Site sourcing and screening — Virginia

Confirming which document governs, and what to call the agency

The agency's legal name has not changed: the QAP itself is still styled "THE PLAN OF THE VIRGINIA HOUSING DEVELOPMENT AUTHORITY FOR THE ALLOCATION OF LOW-INCOME HOUSING TAX CREDITS," and its own definitions section states plainly that "'Authority' means the Virginia Housing Development Authority." "Virginia Housing" is the operating brand the agency adopted in 2020 for its public-facing name and logo — the legal entity, the regulations at 13VAC10-180, and the QAP's own defined terms never stopped using VHDA. A screen or citation that treats "Virginia Housing" as a different, newer agency than "VHDA" is describing the same body twice.

The QAP is a living, continuously amended document, not a fixed biennial artifact. Its own preamble lists amendment dates running from the original May 16, 1995 plan through January 1, 2025, and states it "is amended effective December 17, 2025" — that December 2025 version, which virginiahousing.com itself labels "Coverage Year: 2026," is the plan actually governing every 2026 reservation round. A draft 2027 QAP was released June 9, 2026 and was, as of this research, not yet the adopted, governing plan; a tool or checklist that cites "the 2027 QAP" this year is citing a draft rather than controlling text, the same currency trap this library has flagged in other states whose agencies amend mid-cycle.

Eleven pools, not a handful of regions — and no locality-size tier at all

Virginia's Total Credit Authority is divided, before anything else happens, into eleven named pools rather than the smaller set of regions some other states run. Every geographic pool below except the Balance of State pool is explicitly described in the QAP as carrying "an increasing rent burdened population" — the plan's own shorthand for where housing pressure is judged to be growing, which matters because it also feeds a separate scoring item (up to 20 points, discussed below) that is unavailable to a site in the Balance of State pool.

This is a purely geographic (plus ownership-type) pool structure — nothing in the 2026 QAP ties a pool, a set-aside, or a scoring boost to a locality's population size the way some other states tier by city size. The one place population does the QAP's own regulatory definitions section defines a "low-income jurisdiction" as any city or county at or below the Virginia nonmetro area median income (a HUD-derived threshold), which is used elsewhere in scoring and underwriting rather than as a separate credit pool. A screen built on the assumption that Virginia tiers by locality size — the way its historical pool structure is sometimes described informally — should verify that assumption against the current QAP's Part I rather than carry it forward from an older cycle or a different state's model.

The New Construction Pool deserves its own flag: it covers the identical nine-jurisdiction footprint as the Northern Virginia/PD8 geographic pool, funded instead from next year's ceiling. A NoVA new-construction site effectively gets two independent looks — first in Pool 3, then, if unfunded there, in Pool 4 — which is easy to misread as "the same pool twice" rather than two separate competitions with two separate credit sources.

Housing needs characteristics: revitalization areas, a poverty-rate test, and an Opportunity Zone map about to move

Virginia's closest analogue to an "opportunity area" score is not a QCT/DDA bonus. It sits inside the QAP's Housing Needs Characteristics scoring item (13VAC10-180-60(E)(2)(c)), which lists seven location-based triggers and states explicitly that "if the development is located in more than one such area, only the highest applicable points will be awarded" — the items do not stack.

The revitalization-area mechanic itself runs through a housing-authority statute, not the zoning code: Va. Code §36-55.30:2, part of the Virginia Housing Development Authority Act (Title 36, Chapter 1.2), gives a locality three separate paths to the designation — an outright resolution finding blight or an economic-development need Title 36, Chapter 1 redevelopment/conservation/rehabilitation area, or a census tract where 70% or more of families earn at or below 80% of the statewide median income, or a HUD-designated area meeting its own income/poverty thresholds. Confirming which of these three paths, if any, actually applies to a given tract is a title-and-locality-records question, not something a screen should infer from a QCT map alone.

The Opportunity Zone item is the one most likely to change under a screener's feet this year. Virginia's current Opportunity Zone map traces to the 2017 Tax Cuts and Jobs Act designation, but the One Big Beautiful Bill Act made the federal Opportunity Zone program permanent and established a decennial redesignation process: a new round of zones takes effect January 1, 2027, each state's governor may nominate up to 25% of eligible tracts, and nominations are due to the U.S. Treasury by September 28, 2026. Virginia's Department of Housing and Community Development and Virginia Economic Development Partnership have been running that nomination process through 2026 against the Governor's four investment priorities (housing development, downtown revitalization, business-ready investment, regional asset development), and Virginia's own reporting projects the state's designated-tract count falling from 212 to roughly 152 once the new map takes effect. A site that qualifies for the QAP's 15-point Opportunity Zone item today may not carry that designation for an application filed after the new map is certified — and a site that doesn't qualify today could gain it. Confirm current OZ status against the live federal map for the round in question rather than a cached list.

The state basis boost tops out at 10 percent, not 30 — and it is not the federal QCT/DDA boost

The automatic federal 30% basis boost for a Qualified Census Tract or Difficult Development Area (26 U.S.C. §42(d)(5)(B)) is not separately administered anywhere in Virginia's QAP — it requires no agency action, and the regulatory text at 13VAC10-180 never needs to restate it. What the QAP does administer is a much narrower, discretionary mechanism tied to a specific scoring item rather than to geography: under the QAP's Development Characteristics scoring (13VAC10-180-60(E)(3)(d)), the executive director "may, if needed, designate a proposed development as requiring an increase in credit in order to be financially feasible and such development shall be treated as if in a difficult development area as provided in the IRC" for an applicant earning the additional 10 points available under that same energy-performance item (Zero Energy Ready Home or Passive House certification) — but "any resulting increase in such development's eligible basis shall be limited to 10% of the development's eligible basis," and the authority may remove the increase if it later determines the development is feasible without it.

Two things follow directly from that text. First, this state-level boost is capped at a third of the federal program's 30% — a screen that treats "Virginia has a basis boost" as interchangeable with the federal QCT/DDA boost will overstate available basis by up to 20 points of eligible-basis percentage. Second, it is triggered by an energy-performance scoring outcome, not by a QCT, DDA, or revitalization-area hit — a site's location does not by itself make this boost available, and a green-certification decision made for scoring reasons has a basis-sizing consequence that is easy to miss if the two are modeled separately.

Virginia also layers its own state Housing Opportunity Tax Credit (HOTC) on top of the federal program — created by SB 1197 (2021 Session), codified at Va. Code §§58.1-439.29 and 58.1-439.30 (Article 13.4, Chapter 3, Title 58.1) and implemented through regulations at 13VAC10-200. HOTC is a separate state tax credit sized against a project's federal LIHTC allocation, not a basis adjustment, and it runs its own application rounds (the "HOTC-4%" round on the 2026 calendar above). Its program-election mechanics belong to this library's site-sourcing successor phase covering the 9%/4%/hybrid decision; the point for a screen is simpler — don't conflate HOTC, the federal automatic boost, and the QAP's own 10%-capped discretionary boost. They are three distinct Virginia mechanisms with three distinct trigger conditions.

Hazard data, parcel data, and the LNI clock that actually gates a Virginia site

Virginia's Department of Environmental Quality (DEQ) publishes its holdings through the Virginia Environmental Data Hub (an ArcGIS-based portal) and the separate DEQ Environmental Data Mapper, covering Superfund and RCRA sites, the Voluntary Remediation Program, landfills and solid waste permits, and flood/wetland/slope layers; DEQ also runs a dedicated Brownfields Development Resource Tool aimed specifically at redevelopment screening. These are genuinely open, queryable resources — but this research did not confirm a single normalized, parcel-keyed layer spanning all of Virginia's local jurisdictions the way some other states' regional planning bodies provide. That fragmentation is compounded by a fact specific to Virginia's structure of local government: the Commonwealth's 95 counties and 38 independent cities are separate, co-equal local jurisdictions rather than cities nested inside counties — each runs its own assessor and, in most cases, its own GIS stack, so a screening tool needs 133 integration points, not 95.

Income and rent limits are published on Virginia Housing's own site rather than left to HUD's national release date alone. The 2026 MTSP and HERA Special Rent Limits reflect a HUD update dated May 18, 2026 — confirm the current-year figures against Virginia Housing's own income-limits page rather than assuming HUD's national publication date controls Virginia's implementation timing.

The clock that actually disciplines a Virginia screen is the Locality Notification Information (LNI) form — an online submission due at least 45 days before whichever Application deadline a site is aimed at (13VAC10-180-50(A)), which triggers Virginia Housing, "after receipt of the local notification information data, if necessary," to notify the chief executive officer of each affected locality and give that officer "a reasonable opportunity to comment" (13VAC10-180-50(L)). The scoring consequences are real: failure to make a timely LNI submission costs 50 points, and a locality's formal written opposition — which must itself be accompanied by the locality attorney's opinion that the opposition is not discriminatory under the Fair Housing Act — costs another 25 (13VAC10-180-60(E)(2)(a)-(b)). Anyone filing more than five LNIs must first schedule a meeting with Virginia Housing's Tax Credit Allocation staff. A site screen that treats "find out if the locality supports this" as a late-stage courtesy rather than a 45-day-out administrative deadline is treating a scored, penalty-bearing requirement as optional.