Site sourcing and screening — Tennessee

Six Regional Housing Needs Areas, not a county-by-county pool table

THDA's Total Credit Ceiling is calculated under the federal per-capita formula at 26 U.S.C. § 42(h)(3)(C); the QAP does not restate it as a fixed dollar figure. Section 11 splits that ceiling into set-asides and three "General Priority Categories." The 10% nonprofit set-aside required by 26 U.S.C. § 42(h)(5) is not carved out as its own competitive pool the way some states run it -- the QAP states THDA's obligation "is intended and expected to be met through the normal course of the competition," with THDA reserving the right to prioritize nonprofit allocations directly if the normal competition doesn't get there. A separate Permanent Supportive Housing for Homeless set-aside caps out at $1,000,000. Of the three General Priority Categories, Existing Multifamily Housing (rehabilitation) and the PHA category are each capped at $3,600,000 of the Competitive Credit Ceiling; everything else funds New Construction.

The QAP text itself does not print which counties fall into which of the six regions -- that assignment lives entirely in an external, map-based tool the QAP calls "Proposed Siting Model for New Construction - 2026 QAP Public" (referenced directly in Section 17.A.1's scoring language). This research was not able to independently extract a county-to-region crosswalk from that live GIS tool; a screening product needs to treat the map itself, not any text summary of it, as the source of truth for which region a given parcel falls in, and should re-pull it before every cycle since THDA describes the siting model as extending from the 2026 QAP into the 2027 QAP rather than being fixed permanently.

Location scoring is a single 4-point line item -- there is no graded amenity table

For new construction, Section 17.A sets a 100-point scale where "the scoring criteria in this section are not intended to allow an Applicant to claim the maximum 100 points"; the minimum eligible score is 65 points (52 points inside the PHA General Priority Category). Within that scale, "Housing Credit Development Location" is worth "up to 4 points," tied to "Initial Applications proposing developments located in areas with the greatest Regional Housing Needs Score," and the QAP adds this directly: "consistent with the legend associated with the map found at 'Proposed Siting Model for New Construction - 2026 QAP Public,' priority areas identified by cities will automatically qualify for 4 points." This criterion does not apply at all inside the PHA General Priority Category.

This research found no proximity-to-services scoring category anywhere in Section 17 -- no distance table for schools, grocery stores, transit, or medical services of the kind California, Georgia, or Colorado publish. That absence should be stated plainly rather than assumed to be an oversight in this research: a full-text search across the entire 139-page QAP for "proximity," "grocery," "transit," and "amenit-" (as a stem) turned up only on-site development amenity requirements (community rooms, playgrounds, and similar), never a neighborhood-location scoring table. A Tennessee screening tool should not manufacture a graded proximity score CTCAC-style; the only location-based scoring lever in the new-construction track is the single 4-point Regional Housing Needs Score item.

Rehabilitation scoring (Section 17.B) runs a separate 100-point scale with a 60-point minimum, and its location item is different in kind, not degree: a flat 2 points for "a development and Housing Credit Development site wholly located within a HUD-defined QCT covered by a CCRP." A Concerted Community Revitalization Plan ("CCRP") is itself a defined term with five mandatory elements: it must delineate a targeted area within a local government boundary and show where the site sits inside it; include housing as a stated goal; assess the targeted area's existing infrastructure needs; designate implementation measures; and be "approved or re-approved by the appropriate local government or entity no earlier than 2016" -- the QAP specifically excludes local Consolidated Plans written for HUD CPD funding from counting as a CCRP. The same QCT-plus-CCRP combination also serves as Tennessee's statewide tiebreaker for scoring ties among new-construction applications (Section 18.F.1.a), after the primary tiebreaker of lowest credit requested per unit.

No Phase I ESA in the QAP itself -- TDEC's own databases are the real screening layer

This is worth stating precisely because it cuts against how most other states in this library run their site screen: a full-text search of the 2026 QAP for "environmental," "Phase I," "Phase II," "flood," "hazard," and "brownfield" returned zero threshold or mandatory-requirement hits. The only "environmental" reference in the document is to the federal ENERGY STAR program. A cross-check of THDA's own THOMAS Documents Page -- the page the QAP itself incorporates by reference for every guidance document it names -- lists Market Study, Appraisal, Physical Needs Assessment, and Utility Allowance guidance by name, but nothing under an environmental-review or Phase I heading. That absence is a finding about THDA's own application threshold, not a claim that no Tennessee LIHTC deal ever needs a Phase I; see the due-diligence phase of this guide for why a lender or investor will very likely still require one.

Site Utilities is a genuine Threshold Requirement (Section 6.B.2), and it is the closest thing to an infrastructure-readiness gate the QAP runs at screening time: the Initial Application must include documentation from the relevant local jurisdiction verifying availability of electricity, water, sewer, and (if applicable) natural gas. Septic fields are prohibited outright for buildings of more than 4 units, and a proposed on-site treatment facility requires its own separate financing commitment inside the application. None of this substitutes for an environmental hazard check -- it confirms service availability, not site contamination or flood risk.

Basis boost is THDA's own call, not a fixed QCT/DDA formula

The QAP defines "Basis Boost" as "An increase of up to 30% in eligible basis for a building in order to improve the financial feasibility of the building in a difficult to develop area, as determined by THDA in its sole discretion," and defines "Difficult Development Area" as "Any area designated as such by HUD or as so defined by THDA in accordance with Section 42(d)(5)(B)(v)." Section 11.I restates the mechanism for the competitive program directly: "A 'Basis Boost' of no more than 30% will be available to all applicants and awarded at THDA's discretion." Unlike Colorado's published exclusion rule or California's fixed QCT/DDA-plus-negotiated-basis-limit formula, this research found no published criteria in the QAP text describing how THDA actually exercises that discretion -- no scoring rubric, no list of qualifying factors, no stated cap on how many projects per cycle can receive it. That gap should be treated as a genuine open question to confirm directly with THDA staff, not filled in with an assumption borrowed from another state's formula.

The noncompetitive bond program runs a narrower rule. The 2026 MTBA Program Description defines its own Basis Boost identically at up to 30%, but adds a sentence the QAP's competitive-program definition does not carry: "In this MTBA Program Description, only areas defined by HUD as Difficult Development Areas are eligible for the Basis Boost." A 4% bond deal cannot reach THDA's broader discretionary boost the way a 9% competitive deal can -- it is limited strictly to the federal QCT/DDA designation. A screen that treats the two programs' boosts as interchangeable will overstate eligible basis on a bond-financed deal.

Income and rent limits: pulled straight from HUD, not republished by THDA

The QAP's own introduction lists the external resources it relies on rather than republishing: "This QAP contains uniform resource locators to resources utilized by THDA in the application process, such as the Tennessee Growth Policy Act, Multifamily Tax Subsidy Project Income Limits, Qualified Census Tracts, designations of Difficult to Develop Areas, Fair Housing Act requirements, etc." Later, in the compliance section, the QAP refers directly to "HUD-published income limits" as the operative figures for gross-rent and over-income determinations. This research found no separate THDA-issued income-and-rent-limits memo of the kind Colorado or Georgia publish annually -- the applicable numbers are HUD's own Multifamily Tax Subsidy Project (MTSP) limits, published at huduser.gov on HUD's own annual cycle. A Tennessee screening tool should key its income/rent-limit refresh to HUD's MTSP release rather than watch for a THDA-specific publication that does not appear to exist.

Where this screen stops: a Table of Contents that doesn't match the body, and a 2027 QAP that isn't final

This is a confirmed defect in THDA's own published PDF, not a research gap: the 2026 QAP's Table of Contents lists Section 13 as "Economic Development Area Set-Aside" (page 71). The document's actual body has no such section -- its Section 12 ("Non-Profit Allocations") is followed directly by a section headed "Section 13: Permanent Supportive Housing for Homeless Set-Aside," and every subsequent body section number runs one lower than its Table of Contents entry (the ToC's Section 15, for instance, corresponds to the body's "Section 14: New Construction General Priority Category"). This research cites body section headings and page numbers throughout rather than trusting the Table of Contents past Section 12, and a screening or citation tool built against this document should do the same until THDA corrects the front matter.

The 2026 QAP's own competitive cycle already closed before this research was conducted: the calendar (Section 18) set the Initial Application deadline at April 16, 2026, 4:30 PM Central. The document that will govern the next cycle -- the 2027 QAP -- was still an unadopted draft as of this research: THDA circulated a redline dated February 4, 2026 and posted a public hearing notice dated March 11, 2026, but no THDA Board or Governor approval of a 2027 QAP was confirmed. THDA's own materials describe "the 2026 & 2027 QAP siting model" as one continuous regional-needs methodology extending across both years, so the six-region structure and general scoring approach documented here are likely to carry forward -- but every specific number in this phase (the per-region development caps, the $3,600,000 category caps, the deadlines) should be re-verified against the adopted 2027 QAP before being relied on for a 2027-cycle site pursuit.