Site sourcing and screening — Wisconsin

The QAP just turned over -- and the next cycle's clock is already running

WHEDA administers Wisconsin's Housing Tax Credit program under a Qualified Allocation Plan that it revises on a two-year cycle. The plan governing the 2027 and 2028 program years -- the 2027-2028 QAP -- carries a cover letter from Governor Tony Evers dated June 15, 2026, and WHEDA's own press announcement of "the final 2027-28 Qualified Allocation Plan" followed on June 16, 2026. That supersedes the 2025-2026 QAP, which governed the 2026 competitive round (Project Concept December 5, 2025; full Application March 27, 2026; awards announced June 2026) and remains the document of record only for credits already reserved under it. A site being screened today should be built against the 2027-2028 QAP, not the outgoing plan and not a cached copy of it on a third-party aggregator.

One loose end is worth naming rather than quietly resolving: the copy of the 2027-2028 QAP posted at WHEDA's own file path still carries the filename "2027-2028-qap-final-draft.pdf" and an internal cover-page line reading "Revised _____ 2026" with the date left blank -- an artifact that would ordinarily raise doubt about whether the document is truly final. A separate file at a clean "2027-2028-qap.pdf" path on WHEDA's own site carries the Governor's signed cover letter and no such placeholder, and WHEDA's own press office announced the plan as final the next day. Both are hosted by WHEDA itself; treat the signed, undated-placeholder-free version as authoritative, and don't let the leftover draft filename on the other copy read as evidence the plan is still pending.

A site screen has to work backward from whichever deadline actually applies: a Project Concept proposal (project narrative, proposed unit mix and population, site control, development-team forms) is a mandatory gate before any competitive full application, and WHEDA can eliminate a project at that stage if its market is overrepresented among the concepts already filed -- a Wisconsin-specific reason a site can die weeks before anyone reads a full application.

Wisconsin's set-asides: six Metro counties, not "Milwaukee vs. everywhere else"

WHEDA targets its Competitive Credits (the federal 9% credit plus the State of Wisconsin Housing Tax Credit) into two geographic set-asides, and the Metro pool is defined by name, not by metropolitan-statistical-area boundaries or by Milwaukee alone.

Layered on top: WHEDA reserves $2.4 million of the 9% credit for a 2027 Innovative Set-Aside (one Metro and one Non-Metro project demonstrating innovative cost-reduction methods), calculated before the geographic set-asides are sized and excluded from the county caps. WHEDA also makes adjustments, if needed, to ensure at least 10 percent of the 9% credit awarded goes to projects involving qualified nonprofit organizations and rehabilitating existing rental housing, and it caps rehabilitation projects generally at no more than 15 percent of the Competitive Credits absent insufficient new-construction applications. The minimum score to compete for a Housing Tax Credit award is 65 points -- a threshold the QAP itself notes WHEDA may change.

Scoring the site before it's scored on paper

WHEDA's Appendix C: Selection Criteria (revised August 19, 2026) lays out seventeen scoring categories with no stated grand-total ceiling -- only the 65-point floor is fixed. Several of the largest categories are decided entirely by where the site sits, which is exactly the work of this phase.

The Qualified Census Tract fact is worth stating plainly because it cuts against a reasonable assumption carried over from other states: a QCT hit is worth exactly one point, inside the two-point Lower-Income Areas category -- it is not a scored category of its own, and it has no connection to the QAP's scoring table for the separate QCT/DDA basis boost. A screening tool that treats a QCT hit as a major scoring driver in Wisconsin is overstating it by an order of magnitude relative to categories like Area of Economic Opportunity or Tribal/Rehabilitation/Neighborhood Stabilization.

"Serves Lowest-Income Residents" (10 points) works on a third axis: WHEDA sorts every county into a High, Moderate, or Low income tier, and the AMI target an applicant must commit to at a 40%-at-60%-CMI or Average Income set-aside (30%, 40%, or 50% AMI, respectively) depends on which tier the county falls into. A site screen that doesn't carry a per-county income-tier lookup will misprice what this category actually costs a deal in rent.

Basis boosts: HFA and QCT/DDA don't overlap in Wisconsin

Appendix D: Housing Tax Credit Application Underwriting Criteria (revised August 27, 2026) splits Wisconsin's basis-boost mechanics cleanly by credit type, in a way worth stating precisely because it inverts an assumption that holds in some other states: a 9% project cannot request the QCT/DDA boost at all, and a Federal 4% project cannot request the HFA boost at all.

The State of Wisconsin Housing Tax Credit itself carries its own, separate credit-percentage split by set-aside -- 4 percent in Metro counties, 10 percent in Nonmetro counties -- which is easy to confuse with the federal 4%/9% credit-type vocabulary but is a distinct number governing only the state credit's own sizing.

The state credit's rural preference is not merely a QAP policy choice. Wis. Stat. § 234.45(5) requires WHEDA to "give preference to qualified developments located in a city, village, or town with a population of fewer than 150,000" when issuing state-credit allocation certificates, and § 234.45(5m)(a), added for QAPs adopted after April 10, 2026, requires WHEDA to "ensure that at least 35 percent of the value of all state tax credits" allocated each year go to developments in rural areas -- with a narrow escape valve at § 234.45(5m)(b) if too few qualifying rural applications come in. The 2027-2028 QAP's own "goal of awarding at least 35% of credits" to small, remote communities is this statute's floor restated as QAP text, not a discretionary aspiration WHEDA could quietly abandon.

Environmental and parcel data: DNR runs the hazard layer, nobody runs a live statewide parcel layer

Wisconsin DNR's Remediation and Redevelopment Program maintains BRRTS on the Web (BOTW), the state's public database of known hazardous-substance discharges, investigations, and cleanup activity, paired with the RR Sites Map -- an ArcGIS-based viewer that plots the same records geographically and lets a user drill into site-level detail. Between BOTW and the RR Sites Map, DNR gives Wisconsin something CAL FIRE-style states don't always have for their own hazard-of-record data: a public, site-searchable brownfields and contamination layer with a genuine map front end, not just a downloadable table. The federal floor underneath it -- FEMA's National Flood Hazard Layer -- is public and unauthenticated the same as anywhere else, and undeveloped sites carry an added DNR touchpoint through the Natural Heritage Program's endangered-species and unique-habitat files, referenced directly in WHEDA's own Phase I Environmental Report Requirements for exactly that scenario.

Parcel data is the harder gap, and it should be named precisely rather than assumed away. The Wisconsin Statewide Parcel Map Initiative, run through the University of Wisconsin-Madison's State Cartographer's Office with state funding, aggregates each county's own parcel and tax-roll data into a single statewide GIS layer -- but it does so on an annual cycle, not continuously: the most recent public release drew on parcel polygons that counties submitted between January and May of 2026, most carrying a 2025 tax-roll year, with the next release not scheduled until roughly June 2027. It is a genuinely useful research-grade composite of 3.5-plus million parcels, and it is not a live, authoritative source a screening tool can treat as current between annual releases -- the authoritative record for any given parcel still sits with that county's own assessor.

Income and rent limits follow the pattern common to every state: WHEDA doesn't independently derive them. It republishes HUD's Multifamily Tax Subsidy Project (MTSP) limits, county by county, on WHEDA's own Multifamily Data Library page, on the same effective date HUD sets nationally -- May 1, 2026 for the 2026 figures, following HUD's own delayed national release that year. A screen that hardcodes last year's WHEDA rent table without checking HUD's own release date and any decrease hold-harmless treatment will be showing stale numbers exactly as long as every other state's tool would.