Site sourcing and screening — Utah

Confirming which QAP governs -- the 2027 Plan, not the more heavily-indexed 2026 Plan

Utah's QAP is renamed and re-approved every year rather than amended in place, which makes it easy to grab last year's document by mistake. As of this research (September 2026), the current, Governor-approved governing document is the "State of Utah 2027 Federal and State Housing Credit Program Allocation Plan," published directly by UHC at utahhousingcorp.org/pdf/2027_Final_QAP.pdf. Its own cover page states it was Approved By UHC Trustees on April 23, 2026 and Approved By Governor Spencer J. Cox on May 12, 2026. Search engines and third-party aggregators, however, continue to surface the 2026 QAP (approved roughly a year earlier, in May 2025) far more prominently, because it has simply been indexed longer. A screen, underwriting model, or scoring worksheet built from the 2026 document for the current 2027 Reservation Cycle would be working from a superseded plan.

One internal wrinkle is worth flagging rather than silently resolving: the 2027 QAP's own title page carries a leftover template date of "03/17/2025" beneath its cover art, which predates both of the plan's own stated approval dates and does not match the "4/7/2026" date stamped in the document's running footer throughout the body text. This reads as an unedited template artifact rather than a substantive currency problem -- the cover page's own approval dates (4/23/2026 Board, 5/12/2026 Governor) and the Exhibit 1 critical-dates table (Application due 6/16/2026) are internally consistent with each other and with UHC's own board meeting minutes, so those are the dates a screen should rely on.

No amendment to the 2027 QAP was found published as of this research date. Given how often sibling states' agencies have amended a QAP mid-cycle without renaming it, a Utah screen should still re-check utahhousingcorp.org's Multifamily Allocation Plan & Application page directly before relying on any cached or mirrored copy of the 2027_Final_QAP.pdf file.

Location scoring runs on Utah's own Healthy Places Index, not the federal QCT/DDA map

Utah's location-scoring category, "Project Location," is far more compact than the equivalent sections in some other states' QAPs: it carries a weight of 20 against a maximum raw score of 15 points, for a maximum weighted score of 300. Rather than a long table of amenity categories, it is built from exactly three things: whether the site is in an "Area of Opportunity," whether it is in a "Non-Participating Area," and whether it is within 1/3 of a mile of qualifying transit.

The Area of Opportunity score is driven entirely by the Utah Healthy Places Index (HPI), described in the QAP as "an evidence-based and peer-reviewed tool developed by the Utah Department of Health and Human Services" that combines 20 community characteristics -- healthcare access, job opportunities, education, and others -- into a single percentile score. UHC directs Applicants to look up a site's percentile directly at map.utah.healthyplacesindex.org by entering the project address; if the specific census tract lacks enough data to generate an HPI score, the Application instead uses the site's zip code. This is a genuinely different data source from the federal Qualified Census Tract (QCT) map that drives basis-boost eligibility in many other states' scoring -- a Utah screen that reflexively pulls a QCT layer to estimate location points, rather than checking the HPI tool directly, will get the wrong number.

The "Non-Participating Area" points reward geographic novelty rather than any fixed amenity or distress measure: 5 points for the first Housing Credit-restricted project in a given county, the first in a given municipality, or any project on tribal land, from a named list in Exhibit 8B. That list -- four counties (Daggett, Morgan, Piute, Wayne) and roughly 190 cities and towns, plus several named tribal nations -- carries its own explicit currency warning in the QAP's own text: "This list may not be current. Please check with UHC Multifamily staff with questions." A screen should treat Exhibit 8B as a starting point to confirm with UHC directly, not as a settled fact, especially for a jurisdiction that has seen recent growth or its first-ever Housing Credit award.

Three separate basis-boost mechanisms, only one of which is federal

A Utah site can potentially qualify for eligible-basis increases through three distinct, non-identical mechanisms, and a screen has to keep them apart because the QAP caps the combined benefit rather than letting them add without limit.

The Non-Metro set-aside, the Wasatch Front growth engine, and the scattered-site geography rule

UHC sets aside approximately 15% of its Housing Credit ceiling for projects that are both located in a designated "Non-Metro Area" and 50 units or fewer. Exhibit 3A defines Non-Metro status by reference to federal Office of Management and Budget statistical-area designations rather than a state-drawn line: every part of Utah is treated as Non-Metro targeted except eleven named counties -- Box Elder, Cache, Davis, Iron, Juab, Morgan, Salt Lake, Tooele, Utah, Washington, and Weber. That means roughly two-thirds of Utah's 29 counties qualify for this set-aside, while the state's fastest-growing, highest-population corridor is carved out of it entirely.

That corridor's growth is not a marginal factor. Utah's population reached an estimated 3,551,150 as of July 1, 2025, according to the Utah Population Committee (chaired and staffed by the University of Utah's Kem C. Gardner Policy Institute) -- an increase of roughly 44,351 residents, or 1.3%, over the prior year. Utah County alone accounted for about 36% of that statewide growth (nearly 15,900 new residents), with Salt Lake County adding roughly 8,300 more; reporting on the same estimates put more than 70% of the state's 2025 population growth along the Wasatch Front specifically, and noted that for the first time in Utah's history, over half of the state's population now lives in cities of 50,000 or more residents. A site-sourcing strategy built only around the Non-Metro set-aside's 15% carve-out is, by definition, working against the geography where most of the state's housing demand is actually landing; a strategy built only around the Wasatch Front is competing in the QAP's General Pool and Project Location scoring without access to the Non-Metro set-aside's separate allocation.

The QAP's own "Scattered Site Project" definition ties directly back to this same geography: UHC requires every component of a scattered-site project to sit within no more than two adjacent counties if either county is rural-targeted under Exhibit 3A, or within some combination of Utah, Salt Lake, Davis, and Weber counties specifically -- the QAP's own shorthand for the core Wasatch Front. A scattered-site strategy that mixes a rural-targeted county with a non-adjacent metro county, or that spans more than two rural-targeted counties, does not meet this definition regardless of the underlying ownership structure.

Two more screening-stage notices are worth confirming directly against the current QAP text rather than assuming from past cycles: as of the 2027 QAP, "Currently all counties in Utah demonstrate sufficient housing stability to absorb additional Housing Credit projects" -- i.e., no county-level Market Saturation Ineligibility is presently in effect anywhere in the state -- and UHC will not accept Applications for projects licensed as Assisted Living, an outright project-type exclusion rather than a scoring penalty.

Federal land is real background geography in Utah -- but it is not something the QAP administers

Utah has the second-highest share of federally owned land of any state: according to a March 2025 Kem C. Gardner Policy Institute report, the federal government owns 64.4% of Utah's total land area (roughly 35.0 million of the state's 54.3 million acres), with the Bureau of Land Management (BLM) administering about 65.1% of that federal share and the U.S. Forest Service another 23.4%. That ownership is extremely uneven by county: the same report put the low at 4% of a county's land area in Morgan County and the high at 90% in Garfield County, and it specifically noted that counties in northern Utah and along the Wasatch Front carry some of the lowest federal-land shares in the state.

This is genuinely useful context for site sourcing -- a rural, Non-Metro-targeted county is statistically far more likely to have large, unrelated blocks of BLM or Forest Service land bordering or checkerboarding the private and municipal parcels actually available for development than a Wasatch Front county is. It is not, however, a UHC-administered process: nothing in the 2027 QAP references BLM, the Forest Service, or federal land status directly, and the vast majority of real LIHTC sites are already-platted private or municipal parcels whose title and boundary questions are resolved through the same ordinary title commitment and survey process used anywhere else in the state. This research did not find, and would not expect to find, a QAP-administered federal-land review step; a parcel-specific federal land history only becomes a real diligence question if that particular parcel's own chain of title runs through a past federal land conveyance or exchange -- a fact a normal title search should surface on its own.