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What is the "But For" Test, and who determines if it has been met?

VEPC will review each application - other than those for which the housing development is an affordable housing development - to determine whether the infrastructure improvements proposed to serve the Housing Development Site and the proposed housing development would not have occurred as proposed in the application or would have occurred in a significantly different and less desirable manner than as proposed in the application but for the proposed utilization of the incremental tax revenues.

A non-exhaustive list of factors VEPC may consider around the question of what is a “significantly different and less desirable manner” may include, but is not limited to: 

  • a housing development occurring significantly later than it could occur with CHIP financing, 
  • a housing development that would include fewer units without CHIP financing, 
  • a housing development that is significantly less affordable than could occur with CHIP financing.