Texas LIHTC
Rehabilitation Guide
What it takes to rehab an apartment community under the Texas (TDHCA) Qualified Allocation Plan, and the cost-drivers worth pricing before you bid.
Built for developers, contractors, and design teams.
If you're underwriting a LIHTC acquisition-rehab in Texas, 4% or 9%, the Qualified Allocation Plan (QAP) decides a lot about your scope and your budget, often before you've made an offer. This guide lays out what the Texas Department of Housing and Community Affairs (TDHCA) expects of a rehab, and where the real money hides.
True Craft is licensed in Texas and has rehabbed communities across the state, from El Paso to Corpus Christi. We read the current QAP against your specific building so a requirement never blindsides your budget.
Texas quick facts
- Agency: TDHCA
- Programs: 9% competitive HTC · 4% HTC + tax-exempt bonds (statewide, no regional cap)
- Governing rules: QAP (10 TAC Ch. 11) + Uniform Multifamily Rules (10 TAC Ch. 10)
- Standards: Texas Minimum Construction Standards
- Accessibility: Fair Housing · ADA · Section 504
- Typical timeline: 6–9 months to bid
What TDHCA counts as "rehabilitation."
TDHCA defines rehabilitation as the repair, refurbishment, or replacement of existing mechanical or structural components, fixtures, and finishes: work that corrects deferred maintenance and reduces functional obsolescence. It can also fold in energy-efficient components and appliances, life- and safety-systems, and site and resident amenities.
One practical break for rehabs: when you're not altering unit configurations, the project is exempt from many of the bedroom and closet width, length, and square-footage minimums that bind new construction. That keeps a like-for-like renovation from triggering expensive reconfiguration, as long as the scope is drawn correctly.
The Texas cost-drivers worth pricing early.
These are the requirements that most often move a Texas rehab budget. Not all apply to every deal. The skill is knowing which land on yours.
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Accessibility & Section 504
Fair Housing, ADA, and, when federal money is in the stack, Section 504. A substantial alteration generally means 5% mobility-accessible and 2% sensory-accessible units. Retrofitting bathrooms, unit entries, and path-of-travel into an older Texas garden-style property is a common budget surprise.
FHA · ADA · 504 -
Texas Minimum Construction Standards
TDHCA's Uniform Multifamily Rules set required materials, durability, and unit/site standards. Even on a like-for-like rehab, certain components must be brought up to standard.
10 TAC Ch. 10–11 -
Energy & efficiency
Energy-efficient HVAC, water heaters, lighting, and envelope upgrades are expected and often scored. Plan utility-allowance impacts and any required efficiency thresholds into the scope.
TDHCA energy rules -
Tenants in place & relocation
Most Texas rehabs are occupied. Relocation logistics, phasing, and temporary-relocation costs belong in the budget and the schedule from day one.
URA / relocation -
Prevailing wage triggers
LIHTC equity and private debt alone usually don't trigger Davis-Bacon, but layering in HOME, CDBG, or FHA-insured financing can, which moves the GC bid and compliance load.
Davis-Bacon -
Scope & cost certainty
A Property Condition Assessment grounds the scope; how tightly it's defined drives how much contingency risk rides in your bid.
PCA · SOW
We turn the Texas QAP into one number.
Every property we assess gets a True Craft Score: a 0–100 read on how ready and how risky it is as a rehab, with the Texas-specific cost-drivers above flagged green, amber, or red. You walk into the bid knowing exactly where the risk is.
- Columbia Apartments — El Paso (200 units)
- Gulfway Manor — Corpus Christi (151 units)
- Oso Bay Apartments — Corpus Christi (104 units)
- Las Palmas Villa — Eagle Pass (64 units)
- El Rosario Homes — Mission (100 units)
- La Merced Homes — Mercedes (100 units)
Texas LIHTC rehab: common questions.
Who administers LIHTC in Texas?
TDHCA is the Texas Department of Housing and Community Affairs. It runs both 9% competitive credits and 4% credits paired with tax-exempt bonds. 4% credits are available statewide and aren't subject to regional allocation.
Do rehab projects have to meet new-construction unit sizes?
Not when unit configurations aren't changing. Those rehabs are exempt from many bedroom and closet sizing requirements. Other minimum construction standards still apply.
How many accessible units will my rehab need?
It depends on the funding and the scope, but a Section 504 substantial alteration generally requires 5% mobility-accessible and 2% sensory-accessible units, on top of Fair Housing and ADA obligations.
How fast can you get us to the bid table?
With a clear scope, typically 6–9 months from first call.
Have a Texas property in your pipeline?
Send us the address. We'll read the current TDHCA QAP against the building and hand you a True Craft Score with your scope of work.
Get Your Property Scored