the Longitudinal Employment Household Dynamics database, using the most current year available as of the preliminary application deadline. USDA Rural adds a flat 5 points for a site located entirely within a USDA-defined rural area, checked against USDA's own eligibility tool -- and that same USDA Rural designation, not any QCT/DDA test, is the geographic screen that feeds directly into the state tax credit's own rural set-aside (see Entitlement Pathway Election).

A separate points category, Affordable Housing Shortage, functions as South Carolina's substitute for the kind of opportunity-area or high-resource-area scoring other states build around QCT and DDA status: 10 points for a county that received no new-construction 9% LIHTC award in the previous fifteen funding cycles, stepping down to 7 points (ten cycles), 5 points (five cycles), or 3 points (three cycles). This is a county-level lookback against SC Housing's own award history, not a Census-tract-level opportunity score, and not something a screening tool can compute from open federal geodata alone -- it requires SC Housing's own award history by county and year.

What this research did not find, anywhere in the 2026 QAP, Appendix C1's scoring criteria, or Appendix E's tax credit manual, is any scoring category, threshold requirement, or underwriting instruction tied to Qualified Census Tract or Difficult Development Area status. That does not mean the federal 30 percent basis boost under 26 U.S.C. Section 42(d)(5)(B) is unavailable in South Carolina -- that boost is a self-executing feature of federal law tied to a project's location in a HUD-designated QCT or DDA, independent of anything a state QAP says. But unlike Colorado's QAP, which explicitly discusses the federal boost and layers a separate discretionary state boost on top of it (with an explicit anti-double-counting rule), South Carolina's QAP is simply silent on it. A screening tool built for South Carolina should compute QCT/DDA status as a federal eligible-basis input for underwriting, but should not expect it to appear anywhere in SC Housing's own scoring, and should not assume any state-level discretionary boost analogous to Colorado's exists -- this research found no evidence of one.

Environmental and hazard screening, and an agency name the QAP hasn't caught up to

South Carolina's Threshold Participation Criteria (Section IV.D and IV.J) layer a wetlands determination, a Phase I Environmental Site Assessment, and a detailed set of distance-based site disqualifiers on top of the standard federal flood-hazard screen (FEMA's National Flood Hazard Layer, public and unauthenticated everywhere). The disqualifiers are specific and largely waivable with advance documentation: sites within 1,000 feet of an active railroad, within 2,500 feet of a civil airport (or 15,000 feet of a military airfield) inside a runway clearance or accident-potential zone, within a quarter mile of an active livestock or poultry operation, hazardous- or solid-waste facility, or sewage treatment plant, or within 500 feet of a junkyard, bulk fuel storage facility, adult-entertainment venue, or a defined list of heavy-industrial uses. These are covered in depth under Site Control and Due Diligence, but they belong in the screening pass too -- they can eliminate a site before an option is ever signed.

One specific threshold item is worth flagging on its own: Section IV.J.2.d disqualifies any site on the CERCLA National Priorities List, or requiring a voluntary or involuntary cleanup agreement, "with Department of Health and Environmental Control," unless the site has been determined appropriate for residential use and mitigated to that agency's satisfaction. That agency name is no longer accurate. Under 2023 Act No. 60 (S.399), South Carolina's Department of Health and Environmental Control (DHEC) ceased to exist as a single agency on July 1, 2024, splitting into the South Carolina Department of Environmental Services (SCDES) and the South Carolina Department of Public Health (DPH). Environmental cleanup functions -- including the Brownfields and Voluntary Cleanup Program that would govern exactly the kind of CERCLA-adjacent mitigation this threshold describes -- now sit with SCDES, not DPH. The 2026 QAP, adopted more than a year after the split, still uses the pre-2024 agency name verbatim. This is not a drafting choice a screening tool should silently correct without flagging it: an applicant relying on the QAP's literal text could reasonably look for "DHEC" and not find it, and should be pointed to SCDES's Bureau of Land and Waste Management instead.

No South Carolina-specific wildfire-risk portal or state-run hazard layer analogous to Colorado's Forest Atlas was identified in this research pass -- South Carolina's wildfire exposure is materially lower than Colorado's Front Range, and the state does not appear to run an equivalent public-facing GIS tool. A screening product should not assume one exists without checking the South Carolina Forestry Commission's own current holdings directly.

Income and rent limits: SC Housing's own tables, and a hold-harmless question this pass could not answer

SC Housing publishes its own rent and income limit tables by county and AMI band, derived from HUD's Multifamily Tax Subsidy Project (MTSP) income limits, on its Income and Rent Limits page. Following the standard federal LIHTC rule, HUD's 2026 MTSP limits (released May 1, 2026) had to be implemented by all LIHTC properties within 45 days -- by June 15, 2026 -- and SC Housing's own published rent tables for 2026 reflect that release.

This research did not find, in the 2026 QAP or on SC Housing's public income-and-rent-limits pages, any South Carolina-specific hold-harmless or HERA Special (pre-2008) carryover mechanism comparable to the one Colorado's QAP describes for 37 of its counties. That absence should be stated as a gap in this research pass rather than assumed to mean no such mechanism exists: HUD's own hold-harmless policy is a nationwide floor that applies wherever a jurisdiction's income limits would otherwise decrease, and it would apply in South Carolina the same as anywhere else if a county's calculated limits ever fell. What this pass did not confirm is whether any South Carolina county currently carries a hold-harmless or Special limit that a single-year MTSP table would miss -- that should be checked directly against HUD's own MTSP dataset for South Carolina before a screening tool asserts a single current-year rent number is authoritative for every county.